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Cultural Barriers

By Elan Head

by Elan Head | October 23, 2015

Published on: October 23, 2015
Estimated reading time 24 minutes, 25 seconds.

There are thousands of instrument-rated helicopter pilots in the U.S., but IIMC remains a deadly problem. Would IFR-certified single-engine helicopters help?
IFR-certified single-engine rotorcraft are practically nonexistent today. A new industry proposal would make it easier to certify single-engine helicopters for IFR operations, a change that proponents say would improve safety and pave the way for an “IFR-as-normal” culture in the commercial helicopter industry. Anthony Pecchi Photo
Like many commercially trained pilots who have entered the United States helicopter industry over the past decade, I’m a certificated flight instructor with an instrument helicopter rating. I can say without question that earning my instrument and instrument instructor ratings made me a better pilot. But it didn’t make me an instrument pilot.
I did my instrument training — and subsequent flight instruction — in a Robinson R22 equipped with a standard “six-pack” of steam gauges and a Garmin 430 GPS. Hand-flying an ILS approach in an unstabilized R22 is a special kind of challenge, but it doesn’t bear much resemblance to the world of actual instrument flight. For me, and for many of my peers, instrument ratings were strictly a career investment; endorsements to satisfy a future employer’s insurance requirements. If someday we were to find ourselves in a real instrument flight rules (IFR) program, we were told, we would learn the rest of what we needed to know then.
If an IFR-certified helicopter had been available at my school, I would have happily paid a premium for some actual IFR flight time, at least occasionally. Of course, no such helicopter was available, because for the past 15 years, only multi-million-dollar, multi-engine helicopters have been approved for IFR operations. Initially I assumed that a second engine was required for IFR flight. Later, it was explained to me that the requirement wasn’t for the extra engine, but for the avionics and stabilization systems associated with larger, more expensive rotorcraft.
Even after meeting pilots who had previously flown IFR-certified Bell LongRangers, I took it for granted that IFR helicopter flight was synonymous with two engines. Like many of my friends who have stayed in the visual flight rules (VFR) world, my actual helicopter instrument flight time has remained at exactly zero. Unlike many of my friends, however, I haven’t moved on to flying air ambulance or law enforcement missions at night, in marginal weather, in single-engine Bell 407s or Airbus Helicopters AS350s. In these VFR-only aircraft, my peers are necessarily excluded from the IFR system, and many of them also lack the equipment and proficiency necessary to survive inadvertent flight into instrument meteorological conditions (IIMC).
The accident statistics bear this out. According to a recent industry white paper — jointly prepared by Helicopter Association International (HAI), American Helicopter Society (AHS) International, General Aviation Manufacturers Association (GAMA), and Aircraft Electronics Association (AEA) — between 2001 and 2013, there were 194 civil single-engine helicopter accidents worldwide (including 57 in the U.S.) related to IIMC or controlled flight into terrain (CFIT) while attempting to avoid weather. One hundred and thirty-three of them were fatal, resulting in the deaths of 326 people. The white paper notes that the year-to-year statistics are erratic, indicating “a broader issue where a high-risk practice of ‘scud running’ is prevalent, and what is captured in the data are the aircraft that failed in the gamble.”
Modern glass cockpits have reduced the workload and interpretive skill level required to fly IFR — a strong argument for restoring single-engine IFR certification, according to proponents. Sheldon Cohen Photo


None of the 194 helicopters involved in these accidents were IFR-certified, but in the U.S., at least, a significant number of pilots were instrument-rated. In an independent review of National Transportation Safety Board (NTSB) accident data, I found 47 single-engine helicopter accidents during the 2001-2013 time period that were obviously the result of IIMC or weather-related CFIT (I excluded some accidents that took place in IMC, but which involved maneuvering close to the ground or contributing mechanical failures). The pilots in fully half (24) of these accidents held helicopter instrument ratings, while the pilots in another six accidents held airplane instrument ratings. Moreover, because the instrument-rated pilots in this sample tended to be commercially employed and carrying passengers or crewmembers, they were responsible for 22 more fatalities than the non-instrument rated pilots (many of whom were low-time private pilots flying personal aircraft).
Under its recently issued helicopter air ambulance (HAA) rule, the U.S. Federal Aviation Administration (FAA) is requiring that all HAA pilots in command hold an instrument rating. As is clear from the accident data, however, an instrument rating alone does not guarantee that a pilot will avoid or survive IIMC in a single-engine VFR helicopter (and in fact all of the air medical pilots in my accident sample held instrument ratings, which have long been a common employer requirement). But what if those instrument-rated pilots had been flying IFR-certified aircraft — would that have made a difference to their outcomes?
Not necessarily. The aforementioned white paper also cites 54 worldwide IIMC/CFIT accidents between 2001 and 2013 involving multi-engine helicopters, most of which aircraft were equipped for IFR flight. In the majority of these cases, however, the pilots were attempting to fly VFR, usually because they weren’t current or confident in IFR procedures. Now, if instrument-rated pilots had been flying IFR-certified helicopters under the structure, surveillance, and currency requirements of actual IFR — well, that might have made a very great difference indeed.
“If these helicopters had been operating IFR, these accidents, hundreds of them, would not have taken place,” said Paul Schaaf, a former U.S. Army and Fairfax County Police Department pilot who currently serves as advisor, Technology in Regulations for AHS International. In their white paper — which outlines a proposal to make IFR certification of single-engine helicopters financially viable — AHS, HAI, GAMA, and AEA don’t argue that IFR-certified single-engine helicopters will, on their own, lead to improved safety. However, they do identify cost-effective IFR helicopters as a necessary step in producing “a shift of rotorcraft operational culture to a more ‘IFR as normal operation’ mindset,” which they think would dramatically improve the IIMC/CFIT accident rate. As the associations put it: “A culture of IFR operation cannot be cultivated where the largest population of rotorcraft, and almost all training rotorcraft, are not IFR certificated.”

Divergent Policies

So why are there no new single-engine IFR helicopters? A second powerplant is certainly a welcome thing to have when you’re operating in the clouds, but it’s also true that single-engine helicopters routinely operate on missions and over terrain where the outcome of an engine failure would be catastrophic. In fact, there is no regulation in the U.S. prohibiting single-engine IFR helicopters. Their scarcity can be traced, instead, to 1999 and 2001 changes to an FAA advisory circular (AC) that made single-engine IFR certification extraordinarily cost-prohibitive.
The Aérospatiale SA-341 Gazelle was the first single-engine helicopter to be certified, in the mid-’70s, for IFR operations in the U.S. Simon Gregory Photo
The certification of normal category rotorcraft with nine or fewer passenger seats and maximum weights of 7,000 pounds or less is governed by 14 Code of Federal Regulations part 27. In 1983, part 27 was amended to draw a clear distinction between the design requirements for single-engine and multi-engine rotorcraft: while the equipment, systems, and installations of a multi-engine rotorcraft must be designed to prevent hazards to the rotorcraft in the event of a probable malfunction or failure, those of a single-engine rotorcraft must only be designed to minimize hazards. As the industry association white paper points out, the intent of the 1983 rule change was specifically to relax small rotorcraft certification requirements to provide parity with part 23, which prescribes airworthiness standards for normal category airplanes.
While part 27 provides the regulatory basis for normal category rotorcraft certification, it’s relatively short on specifics. The details of what the FAA expects for certification are spelled out in AC 27-1, which in its current form runs to more than 1,000 pages. Like other advisory circulars, AC 27-1 is a policy rather than a regulatory document, which “establishes an acceptable means, but not the only means, of compliance” with part 27. Like many other FAA policies, however, AC 27-1 is often treated as having the force of regulation, since to challenge FAA policy can be expensive, time-consuming, and unpleasantly antagonistic (see p.56, Vertical, April-May 2014).
The white paper explains that in 1999, AC 27-1 was revised to incorporate numerical safety analysis methods for means-of-compliance. These defined the term “extremely improbable” as less than one event in a billion flight hours (1E-9). This is the same definition that is used for part 25 and 29 transport category airplanes and rotorcraft, and evidently geared toward preventing, rather than minimizing, hazards.
In 2001, AC 27-1 was revised again to state that loss-of-function or hazardously misleading indication of attitude, airspeed, and barometric altitude in IFR are individually “catastrophic,” and that such events must be substantiated to be “extremely improbable” when seeking IFR certification. Not even dual independent attitude indicators — which part 27 recognizes as providing acceptable redundancy — can meet this “extremely improbable” standard. According to the white paper, dual independent attitude indicators can at best support a functional probability for loss of 1E-6 to 1E-7 failures per flight hour, and “in general, substantiations of such low probability require the installation of triplex systems.”
At the same time, FAA policy for the certification of part 23 normal category airplanes was moving in the opposite direction. Recognizing that “most aircraft accidents are caused by something other than equipment failures,” the FAA decided that it didn’t make sense to hold the systems in a Cessna 172 to the same reliability standards as those in a Boeing 777. Its definition of “extremely improbable” for part 23 airplanes weighing less than 6,000 pounds is now 1E-6 or 1E-7, depending, in part, on whether the aircraft has a reciprocating or turbine engine. As the FAA remarked in its introduction to AC 23.1309-1C, “If systems are required to meet safety and reliability parameters much greater than the operational environment, the cost of the improved systems are driven to a level that makes them impractical.”
The consequences of these divergent policies are readily apparent. Today, light single-engine airplanes are routinely IFR certified with the latest glass cockpit and GPS technology. Meanwhile, IFR-certified single-engine helicopters have gone the way of the dodo — despite technological advancements not only in avionics, but also in the stability augmentation systems (SAS) needed for helicopter instrument flight. Many people in the industry believe that the FAA’s stringent certification requirements for part 27 rotorcraft, while well intentioned, have ultimately proved counterproductive.
With its sophisticated Garmin G1000H avionics suite and available autopilot, the Bell 407GX is a natural candidate for IFR operations, should single-engine IFR certification become cost-effective. Guy R. Maher Photo
“There has to be economy in safety,” remarked Erik Oltheten, a technical fellow with Bell Helicopter who has been tracking the issue since 1999. “Safety without economy isn’t safety.” He drew an analogy to home fire extinguishers, which are only widespread because they cost $20 or $30, not $10,000. “If fire extinguishers cost $10,000,” he pointed out, “people would go back to boxes of baking soda.”
In their white paper, HAI, AHS, GAMA, and AEA propose that the FAA adopt a part 27 definition of “extremely improbable” that is consistent with the definitions for Class I and II airplanes certified under part 23. They also propose that the FAA recognize the distinction between “minimizing” as opposed to “preventing” hazards in other aspects of IFR certification, by making due allowance for other features, systems, or pilot actions that would mitigate the effects of any equipment failure. The associations contend that these changes would make single-engine IFR-certified helicopters sufficiently affordable that the market would demand them and manufacturers would supply them — no special mandates required.
“The quality of the technology today is what makes it feasible,” Oltheten said of the white paper proposal, explaining that reliable digital autopilots and glass cockpits have made IFR flight easier and safer than ever before.  Meanwhile, the advent of wide area augmentation system (WAAS) GPS, ADS-B, and point-in-space approaches have made it possible to develop low-level IFR infrastructure that is practical and relevant for helicopters. “It doesn’t make sense not to have this capability in small rotorcraft,” he stressed.


Pieces of the Puzzle

The existence of appropriately equipped and certified aircraft is a necessary condition for IFR operations, but it’s not a sufficient one. “It’s only one part of a puzzle that needs to be put together,” said Chris Martino, a former U.S. Coast Guard H-65 Dolphin pilot who is now vice president of operations for HAI. The development of low-level IFR infrastructure is a second piece of that puzzle, he explained, while having current, proficient instrument-rated pilots is a third. “Once the equipment is there, the system needs to be there,” he said.
The HAI, AHS, GAMA, and AEA white paper predicts that market forces would play a large role in developing that system, if cost-effective IFR-certified helicopters became available. “The associations’ position is that it is natural for the part 27 single-engine rotorcraft community to want to have IFR capability and be IFR current — if it is affordable,” the white paper states. “Most helicopter operations are commercial, and being limited by weather prevents the aircraft from being consistently employed.”
Steve Wysong, president of the helicopter customization company Wysong Enterprises and chairman of AEA’s Rotorcraft Government and Industry Affairs Committee, said he has seen growing interest in IFR-certified single-engine helicopters, particularly among his air medical and corporate customers. Wysong noted that many of these customers are already choosing to install autopilots in their single-engine helicopters for safety reasons, and would be likely to invest a little more to gain IFR capability. Meanwhile, some air medical operators that are currently flying twin-engine helicopters only because their customers have an IFR requirement would likely shift to less expensive aircraft: “They would be real keen on the idea of going to single-engine IFR,” Wysong said.
IIMC is a stubborn problem in the civilian helicopter industry. However, it is less prevalent in the U.S. Coast Guard and other environments where helicopter IFR operations are routine, noted HAI vice president of operations and former USCG H-65 pilot Chris Martino. Skip Robinson Photo
Providing an incentive for air medical operators to downgrade from larger, multi-engine rotorcraft isn’t exactly a winning safety argument for the associations’ proposal. Yet even some committed advocates of twin-engine helicopters believe the net effect of single-engine IFR certification would be positive. “From a safety side the data is incredibly compelling,” said Tom Judge, executive director of LifeFlight of Maine and chair of the U.S. Helicopter Safety Team Infrastructure Work Group. LifeFlight of Maine operates two twin-engine AgustaWestland A109E helicopters as part of a particularly sophisticated IFR program, which has involved substantial investments in IFR infrastructure throughout the state. While LifeFlight of Maine wouldn’t have it any other way, “the reality of the market today is that there is so much more single-engine,” Judge said. “Then it becomes, what can you do to enhance the safety of that fleet?”
However, the safety currently associated with IFR operations is not simply the product of capable aircraft and supporting infrastructure — it also has much to do with experienced, professional pilots exercising discipline and judgment in their pre-flight planning and decision-making. On Aug. 26, 2015, the pilot of a Cessna 310R was killed when his plane crashed into the Indian River after performing a missed approach at Space Coast Regional Airport in Titusville, Fla. The commercially certificated, instrument-rated pilot had departed Orlando Executive Airport on an IFR flight plan 40 minutes earlier, despite the presence of thunderstorms at his destination. The pilot had deviated from the missed approach procedure and was attempting to fly out of the storm when he dropped out of radar contact.
A few days after the accident, I spoke with Philipp Wynands, a chief flight instructor for Titusville-based Bristow Academy. He pointed to it as a cautionary example of the limits of IFR, and the potential dangers of empowering pilots to fly IFR without adequate guidance, oversight, and operational procedures. Wynands said that Bristow Academy has identified some areas in which IFR-certified single-engine helicopters would be useful for primary training — for example, on the IFR cross-country flights required for the instrument rating. Yet he suggested that the potential benefit of single-engine IFR trainers “in the primacy phase probably is not very great.” Far more important to Bristow Academy’s training is a strong grounding in primacy of aircraft control and threat and error management to remove fear of IMC, and in the principles of automation and crew resource management. With these fundamentals, Wynands said, students are well prepared to receive mentoring from experienced IFR pilots within the operational environment, such as the command pilots in Bristow Group’s multi-engine offshore programs. “It’s the mentorship that’s missing in the industry,” he said. “Ownership needs to exist in the helicopter industry to mentor pilots appropriately into IMC operations.”
Dan Doepker, chief helicopter flight instructor for Hillsboro Aero Academy (formerly Hillsboro Aviation) in Oregon, voiced similar concerns. “I think the training industry would be affected some by it,” he said of single-engine IFR certification, “but I think the rest of the industry should look at training as well.” Doepker, who started his career flying airplanes, sees among many helicopter pilots “a huge lack of experience and understanding of the whole [IFR] structure.” Moving to an IFR-as-normal culture would require “a change in training and mindset,” he said, not just certified equipment.
The FAA’s uniquely permissive approach to helicopter instrument training — allowing low-time instructors with no actual IFR experience to provide training in VFR-only aircraft — has contributed to a huge pool of instrument-rated pilots in the U.S. According to the agency’s 2014 U.S. Civil Airmen Statistics, currently more than 9,600 rotorcraft-only pilots (around 62 percent of the total) hold FAA instrument ratings, in addition to nearly 15,000 pilots who are certificated in airplanes as well as helicopters. As my own example illustrates, however, plenty of us have no business flying a helicopter IFR without additional training and experience. While IFR certification of single-engine helicopters would allow many more of us to gain that training and experience, it remains to be seen how the U.S. commercial helicopter industry would transition from its current, VFR-oriented culture to a more disciplined IFR one.
While single-engine IFR certification is a greater priority for some sectors of the helicopter industry than others, “HAI believes that all sectors can benefit from having current, proficient instrument-rated pilots on staff because they tend to hold themselves to IFR standards even when flying in VFR weather,” according to an HAI spokesperson. Mike Reyno Photo
“There needs to be some wisdom in the system . . . otherwise we have people with no experience teaching people with less,” observed Michael Maya Charles, a former airline pilot, fixed-wing and rotorcraft CFII, and author of Artful Flying who has long been dismayed by the “pseudo” standards for helicopter instrument flight instruction in the U.S. Charles suggested that the IFR certification of single-engine helicopters may need to be accompanied by some operational “fences” to allow a higher level of safety while the commercial helicopter industry gains experience with its new abilities. Moreover, he said, the industry may need to draw on outside experience, perhaps from the airlines or corporate aviation, to build up its IFR culture. “Where does the wisdom come from in a system that has done so little of it? It may have to come from outside that system,” he said. “And that’s not where we customarily look.”
At press time, HAI, AHS, GAMA, and AEA were planning to present a final version of their white paper to the FAA in early October. “From our perspective,” said HAI’s Chris Martino, “that will start a dialogue” — not only with the FAA, but throughout the commercial helicopter industry. Beyond the technical and regulatory aspects of the proposal, that dialogue will naturally encompass the “other pieces of the puzzle.” What additional regulatory or policy changes would be needed to enable practical operations should single-engine IFR certification come about? How can industry and government collaborate to develop useful low-level IFR infrastructure for helicopters? And how can we move from our present “scud-running” culture to one of safe IFR operations, without dragging along the overconfidence and commercial pressures that are contributing to IIMC accidents now?
“This is not necessarily a sprint,” said Martino. “It’s a little bit more of a marathon.”

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