1. Luftfartstilsynet T: +47 75 58 50 00 F: +47 75 58 50 05 postmottak@caa.no Postadresse: Postboks 243 8001 BODØ Besøksadresse: Sjøgata 45-47 8006 Bodø Offshore helikopteroperasjoner - en sektor i endring? Seen from the authority

2. Content The current situation Regulatory changes New areas of operation Changes in activity The Committee for Helicopter Safety on the Norwegian Continental shelf (SF)

6. HEMS Thorough shake up and improvements following the 1997 safety study No fatal accidents since 1996 Safetc study 2013 Then suddenly on the 14. January 2014

7. HSS-1 FAR (1990) «10 times more dangerous» than fixed wing scheduled airline services

8. HSS-2 Fatalities per million passenger hours (1999) Accidents NCS: 14 Accidents 8 On passenger flights 54 Fatalities 41 Passengers 13 Crewmembers 10 Serious injuries 5 Controlled ditchings/ survivable crashes

9. HSS-3 On risk levels

10. CAA-N comment to CRD 2013-10 There can be little doubt that HOFO, as clearly stated in the NPA (e.g. Table 7), must be considered high risk operations. The difficult operating conditions in the areas of operation, previous accidents and incidents, and the interest of the passengers being transported and not least the additional safety measures implemented by states, operators and customers, support this view.

11. Components of safe operations Safety margin Acceptable risk ”Safe” Regulations: -Aircraft design -Maintenance -Sertification -Operation ATM Customer Operator Crew ”Less safe/ Unsafe” Safety margin

12. EASA regulations Airworthiness - since 2003 Air Crew – May 2014 Operations - October 2014 Rules of the air - November-2014 Aerodromes..., Air traffic management …, …

13. EASA Rulemaking process Anyone can propose a RMT Anyone can comment on an NPA, and then the CRD 5-10 years Rulemaking programme / task Terms of reference/ working groups NPA CRD EASA Opinion to EC AMC, GM and CS Implementing Rules EASA Decision

14. Influence - flexibility Work group participation, commenting, lobbying … Flexibility? –BR art 14.1/ARO.GEN.135 immediate safety problem –BR art 14.4 exemption due to unforeseen urgent operational circumstances or operational needs of a limited duration –BR art 14.6 exemption if equivalent level of protection to that attained by the application of the rules implementing this Regulation can be achieved by other means. –ORO.GEN.120/ARO.GEN.120 Alternative means of Compliance (AltMoC) to fulfil the requirements of the Implementing Rule (IR) –Propose new rulemaking task

15. CAA-N comment to CRD 2013-10 We strongly disagree with the Agency in its reply to Norway’s NPA comment # 223, where the Agency appears to state that commercial issues and competition has priority over flight safety: “The comment is understandable in relation to maintaining a safety standard defined by a MS, but not in relation to the intentions behind a level-playing field, 'free movement' and acceptance of privileges by another NAA”.

16. HOFO Opinion, CAA-N view Being forwarded in the EASA committee Generally acceptable Some comments –Need to fill the gap left by late implementation of requirements –Arming of EFS for over water arrivals and departures –EBS in hostile area for all passengers – depends on AMC/GM –Night recency not adapted to arctic operations I.e.: do we generally think it is too strict?

17. HOFO CRD AMC/GM, CAA-N comments Issues –Cross border operations –Passenger briefing language –EBS suitable for underwater deployment SPA.HOFO based on best practice? CAP 1145 a missed opportunity?

18. Notified additional 21 national «requirements» EquipmentNumberStricterSimilarLess strictNot covered Regulations22 Customer716 TrainingNumberStricterSimilarLess strictNot covered Regulations Customer22 ProceduresNumberStricterSimilarLess strictNot covered Regulations422 Customer624

19. Conclusion SPA.HOFO as of now CAA-N has no major issues with the Opinion or CRD Some «Contentious» issues (generally stricter) –Class A EBS Possibility for additional requirements Oversight of foreign operators Customers can continue to add requirements (Guideline 066) Other current issues (UK SD 2015/01) –Significant wave height –Passenger vs. emergency exit

20. CRD 2013-13 Additional requirements/limitations … Therefore, the Agency finds it difficult to propose a harmonised requirement while conditions may differ in the Member States and decisions might be better taken at a local level. It is to be noted that for CAT operations, there is already a requirement in CAT.OP.MPA.135(b) as follows: –‘The operator shall ensure that operations are conducted in accordance with any restriction on the routes or the areas of operation specified by the competent authority.’ … Moreover, the Agency will include GM to ARO.OPS.200 containing information for the authorities which additional conditions for operations in certain areas might need to be specified via the AIP or by other means.

21. ARO.GEN.300 Oversight (d) … the scope of the oversight of activities performed in the territory of a Member State by persons or organisations established or residing in another Member State shall be determined on the basis of the safety priorities, as well as of past oversight activities. (e) Where the activity of a person or organisation involves more than one Member State or the Agency, the competent authority responsible for the oversight under (a) may agree to have oversight tasks performed by the competent authority(ies) of the Member State(s) where the activity takes place or by the Agency. …

22. New operational areas These operations are ongoing - and considered safe What will be new /what are the changes if the activity moves further north/east? –What new hazards? Regulations are the same everywhere …? The operators (helicopter- and rig-) has to do their own risk assessments and control the risk To achieve an acceptable level of risk and regularity There is a limit to what can be done

23. Aviation regulations Can not and does not cover «everything» required for safe operations The gaps has to be identified and filled by the operator/ customer Some additional requirements based on area/local conditions can and should be added

26. Lifespan of a hypothetical organization through the production-protection space Bankruptcy Catastrophe Protection Production Unrocked boat Better defences converted to increased production - € + €

27. SF 4 annual meetings, since June 2003 Representation from: –Employers (helicopter companies, NOG) –Employees (helicopter companies, NOG) –Service provider –Authorities (PSA, CAA-N) –AIBN, RNoAF Three party corporation Main task to push for follow up of recommendations from the studies: –NOU 2001-17, 2002-21 (59 recommendations) –HSS-3 (35 recommendations)

28. SF – ongoing work HSS-3 recommendations remain priority # 1 Results Latest initiatives: –CAP 1145 evaluation (61 actions/recommendations) –Request to MoT for an analysis of the consequences of implementation of HOFO and market access –Update HSS-3 with new development (to NOG) –Consider if current NOG guideline 066 could be formalised

29. CAP 1145 – preliminary evaluation Describes a situation that is not significantly different from the Norwegian operation Somewhat lacking in consequence assessments Initial actions recommended –Establish FDM user group –Significant wave height –recommend CAA-N evaluation –EBS - Recommend NOG to assess the consequences Follow implementation on the UK side Further assessments to be performed

30. www.helikoptersikkerhet.no