Presentation to

A different the NL CAA

way to
23/04/2010
comply to
JAR-OPS 3
‘PC2
Enhanced’
Stakeholders representatives

-On behalf of Bond, Bristow, British International, CHC Scotia: Captain Steve
O’ Collard – Manager Flight Standards – CHC European Operations

- Eurocopter: Gilles Bruniaux – VP Fleet Safety

- Eurocopter: Olivier Voinchet – Flight Test Engineer Dauphin/EC155

- Eurocopter: Michel Gaubert – Airworthiness Department - Operational

Regulations and Policies, and OEB Manager
Agenda

- The context

- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
Agenda

- The context
- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
The context (1/3)
- JAR-OPS 3 amendment 5 includes additional Flight Performance
requirements for helicopter operations from/to offshore helidecks located in a
hostile environment (such as the North Sea), and proposes to the NAAs an
implementation starting on 01.01.2010. These requirements are called ‘PC2
Enhanced’ (PC2E).

- These requirements are (NB: in the event of one engine failure during the
take-off or the landing phases): « The take-off mass takes into account: the
procedure; deck-edge miss; and drop down appropriate to the height of the
helideck » (JAR-OPS 3.520(a)(3)(ii)), and « The landing mass takes into
account: the procedure; and drop down appropriate to the height of the
helideck » (JAR-OPS 3.535(a)(3)(ii)).

-Several North Sea Countries have introduced the PC2E requirements in their
national law since 01.01.2010,

- Problem is that some NAAs have a unique interpretation on how to comply,

which is to impose for PC2E the CAT A / PC1 take-off and landing profiles.
The context (2/3)
- On another hand the Eurocopter position, shared by the North Sea
operators (Bond, Bristow, British International, CHC) is that these CAT A /
PC1 profiles, as part of PC2E, might be less safe in the offshore helidecks
environment, mainly because they use a Rotation Point (RP) / Take-off
Decision Point (TDP) at 30 ft instead of a low height vertical climbing.

- This is the reason why Eurocopter, in its letter to EHOC (dated 30/11/09),
has recommended not to apply the PC2E procedures in an offshore helideck
environment and has recommended to continue to use the ‘PC2 Limited
exposure’ instead (NB: because of Eurocopter commitment to EHOC made in
2008, draft PC2E Flight Manual procedures and performance were
nevertheless provided for EC225LP and EC155),

- The UK North Sea operators have presented this position to the CAA UK in
2009, which has received a very positive feedback. An extra delay has been
granted to the operators until 01.07.2010 in order to allow the CAA UK to take
a final position.
The context (3/3)
- The Eurocopter Letter to EHOC has been officially transmitted to the UK
and NL CAAs at the end of February 2010,

- Eurocopter and the UK offshore operators have presented the current

position to EASA on March 4th 2010. EASA has positively received and
understood the Eurocopter and UK operators concern and seems to have
agreed that, according to JAR-OPS 3 ACJ to Subpart H, imposing for PC2E
the CAT A / PC1 profiles is not the unique way of compliance (NB: official
minutes from this meeting awaited from EASA).

- In addition this position has been presented in 2009-2010 to:

-Shell
-Total
-OGP ASC
-During the Eurocopter oil and gas marketing seminar
-EHOC
-Some operators like NHV, Dankopter …

and has received a good feedback

Agenda

- The context

- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
Background

• Performance Class 2 (PC2) limited exposure:

• One engine failure can lead to an accident with a probability of 5 10exp-8

per take off or landing (exposure of maximum 9 seconds, engine
reliability rate approximately 10 exp-5 per flight hour)

• PC2 enhanced:

• Theoretically safer than PC2 limited exposure

• Reduction of margins as compared to PC1:
• Safe forced landing in case of engine failure before TDP for take-off
and after TDP for landing
• Possible reduction of deck edge and drop down margin in case of
engine failure after TDP for take-off
PC2 limited exposure (AEO)

• The current take off procedure performed by UK operators = limited

exposure with climb at about 15ft to 20ft before rotation

h TDP
= 15ft
PC2 enhanced (AEO)

• What would be the take off PC2 enhanced AEO?

Every day, risks will increase,

especially with inexperienced pilots,
in bad weather conditions and at night:
-Loss of helideck visual reference
-Obstacle strike with the tail
- Moving decks
h TDP = 30ft
PC2E (AEO)

• PC2E profiles are very precise and difficult to fly accurately in

an offshore helideck environment. They depend on several
parameters (clear approach and go-around, clear continued
take-off, no lateral flight path component, no turbulence, no
movement of helideck, accurate tide and significant wave height
data). If any of these requirements are not met, PC2E profiles are
not possible even if operating at PC2E weight.

• For example: in case of take off and landing with the « 90°
offset » procedure (almost one third of the cases according to
operators): PC2 limited exposure is the only realistic solution (or
OEI OGE performance!)
PC2 (AEO)

• Combination of PC2 limited exposure and PC2 enhanced

profiles is complicated for the pilot (calculation and
execution), and therefore leads to difficulty in
standardization.

• For Eurocopter, safety level in AEO mode (everyday

operation) will be higher with PC2 limited exposure than
with PC2 enhanced profiles
PC2 limited exposure (OEI)

• An engine failure during the limited exposure time leads to an accident:

probability 5 10-8 per take off or landing

15ft
PC2 enhanced (OEI)

• PC2 enhanced take off: in case of engine failure before TDP, a safe forced
landing is theoretically possible before TDP but more difficult if the TDP is
higher because
• The risk of losing the visual reference of the helideck is higher
• The risk of obstacle strike is higher

• If the pilot moves forward before the TDP, the safe forced landing in case of
engine failure before TDP can be impossible: deck edge strike

The trend for the crew can be to move forward before the TDP,
because:
TDP Fear of the obstacle in the rear and fear of loss of
h TDP references greater than the fear of engine failure,
= 30ft Priority to leave the helideck and pass the deck edge.

This trend will be greater in case of:

Bad weather conditions,
Night flight,
Height increase of the TDP
Moving decks
PC2 enhanced (OEI)
• In case of engine failure after TDP, PC2 enhanced take off regulation allows
having deck edge margin less than 15ft and drop down margin less than 35ft
• Today, everybody agrees not to have a margin less than 15FT for the deck
edge miss
2nd segment
• Drop down margin below 35FT not reasonable
ENGINE FAILURE Vy, 150ft/mn
OEI cont

1st segment
TDP VTOSS, 100ft/mn
OEI 2mn 1000ft
OEI 30s
Vy
30ft

200ft
VTOSS=45kTAS
15ft

HEIGHT LOSS
35ft
Safety in OEI
Comparison of the PC2 enhanced risk with the PC2 limited exposure risk

PC2 limited exposure risk: catastrophic event at 5 10E-8 per take off and landing

PC2 enhanced risk:

• In case of engine failure before TDP, if (pure assumption) 1 safe forced
landing procedure out of 2 leads to a catastrophic event (1 out of 2 trajectory
not vertical) and
• If the associated exposure is approximately 3 seconds during climb to TDP,
• The calculation of the catastrophic event probability is 10E-5 (engine
reliability rate) * 3 (exposure time)/3600 *2 engines and /2 (missed procedure)
= 10E-8
we should also take into account for PC2 enhanced the risk of
a missed procedure in case of engine failure during landing and after
TDP during take off (piloting margins)

• the orders of magnitude are the same:

• 10E-8 to be compared to 5* 10E-8

For Eurocopter, SAFETY in OEI is similar for PC2 enhanced and

PC2 limited exposure
OGP Statistics
Global safety of a twin engine helicopter in the oil and gas industry:

• According to OGP data, the Offshore WW average accident rate (1998-

2006 all manufacturers included) is 1.65 accidents per 100 000 flight
hours (134 accidents)
• Regarding one average flight duration which is 1 hour (equivalent to one
take off and landing), this figure has to be compared to the theoretical
risk taken by operating PC2 limited exposure which is 5 10exp-8 = 0.005
per 100 000 flight hours

• 0.005 very small in relation to 1.65 !

• In addition to that,
If 10% of additional flights due to the potential payload loss with PC2E,
10% of additional accidents at the end, more than 1 additional accident
per year! (134 accidents in 8 years)

for EC twin engine helicopters, there is no experience of accident

following an engine failure during take off or landing from a helideck for
the last 10 years.

In the helicopter world, many more accidents due to obstacle strike and
loss of visual reference than to engine failure.
Eurocopter safety conclusion

EC thinks that the global risk with ‘PC2 limited exposure’ is smaller than the
global risk with ‘PC2 enhanced’ due to the facts that:

• In case of one engine failure, the order of magnitude of an accident

probability is the same for PC2 limited exposure and PC2 enhanced and
is very low,

• The daily risk is lower by performing a PC2 limited exposure than a PC2
enhanced procedure.

• The increasing number of flights caused by PC2 enhanced payload

reduction will increase the number of accidents

• The previous safety conclusions drawn for PC2 enhanced are mainly
also valid for PC1 in an offshore environment (TDP PC1 = 30ft, loss of
payload….)
Agenda

- The context

- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
Way forward proposed by EC

Proposition of a new PC2 philosophy : PC2 Defined Limited Exposure (PC2D)

• Keeping a TDP/Rotation Point at 15/20 ft
• Quantifying the exposure time from 0 to a maximum of 9 seconds
• Decision to be taken by the Operators/End User taking into account
the global risk assessment

Probable effect of Exposure time :

• No exposure time : safe forced landing or fly away

• Exposure time less than 1 second: risk limited to possible deck

edge strike (no ditching )

• Exposure time between 1 and 9 seconds: risk covers possible deck

edge strike and ditching . But fly away could still be possible
depending on positive effect of:
• Real wind compared to factorized wind
• No total-and-sudden loss of power
• Real remaining engine power greater than minimum criteria
PC2 Defined Limited Exposure : principles

To give all the information to the operator to determine the optimized take off
weight for the mission taking into account the best safety compromise between :
• Risks induced by platform environment (AEO)
• Risks induced by exposure time (OEI)
• Risks induced by additional flights (AEO)

2 ways offered to the pilot:

• Calculation of the take-off weight versus the wished (defined) exposure

time and Zp, Ts, platform height, factorized wind.
or
• Calculation of the defined exposure time versus the wished take-off
weight and Zp, Ts, platform height, factorized wind.
PC2 Defined Limited Exposure : principles

In any case, the crew knows the theoretical exposure time (X seconds):

In practice:

Real exposure time : Y , could be lower than theoretical exposure time X

due to :
• wind factorization effect,
• engine failure profile,
• engine power check positive

In case of engine failure occurring before the theoretical exposure time X , the
combination of parameters ( height, IAS,VS …) that could permit a fly away could
be defined in the flight manual
PC2 Defined Limited Exposure: 3 scenarii

1 –ENGINE FAILURE BEFORE TDP : no exposure time (safe forced landing)

• Carry out a rejected landing and cushion the touchdown

2 - ENGINE FAILURE AFTER TDP AND WITHIN THE THEORETICAL

EXPOSURE TIME: 3 possibilities:

a/ A safe force landing could be not possible (Æ deck edge strike risk):
• no effect of wind factorization ,
• sudden loss of power
• engine remaining without positive power margin
• .....
b/ Water impact avoidance could not be possible (Æ ditching risk)

c/ A Fly away is possible (the real time exposure is lower than the
theoretical exposure time due to: wind effect , power effect...

3 - ENGINE FAILURE AFTER TDP AND AFTER THE THEORETICAL

EXPOSURE TIME:

• Carry out fly away and join Cat A flight profile

PC2 Defined Limited exposure: THEORETICAL Exposure Time

THEORETICAL TIME EC 225 332L1 EC 155 B1

EXPOSURE
( DRAFT )
Exposure time relative to <0.5s @ MAUW <0.5s @ MAUW <0.5s @ MAUW
deck edge up to ISA+10 up to ISA+10 up to ISA+10
At SL ISA, for a 100ft helideck height:

Wind=0kts 2.5s @ MAUW 2.0s @ MAUW 2.5s @ MAUW

WITH an Factorised (0.5) 0.5s @ MAUW 0.5s @ MAUW 0.5s @ MAUW

Wind=10kts
At SL ISA+10 (less than 15% for North Sea), for a 100ft helideck height:

Wind=0kts 4.0s @ MAUW 4.0s @ MAUW 3s @ MAUW

WITH an Factorised (0.5) 2.0s @ MAUW 2.0s @ MAUW 1.5s @ MAUW

Wind=10kts
PC2 DEFINED Limited Exposure: gap between the Theoretical and Real
Exposure Time
Effect of 50 % wind factorisation
Effect of engine power
EC225 & 332L1 & EC155B1
With a wind 10kt greater than the wind factored:
ÆDLE is reduced by 2s compared to the theoretical
value
Example : With a 40kt real wind
Æ DLE is reduced by 4s compared to the theoretical
value
2% margin on Engine Power Check
Æ DLE is reduced by 0.5s compared to the theoretical
value
10% remaining power on the failed engine during the
theoretical DLE
Æ DLE is reduced by 2.5s compared to the theoretical
value
Agenda

- The context

- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
‘PC2 Enhanced’: a non-prescriptive requirement – Why?

- Reason 1: The ‘PC2 Enhanced’ requirements (§ 520 (a)(3)(ii) (take-off)

and 535(a)(3)(ii) (landing) are part of ‘Helicopter operations without an
Assured Safe Forced Landing Capability’ ,as shown here after:

‘PC2 Enhanced’
‘PC2 Enhanced’: a non-prescriptive requirement – Why?

- Consequently JAR-OPS 3 acknowledges by definition that ‘PC2 Enhanced’

cannot ensure a « 0 risk » versus an engine failure during take-off and
landing phases.

- Reminder: Helicopter operations without an assured safe forced landing

capability accept a maximum risk:

- lower than 1 case to 20 millions take-offs or landings (5. 10-8)

- which corresponds to a maximum permitted exposure time of 9 seconds
for a twin-engine helicopter having an engine failure rate of 10-5/hour
The ‘Enhanced PC2’: a target where practically possible

- Reason 2: The ‘Enhanced PC2’ requirements intentionally use:

- soft wording (‘the take-off mass takes into account deck-edge miss’)

- no prescriptive wording (‘An operator shall be satisfied that …’ ). This is not the
same as « an operator shall ensure that… »

- no prescriptive deck-edge and sea level clearance margins to be respected

Because…: see ‘ACJ to Subpart H, § 7.4.2’ (next slides)

JAR-OPS 3 ACJ Subpart H, § 7.4.2

7.4.2 Additional requirements for operations to Helidecks in a Hostile Environment

For a number of reasons (e.g. the deck size, and the helideck environment – including obstacles and
wind vectors), it was not anticipated that operations in PC 1 would be technically feasible or
economically justifiable by the projected JAA deadline of 2010 (OEI HOGE could have provided a
method of compliance but this would have resulted in a severe and unwarranted restriction on
payload/range).

However, due to the severe consequences of an engine failure to helicopters involved in take-off and
landings to helidecks located in hostile sea areas (such as the North Sea or the North Atlantic), a policy
of Risk Reduction is called for. As a result, enhanced Class 2 take-off and landing masses together with
techniques that provide a high confidence of safety due to: deck-edge avoidance; and, drop-down that
provides continued flight clear of the sea, are seen as practical measures.

For helicopters which have a Category A elevated helideck procedure, certification is satisfied by
demonstrating a procedure and adjusted masses (adjusted for wind as well as temperature and
pressure) which assure a 15ft deck edge clearance on take-off and landing. It is therefore
recommended that manufacturers, when providing enhanced PC2 procedures, use the provision
of this deck-edge clearance as their benchmark.
JAR-OPS 3 ACJ Subpart H, § 7.4.2 (ctnd)

As the height of the helideck above the sea is a variable, drop down has to be calculated; once clear of
the helideck, a helicopter operating in PC1 would be expected to meet the 35ft obstacle clearance.
Under circumstances other than open sea areas and with less complex environmental conditions, this
would not present difficulties. As the provision of drop down takes no account of operational
circumstances, standard drop down graphs for enhanced PC2 - similar to those in existence for
Category A procedures - are anticipated.

Under conditions of offshore operations, calculation of drop down is not a trivial matter - the following
examples indicate some of the problems which might be encountered in hostile environments:

-Occasions when tide is not taken into account and the sea is running irregularly - the level of the
obstacle (i.e. - the sea) is indefinable making a true calculation of drop down impossible.

-Occasions when it would not be possible - for operational reasons - for the approach and departure
paths to be clear of obstacles - the ‘standard’ calculation of drop-down could not be applied.

Under these circumstances, practicality indicates that drop-down should be based upon the height of the
deck AMSL and the 35ft clearance should be applied.
JAR-OPS 3 ACJ Subpart H, § 7.4.2 (end)

There are however, other and more complex issues which will also affect the deck-edge
clearance and drop down calculations:

- When operating to moving decks on vessels, a recommended landing or take-off

profile might not be possible because the helicopter might have to hover alongside in order that the
rise and fall of the ship is mentally mapped; or, on take-off re-landing in the case of an engine failure
might not be an option.
Under these circumstances, the Commander might adjust the profiles to address a hazard more
serious or more likely than that presented by an engine failure.

It is because of these and other (unforeseen) circumstances that a prescriptive requirement is

not used. However, the target remains a 15ft deck-edge clearance and a 35ft obstacle clearance and
data should be provided such that, where practically possible, these clearances can be planned.

As accident/incident history indicates that the main hazard is collision with obstacles on the
helideck due to human error, simple and reproducible take-off and landing procedures are
recommended.

In view of the reasons stated above, the future requirement for PC 1 is replaced by the new requirement
that the take-off mass takes into account: the procedure; deck-edge miss; and drop down appropriate to
the height of the helideck. This will require calculation of take-off mass from information produced by
manufacturers reflecting these elements. It is expected that such information will be produced by
performance modelling/simulation using a model validated through limited flight testing.
The ‘Enhanced PC2’: a target where practically possible

- Summary of ACJ to Subpart H, § 7.4.2:

- although, it is ‘recommended’ that manufacturers, when providing Enhanced Class

2 procedures, use the 15 ft deck-edge clearance and the 35 ft obstacle (i.e. the sea)
clearance ‘as their benchmark’ ‘when it is practically possible’,

- because there are ‘circumstances’ where ‘the pilot-in-command might adjust

the profiles to address a hazard more serious or more likely than that
presented by an engine failure, a prescriptive requirement is not used,

- ‘as accident/incident history indicates that the main hazard is collision with
obstacles on the helideck due to the human error, simple and reproductible
take-off and landing procedures are recommended’.
Conclusion of the JAR-OPS 3 intent for ‘PC2 Enhanced’

- It is accepted by JAR-OPS 3 that ‘PC2 Enhanced’ operations on helidecks

located in a hostile non-congested environment do not ensure, in case of one
engine failure, a safe forced landing capability in all circumstances (although
the risk has to be assessed and minimised),

-Beyond the risk linked to one engine failure, JAR-OPS 3 states that the
‘Enhanced Class 2’ take-off and landing procedures have also to take into
account the following risks:
- collision with obstacles on the helideck due to human error (main
hazard according to in-service history),
- moving decks
- sea level (tide)
Conclusion: compliance of the « PC2 with time exposure »

Taking into account that the day to day risk (AEO conditions) of collison with
the obstacles on the helideck is much higher than the risk linked to one
engine failure, the risk induced by moving decks, Eurocopter consider that the
current ‘PC2 with time exposure’ characterized by:
- A low height vertical climbing
- A risk, in case of one engine failure, lower than one per 20 millions take-offs
or landings.

is compliant with JAR-OPS 3 requirements in the offshore helideck

environment.
Agenda

- The context

- The safety issue

- The proposed way-ahead

- The JAR-OPS 3 compliance status

- Conclusion
Conclusion

1. Imposing the CAT A / PC1 take-off and landing profiles in the offshore
helideck environment is less safe than the current ‘PC2 with exposure’
way of operating,

2. Eurocopter recommends not to apply the PC2E and PC1/CAT A

procedures in the offshore helideck environment and currently
recommends to continue to use the ‘PC2 with exposure’ procedures with a
low TDP,

3. As a way ahead Eurocopter proposes the new concept of PC2D (‘Defined

Limited Exposure’) which shows that the real exposure time is most of the
time lower than 1 second. In any case, it offers to the pilot the possibility to
quantify the theoretical exposure time and to minimize it if needed (risk
assessment),

4. Current ‘PC2 with exposure’ is a minimal way to comply with JAR-OPS 3.

PC2D brings a significant safety added value
MANY THANKS FOR YOUR ATTENTION