Par 5-1 Page 43 CHAPTER 5. EQUIPMENT
5-1. THE HELICOPTER AIR AMBULANCE (HAA) HELICOPTER. The selection of a suitable HAA helicopter (and its subsequent modification) will include considerations exclusive to the HAA operating environment. An applicant should identify, in their initial application, any specialized flight operations equipment that will be aboard the helicopter(s) used for HAA operations.
a. Weight and Performance of HAAs. An operator should consider the effect of the significant added operating weight associated with even a basic HAA helicopter’s mission-specific modifications including equipment such as a Helicopter Terrain Awareness and Warning System (HTAWS), radio altimeter, and Flight Data Monitoring System (FDMS). In addition, weight penalties are associated with an aeromedical interior, medical equipment and supplies, and provision for medical personnel and their personal gear. Equipment such as Night Vision Imaging System (NVIS), satellite communication (SATCOM), position tracking and reporting systems and possibly equipment supporting instrument flight rules (IFR) capability provides additional operational capability but further reduces helicopter payload and performance.
b. Control and Use of HAAs. By regulation (Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.25), the certificate holder is required to have control and exclusive use (including maintenance) of at least one aircraft to be used in part 135 service. Helicopters used in HAA operations may be owned or leased by the certificate holder. In the case of leased equipment, the lessor may be the certificate holder’s customer (hospital group or community).
This common industry practice may introduce operations control complications unless the lease is executed in a manner that transfers operations control unequivocally to the certificate holder.
Operators should be on guard against the potential of perceived operations control retention by the lessor. This practice has historically led to undue pressure on the operator during flight risk analysis and flight authorization decisionmaking processes.
5-2. EQUIPMENT REQUIRED BY REGULATION FOR HAA OPERATIONS.
a. Radio Altimeter. A Federal Aviation Administration (FAA)-approved radio altimeter or an FAA-approved device that incorporates a radio altimeter, is required and must be operational unless otherwise authorized in the certificate holder’s approved minimum equipment list (MEL). Specifications for radio altimeters under this requirement are in § 135.160. Operators should establish and document procedures to be followed if operations are conducted with an inoperative radio altimeter in accordance with an MEL. Incorporating procedures such as requiring increased ceiling and or visibility and limiting flights where white out, brownout, or encounters with flight light conditions may be possible may mitigate risk. Inoperative equipment should also be addressed as a risk analysis factor as discussed in appendix A of this advisory circular (AC).
NOTE: The FAA may authorize deviations for certain helicopters (maximum gross takeoff weight no greater than 2,950 pounds) unable to incorporate a radio altimeter. (Refer to § 135.160.)
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b. HTAWS. An HTAWS that meets the specifications of FAA Technical Standard Order (TSO) C-194 and RTCA DO-309 must be installed and operational in all HAA helicopters. The operator’s manuals or other documentation must specify appropriate procedures for the use of this equipment, including the proper flightcrew response to audio and visual warnings. There is a process for operators with HTAWS covered by a deviation under § 21.618 to meet the regulatory requirements of § 135.605. The HTAWS requirement becomes effective on April 24, 2017.
c. FDMS Capable of Recording Flight Performance Data. To meet the requirements of § 135.607, the operator must install an FAA-approved FDMS in each HAA. In this context, “approved FDMS” means only that the installed FDMS be capable of recording “flight performance data” including at minimum: Latitude, Longitude, Barometric Altitude, and Date/time of recording, once per second and have sufficient memory to retain these data over 4 hours of flight time. The FDMS is approved by Supplemental Type Certificate (STC), design review, or field approval, depending upon the complexity of the installation, the interface between the FDMS and other systems installed aboard the aircraft, and that it poses no hazard to other onboard equipment, nor any hazard to occupants. Beyond the minimum parameters, additional parameters recorded by the FDMS are at the discretion of the operator. Retention and use of recorded data is also at the discretion of the Operator. The FDMS requirement becomes effective on April 23, 2018. The FDMS is not to be confused with a flight data recorder (FDR) certified under § 27.1459, though an FDR would be acceptable to meet the FDMS requirement.
(1) The FDMS must operate from the application of electrical power prior to engine start until the removal of electrical power after termination of the flight (refer to § 135.607). The FDMS design should be compliant with Design Assurance Level D (DAL-D) as set out in the latest revisions of both RTCA DO-178 (for software development) and RTCA DO-254 (acceptable airborne electronic hardware development standards). FDMS inspection and maintenance should be conducted in accordance with the manufacturer’s instructions for continued airworthiness (ICA). Additional information is in AC 27-1B MG 6, Miscellaneous Guidance (MG) for Emergency Medical Service (EMS) Systems Installations.
(2) The operator determines and maintains the FDMS data stream format and parameter documentation. The operator is responsible for determining:
• Parameters(beyond the minimum direct parameters of latitude, longitude, barometric altitude, and date/time of recording) that are recorded and which are derived from recorded data;
• Latency (how frequently each recorded parameter is recorded);
• Bit resolution of each parameter;
• Operational range of each parameter; and
• Conversion algorithms from digital or analog signal units to engineering units.
(3) Information may be directly recorded or may be deduced from recorded data
(e.g., continually updated three dimensional Global Positioning System (GPS) location data may yield ground speed, heading and course being flown and altitude). The FDMS should record digital or analog raw data, images, cockpit voice or ambient audio recordings or any combinations thereof which ideally yield at least the following flight information:
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• Location;
• Altitude;
• Heading;
• Speeds (airspeed and groundspeed);
• Pitch, yaw, and roll attitudes and rate of change;
• Engine parameters;
• Main rotor RPM;
• Ambient acoustic data;
• Radio ambient audio; and
• Any other parameter the operator deems necessary (e.g., high definition video recording looking forward including instrument panel and forward cockpit windshield view, intercommunications system (intercom) between pilot and medical crew, communications with air traffic control (ATC), OCS, base operations, first responders at scene, hospital, etc.)
(4) The FDMS should have sufficient non-volatile memory to record flight performance data over the course of an entire flight operation. FDMS data should be retrieved periodically and the resulting information be used for Safety Assurance (SA) programs such as flight operations quality assurance (FOQA) at the discretion of the operator. The recording memory capacity of the FDMS would correlate directly to the maximum data retrieval period.
(5) Though the FDMS is not required to be hardened or crash worthy such as an FDR, it should be able to endure extreme environmental conditions including storage and operational use temperatures, the forces applied during an accident, post-impact water immersion, and to a limited extent, to high heat or fire. Refer to AC 27-1 and RTCA DO-160 (current revisions) for test and analysis options.
d. Additional Equipment Required for HAA Overwater Operations. Except for takeoff and landing, or unless operations specifications (OpSpecs) allow otherwise, overwater operations beyond autorotational distance from the shoreline requires the following special equipment to be aboard the HAA. Refer to the appropriate Title 14 of the Code of Federal Regulations (14 CFR) section. Requirements can be found in §§ 135.168, 135.183 and 136.1.
(1) Approved life preservers, equipped with an approved survivor locator light, must be carried aboard all part 135 helicopters, including HAA, for each occupant. Each occupant must wear a life preserver when the flight operates beyond an autorotational distance from the shoreline. The exception to this requirement is when wearing a life preserver would be inadvisable for medical reasons as determined by medical personnel.
(2) A 406 megahertz (MHz) emergency locator transmitter (ELT), with a 121.5 MHz homing capability and approved batteries must be installed in the HAA. This ELT must meet the TSO and RTCA standards listed in § 135.168(f).
5-3. MEDICAL EQUIPMENT FOR HAA OPERATIONS. Part 135 certificate holders conducting HAA operations will utilize equipment associated with medical transport.
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a. HAA Interiors. HAA interiors are typically lined with washable panels, edge sealed to prevent leakage of fluids into interior spaces beneath the subfloor. Interlocking and sealed flameretardant and moisture-resistant interior panels be designed in accordance with 14 CFR parts 27 or 29 would meet the requirements of an STC.
b. Stretchers (Litters). Stretchers should be designed and FAA-approved for HAA use.
Refer to part 27, § 27.561 and part 29, § 29.785 for further information. Restraining devices, including shoulder harnesses, should be available to ensure patient safety.
c. Medical Oxygen Systems. Medical oxygen and nitrous oxide for patient use may be delivered via compressed gas systems consisting of high pressure compressed gas cylinders, regulators, valves, and plumbing; cryogenic liquid oxygen systems consisting of an insulated reservoir tank instead of high pressure compressed gas cylinders and the rest of the downstream equipment mentioned above; and molecular sieve oxygen concentrators. In all cases, the installation must utilize only FAA-approved components installed in accordance with the manufacturer’s STC and field approvals as appropriate to the system chosen. Servicing of permanently installed medical oxygen systems should be delegated to appropriately trained flightcrew members or maintenance personnel. Removal, replacement, and securing of portable oxygen systems may be accomplished by appropriately trained medical personnel.
d. Medical Portable Electronic Devices (MPED). MPEDs, such as Automated External Defibrillators (AED), airborne patient medical telemonitoring (APMT) equipment and portable oxygen concentrators (POC), authorized by Special Federal Aviation Regulation (SFAR) 106, should be designed and tested to meet requirements in accordance with the current edition of RTCA/DO 160, section 21, Category M (as referred to in paragraph 1-7 of this AC.) For further information, refer to the current edition of AC 91-21.1, Use of Portable Electronic Devices Aboard Aircraft.
e. Supplemental Lighting System. Standard aircraft lighting may not be sufficient for adequate patient care. Some HAAs may require additional lighting. The cockpit must be shielded from light emitted from the patient area during night operations. Any supplemental lighting must be compatible with an NVIS installation. HAA industry best practices suggest, where possible, installing an emergency lighting system with a self-contained battery pack to allow for continued patient care and emergency egress from the helicopter in the event of a primary electrical failure.
f. Electric Motor-Driven Medical Devices. Medical equipment attached and secured to a mounting inside the HAA should have electric motors thermally protected and isolated against inadvertent overheating to reduce fire hazards. Electrical motors should also be fitted with shielding and filters as necessary to prevent conducted and radiated electromagnetic interference (EMI).
g. Electrical Power Generating Capacity. For each HAA equipped with multiple electrically powered auxiliary systems, an analysis of generating capacity against power consumption should be performed and documented. The operator must be able to meet § 135.159 regulatory requirements.
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5-4. RECOMMENDED EQUIPMENT FOR HAA OPERATIONS. Other equipment may also be installed on HAA aircraft such as: a helicopter-approved searchlight, specialized communication equipment for coordination with ground responders, NVIS with STC or manufacturer approved NVIS compatible interior lighting, SATCOM, and aircraft position tracking equipment.
a. Helicopter-Approved Searchlight. Industry best practices are that a HAA should be equipped with a high-powered mounted searchlight manipulated by the pilot, having a minimum traverse of 90 degrees vertical and 180 degrees horizontal and capable of illuminating a landing site. The pilot should be able to fly hands-on with the helicopter flight controls while operating the searchlight.
b. Communications with Hospitals and First Responders. In addition to the radios required for ATC and communication with the Operations Control Center (OCC), a radio capable of air-to-ground communications is recommended to ensure coordination with ground personnel (e.g., hospitals, personnel on the scene, police or fire department).
c. Intercommunications System (intercom). An intercom should be provided for pilots and medical personnel to communicate with each other aboard the helicopter. The intercom should provide for isolation of pilot from crew and crew from pilot, with an over-ride in case of an emergency that either party wishes to advise the other about.
d. Wire Strike Protection System. A wire strike protection system is a recommended safety enhancement modification if it has been type certificated (TC/STC) for installation on the specific make, model, and series (M/M/S) of helicopter.
e. Pyrotechnic Signaling Device(s). Recommended to be aboard in a conspicuously marked location easily accessible to HAA occupants.
5-5. EQUIPMENT INSTALLATION EVALUATION FOR HAA OPERATIONS. Any equipment installed onboard a helicopter should comply with the data in AC-27-1B MG 6 and be installed in accordance with the current edition of AC 43.13-2, Acceptable Methods, Techniques, and Practices—Aircraft Alterations; 14 CFR part 43 and part 135 subpart J.
a. Equipment Installation General Considerations.
(1) Equipment installed in racks should meet the G loading requirements imposed by normal flight and an emergency landing, using approved data provided by the equipment manufacturer. Industry best practices suggest that rack mounting is considered preferable to other mounting approaches, such as attachment to FAA-approved poles or other mounting devices. Medical equipment mounting structures in racks should be installed so that equipment that has been attached to them it may be readily removed to accompany a patient.
(2) Mounting structures attached to the aircraft, regardless of type, should be installed and removed by FAA-authorized personnel. A HAA operator should document instructions for removal and replacement of such equipment. The installation of additional equipment following issuance of a STC or field approval is normally done using instructions and operational supplements. Weight and Balance (W&B) data and ICA should be included. Consider also
Par 5-5 Page 48 including such installed equipment in the aircraft MEL. Medical instruments and equipment attached to mounting structures are considered carry-on baggage for W&B purposes. The operator should ensure medical personnel are adequately trained to securely attach equipment to installed mounting structures to prevent hazards in flight.
(3) The requirements of § 135.91(a)(1)(iv), concerning oxygen for medical use by passengers, requires that all installed equipment, including portable devices, be appropriately secured. The structure(s) supporting this equipment should be designed to restrain loads in accordance to FAA certification requirements. (Refer to AC 27-1B MG 6.)
(4) Any cockpit equipment with self-contained illumination that is added to a previously-approved NVIS-compatible cockpit under an STC must be evaluated. Such new cockpit equipment must be approved with respect to NVIS compatibility and appropriate STC or field approval secured. Consult the principal avionics inspector (PAI) and principal maintenance inspector (PMI) for further details.
b. Installation Evaluation.
(1) Each installation should be evaluated at its time of approval to determine if a mechanic is required to perform installation or if other personnel can be trained for its removal or replacement.
(2) The certificate holder must ensure that installation of any additional equipment is compatible with all previously installed and certificated aircraft systems.
(3) Before returning a helicopter to service after the installation of additional equipment, flight tests may have to be accomplished to determine any interference with avionics, navigation, communications or flight and engine control systems. Such flight tests should be accomplished in visual meteorological conditions (VMC). Tests should include all installed equipment and carry-on medical equipment intended to be used for patient monitoring and care during transport. If any incompatibility cannot be solved by appropriate adjustments to newly installed additional equipment or de-conflicted with pre-existing systems, new equipment may not be operated until compatibility issues are resolved. Results of flight tests verifying non-interference and acceptability should be entered into appropriate permanent records for each helicopter.
NOTE: Medical monitors may be affected by the aircraft’s electronic equipment. Therefore, at the time of installation and following maintenance, medical personnel should ensure the calibration and operation of such equipment is in accordance with the manufacturer’s instructions, operational tolerances and approved data.
NOTE: Patient life support systems, which include litters/stretchers, incubators or isolettes, balloon pumps, etc., not normally included in the type design of the helicopter should be installed in accordance with the applicable part 43 regulations, AC 27-1B MG6, and FAA-approved data.
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c. Medical Portable Electronic Devices (MPED). MPEDs that do not exceed electromagnetic emission levels contained in RTCA/DO 160 section 21, Category M, in all modes of operation (i.e., standby, monitor and/or transient operating conditions, as appropriate), may be used on board aircraft without any further testing by the operator. Equipment tested and found to exceed section 21, Category M emission levels are required to be evaluated for EMI and radio frequency interference (RFI) while mounted in the operator’s aircraft. All navigation, communication, engine and flight control systems will be operating in the selected aircraft during the evaluation.
d. Medical Oxygen System. Depending upon the type of medical oxygen system installed (including bottles, lines, connectors, gauges, regulators and other system components), the certificate holder will establish an FAA-accepted method, or adopt a manufacturer’s approved method, for its servicing and replenishing. If the method of servicing a medical oxygen system requires the disconnection and reconnection of installed fittings, (other than the removal and replacement of a service port cap) a certificated mechanic must perform the servicing. If the method of oxygen system servicing does not require any of the above operations, the service and replenishment procedure must be documented in an appropriate form and be available to the pilot. Each pilot must be trained and checked in the performance of these medical oxygen servicing and replenishment procedures.
e. Electrical Power. All wiring, electrical components and installation procedures should conform to the requirements of parts 27 or 29, as applicable. An electrical load analysis (ELA) should be performed to preclude overload of the helicopter generating system. The system should provide the pilot with a means of rapidly shedding electrical load in an emergency.
f. Motor-Driven Vacuum/Air Pump. Motors and/or pumps should be installed in accordance with appropriate STCs or other FAA-approved information. Any motor-driven device should be installed so as to preclude contact with any flammable fluid, gas or foreign materials that may cause or be susceptible to heat buildup which could lead to fire. Helicopters should be flight-tested with electric motors running to check for interference.
Par 6-1 Page 51 CHAPTER 6. OPERATIONS CONTROL CENTER (OCC)
6-1. GENERAL. This chapter summarizes regulatory requirements, recommendations and best practices regarding the Operations Control Center (OCC). An OCC is required for operators conducting helicopter air ambulance (HAA) operations with 10 or more HAAs and is recommended for other operators. The OCC requirement becomes effective on April 22, 2016.
The current edition of Advisory Circular (AC) 120-96, Integration of Operation Control Centers into Helicopter Emergency Medical Services Operations, provides detailed guidance, including recommendations on establishing the physical layout of an OCC. This chapter provides recommendations to assist HAA operators with identifying best practices for implementing OCCs and operations control procedures. It is intended to help encourage and enable operators without a regulatory requirement to establish and operate an OCC to attain their operational benefit.
6-2. CORE CONCEPTS: OCC AND ENHANCED OPERATIONS CONTROL PROCEDURES. There are three primary concepts from AC 120-96 that define an effective OCC and enhanced operations control procedures:
a. Joint Flight Safety Responsibility. The first concept is joint flight safety responsibility for each HAA flight. Joint flight safety responsibility requires that at least one qualified ground staff member, in addition to the PIC, be actively involved in reviewing the PIC risk analysis in accordance with the required risk analysis program (Title 14 of the Code of Federal Regulations (14 CFR) part 135, § 135.617) and be responsible for monitoring factors affecting flight safety before and during the flight. The utilization of qualified Operations Control Specialists (OCS) on the ground also provides additional support and risk monitoring redundancy for pilots in high workload situations.
b. Written Standard Operating Procedures (SOP). The second concept is a requirement for documented SOPs that are used to guide training and standardize operations performance.
Standardization of written Operations Control procedures reflects the same concerns that mandate the use of checklists on the flight deck. SOPs are documented so they can be referenced and performed the same way each time. The detail and scope of this documentation should reflect the size and complexity of each HAA operations. SOPs may be accessed either electronically or via hard copy (refer to Operations Specification (OpSpec) A061, Use of Electronic Flight Bag, for in-flight use of electronic documentation), Regardless, written procedures should be readily available, especially in times of high work load situations such as abnormal or emergency operations.
(1) Though industry is moving towards a less paper-dependent environment, a truly paperless environment has yet to be achieved. A key technology (e.g., a local area network (LAN) or workstation) may fail in conjunction with an emergency, or could even be the cause of emergency or abnormal operations. Technology failures may render electronic access to written SOPs unavailable. Therefore, while standard access to written SOPs may be accomplished electronically, these SOPs may not be available, especially in an emergency situation. Hard copy current written versions of all critical SOPs should be maintained and be readily available for use during abnormal or emergency operations.
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(2) The requirement for hard copy Operational Control SOPs therefore mandates that the operator also include the Operations Control SOPs in the version and distribution control SOP for managing other required hard copy documents.
(3) Operators should also develop an SOP to provide for a continual internal process to solicit, obtain, and respond to feedback on SOPs and update these SOPs and ensure the value of training based on them. An SOP is needed to provide for a vehicle to continually receive feedback on procedures, respond to and prioritize feedback and accordingly, update procedures, inform staff of changes to procedures, and train staff on new procedures.
c. Leveraging Technology and Communication. The third core concept of OCCs and enhanced operations control procedures is to leverage technology and communication to enhance safety and efficiency. This includes providing an enhanced level of situational awareness to the pilot in command (PIC), OCS, and other individuals.
(1) Flight Operations Support. An OCC is an optimal environment for leveraging technology to support flight operations. An OCC’s centralized location can provide economies of scale that make it economically viable to invest in both the information technology (IT) infrastructure and the IT support staff required to support its functions.
(2) Benefits to HAA Operations. An OCC can leverage technology to provide communication and safety benefits to HAA operations. For example, an OCC may be able to acquire weather information for currently non-covered locations. This information may come from a variety of weather feeds available at the OCC, including non-aviation sources such as telephone calls.
(3) Situational Awareness Improvement. As a result of this leveraging of technology, an OCC can contribute to improving the situational awareness of HAA personnel. This includes receiving and filtering information (including weather as in the example above) and providing inputs for or conducting shift-change and preflight briefings.
(4) Provision of Situational Awareness Information. In addition to the regulatory requirements the operator should establish and document procedures to acquire, fuse and provide situational awareness information to the PIC, using the OCC, OCS and other individuals and capabilities as appropriate. This is an example of the use of leveraging technology and communications to reduce risk in HAA operations.
(5) Shift Change Briefing. Operators should have a procedure to ensure the explicit provision by the OCS being relieved, of information on current operational and flight conditions, locations and status of all flights transferred to the relieving OCS, with emphasis placed on hazard updates to the pilots. This may include using conference call or other technology to link personnel at remote sites. This is an example of the use of leveraging technology and communications to reduce risk in HAA operations.
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6-3. OCS.
a. OCS Requirements. The OCS is a critical component of the overall concept of emphasizing safe HAA operations. An OCS must be trained for a range of capabilities, as set out in paragraph 4-5 of this AC. The OCS must:
(1) Provide two-way communications with pilots.
(2) Provide pilots with weather briefings, to include current and forecast weather along a planned route of flight.
(3) Monitor progress of each HAA flight.
(4) Ensure pilots have completed all of the required items (as described in § 135.617) on a preflight risk analysis worksheet.
(5) Acknowledge, in writing, specifying date and time, that a preflight risk analysis worksheet has been accurately completed and that, according to their professional judgment, a flight can be conducted safely (as described in § 135.619(a)(iv)).
b. OCS Recommended Capabilities. It is recommended that an OCS:
(1) Participate in adjustments to risk analysis as a continuous process throughout a flight while carrying out regulatory-required flight monitoring responsibilities;
(2) Assist the pilot in mitigating any identified high risk prior to takeoff; and
(3) Secure management approval of a flight authorization if a predetermined level of individual or total risk is exceeded.
6-4. OCC FACILITIES AND CAPABILITIES. AC 120-96 describes possible OCC facilities and capabilities that can be realized by many different structures and physical configurations, depending on operator requirements. There are many possible alternatives, depending on the size and scope of the HAA operator. The OCC provides a physical location where the OCS and any other personnel can access technologies with the overall objective of being able to assist the PIC.
a. Recommended OCC Facilities. The following hardware and software resources should be considered as best practices for developing an OCC. Refer to AC 120-96 for further explanation and details concerning the following issues:
(1) Enabling technologies (to include LANs, Internet access, and digital signature capabilities for form completion).
(2) Aircraft situational displays depicting status of all certificate holder HAA aircraft.
(3) Aviation weather analysis tools (to include textual, graphical and Geographic Information System (GIS)-enabled).
(4) Notice to Airmen (NOTAM) tools (both textual and graphical).
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(5) Air traffic flow tools (to include temporary flight restrictions, special use airspace, special areas of operation, military operations airspace, high density and congested airspace, warning areas and weather watch boxes).
(6) Communication tools (to include telephones, email, datalink, radio (aircraft and first responders including Voice over Internet Protocol (VoIP) capabilities), satellite communications (SATCOM) and advanced communication consoles).
(7) Non-aviation situational awareness tools such as the Federal Highway Administration (FHWA) Meteorological Assimilation Data Ingest System (MADIS), Internet capable of accessing weather cams, or television capable of receiving cable news channels.
b. Adapting OCC Facilities and Capabilities to Smaller Operators. Smaller (less than 10 HAAs) operators are not required by regulation to have an OCC staffed by OCSs. However, best practices of such operators have provided examples of the use of similar appropriately scaled methods to achieve the same goal.
c. Voluntary Implementation. If an OCC is not required and the operator chooses to voluntarily implement a similar capability or function, the operator’s policies and procedures (and details of training specialists in operations control subject matter) should be established and documented by the operators in their General Operations Manuals (GOM) or other permissible forms of documentation. This documentation system must be accepted by the principal operations inspector (POI). The operator should demonstrate that operational control and PIC responsibility and authority is maintained and safety is not compromised through the duties and responsibilities of the individuals staffing that non-regulatory function.
d. Training Requirements. Operations control training of existing staff members should reflect the training requirements of § 135.619(b). Creating SOPs appropriately reflecting the size and complexity of the operation makes it possible for a small operator to increase the safety of their HAA operations with minimal expense.