On October 7, 2010, the Federal Aviation Administration (FAA) released a proposed set of rules that, if imposed, would go a long way toward enhancing Helicopter EMS (HEMS) operational safety. These rules are the FAA's response to recommendations from the National Transportation Safety Board (NTSB) following four days of HEMS safety hearings held in 2009.
"We can prevent accidents by preparing pilots and equipping helicopters for all of the unique flying conditions they encounter," said FAA Administrator Randy Babbitt. "These new rules are designed to protect passengers, patients, medical personnel and pilots."
Under the new rules, HEMS operators would have to equip their aircraft with Helicopter Terrain Awareness and Warning Systems (HTAWS). According to the Federal Register (the official publication for all proposed new federal rules), "The FAA believes that HTAWS would assist helicopter air ambulance pilots in maintaining situational awareness of surrounding terrain and obstacles, and therefore help prevent accidents caused by CFIT [controlled flight into terrain], loss of control, inadvertent flight into IMC [Instrument Meteorological Conditions, i.e. sudden bad weather], and night operations. HTAWS has particular relevance to helicopter air ambulance operations, which often are conducted at night and into unimproved landing sites."
The FAA also wants HEMS operators to add radio altimeters to their aircraft. "Radio altimeters are designed to inform the pilot of the aircraft's actual height above the ground," explains the Federal Register. "A radio altimeter can greatly improve a pilot's awareness of height above the ground (AGL) during hover, landing in unimproved landing zones (rough field landings), and landings in confined areas where a more vertical approach may be required. Additionally, radio altimeters help increase situational awareness during inadvertent flight into IMC, night operations and flat-light, whiteout and brownout conditions."
The FAA rules contain a lot more ideas to enhance HEMS operational safety. These include using IFR (Instrument Flight Rules) at airports and heliports that lack weather reporting systems, so if bad weather crops up suddenly, the helicopter will already be in the right flight mode to fly 'blind.' The FAA would also like to see flight crew time limitation and rest requirements when medical personnel are on board; having pilots prove they know how to recover from inadvertent IMC (i.e., losing visibility while in flight and switching to an instruments-based approach); and ensuring that all pilots-in-command have instrument ratings (i.e., the ability to fly using instruments rather than sight).
In general, the HEMS community has applauded the FAA's proposed rules; however, there is one glaring omission: The FAA does not require HEMS pilots to have access to night vision goggles (NVGs), which was recommended by the NTSB after the 2009 hearings and endorsed by Helicopter Association International (HAI). "We believe that NVGs should be mandatory in medical helicopters," HAI President Matt Zuccaro told EMS World Magazine. "People don't realize that, even though the majority of the U.S. HEMS fleet has NVGs, there is no requirement for them to do so. Ironically, we think there should be to ensure full compliance by all HEMS operators."
The obvious question is, why not? According to the Federal Register, "The FAA notes that it considered allowing certificate holders to use NVGs in lieu of HTAWS. However, the FAA has decided against such a proposal because NVGs may not be appropriate for all operations (for example, inadvertent flight into IMC), and additional time is needed to research the best use of the equipment before allowing it to be used as an alternate method of compliance." This said, the FAA will allow aircraft that have NVGs to conform to less stringent VFR weather flying minimums. In plain English, they will be allowed to fly closer to the ground.