A HOT TOPIC OF CONVERSATION at this month’s Air Medical Transport Conference in Tampa, Fla. Is likely to be whether Congress really wants to cram down the helicopter air ambulance industry’s throat a requirement to forgo flights they otherwise might make, operate like major U.S. airlines when they do fly, and install warning devices for which standards are sketchy.
Emergency medical service operators and industry lobbyists were caught by surprise when Sen. Maria Cantwell (D-Wash.) slipped into a key piece of legislation requirements along those lines. The Senate bill, S.1300, is the FAA reauthorization act, which must be passed every four years if the aviation agency is to continue to exist.
The vital nature of the bill had lobbyists fearing the requirements would be rushed into law before they had a time to persuade senators that might be more effective ways of improving the safety of helicopter EMS operations.
Cantwell’s proposals paralleled very closely the recommendations of the U.S. National Transportation Safety Board following its special investigation of air ambulance safety.
Specifically, she wanted to require the FAA to enact rules that would force EMS operators to comply with FAR Part 135 whenever medical crewmembers were aboard the aircraft. Typically, crews fly under Part 91 outbound to a crash scene or patient transport, shifting to Part 135 when the patient is on board.
The NTSB argued that such a requirement would prod EMS pilots to use better judgment in deciding whether or not to fly mission and put better weather data in their hands. Industry officials counter it would severely limit safer instrument flight rule operations.
Cantwell also wants an FAA requirement that EMS operators do a formal risk assessment before launching a mission. Industry and FAA officials say such a requirement already exists in the agency-approved operations specifications. The NTSB says that requirement is not a permanent one and should be so.
Another requirement Cantwell seeks would force EMS operators to adopt standardized dispatch procedures based on FAR Part 121, which governs scheduled airlines. Industry officials note those operators fly from one improved airfield to another, with some form of traffic communications and weather observations at either end. EMS flight crews often do not have that luxury.
Part 121 also dictates shared responsibility between the pilot in command and the dispatcher for the safe conduct of a flight and imposes stringent certification requirements on the dispatcher, who must have the equivalent of an air transport pilot’s license. Industry officials argue such requirements are impractical and would impose significant costs on operators without a commensurate safety gain,
In addition, Cantwell wants an FAA rule requiring the installation of terrain awareness and warning systems (TAWS) on EMS helicopters. While helicopter TAWS are available and installed in aircraft, the FAA has yet to specify technical standards for those units, so it is unclear what benchmark Cantwell expects operators to meet.
This may be a bureaucratic issue.
"From our standpoint, the helicopter TAWS is done," said Gordon Pratt, vice president of business development for Cobham Avionics. Cobham’s Chelton Flight Systems unit has "had our helicopter TAWS certified for several years. It’s a mature product. It’s been deployed in a variety of helicopters all over the United States and it’s an extremely effective product. So from our standpoint, there really is no development that needs to be done to it."
Lastly, Cantwell’s proposals would require all HEMS aircraft be equipped with cockpit voice and flight data recorders. Such recorders are tremendous aids to accident investigation and the safety advancements that often stem from them. Industry officials argue requiring the quick installation of this equipment, as Cantwell proposes, on all existing HEMS aircraft would lead to huge disruptions in service and customer access to air medical services.
The Assn. of Air Medical Services has proposed instead that studies be launched on the effectiveness of helicopter TAWS and the best way to get recorders on EMS aircraft quickly.
A questionable aspect of Cantwell’s proposals was their timetable. She would mandate new FAA rules within weeks, in some cases, of the bill becoming law. Few federal agencies, let alone the FAA, can act that fast under the most ideal of circumstances. The proposals’ effect would be to force overworked FAA safety officials to waste their time in a rushed rulemaking process that inevitably would be bogged down in appeals and court challenges.
In meetings with AAMS staff, Cantwell and her aides have said they will consider the industry’s complaints and counterproposals in good faith.
It is ironic that Cantwell’s proposals come as the industry and FAA are in the midst of one of their most productive periods of collaboration on safety matters.
While the NTSB spent 18 months on what amount largely to a review of accident reports before publishing its "special investigation" findings, FAA and industry worked on a number of safety areas. Since late 2005, agency and industry officials have worked hand in hand on more extensive analysis of helicopter accidents as part of the International Helicopter Safety Team’s drive to cut helo accidents 80 percent by 2016.
Over this year, FAA officials have soothed the nerves of EMS operators who were rattled at last year’s AMTC by the FAA’s stated intention to clarify its rules about operational control of aircraft. A number of industry officials last year expressed fear that the agency’s focus on that topic would drive some operators out of business.
Another topic of discussion at this year’s conference will be the FAA’s development of the Helicopter EMS Weather Tool, which the agency fielded as a prototype after the last AMTC. This description of the tool is drawn from an article that first appeared in the January/February 2007 issue of FAA news.
The agency’s own review of EMS accidents from 1998 through 2004 identified a need for more detailed flight planning. A weather source FAA officials expected to be useful to helicopter pilots is the Aviation Digital Data Service, introduced in 1997 as an experimental digital data program that would contain weather observations and forecasts important to the aviation community and would be available via the Internet. The HEMS Weather Tool is a supplement to that service.
The tool is intended as an aid for pilots in deciding not to fly because of weather, FAA officials have stressed that the tool is experimental and cannot be used to justify a "Gio" decision, Every one knows that HEMS operate in a very demanding environment.
To prevent controlled flight into terrain (CFIT) and loss of control (LOC) accidents, the FAA, the HEMS industry, and the University Center for Atmospheric Research (UCAR) conducted a HEMS Weather Summit in early 2006.
The weather tool derives ceiling and visibility by interpolating the nearest METAR data. This interpolation process, in effect, "stretches" limited-area METAR observations across a broader area between stations accounting for terrain effects on ceiling height. The results are the likely conditions between METAR stations. However, a critical issue is that the reliability of the information generally degrades as distance from a METAR site increases. Thus, users should apply practical judgment when considering the "likely" weather conditions that are remote from a METAR site. To aid in this judgment, the product provides confidence fields that integrate a variety of product quality factors.
The ADDS HEMS Weather Tool allows the user to identify gridded weather assessments in 5 km by 5 km blocks. The weather data available includes flight category, ceiling, visibility, radar, convection, icing, temperature, relative humidity, and wind. Overlays on the graphical data include wind barbs, METARs, PIREPs, AIRMETs/ SIGMETs, TAFs, VORs, state and county boundaries, and a base map of terrain and cultural information.
This data is available at www.weather.aero/hems. The site contains a tutorial as well as "frequently asked questions." In addition, you can find a technical report on the performance of this weather tool at www.avmet.com under the "Supplementary Weather Products" menu. Taking the tutorial and reviewing the report will help users understand how to use the tool most effectively.