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3.2.6 Congested Area Plan (CAP). For congested area operations, the operator must develop a plan for each complete operation, coordinate this plan with the FAA FSDO having jurisdiction over the area in which the operation will be conducted, and obtain approval for the operation from that district office. The plan must include a Letter of Agreement (see Figure 3-2, Letter of Agreement for Congested Area) with the appropriate political subdivision that local officials will exclude unauthorized persons from the area in which the operation will be conducted, coordination with ATC, if necessary, and a detailed chart depicting the flight routes and altitudes.
3-5 Figure 3-1. Sample Congested Area Plan (Submit in duplicate.)
Name, Address, Telephone Number of Operator:
Name, Address, Telephone Number of Contractor:
Rotorcraft Identification Number: N Rotorcraft Make and Model (HU-369D, etc.):
Rotorcraft Airworthiness Category (Normal, Restricted, Transport):
Pilot Name and Certificate Number:
DATES AND TIMES OPERATION WILL BEGIN AND TERMINATE:
Date Time begin Time end
Name, title, and telephone number of appropriate official of the local subdivision who has agreed to exclude unauthorized persons from the operational area, if applicable:
Copy of agreement attached? Yes/No List of streets or roads that will be blocked during operation, if applicable:
Ingress/egress routes, if applicable:
(If appropriate) This operation has been coordinated with the following air traffic control facilities:
Description and weight of loads to be carried:
Class:
Description:
3-6 Length of attaching means (includes hook and cable):
Weight of load:
Physical size of load:
List of buildings that must be either partially or entirely unoccupied by persons:
Building description/address:
Owners:
Telephone number:
Load penetration (for occupied buildings):
How many floors could the load penetrate if dropped from the highest point of lift above the building? floors What is the maximum height the load will be lifted above the building? feet Are charts, maps, and/or diagrams attached? Yes/No Narrative description of pickup site, route, delivery site, and plan for ceasing operation if unauthorized persons enter operational area:
(Use additional sheets as necessary.)
[Company official’s signature] [Title] [Date]
Sample Diagram of Congested Area Plan Route of Flight Pick-up SIte
• Emergency 8th Street + Landing Site Locations Operational Area 7th Street B Tower AV Street Blocked Tower will be vacated. No persons or vehicies will 14 stories to rooftop. Top two stories of the be on the ground in the operational area who are not directly associated with the operation. Seven city policemen will be provided to secure the operational area. See attached agreement with city police department. The fire department was notified of the operation and stated that they would be on the scene If possible.
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3-8 Figure 3-2. Letter of Agreement for Congested Area
LETTER OF AGREEMENT FOR CONGESTED AREA Personnel of the [name of the political subdivision] agree to exclude all unauthorized persons from the operational area described on the attached CAP, which was prepared for rotorcraft external-load operations. I understand that the operations will be conducted on [dates] and remove the operator’s responsibility to exclude all unauthorized persons from the operational area.
[Signature of official] [Name of official] [Title of official] [Date]
3.3 Carriage of Persons.
3.3.1 Passenger Carrying Versus Carriage of Persons. Part 133 does not provide for “passenger-carrying” operations, but does provide for the “carriage of persons” in accordance with § 133.35. If conducting passenger-carrying operations, the operation must comply with part 91 or 135. No Class A, B, or C external-load operator may allow passenger carrying during external-load operations unless the person carried is a flightcrew member, is a flightcrew member trainee, performs an essential function in connection with the external-load operation, or is necessary to accomplish the work activity directly associated with the external-load operation. An operator with Class D external-load approval may receive authorization to transport persons externally who are other than a crewmember or not directly associated with the external-load operation.
3.3.2 Class B Human External Cargo (HEC). Under § 133.35, an operator with a Class B approval is authorized to externally carry a crewmember, a person essential to the external-load operation, or a person who is necessary to accomplish the work activity directly associated with that operation with a single-engine or multiengine rotorcraft, in accordance with applicable operating limitations. If Rotorcraft Flight Manual (RFM) or RFM Supplement (RFMS) operating limitations, markings, or placards contain language prohibiting use for HEC, operators of civil rotorcraft must comply with those limitations in accordance with § 91.9(a) (e.g., an RFMS limitation such as, “the cargo hook is approved for non-human cargo, Class B rotorcraft-load combinations only”).
The RFM or RFMS may also include additional limitations indicating certification for HEC (e.g., “the external load system meets the 14 CFR part 27 certification requirements for HEC”). The operator may carry the persons in the following examples as a Class B external load, which must be jettisonable:
• Power line patrol/maintenance personnel.
• Rescue personnel who are performing emergency medical and rescue services.
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3.4 Human External Cargo (HEC).
3.4.1 Class D Load Combination Operations. As with other load combinations, Class D operations must be authorized per § 133.17. Additionally, the operator is required to have an FAA-approved initial and recurrent training program. Any pilot conducting Class D operations must be current in accordance with the training requirements of § 133.37.
Finally, the rotorcraft must meet the equipment requirements of § 133.45(e) and the Rotorcraft-Load Combination Flight Manual (RLCFM) must contain information essential for safe operation with Class D loads.
Note: Part 133 operations under instrument flight rules (IFR) must be specifically approved by the FAA; however, no person may be carried as part of an external load under IFR.
3.4.2 Class B Load Combination Operations. As with other load combinations, Class B operations must be authorized per § 133.17. The test for determining whether it is appropriate to conduct a human external load as a Class B versus a Class D external-load combination operation is to consider the standard industry practices for the work activity being accomplished. If the person is performing an essential function in connection with the external-load operation or is necessary to accomplish the work activity directly associated with that external-load operation, the operator may be authorized to transport the person as a Class B external-load combination. If the person is not performing an essential function in connection with the external-load operation or is not necessary to accomplish the work activity directly associated with that external-load operation, then the operator would be required to transport the person as a Class D external-load combination if that person is transported externally.
3.4.2.1 Class B HEC has become an essential tool within the rotorcraft-helicopter industry and when conducted utilizing best safety practices has proven to be a safe and efficient means of transport. Pilots and operators should conduct a thorough safety analysis of any proposed Class B HEC operation to ensure that the use of Class B HEC is appropriate to the mission and that a proper hazard identification and risk analysis has been conducted.
3.4.2.2 When conducting Class B HEC operations, it is important to understand the current regulatory requirements. Section 133.23 states the applicant must demonstrate to the Administrator satisfactory knowledge and skill regarding rotorcraft external-load operations. An operator that conducts HEC operations must demonstrate the specific knowledge and skill for safe HEC operations as part of the knowledge and skill test.
3.4.2.3 Section 133.33 states that before a person may operate a rotorcraft with an external-load configuration that differs substantially from any that person has previously carried with that type of rotorcraft (whether or not the RLC is of the same class), that person must conduct, in a manner that will not endanger persons or property on the surface, flight operational checks as the Administrator determines are appropriate to the RLC. Class B HEC load
3-10 combinations differ substantially from other Class B rotorcraft loads and require an operational flight check.
3.4.2.4 Section 133.41 states the applicant must demonstrate to the Administrator, by performing the operational flight checks prescribed, as applicable, that the RLC has satisfactory flight characteristics. HEC operations must be demonstrated utilizing a simulated load (ballast) on the personnel lifting device to verify satisfactory flight characteristics, unless these operational flight checks have been demonstrated previously and the RLC flight characteristics were satisfactory. For the purposes of this demonstration, the external-load weight (including the external-load attaching means) is the maximum weight for which authorization is requested.
3.4.2.5 Section 133.47 states that the applicant must prepare an RLCFM and submit it for approval by the Administrator. The RLCFM must set forth any other information essential for safe operation with external loads. With regard to HEC operations, this information should include at a minimum:
1. Class B HEC Operations.
2. Class B HEC Training:
• Pilot training.
• Crewmember training.
• Recurrent training.
• Recent experience.
3. Personnel Qualifications:
• Pilot qualifications.
• Crewmember qualifications.
4. Class B HEC Briefings.
5. Operational Safety Considerations.
6. Communications.
3.4.2.6 Helicopter operators should select only those pilots that have demonstrated a sufficient level of experience, skill, and ability within Class B vertical reference operations. Class B HEC pilot training should be conducted by an operator’s Chief Pilot or the Chief Pilot’s qualified designee. Pilot training should be conducted and documented in accordance with the operator’s Class B HEC training program and should contain, but is not limited to, the following minimum curriculum:
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3.4.2.6.1 Pilot training:
1. Knowledge and skill training.
2. Demonstrated proficiency with precision vertical reference load placement.
3. Proper load configuration, use, and application of Class B HEC.
4. Installation, inspection, and operation of secondary safety device(s).
5. Acceptance or rejection criteria of HEC attaching means to include long lines, chairs, and/or harnesses.
Note: See Appendix C, Possibility of D-Ring Reversal or Dynamic Rollout During Winching or Long Line Operations, for information about winch operation.
6. Hazard identification, risk analysis, and mitigation.
7. Crew Resource Management (CRM).
8. Communication.
9. Normal/abnormal and emergency procedures pertinent to Class B HEC operations.
10. Electrical wire environment hazards.
11. Fuel management.
3.4.2.6.2 Crewmember training. Crewmembers working on or around the helicopter should be trained by a competent person in the following areas:
1. Acceptance or rejection criteria of HEC attaching means to include long lines, chairs, and/or harnesses.
2. Task-specific operations.
3. Hazard identification, risk analysis, and mitigation.
4. CRM.
5. Communication:
• Emergency procedures pertinent to Class B HEC operations.
• Ground.
• Flight.
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6. Mock-up training and review of:
• Rigging inspection and acceptance or rejection criteria of equipment.
• Communication procedures.
• Simulation of task (both crew and pilot tasks).
7. Documented completed proficiency on all of the above.
Note: Each operator is responsible to ensure that the individuals providing crewmember training have sufficient experience with Class B HEC operations, safe rigging, and fall protection.
Additionally, competent instructors should have working knowledge and understanding of the particular risks associated with the specific operation being conducted.
3.4.2.6.3 Recurrent training. Both pilots and crew members should receive recurrent Class B HEC training annually. Additional training should be conducted and documented for each new operation type, equipment change, or when the mission profile is significantly modified.
3.4.2.6.4 Recent experience. Each operator should have a recent experience program that is designed to ensure each pilot and crewmember is prepared to perform Class B HEC safely and has conducted Class B HEC or equivalent precision operations within a specified period of time. An individual’s recent experience must be obtained from the company’s specific operations and should not carry over from outside experience.
3.4.2.6.5 Pilot qualifications. Helicopter pilots selected to perform Class B HEC operations should have previous experience with HEC operations and should be trained for safe operations within the HEC operating environment.
Operators should establish minimum sufficient experience levels to serve as a basic qualification threshold. Considerations of such minimum experience may include:
• 2,000 hours as pilot in command (PIC) in helicopters.
• 500 hours of vertical reference long line experience.
• 200 hours as PIC in specific type of the helicopter to be used in the Class B HEC operation.
• 200 hours as PIC conducting precision vertical reference, long line operations.
• Knowledge of the hazards and “hands-on” operations to be conducted.
• Fitness for duty and physical or psychological limitations (IMSAFE).
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• Communications limitations.
• Understanding of the five hazardous attitudes and their antidotes:
anti-authority, impulsive, invulnerability, macho, and resignation.
3.4.2.6.6 Crewmember Qualifications:
1. Not all crewmembers will be comfortable with or qualified to perform Class B HEC operations. All crewmembers should be selected for Class B HEC operations on a voluntary basis.
Crewmembers selected should be qualified for Class B HEC operations based on:
• Experience level.
• Knowledge of aircraft limitations, including weight limitations to meet aircraft performance limitations.
• Knowledge of the “hands-on” operations to be conducted.
• Fitness for duty and physical or psychological limitations (IMSAFE).
• Communications limitations.
• Understanding of the five hazardous attitudes and their antidotes:
anti-authority, impulsive, invulnerability, macho, and resignation.
2. Thorough training of both pilots and crewmembers is critical to safely conducting Class B HEC operations. The following topics should be developed and integrated into an operators Class B HEC training program:
• General helicopter safety training,
• Applicable regulations pertaining to Class B HEC operations, and
• Company-specific requirements and limitations.
3.4.2.6.7 Class B HEC briefings. The daily briefing should be attended by all persons involved in the operations for that particular day. The briefing should cover concerns, identified risks, and hazards. Additionally, this briefing should cover:
1. Definition of the core operational and individual tasks for the day.
2. Identification of specific hazards.
3. Discussion of hazard and risk mitigation.
4. Communication issues.
5. Weather conditions and forecasts (i.e., wind gusts, lightning, or other weather factors that could increase risk).
6. Any revisions to the site-specific safety plan.
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7. Universal “go/no-go” authority.
8. Pre-operation reconnaissance flight.
9. Personal protective equipment (PPE) appropriate for the task.
10. Review of key points of the Emergency Action Plan.
11. Weight and Balance (W&B) calculation.
Note: An additional briefing should be conducted upon any significant change in the daily operations which was not covered by the daily briefing.
3.4.2.6.8 Operational safety considerations. When selecting crewmembers for Class B HEC, care should be given to ensure that those individuals with the least experience and knowledge be paired with qualified crewmembers experienced in Class B HEC operations (no green on green). Each aircraft used for Class B HEC operations should be subject to daily engine power assurance checks and trend monitoring.
3.4.2.6.9 Communications. Prior to any Class B HEC operation, it is essential that all crewmembers and the pilot have established a clear method of communication. This may consist of hand signals and/or two-way radio communications. Communications should be tested prior to each day’s operation. When there are communication failures or confusion, operations should be suspended until clear communications are restored.
3.5 Night Operation Considerations, Limitations, Training, and Risk Mitigation Procedures (if applicable).
1. It is more dangerous to conduct rotorcraft external-load operations during darkness; therefore, extensive training and detailed planning become increasingly important. In accordance with § 133.47, the RLCFM must set forth any other information essential for safe operation with external loads.
With regard to night operations, this information should include, at a minimum, adequate considerations, limitations, training, and risk mitigation procedures describing how the operator will conduct operations at night.
2. It is important to realize that certain problems will exist at night that do not occur during daylight operations. Common night problems include increased time required for hookup, tendency for the helicopter to drift during hover, and lack of depth perception for crewmembers and ground personnel. During night operations, hand-and-arm signals are the same as daylight operations except that flashlight wands or other visible light sources are used.
3. Whenever possible, and if the situation permits, personnel should wear reflective vests. Manmade securable lighting (e.g., chemlights, battery powered light source, etc.) attached to the top of the load assists the aircrew in identifying the load; likewise, a chemlight attached to the cargo hook aids the hookup team during the hookup operation. Some helicopters are equipped
3-15 with lights positioned by the cargo hook. The aircrew identifies the cargo hook by illuminating the cargo hook light.
3.6 Public Aircraft Operations (PAO).
1. Section 133.1 prescribes that part 133 subpart B, Certification Rules (§§ 133.11–133.27) do not apply to a Federal, State, or local government conducting PAO. However, operators conducting PAO must still comply with part 133 subparts A, C, and D.
2. PAO are required to comply with part 133 subparts A, C, and D. For further information, refer to AC 00-1.1, Public Aircraft Operations. Each external-load attaching means must be approved as specified in § 133.43.
3. Any government or public entity conducting civil operations must hold a part 133 certificate in order to conduct external-load operations. This obligates them to comply with all sections of part 133.