3.001(a)(1) Applicability

1. 3.001(a)(1) Applicability Add: Except for HEMS operation i.a.w. 3.005(d) and Appendix 1 to 3.005(d) State aircraft should compete with our operation on a level playing field

2. 3.030(a) MMEL Change in first sentence: …shall… to ‚MAY‘ Add: The authority may accept only MMEL issued by the competent authority of the country of design of the type certificate holder or issued and approved by the competent authority within the EASA member states The authority may allow operation without any MEL (all items must be operational – this is a decision of the operator – not a safety issue) The authority may not force us to use a none European MMEL, except the one from the design holder state

3. 3.140(a)(1)(iii) Information retained on ground Add to (iii): …., or Add new (iv): If appropriate; HEMS operation are excepted It is not practicable, resonable nor feasable to leave copies of information on ground at EMS missions, due to short time until start. It is not reasonable to install a fireproof container, which is really protecting papers on board, in a small and medium size helicopter.

4. 3.165(d)(4) Leasing, short term Add # (d)(4): For Dry lease i.a.w. para. (b)(1)(2)(i)(ii) and (c)(2)(1) above, the AOC shall be issued by the competent authority of a EASA member state. For Dry lease the continued airworthiness management shall stay with the lessor. This shall be governed by a contract between the lessee and the lessor, acceptable to the authority.  Short term dry lease, without change of the continued airworthiness system, should be possible.

5. Appendix to 3.005(d)(2) HEMS operation, tactical radios Add: …….will require airworthiness ‚INSTALLATON‘ approval ‚ONLY‘ Tactical radios do not hold regularily an airworthiness approval, so only the installation can be certified

6. Appendix to 3.005(d), (e)(4) Applicability Cancel complete: Operator should not be made responsible to train and educate any ground personnel, as this seems to be unreasonable

7. Appendix 1 to 3.005(f), (c)(12) Supplemental oxygen Add: The local competent authority may grant excemtions. Some operations may be carried out safely above 10.000´ without supplemental oxygen on board.

8. Appendix 1 to 3.005(h), (e)(2) Tactical radios for hoist ops. Change: ……, will require „to be verified that their operation will not interfere with the helicopter basic systems“ (cancel: airworthiness approval) Tactical radios are usually not airworthiness certified. An interference check will provide equivalent safety.

9. 3.180(a)(1) Issue AOC, Aircraft certification Change: … standard C of A to none restricted C of A Better definition of certification, as standard is not defined (but definition exists for none standard (restricted)

10. Appendix 1 to 3.517(a), (b)(vi) (B)(C) Repair time for UMS Change: 8 flights to or 50 HEMS Missions 72 hours to 10 days Very short rectification requirement is technically not feasable and unreasonable. Extended rectification time will not jepardise flight safety.

11. 3.700, 3.705, 3.715(a) VCR, FDR requirement Change: Weight restriction for installation from 3175 Kg to 5700 Kg. No real reason, why OPS-1 airplanes requiring such equipment (with more pax. on board) only at 5700 kg, but helicopters at a lower weight. Second solution: No retrofit to existing CofA‘s and for new helicopters up to 5700 Kg only VCR installation

12. 3.745(a), AMC to 3.745(a) First Aid kit Change to AMC: delete requirement for second language. Add: local, and if required for operations, in English language Add to regulation: ….., except in HEMS operations Mandatory second language, describing contens of first aid kit is unreasonable. In HEMS operation first aid kit should not be required. Remark: If first aid kit is required it should not contain prescriptive drugs.

13. 3.875(a) Pre-Flight inspection Change from pre-flight Inspection to: Pre flight check Inspections, as per Part-145 definition, require a release to service. Change required to standarize wording and to avoid misinterpretation.

14. 3.1160(b)(4) Dangerous goods, in HEMS Add: ……a patient…., „ and HEMS operations, including all flights associated to the HEMS operation“ Wording may lead to misinterpretation. For flights without a patient on board, all medical dangerous goods must be removed from the helicopter.

15. AMC to 3.035(4.7.2) Required QS Audit intervall Change: … Audit interval from 12 to 36 month An annual audit requirement for all ops. points is unreasonable. An internal auditing in a three year intervall is sufficient, without jepardising safety in any manner.

16. IEM to 3.175(c)(2) Applicable authority, place of business Change: …… and …..and … to „ administrative headquaters“ Today location of administrative, maintenance and operational location may define the priciple place of business. This could be in three different countries – so ist unclear which airworthiness authority may be responsible for the operator.

17. OPS 3.285 Briefing of passengers Add: “Exception is a medical patient under proper care” Its clear that a patient can not be briefed in a HEMS mission

18. Change: “..to/from HEMS operating site located in a hostile environment shall be operated in accordance with subpart H (Performance Class 2)” PC 1 specifications for obstacle clearance in take-off and landing area can hardly ever be achieved at HEMS operating sites. PC 2 is achievable, realistic and in accordance to daily practise in HEMS operations. App 1 to 3.005(d)(c)(2)(i)(B)

19. Change: “Recency.All pilots conducting night HEMS operations shall have completed….” What is the philosophy/reason of sim IMC training for pilots operating day VFR only? App 1 to 3.005(d)(c)(3)(iii)

20. Change: “…specified geographical area … to the satisfaction of the authority…” INTO .. Up to the distance of a 1 hour flight… Uniform specified geographical area for all operators (level playing field). Also prevents current problems: if target hospital is outside specified geographical area, how back to base during night? Endurance of present day HEMS helicopters is normally limited to 2 hrs. App 1 to 3.005(c)(3)(iv)(B)

21. Change;“…1 July 2002”. Into a later date. Add: Introduce option to allow use of PIS after a flight operational evaluation by operator and Authority (as in present German Heliport regulations) This will reduce the number of usable hospital sites, some states did not implement 3.005 (i) and have introduced landing sites after this date that do not allow for PC1. No uniform hospital helipad design in place. App 1 to 3.005(i)(c)(2)

22. All implemented EG 2000-79: 2000 hr, 96 days off etc. HEMS operators were never consulted toward this regulation! All have special national HEMS FDRs: Allowing for region specific requirement (geographical area, number of missions, response times required, number of cumulative actual flight hours per year); Taking into account the impossibility to plan the missions; All flight safety driven; Proven experience: no HEMS FDR related accidents The existing national HEMS FDRs work to the satisfaction of the operators, the crew and the national authorities . Use: Operator risk base analysis incorporating region specific requirements: geographical area, number of missions, response times required, number of cumulative actual flight hours per year (good track record, most present FDR’s work to the satisfaction of the operators and pilots); Consult EHAC in the FDR change process if changes are to be made Subpart Q

23. Low level IFR NVIS Other

24. OPS 3.037Accident prevention and flight safety programme / Safety Management System Implementation of 3.037 (B) according to Draft-NPA-OPS 66A (Safety Management System)