Although this long-awaited Notice of Proposed Rulemaking (NPRM) was billed as a regulatory initiative aimed at helicopter air medical operations, it goes well beyond that. It would affect other Part 135 operations, all commercial helicopter operations, and even Part 91 operations.

HAI has been receiving considerable feedback from air medical operators and working closely with the Air Medical Operators Association (AMOA) and the Association of Air Medical Services (AAMS), both affiliates of HAI, in developing a response to this major rulemaking proposal.

However, we would like to hear more from operators involved in mission areas other than air medical transport. The NPRM proposes new equipment requirements, new weather minimums, and new training requirements, all of which could affect you. For instance,

• The NPRM would extend the Part 135 requirement that now applies to multi-engine aircraft, requiring Part 135 operators to prepare a load manifest document, including weight and balance, prior to any flight. (It would allow operators to transmit a copy of the load manifest documentation to their base of operations, in lieu of the duplicate copy).
• The NPRM proposes to revise Part 91 Visual Flight Rules weather minimums, changing the current requirement to remain clear of cloudsto clear of clouds with minimum visibility of a half mile in daytime and one mile at night.

For all commercial helicopter operations, the NPRM proposes to:

• Revise instrument flight rules weather minimums for an alternate airport.
• Require pilots to demonstrate competency in recovering from inadvertent instrument meteorological conditions.
• Change the definition of “extended over-water operation” for all helicopters operating under Part 135 and require additional equipment for these operations. It also would define “over-water operations” and require electronically deployable life rafts for all flights operating over water beyond autorotational distance from shore.

The NPRM also proposes to require radio altimeters for all commercial helicopters.

We need to hear from you soon. The deadline for public comment is January 10, 2011.

Review the “Air Ambulance and Commercial Helicopter Operations, Part 91 Operations, and Part 135 Aircraft Operations; Safety Initiatives and Miscellaneous Amendments” NPRM and share your thoughts with HAI Vice President of Regulations and International Affairs Dave York (703-302-8451, david.york@rotor.com).