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Monday, February 1, 2016

Flight Reports

The FAA’s new air ambulance data requirements have received pushback from wary operators even as flight data experts call them too vague.

By Joseph Ambrogne

A 737 MAX 8 in CIT livery. Photo courtesy of Boeing

If we take popular news coverage at its face, it may seem like dodging quadcopters and laser pointers is the primary concern of public service helicopter pilots in the U.S.

But let’s not forget flight data analysis—an issue far less likely to drum up images of a summer blockbuster, but still of great relevance to air ambulance operations as we get closer to 2018. By then, more data requirements will become law under Federal Aviation Regulations Part 135 subpart L (thanks to the 2014 set of changes “Helicopter Air Ambulance, Commercial Helicopter, and Part 91 Helicopter Operations,” broadly known as the Helicopter Air Ambulance rule).

The U.S. airline industry successfully uses flight data analysis tools—particularly flight data monitoring systems—following more than two decades of development.

Although worldwide helicopter aviation laws only sparsely require them, flight data monitoring systems and operations control centers have been well received on a voluntary basis by offshore transport operators worldwide. In both cases, proper use of the technology and of its underlying philosophy has resulted in safety improvements and in its favorable perception among operators.

But within the U.S. air ambulance community, the FAA’s final rule has encountered resistance from both critics and proponents of flight data analysis. The former cite concerns about privacy, legal liability and the cost of implementation. The latter say the regulations don’t go far enough to properly reap safety benefits. Now, as operators struggle with how to best meet the new requirements, some proponents are stepping forward to correct what they perceive as a misunderstanding of the rule’s intentions and effectiveness, and to push the boundaries of what data can do to improve safety in the air.

Flight Data Monitoring

The FAA’s March 26, 2015, Advisory Circular 135-14B explains one of the new regulations, FAR 135.607, which says, “After April 23, 2018, no person may operate a helicopter in air ambulance operations unless it is equipped with an approved Flight Data Monitoring System (FDMS).” Later, that rule says such a system is free to collect data “according to a broadly defined set of parameters, including information pertaining to the aircraft’s state (such as heading, altitude and attitude), condition (such as rotors, transmission, engine parameters and flight controls) and system performance (such as full authority digital engine control and electronic flight instrumentation system).”

Notably, the rule requires no specific data points and gives little advice about what types of data would be valuable during post-flight analysis. (For example, it doesn’t say that attitude and rate of descent would be useful in reviewing a hard landing.) The FAA left this aspect purposely vague, out of concern that requiring specific data would make the operator legally liable for them.

There is also no requirement to establish flight operational quality assurance—a program designed to improve aviation safety through the proactive use of data collected from a flight data monitoring system.

According to Stuart “Kipp” Lau, a consultant with flight data monitoring provider SkyTrac, the regulation falls short of the mark. Lau wrote about the new requirements in a 2015 white paper while acting as the lead for the International Helicopter Safety Team’s systems and equipment working group.

In the paper, he called the lack of data requirements in 135.607 “a missed opportunity,” adding that flight data monitoring programs—from airlines to large offshore helicopter operators—”leverage large amounts of data to benefit the entire enterprise.” He also wrote that the value of “each additional parameter is exponential to the organization when employed” in an effective program, from safety to maintenance to “back-office functions such as operations and dispatch.”

CHC Helicopter is using flight data analysis to improve its line-oriented flight training program.
On the other hand, the air ambulance community has still met this baseline requirement with wariness. Resistance from operators generally stems from the cost of implementation. They, pilots and even medical insurance underwriters fear data might be misused. Such fears are not totally unfounded. The FAA’s rule affords operators legal protection of private data only if they have established an agency-approved flight operations quality assurance program. This is good news for large operators, but may concern smaller outfits that lack the resources to establish a robust program.

Lau said even large offshore support operators—which pioneered the use of flight data monitoring and other safety best practices for rotorcraft—initially resisted the technology because of the data-sharing aspect. They feared that if specific operators were identified, one could theoretically benefit from the other’s data. But these fears were ultimately replaced with enthusiasm once those operators began to see tangible benefits to safety.

CHC Helicopter is using flight data analysis to improve its line-oriented flight training program.

“One example relates to landing an aircraft type with a relatively low tail boom as part of its design,” CHC’s Melinda De Boer told R&WI. Pilots of such aircraft must be conscious of the risk of striking the tail on the ground during short final and landing, when the aircraft will have a nose-up attitude.

CHC’s flight data monitoring program “recorded data that indicated our crews were coming in with the nose up at an angle that was increasing the risk of tail boom impact,” said De Boer. “The data was not specific to one base or type of operation, which told us we needed to amend our training and SOPs globally.” She said the data was communicated to all pilots flying the aircraft type. “From the first day after that communication, the data recorded an immediate correction by all crews in all locations.”

CHC is also using flight analysis data to improve its line operations safety audits, examining how flight crews react individually and collectively to threats and errors.

Like their offshore counterparts, air ambulance operators of all sizes stand to benefit from flight data analysis and are in various stages of compliance with the upcoming requirements. Dallas-based aeromedical transport provider SevenBar Aviation currently operates three helicopters—two AgustaWestland AW109Es and one AW109SP—but hopes to have eight by summer. SevenBar is also in the process of starting an FAA-approved flight operational quality assurance program, and is participating in HAI’s Aviation Safety Analysis & Sharing Helicopter Flight Data Monitoring Research Project.

According to B.J. Raysor, SevenBar’s SVP of operations, about half of his line pilots at a previous organization resisted the flight data monitoring program initially. But within 30 days of SevenBar’s implementation, he said, a hospital aircraft was involved in an autopilot excursion under instrument meteorological conditions (IMC) that proved the value of flight data monitoring.

Data collected from the flight “helped the pilot try and validate what happened and allowed us to look at it and say, ‘Wow, you did a really great job of handling that,’” said Raysor. “It picked up a really unusual attitude-type maneuver before he could get it to stop.”

Raysor said he also showed the data to management, further validating the company’s simulator training program.

On the larger end of the size spectrum, Air Methods has not yet completed installations of flight data monitoring systems on all of its helicopters, but expects to meet the 2018 deadline. Dennis McCall, the company’s operations director, told R&WI that the company is in favor of the new rule, saying “it lends itself to driving down the accident rates, and that is what makes it an important initiative.” He added, “It is a huge driver of our SMS by raising awareness within the companies and industry.”

He also added that flight data monitoring has “created the need to make more modern devices at lower prices.”

Metro Aviation’s Helicopter Flight Training Center hopes to harness flight data monitoring information in its simulators to improve training. Photo courtesy of Metro Aviation
Some groups are pushing the boundaries of what flight data monitoring can provide for the rotorcraft industry. Raysor, who previously served with the National EMS Pilots Assn., suggested flight data analysis could benefit that group’s Enroute Decision Point protocol—which it developed to help pilots recognize from their own flight profiles when they are entering deteriorating weather conditions that could lead to inadvertent IMC. Flight data monitoring, he said, could reveal trends in flying behavior that might inform revisions to the protocol. Metro Aviation’s Helicopter Flight Training Center is using its full flight simulators and flight training devices to test pilots against that protocol.

The center’s director, Terry Palmer, said she hopes to harness flight data monitoring information in the simulators to improve training—both by collecting flight analysis data from simulator flights and by using it to run new scenarios.

Operations Control Centers

FAA AC 120-96A describes another regulation established by the 2014 changes. FAR Part 135.619 requires that air ambulance operators with 10 or more helicopters assigned to their operations specifications establish operations control centers by April 22 of this year.

SevenBar established its own center despite being a three-helicopter operation. Though the company’s experience has been positive, Raysor conceded, the cost of setting up and running the center could run as high as $500,000. That contributes to resistance to their use, especially from medium operators barely above the 10-helicopter threshold.

Furthermore, the FAA has set a maximum duty shift of 10 hr for the operations control specialists who staff the centers. This not only means having to employ more specialists, but it also complicates aviation planners’ efforts to staff 24-hr shift schedules (which is far easier to do with two 12-hr-shift employees).

Another point of contention is who to designate as a specialist. Rather than training new employees, a few of the larger operators have insisted on employing former line pilots—such as those who have lost their medical certificates—as specialists. This saves an operator money, since pilots are already familiar with the operation. But it also runs the risk of introducing a dangerous bias into a center’s operation.

Part of an operations control specialist’s job is to perform a risk analysis of each flight. A high-time pilot in that role might have an individual opinion of what constitutes a risk and clear a dangerous flight. Operators choosing this staffing method will have to use caution in emphasizing compliance to procedures.

For those looking to train new specialists, options exist, such as the National Operations Control Academy, which is kicking off its inaugural operations control specialists training courses this month in Wichita, Kansas.

Owner David Hartter has other advice for operators looking to establish their own centers. He stressed five essential components: aviation situation displays for flight following; weather reporting tools; communications systems; navigation systems; and risk assessment tools. With regards to the situation displays, he said there are many options that are partially suitable, such as FlightExplorer. It is a great tool for the airlines, he said, but its airport-to-airport navigation is unsuitable for air ambulance operations. Another option is RotorWatch, which he said has come a long way toward becoming a viable choice. But he said his favorite is Google Earth Pro, which can be used with a SkyTrac overlay to provide surprisingly robust data.

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