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Affected Entities Part 135 – All Aircraft


• Permit operators to transmit a copy of load manifest docu- mentation to their base of operations, in lieu of preparing a duplicate copy.

• Specify requirements for retaining a copy of the load manifest in the event that the documentation is destroyed in an aircraft accident.

Part 91 – Helicopter Operations All Commercial Helicopter Operations (Operating Requirements)

• Revision of part 91 Visual Flight Rules (VFR) weather mini- mums.

• Revision of commercial helicopter instrument flight rules (IFR) alternate airport weather minimums.

• Require helicopter pilots to demonstrate competency in recov- ery from inadvertent instrument meteorological conditions.

• Require all commercial helicopters to be equipped with radio altimeters.

• Change definition of “extended over-water operation,” and require additional equipment for these operations.

Air Ambulance Operations (Operating Requirements and Equipage)

1. Require air ambulance flights with medical personnel on board to be conducted under part 135, including flight crew time limitation and rest requirements.

2. Require certificate holders with 10 or more helicopter air ambulances to establish operations control centers.

3. Require helicopter air ambulance certificate holders to imple- ment pre-flight risk-analysis programs.

4. Require safety briefings for medical personnel on helicopter air ambulances.

5. Amend helicopter air ambulance operational requirements to include VFR weather minimums, IFR operations at airports/heliports without weather reporting, procedures for VFR approaches, and VFR flight planning.

6. Require pilots in command to hold an instrument rating. 7. Require equipage with Helicopter Terrain Awareness and Warning Systems (HTAWS), and possibly light-weight aircraft recording systems (LARS).

All NPRM's proposed by the FAA have a public comment period which allows


and organizations the opportunity to submit writ- ten statements to the FAA to either critique or express support for the individual elements of the proposed rules. The comment period for the rules summarized in the preceding table ended on January 10. At the close of the period there were 331 public submissions on file at the official web- site for NPRM comments at

Those comments were submitted by a wide vari- ety of players in air medical transport, including air medical operators, professional associations, specific air medical provider services, aircraft and aircraft systems manufacturers, State and local government agencies, and more than just a few individuals (mine is there). All of these commentators were eager to express their support of those elements of the NPRM that seemed most likely to have a pos- itive effect on safety, while pointing out the flaws


or omissions in the proposed rules that might hin- der the delivery of air medical services without materially improving operational safety. The full text of all of the comments submit-

ted is available on the government website for those readers who have sufficient interest, time, and caffeine to read them. In this article, I will touch on only a few of the new rules which I feel threaten to be the most problematic for all air medical transport providers. Those rules are the ones num-


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