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preventable accident causes that could have been avoided by simply parking the aircraft or turning around well before the weather or dark night created a situation that even a great pilot couldn’t get out of.

Even with the rules that

existed at the time, we still found pilots pushing below weather minimums or into pitch black situations that created perfect high risk conditions. We hope that the new regulations coupled with enhanced operational control, satellite flight following, flight data recorders, and air medical resource management will reign in the very few “bold” or pressured pilots looking for an accident. So, in the mid eighties, the first significant rules affecting EMS pilots

came along with more restrictive weather minimums for Part 135 flight and actual flight and duty time limits. Pilots had been working very long shifts over many days of the month and this addressed fatigue factors found in those early accidents. Weather minimums at least slowed down a little of the white knights among us. Accident rates went down after the first round of regula- tions from the FAA. Numerous recommended practices and more restrictive rules followed over the years but many more tragic accidents occurred over the subsequent years where pilots continued to push even when they were actually below published VFR minimums, especially at night. The FAA


changed the A021 a few years ago to tighten up weather minimums and flight planning requirements as well. Two major NTSB EMS accident studies in 2006 and 2009 suggested that the FAA actually tighten up the rules even more and become more aggressive in their monitoring and enforcement with- in the industry. Up until this year, most of the FAA involvement in the air ambulance industry was through advisory circulars and notices with a little more bumped up monitoring. and affect.

“Advice” and rules carry much different weight The new regulations, or at least the Notice of Proposed Rule Making

(NPRM) generally reflect the advisory circulars that have come out over the last several years and have incorporated many of the NTSB recommendations. Noticeably absent from the NPRM were any mandates for Night Vision Devices.

FAA’s attention in the NPRM process by industry groups.

This and several other shortcomings were strongly brought to the Input from many

interested parties can be found at You may find the NPRM input under the tab labeled "Read Comments"--pick select all in the first window then put in "FAA- 2010-0982" in the second window if you want to review them.

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