Association Supports Many Changes, But Offers Suggestions On Key Points

The National EMS Pilots Association has submitted a 22-page position paper on the FAA Notice of Proposed Rule Making pertaining to helicopter air ambulance operations.

January 10 was the deadline for the public submission of comments on the proposed changes to FAR Part 135. The new rules, if implemented as proposed without modification, will be the most far reaching changes to Part 135 of the FARs in recent history. The FAA’s proposal includes provisions that apply specifically to helicopter air ambulance operations, as well as rules that will affect all commercial helicopter operations.

NEMSPA’s comments on the proposed rules express support of much of the contents, but take issue with several elements of the proposal that the officers of the EMS pilots’ organization feel will have unintended consequences that could hinder the ability of the air medical transport industry to provide
the life-saving services that our national system of healthcare facilities has come to rely upon.

The organization said in its comments that it believes that "the FAA should not mandate HTAWS in lieu of other proven technologies to include NVIS (NVG). It is our opinion that the current NPRM is somewhat myopic to the benefits of other technologies available to industry such as NVIS. Although the FAA proposes a rule that includes NVIS for weather reduction minima, no recommendation for NVIS utilization is given." They suggest alternate language that would mandate the use of NVG technology, which the association says is proven. The language would also "strongly encourage" HTAWS installation.

The NPRM also calls for all helicopter pilots to "be required to demonstrate recovery from an inadvertent IMC encounter and understand procedures for aircraft handling in flat-light, whiteout, and brownout conditions. Pilot required to demonstrate realistic course of action that he or she might take to escape from inadvertent IMC during a competency check." In its responses, the NEMSPA said it had conducted an informal survey showing that "more than 80% of respondents had not conducted a patient transport under instrument flight rules during the previous 12 months. An additional 9% reported that less than 5% of patient transport flights were flown under instrument flight rules. Only 1 pilot (0.2%) had flown more than 50% of patient transports under instrument flight rules." It also found that nearly 70% had not flown in actual IMC conditions during the previous 12 months. The association recommended that "the 'preparation for an annual competency check' be strengthened through recent experience requirements, recommending that helicopter EMS pilots obtain a minimum of 5.0 hours of simulated or actual instrument time, either in an aircraft or flight simulator, every 12 calendar months.

The National EMS Pilots Association is a non-profit professional pilot organization dedicated to serving rotary wing and fixed wing pilots involved in the air-medical transport industry.

FMI: www.nemspa.org