Proposed new FAA policy could revolutionize helo ops

 - November 26, 2007, 11:07 AM

A little known FAA policy statement, dated June 1 of this year, stands to dramatically change the helicopter industry as we know it. Helicopter pilots and manufacturers have long known the unique capabilities of rotorcraft, but have always been obligated to follow regulations and policies set forth and to operate in airspace designed for the much more prevalent fixed-wing aircraft. The new FAA “Vertical Flight Policy Statement” signed by FAA Administrator Jane Garvey could remedy that situation, allowing an increase in rotorcraft operations while simultaneously decreasing the strain on the already overtaxed National Airspace System (NAS).

Barely covering two typewritten pages, the document (see box next page) could easily be overlooked if not for the enormity of the stated goals. If the goals of the policy statement are realized, it will revolutionize helicopter operations to allow safe and effective all-weather flight operations in the NAS while remaining clear of the congested fixed-wing routes.

As with most policy statements of this kind, there are two ways for it to go. It can either die a slow death, buried under the successive policy statements that are issued, or it can be used to its stated purpose as a catalyst for meaningful change. The flight operations committee at the Helicopter Association International (HAI) decided to embrace the goals of the statement and met this past July in Washington with members of Congress, representatives from the FAA and the Helicopter Directorate.

The chairman of the flight operations committee, Steve Hickok, said, “When I first received a copy of the administrator’s policy, I paid it little attention; there have been so many other policy statements issued that effected little relief or change for our industry. Upon a second look, I decided that this policy statement could be used to accomplish positive changes in the helicopter industry. But we need to hold the FAA accountable. They have said they will do it. Now let’s hold them accountable. This is the reason that the visit to Congress by the flight operations committee members was so important. The FAA now must rise to the challenge, which Administrator Garvey’s policy statement claims it is willing to achieve for our segment of the aviation industry.”

HAI president Roy Resavge has dealt with this and related issues for several years. “The FAA just took an enormous step toward recognizing the importance and uniqueness of vertical flight aircraft,” he said. “Administrator Garvey has continued to honor her pledge to include vertical flight requirements in the planning phase of the NAS modernization process. The Vertical Flight Policy Statement is certainly not the answer to all of our problems; in fact it does not provide any new funding sources or personnel or accelerate any project timelines. What it does establish is a commitment within the FAA, at the highest level, to acknowledge the unique nature of our industry and our potential contributions to the public.”

Friends at FAA
Resavage also urged members of the helicopter industry not to be too pessimistic. “The FAA is an extremely large bureaucratic agency that absorbs a great deal of criticism from customers and clients. It has a tough job to accomplish, and we know first-hand that it doesn’t always get it right. However, we need to be mindful that there are many dedicated friends of our industry within the FAA who are going that extra mile to remove some of the institutional barriers that are holding us back.

“The FAA must dedicate the major portion of its budget and energy to solving commercial transportation issues; that’s what the public and Congress demand. Fortunately, a small but dedicated cadre of vertical-flight advocates have the vision to see what the future could hold if rotorcraft and tiltrotor aircraft were properly integrated into the NAS.”

The meetings with members of Congress had three main objectives. Members of the flight operations committee primarily wanted to educate the congressmen on helicopter operations and the benefits to their constituents. Second, members wanted to congratulate Garvey and the FAA for their foresight in pledging support to the helicopter industry. Finally, the committee members wanted to develop cooperation and establish lines of communication to keep the congressmen informed on the progress being made through the implementation of this new policy.
The meetings with the FAA representatives had similar goals, but there were a number of specific topics on the agenda that were discussed to begin the process of meeting the goals of the policy statement. Other goals for the meeting were:
• Establish meaningful FAA testing with usable results.

• Partner industry with the FAA to provide aviation experts and assets.

• Match objectives with the policy statement.

• Establish timelines and accountability for future projects.

Helicopter ILS Procedures
The FAA currently has the ability to authorize helicopter ILS procedures to a 100-ft decision height at all Category II and III facilities. It may also be possible to authorize helicopter ILS procedures to selected Cat I facilities. The agency would like to start testing individual Cat I facilities for signal accuracy to 100 ft. However, Cat I lighting must first be evaluated on a test plan to determine the efficacy of Cat I lighting on glideslope at decision height with normal cockpit obstructions.

The FAA has decided to implement this in two phases.
Steps in phase one, which involves Cat II and III facilities, include the following action items:
• An air-transport handbook bulletin will be sent to all FSDO inspectors authorizing the procedures.

• Initial implementation will be at approximately 100 Cat II/III facilities, with the priority being set by the flight operations committee.

• A charting cycle date will be selected, 60 to 90 days after the first of this month.

• Guidance and procedures will merge at the charting cycle.

• Qualification requirements and procedures will be announced.

Steps in phase two, which involves Cat I facilities, include:
• An FAA/HAI coordinated test plan using Cat I lighting.

• Evaluation of the level-D S-76 simulator as a test platform.

• August 2001 startup, with the FAA to determine test parameters.

• A minimum of 20 test subjects with at least 10 approaches each.

• Combination of coupled and hand-flown approaches.

• Other testing to be determined such as LOC/GS protected area, hold-short lines, taxiways, critical areas, signal in space and redundancy of the transmitter.

The satellite operational implementation team (SOIT) is concerned about the disconnect between avionics standards and helicopter procedures. For example, on a helicopter GPS approach the receiver autonomous integrity monitoring (RAIM) is automatically set internally to 0.3 nm between the final approach waypoint (FAWP) and the missed approach waypoint (MAWP), with airspace boundaries that correspond to that 0.3 nm. If the departure from the heliport would use the same airspace outbound, which nearly all do, it would be expected that the receiver would provide the same accuracy as during the approach, which nearly all do not.

One private company that develops nonprecision GPS procedures for both approach and departure is Satellite Technology Implementation (STI). STI’s work includes departure procedures from sites that have helicopter GPS approaches. To compensate for the inability to accommodate automatic “coded” departures, STI employs a procedural solution through pilot training to permit helicopter IFR departures from heliports. This ensures that the receiver has approach accuracy and terminal RAIM, effectively accomplishing an equivalent level of safety.

Most GPS receivers have a departure capability that is internally coded to a RAIM of one nautical mile. Even at best this would require greater airspace and obstacle evaluations for departures. Not all GPS receivers even offer the departure capability as an automatic coded feature, and it appears that controversy exists as to how specific receivers would perform with this feature. Industry representatives and the FAA have received conflicting answers from the manufacturers of GPS units, so an Internet work group and a Web site are being established by the FAA to discuss these issues.

The heliport crossing height (HCH) and visual segment descent angle (VSDA) of GPS approach procedures may not sound like important issues, but a February 1999 FAA policy letter can dramatically affect GPS non- precision approach minimums or even exclude a large number of existing approved heliports from getting a GPS approach.
The current 8:1 glideslope ratio required for obstruction clearance at VFR heliports equates to 7.125 deg. The TERPs manual has a maximum allowable VSDA of 10.2 deg–in other words, a steeper approach angle than the maximum for obstruction clearance. The 1999 memo dropped the VSDA to a maximum of 7.5 deg; however, certification requires one degree less for obstruction clearance, leaving an effective maximum of 6.5 deg. Most helipads, especially hospital helipads, are built with little room to spare below the 8:1 ratio. If a pad were certified at 8:1 for VFR, the TERPs manual would allow an IFR approach, though the policy letter would restrict the pad from being certified. The current memo could have a major effect on patient care.

The HCH is limited to 20 ft because of references to the height/velocity (H/V) curves of helicopters. It is the opinion of the flight operations committee that the H/V curve should not affect GPS TERPs criteria because it is an individual performance issue, not a certification issue. By raising the allowable HCA to only 50 ft, a much greater number of obstructions can be excluded from the final and missed approach segments, resulting in realistic nonprecision approach minimums. Conclusions of the discussions were:
• FAA AFS 400/800 will develop guidelines for FSDO principal operations inspectors to provide waivers.

• Future FAA plans are to determine if the HCH and VSDA limits will be increased in the TERPs Criteria.

Special Consideration
Current test data from helicopter GPS approaches indicates that the airspace around the missed approach segment could be reduced by 50 percent, dramatically improving approach minimums. The FAA representatives said the existing test data is insufficient for a determination, but that they would like to collect more data to support a change.

As such, the flight operations committee requested that the FAA determine the number of approaches required for a data set and offer a commitment to implement the results. For its part, the FAA flight procedures standards branch has initiated discussions for test program deviations from the turn radius.

The current nonprecision GPS approaches allow for a straight-in landing only, even if it is downwind. Since helicopter pilots are accustomed to maneuvering to land on helipads, the FAA has been asked to allow a “maneuver” to land into the wind during the visual segment on a GPS approach. The FAA currently has no criteria on this, so the agency has requested that the flight operations committee draft a proposal for submission.

In the same FAA policy letter dated February 1999, the FAA restricted single-engine helicopters flying nonprecision GPS approaches to a 10-ft HCH instead of the 20-ft HCH for twins. With the advent of sophisticated IFR singles, such as the Agusta A119 Koala, this action could hinder IFR operations. Suppose an operator has a fleet of Agusta A109E twin-engine helicopters and invests in a GPS approach network. If that operator chooses to add an IFR A119 with the same autopilot and flight director to the fleet, the single-engine helicopter would be restricted from using that network if it were TERP’ed at the 20-ft HCH, solely because of the policy letter. The FAA representatives and flight operations committee will investigate the matter.

The Part 77 obstruction evaluation program currently has no requirement to protect the airspace around private approaches, which are mainly GPS approaches to hospital helipads. Obstructions 200 ft or higher are reported to the FAA, but towers under 200 ft aren’t unless they lie near an airport. This could obviously present a hurdle to certified helipad approaches, especially in and around hospitals.

Often, a hospital that has an IFR helicopter program invests in a GPS approach network to surrounding regional hospitals to provide better patient care. At the main facility it is easy to keep track of proposed construction and antenna placements because the flight program is an integral part of that facility.
At the outlying hospitals, however, many people within the hospital may not even be aware of the GPS approach, not to mention the need to protect the airspace during expansion and construction planning. Pilots certainly do not need surprises, such as a new antenna or unlit tower while transitioning from the approach to the pad. The HAI flight operations committee has requested that private approach airspace be protected, the same as public approaches.