By By Frank Lombardi and James T. McKenna | August 1, 2016
|The Aerospatiale Gazelle is among the last singles certified for IFR operations before FAA guidance raised the bar (left). Newer types like the Marenco Swisshelicopter SH09 (middle) and Bell Helicopter 505 Jet Ranger X (right) would have to prove commercial airliner-level reliability to achieve that capability.
Photos courtesy of Davide Olivati, Marenco and Bell
An industry campaign for less stringent guidelines on U.S. certification of single-engine helicopter for IFR operations may benefit from the FAA’s expanding application of a new philosophy for regulating risk in civil aircraft operations.
In November, four trade associations sent the joint proposal, called the Single-Engine IFR White Paper, to the FAA Rotorcraft Directorate with an objective “to restore affordable single-engine IFR within the current regulatory structure.”
The four groups — the General Aircraft Manufacturers Assn. (GAMA), AHS International, the Aircraft Electronics Assn. (AEA) and HAI — argue that a 1999 change to FAA guidance for certification of Part 27 helicopters made single-engine IFR approval too costly for commercial sales. Part 27 of the U.S. Federal Aviation Regulations (FARs) covers helicopters with a maximum weight of 7,000 lb and nine or fewer passenger seats.
While the Rotorcraft Directorate has been evaluating the proposal, the FAA has been extending its application of what the Safety Continuum philosophy throughout the agency.
“It’s a big-picture FAA philosophy,” said the Aircraft Electronics Assn.’s VP of government and industry affairs, Ric Peri. “We’re starting to see it applied to every category of aircraft.”
FAA officials have said the concepts underpinning the white paper align with the philosophy, according to several in the industry involved with the effort. The directorate’s Regulations and Policy safety program manager, Sandra Shelley, told an AEA/FAA Rotorcraft Forum June 2 in Fort Worth, Texas, that the white paper was one driver of a Rotorcraft Safety Continuum policy statement under development.
That policy statement is being reviewed within the FAA. Shelley said a draft would be published for public review and comment, with a goal of finalizing the document by January.
|Accident data points to the need for broader single-engine IFR use (above). The table opposite contrasts the requirements for such helos and comparable airplanes. Courtesy of the Part 27 Rotorcraft IFR White Paper|
FAA discussions of the Safety Continuum date back to at least 2006. It is based on the presumption that public demands for safety assurance vary by aircraft category, with the highest expectations for commercial airliners and the lowest for personal aircraft, like sport planes. It says those expectations should drive the level of regulatory oversight of the different categories.
In 2012, the agency’s Aircraft Certification Service (which includes the Rotorcraft Directorate) began an effort to raise awareness of the Safety Continuum among its employees. “An increase in awareness is critical to achieving the next level of product safety,” the service said in a September 2014 briefing entitled “The Safety Continuum — A Doctrine for Application.”
The doctrine observed that safety oversight unmatched to risk might allow flaws in safety-critical components and lead to an increase in the rate of fatal accidents. But “too much rigor can prove to be an equal threat,” it noted.
“If certification requirements and oversight are overly stringent,” the 2014 doctrine said, “safety can be jeopardized because the burden of certification will prevent the adoption of safety-enhancing technologies.”
That is exactly what the authors of the industry white paper argue occurred when the FAA changed Advisory Circular 27-1 in a way that set reliability requirements for single-engine IFR certification that are on par with those of commercial airliners. The requirements previously matched those for fixed-wing aircraft that weigh 12,500 lb or less and are covered by FAR Part 23.
The authors compiled data from the safety department of a major helicopter maker — which various people identified as Bell Helicopter. The data included 194 accidents worldwide from 2001 through 2013 that involved single-engine aircraft in the Part 27 category that crashed during inadvertent encounters with instrument metrological conditions (IIMC) or controlled flight into terrain (CFIT).
According to the white paper, 133 of 194 accidents involved fatalities, with a total of 326 deaths. Fifty-seven accidents were in the U.S. None of the aircraft were equipped for IFR flight.
“In fact, IFR-certified single-engine rotorcraft are virtually nonexistent in the current fielded fleet,” the white paper says. “Of the few that do exist, none are recent certifications employing the current state-of-the-art technology that is now commonly used for IFR systems in other aircraft.”
By contrast, the white paper says, there were 54 IIMC or CFIT accidents in the same period that involved multi-engine Part 27 helicopters or heavier Part 29 multi-engine ones. Twelve occurred in the U.S. Of those, 46 involved fatalities. Forty involved helicopters trying to fly under visual flight rules (VFR). Only seven of the accident flights were conducted under IFR. Most of the multi-engine rotorcraft were IFR-equipped, the white paper says, “but often either the pilot had no instrument rating, was not current or had minimal instrument experience and was not confident in IFR procedures.”
The white paper is built on the premise that an increase in rotorcraft IFR operations would provide a significant safety improvement. It notes that IIMC and CFIT continue to be major contributors to rotorcraft accident statistics, “especially single-engine rotorcraft.”
The authors maintain that the accident data they cited in the white paper understate the current safety problem.
“What is not captured,” they say, “are the near misses of obstacles and terrain that occurred” as helicopter pilots tried to avoid weather “or the near losses of control that occurred attempting to exit IIMC.” They argue the erratic year-to-year data shown in the chart here “is indicative of a broader issue where a high-risk practice of ‘scud running’ is prevalent and what is captured in the data are the aircraft that failed in the gamble.”
The white paper’s backers say broader availability of single-engine IFR would benefit many rotorcraft operations, but particularly ones in air medical services and law enforcement and in regions prone to challenging weather.
Rotorcraft Directorate officials and others have questioned the white paper’s safety case. One operator of a flight school, repair shop and electronic newsgathering operation said more widespread availability of IFR-capable, single-engine helicopters might “make people braver than they ought to be” when flying into weather.
This operator and others, including some in the Rotorcraft Directorate, question whether pilots and operators would invest in the training and practice needed to stay current and comfortable with their IFR flying skills.
Others argue that more available IFR aircraft could raise safety and performance levels in the industry. Kurt Robinson, president of Robinson Helicopter, recounted a briefing he gave to students and instructors at Embry-Riddle Aeronautical University on recent accidents, including some involving flights in bad weather. Attendees who were more experienced in IFR flight told him that they would not have even attempted to take off in the described conditions, he said, which left him with this takeaway: “The more training you have, the more you understand how difficult it is to fly” in such conditions.
Joseph Cook said he saw the broader benefit of IFR training when he was president of CALSTAR from 1987 to 2010. The California air ambulance operator used IFR-certified twin-engine Bell 222s and Agusta A109s. The training regime for IFR-qualified pilots “also improved the level of VFR training at our bases,” he said. “It was more expensive to train to an IFR level, but we could make the business case for that expense.”
Robinson was one of several helicopter makers that addressed another criticism of the white paper — that owners won’t spend the extra money for IFR capability — in a closed-door meeting with Rotorcraft Directorate officials at Heli-Expo last March. That company’s representative and ones from Bell, Enstrom Helicopter, Marenco Swisshelicopter and MD Helicopters stated clearly that they and their customers want IFR-certified single-engine helicopters, according to several individuals at the meeting.
“They all said we need this and we don’t want to wait a decade or more for new rulemaking,” said one attendee, who did not want to be identified because his employer had not cleared him to speak publicly on the matter.
Another argument for broader IFR certification is the improvement in helicopter avionics, which steadily have become lighter and more capable, and navigation aids.
“It amazes me that we’ve got an autopilot in the R44,” Robinson said. His company last year gained FAA approval for installation of Genesys Aerosystems’ Helicopter Stability Augmentation System and autopilot in the R44 and the R66.
Regarding navaids, the white paper notes “technology such as Global Positioning System (GPS) area navigation and Wide Area Augmentation System (WAAS) GPS approach procedures” make IFR flight “more relevant to helicopter operations than they were in the 1980s and 90s.” But most IFR singles today were certified back then and can’t take advantage of that tech.
The white paper makes clear that easier certification alone will not enable single-engine IFR operations. Manufacturers must identify a return on investment for developing and producing the needed aircraft and a network of low-level routes, approaches and departures must be created. Also, better weather reporting must be made available more broadly. The joint FAA-industry U.S. Helicopter Safety Team launched an initiative last February to address those issues.
A Bell Helicopter project to gain FAA certification of an IFR-capable single-engine 407GX is a test case for the industry’s white paper on that issue, according to several individuals involved in developing that document.
Bell would not comment, but the industry officials said the project that company has submitted to the FAA was tailored to hew closely to the white paper’s proposal for flight instrumentation, stability augmentation/boosted control, navigation/communications, electrical and high-intensity radiated field (HIRF) requirements.
The objective of the project was to present the FAA with a certification proposal that would prompt no concerns about discrepancies with existing certification standards, they said.
The project is pending.