Entities that build private approaches, departures and airways for helicopters have an obligation to maintain them, cautions Steve Hickok, who is now into his second decade of developing special Rnav/GPS helicopter IFR approaches for U.S. and foreign clients.
They should not expect the government to do it, according to Hickok. “You can’t just develop an approach, walk away from it and expect the FAA to maintain it,” Hickok said.
He estimates that there are now more than 350 private instrument approaches, mainly to hospital heliports, in the U.S.
FAA Order 8260.19D requires a maintenance plan and maintenance on all special instrument approaches. But Hickok points out that much of the nation’s helicopter IFR infrastructure has been privately funded and that the FAA does not have a formal mechanism to notify owners of these private approaches of potential hazards in a Part 77 (heliport) environment. (FAR Part 77 allows the FAA to “identify potential aeronautical hazards in advance, thus preventing or minimizing the adverse impacts to the safe and efficient use of navigable airspace.”)
“Unlike the fixed-wing industry, we don’t get AIP [FAA Airport Improvement Program] funding. If you want a weather station, you have to go dig in your pocket. If you want a heliport or helipad, you have to go spend the money to do it. If you want an instrument approach, departure procedures or routing, you have to pay for it and go do it. Our entire IFR capability as an industry…has been paid for by the industry–not the government,” Hickok said.
With regard to safeguarding existing approaches, Hickok noted that the FAA’s Digital Obstacle File database contains only obstacles that are higher than 199 feet agl or require a Federal Communications Commission (FCC) license. “What they don’t have are any obstructions that are lower than that even if they fall within the Part 77 surface around the heliport,” Hickok said. “The reason for this is that Part 77 applies only to public facilities and public approaches. For the last eight years we [the Helicopter Association International’s Flight Operations Committee, which Hickok chairs] have tried to get private heliports and private approaches included under the Part 77 notification program, and it hasn’t happened.”
On October 31 Hickok became the first pilot authorized by the FAA to conduct flight validations of instrument approach procedures per FAA Notice 8260.66. During his check ride October 7, Hickok completed flight validation of the first three Wide Area Augmentation System (WAAS), lateral precision with vertical guidance (LPV) helicopter procedures to be developed for California Shock Trauma Air Rescue. Hickok’s company is the only company in the world developing WAAS approaches. The FAA currently does not have any formal helicopter WAAS criteria for approaches, so Hickok developed criteria that the FAA approved in January last year.
“They are lower than anything else that can be achieved right now,” Hickok said. “Some are down in the near precision approach category, down to 250 feet.”
Hickok said that receiving flight validation authority would both cut the development costs and time associated with creating special IFR approaches for his clients. Cycle times for approach design had been running approximately six months.
Hickok begins by doing a cost-benefit analysis for a client that combines weather and operational data and demonstrates how many missions lost to weather could have been flown with special approaches. He says it is typically 15 to 25 percent of all weather cancellations and that an operator can generally recover an approach’s development costs in 16 to 18 months. According to Hickok, an individual approach can cost $10,000 to $20,000, while developing a large inter-hospital network of approaches, routes and departures can cost up to $200,000.
Special approaches must be inspected every 540 days, but that leaves plenty of time for something to be built. “Say someone wants to build a 250-foot cell tower in the middle of a final approach fix [FAF]. Because the FAA isn’t required to deal with private heliports or approaches, it doesn’t even consider it [the FAF] and it grants a no-hazard letter because the tower doesn’t impact its public airspace,” Hickok said. “The next time anyone notices it is when they go back and do their public inspection and say, ‘Whoa, how long has this been here?’”
While working with the industry to persuade the FAA to include private heliports and approaches in the Part 77 program, Hickok’s company has developed software that monitors the approaches it maintains to protect them from new obstacles and construction.
The program cross checks applications for proposed towers or buildings on any critical surface along the approaches Hickok maintains. Hickok then notifies the FAA, the operator and the hospital. If the proposed obstacle is a cell tower, Hickok said that the FAA has always issued a determination of hazard, which means the FCC will not issue a license for that tower. In the event of a potential penetration of an approach, Hickok also encourages operators and hospitals to contact their local zoning boards when proposed construction will affect an approach. Hickok said the program “protects the surfaces from any unknown penetration and prevents the construction.” Hickok claimed the program has a perfect success rate on the approaches it covers. “Since 2004 we have never had a single new obstruction found on any periodic flight inspection,” he said.