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Friday, 15 October, 2010

NPRM Targets Helicopter Air Ambulance, Includes Changes For All Part 135

NPRM TARGETS HELICOPTER AIR AMBULANCE, INCLUDES CHANGES FOR ALL PART 135

October 14, 2010

What’s at Issue

The Federal Aviation Administration (FAA) is proposing new regulations that will affect all Part 135 aircraft (whether fixed-wing or helicopter), and includes additional requirements for all Part 135 helicopters, and, most significantly, numerous changes for Part 135 air ambulance helicopters.

Why It’s Important

The Notice of Proposed Rulemaking (NPRM) includes significant changes for equipment, staffing, training and weather minimums for all helicopter air ambulance operations.  Additionally, new equipment requirements are proposed that would apply to all Part 135 helicopters.  Finally, the FAA also intends to change the Part 135 load manifest requirements for all Part 135 aircraft.

Major Provisions

Changes for All Part 135
The new regulations would amend §135.63 to require a load manifest for every flight.  Today, the rule applies only to multi-engine aircraft.  The FAA also intends to permit electronic or paper versions of the manifest to be carried on-board the aircraft and to permit an electronic version to be transmitted to the operator’s base in lieu of preparing a duplicate copy.  This change would take effect immediately following publication of a final rule.

Changes for All Part 135 Helicopters


Change Proposed

Proposed Effective Date
(expressed in time following a final rule)

Radio altimeter required

3 years

Expanded over-water equipment requirements

3 years

Increased minimums for IFR alternate airports

Immediate

Pilots must demonstrate competency in recovery from inadvertent VMC into IMC

Immediate

Changes for Part 135 Air Ambulance Helicopters


Change Proposed

Proposed Effective Date
(expressed in time following a final rule)

Eliminate Part 91positioning flights with medical crew on-board

Immediate

Count all flight hours flown (even those with only medical personnel on-board) toward the pilot’s day flight time limits

Immediate

Instrument rating required for helicopter air ambulance pilots

3 years

Changes to VFR minimums and to VFR flight planning

Immediate

Permit IFR operations to locations without weather reporting

Immediate

Make completion of pre-flight risk assessments mandatory

Immediate

Severe weather detection,  a light-weight aircraft recording system and HTAWS equipment required

3 years

Operations control center required for operators with 10 or more air ambulance helicopters

2 years

NATA Position

NATA agrees that the safety concerns for helicopter operations that were noted by the FAA in the NPRM preamble, particularly those for air ambulance operations, support some of the proposed regulatory changes.  However, based upon the FAA’s own estimates the NPRM will be quite costly for those impacted.  FAA estimates a ten year cost ranging from one to twenty million dollars for each helicopter air ambulance operator, depending on the business size.

NATA is evaluating the proposal and will submit comments to the FAA.

Status

The NPRM was published on October 12, 2010.  Comments on the proposal are due by January 10, 2011.  Click here to download the NPRM.

Staff Contact:
Jacqueline Rosser
Director, Regulatory Affairs
jrosser@nata.aero

View in PDF format.

For general press inquiries, contact Shannon Chambers at 703-298-1347 or schambers@nata.aero

The National Air Transportation Association (NATA) has been the voice of aviation business for over 75 years. Representing nearly 2,300 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.