Health policies
  The advent of JAR-OPS 3
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  European operators

The advent of JAR-OPS 3

There are no international regulations specifically for helicopters. Rotorcraft operations are governed by civil aviation regulations, and helicopter air medical missions fall under the commercial air transport heading. Helicopter aeromedical transport is therefore covered by three different levels of regulations: ICAO (International Civil Aviation Organization) Annex 6 at the international level, JAR-OPS 3 in Europe, and OPS 3 in France.

EC 135 T1 operated by Hélicap (France)

JAR-OPS 3 is a highly detailed regulation, based on ICAO Annex 6, which is a tightly structured but more general document. The JAR (Joint Aviation Requirements) are drawn up by the JAA, or Joint Aviation Authorities, an association of national aviation authorities in Europe, and cover operational aspects of commercial air transport. National regulations are based on JAR-OPS 3, and are nearly identical in all European countries

What does JAR-OPS 3 have to say about helicopter aeromedical transport? First, it distinguishes between three activities: ambulance service; helicopter emergency medical service (HEMS); and Search & Rescue (SAR). The latter activity is not covered by JAR-OPS 3, and remains under the responsibility of each government. Helicopter ambulance flights are considered as commercial air transport, and require only slight modifications to regulations, concerning crews and cabin layouts. HEMS is also considered as commercial transport, but with one particularity: the helicopter site is not a dedicated aviation base, but may be, for example, a highway, or a football field!

HEMS = Performance Class 1

JAR-OPS 3 has a special appendix concerning HEMS. These few pages include a subject that arouses heated debate in the closed circle of helicopter aeromedical operators: the eventual obligation of operating under Performance Class 1 conditions to carry out HEMS flights.

Before we go into this rather arcane subject (except for those conversant with JAR speak), it’s worth listening to an expert: "It’s not JAR-OPS 3 that imposed safety rules on helicopter transport. These standards are based on ICAO Annex 6. It was when the JAA adopted these standards in 1989 that operators had to use twin-engine aircraft."

The watchword for JAR-OPS 3 is safety in helicopter aeromedical transport. However, this safety requirement should not be considered a hindrance, but rather a guarantee that no unfortunate incident will slow down the development of HEMS. The chosen means to accomplish this goal is ICAO Annex 6, which basically says that, "any helicopter carrying passengers must be able to land safely in case of an engine failure, with minimum damage to people onboard and on the ground." The natural consequence is that operators are forced to use twin-engine helicopters. The next step is to fine-tune performance requirements

A 109 E Power operated by Proteus (France)

To be operated in Performance Class 1, a helicopter must be certified in Category A. This means it must be equipped with at least two engines, and also have a certain number of safety-related equipment items, as well as redundant backup for control, lubrication, etc. A Category A helicopter must offer the performance needed to guarantee that, in case of a failure, the flight can continue safely. Under Performance Class 1 conditions, the helicopter can manage the failure of one of its two engines at any given moment while maintaining satisfactory safety, especially during the takeoff or landing phases.

For Performance Class 2, the helicopter is still certified Category A, but a certain "exposure time" to the failure is allowed. When the engine failure occurs early during takeoff, or late during landing, a forced landing may be necessary. This means that Performance Class 2 offers a lesser safety guarantee. However, if the failure should occur in flight, the helicopter’s performance means that it can still continue the flight.

The advantages of powerful engines

In fact, the performance class specifies performance according to weight. For example, a helicopter can be operated in Category 1 by lightening it; in case of failure, it would still have the reserve power needed to maintain satisfactory safety conditions. But reducing weight also implies a compromise: either less fuel, which shortens the range, or decreasing the number of passengers and/or equipment carried.

On the other hand, the more powerful the engines, the more the helicopter is apt for Performance Class 1. The latest, high-performance rotorcraft, fitted with the Arrius 2K1 or Arrius 2B2 engines for example, meet class 1 requirements for most weight configurations. Ideally, the helicopter should meet requirements at all weights, up to the maximum authorized takeoff weight (MTOW). If not (and this sometimes happens to HEMS operators), when they want to take off at MTOW, they no longer meet class 1 requirements, but rather class 2 - and that means they are not authorized for flight, theoretically. In short, that’s why choosing the right engine is critical.

There are, of course, other certification categories and performance classes. A helicopter certified in category B is either single or multi-engined, but does not completely meet category A standards. This means it cannot guarantee that it will be able to continue the flight in case of an engine failure, and the possibility of a forced landing has to be taken into account. Performance Class 3 implies that a forced landing will perhaps be necessary if the helicopter has more than one engine. If it is powered by a single engine, an engine failure automatically means a forced landing. Furthermore, since JAR-OPS 3 aims for maximum safety, it focuses on the possibility of engine failures - which are in fact extremely rare!

Air ambulance: the right performance class

While it is clearly stated that EMS helicopters must be operated to Performance Class 1 standards, JAR-OPS 3 does not address the question of air ambulances. They may be operated under Performance Class 1, 2 or 3 conditions, depending on the circumstances. Since they are used on scheduled flights from known sites, and with higher weather minima, there is less risk involved than with HEMS flights. A helicopter air ambulance following a secure flight path, able to land safely at any given moment, could well be a single-engine model. In fact, as for HEMS flights, helicopter air ambulances overfly inhabited areas, and operate to or from rooftop helipads.

EC 135 T1 operated by OAMTC (Austria) on a rooftop helipad

Most hospitals are of course in cities, considered a hostile environment for helicopters. In addition, many hospitals have rooftop helipads. "A roof helipad is safer and quieter," says Dr. Nicolas Letellier, president of the French association of doctor helicopter users. "When a hospital is in a city, we have to do everything possible for the helipad to be located on the roof, and also to be able to fuel the helicopter there. That makes it easier to use on a routine basis. Also, it fits with the regulations under which hospitals must operate, ICAO Annex 14 or ITAC 13." But a rooftop location means a special kind of takeoff for helicopters - backwards! - which is safer in case of an engine failure, since it allows a quick forward landing. This type of takeoff is prohibited for single-engine machines. It is much safer for Performance Class 2, but there’s less difference for the more powerful Class 1 helicopters.

As part of a contract with the hospital, an operator often performs both air ambulance and HEMS missions with the same helicopter. It would therefore be only logical for ambulance helicopters to aim for the same Class 1 performance level. In Germany, for example, there is no longer any distinction between the two types of flights. It was decided that all aeromedical transport helicopters, whether used for HEMS or ambulance duty, would meet Performance Class 1 requirements - by 2009. This still leaves a lot of time for the older BO105 machines, of which there are a number in Germany, to bow out with honor.

JAR-OPS 3 is not being applied at the same speed everywhere in Europe. In France, for example, complete application is slated for December 2004. But it has already been pushed back a few times. More time was given to operators to avoid throwing a monkey wrench in their medical transport services. Making sure that helicopter fleets comply with the new regulations is very expensive, while the business itself does not generate huge profit margins. "For a hospital, the change from a single-engine helicopter to a twin-engine machine offering first Class 2 then Class 1 performance, represents an increase in the contract price from 150,000 to 600,000 to one million euros a year," explains Nicolas Letellier. "This is a major cost rise. But we still don’t pay enough per hour of flight for this business to be really profitable for operators. In other countries, Italy for instance, the government provides more funding to hospitals. An average annual contract may be for 1.5 million euros. If we want JAR-OPS 3 to be established in Europe, and for everybody to benefit, then our government would be advised to follow the Italian example."