All Weather Operations and Fuel/Energy Planning and Management

For comments on the proposals for new and amended Implementing Rules (IRs) in UK Regulation (EU) 965/2012 relating to All Weather Operations (AWOs) and Fuel/Energy Planning Management.

While the UK was still part of the EU the CAA worked very closely with both ICAO and EASA on developing a performance and risk-based set of regulations that would:

• Facilitate the use of new technological advances enhancing situational awareness;
• Facilitate the operation of helicopters in low visibility conditions;
• Enhance all aspects of initial and recurrent pilot training;
• Harmonise the UK legislative framework relating to flight operations, flight crew licensing and aerodromes with ICAO amendments to Annexes 6 and 14, in particular amendment 44 to Annex 6 Part I, Amendment 37 of Annex 6 Part II, Amendment 23 of Annex 6 Part III and ICAO Doc 9365;
• Introduce changes to fuel/energy planning and management as a result of new ICAO SARPs to Annex 6 Part I via Amendment 38 to ICAO Doc 9976 Flight Planning and Fuel Management (FPFM) Manual.

We received 30 comments from 10 responders which generally agreed with the proposed changes.

You expressed concern that removing the requirement for the commander of a multi-pilot crew to hold an Air Transport Pilots Licence (Helicopters) (ATPL(H)) may imply that holders of Commercial Pilots Licence (CPL(H)) could command multi-pilot cockpits.

You asked for clarification on how the 100 IFR hours proposed as valid towards overall qualification hours could be achieved.

You asked for clarification in respect of the purpose of section (c) of CAT.OP.MPA.192.

You asked why the minimum RVR for helicopters was stipulated as 550m.

You stated that the previous wording for SPA.HOFO.125 (a)(1) was clearer than the proposed new wording. Specifically, you suggested that specifying that a radar for providing real time obstacle information is required is clearer than the proposed wording which makes no such mention.

You said that the proposed text for "real time obstacle clearance" required clarification.

You said that raising the planning minima for destination alternate aerodromes as proposed in NCC.OP.148 (a) is sensible, as the visibility limits are too conservative, and these should be lowered.

There was some concern that the proposals were increasing weather limits by over 100%, in particular in respect of cloud base above decision height and minimum visibility. There were also some reservations that the UK CAA was not proposing that  SPA.PinS.VFR (as in force in Europe) should be adopted, and representations were made as to why the UK should follow the regulations for such operations which have been established in Europe.

The proposed changes to the IRs to UK (EU) Regulation 965/2012 (the UK Air Operations Regulation) are necessary to:

• Introduce the concept of ‘fuel schemes’ for Commercial Air Transport (CAT) which will take into consideration the interrelationships of the operators’ fuel planning policy, in-flight fuel management and the selection of aerodromes;
• Amend Annex VII (Part-NCO) and Annex VIII (Part-SPO) to enable a more performance-based approach with regard to the Final Reserve Fuel (FRF) including moving some of the regulatory requirements from the regulation and into AMC and GM;
• Address fuel issues that are specific to helicopter operations;
• Allow for  better integration and use of new, advanced technology as well as new operational procedures to support AWOs;
• Ensure the availability of aerodrome infrastructure (including meteorological equipment), information and procedures to support AWOs;
• Allow for the use of enhanced flight vision systems (EFVS) to the maximum extent possible (e.g. EFVS to land) and includes ‘light operational credits’ for EFVS 200 operations, not requiring the use of specific low-visibility procedures (LVPs); and
• Allow for safe helicopter flights under instrument flight rules (IFR), using of point-in-space (PinS) approaches and departures.
• Improve the existing mandatory crew training and checking requirements for air operators by addressing initial and recurrent training and checking, the conditions for the operation on more than one aircraft type or variant, the acceptance of previous training and checking by non-commercial operators, and multi-pilot operations of single-pilot certified helicopters.

The CAA therefore intends to propose these changes to the Department for Transport, taking into account the following actions in response to the consultation responses.

• UK Regulation (EU) 1178/2011 Part-FCL.305 Commercial Pilots Licence (CPL)) only permits a CPL holder to act as PIC of single pilot aircraft for CAT. Therefore, the CAA considers that there can be no implication that holders of CPL(H) licences could act as PIC of multi-pilot aircraft.
• Further supporting guidance for CAT.OP.MPA.192(c) will be made available in supporting guidance material for CAT.OP.MPA.192 and will be subject to a future consultation.
• It is not proposed that the requirement for 100 IFR hours should be changed. The CAA intends only to propose that the regulation should allow that 50 hours instrument time can be achieved in a simulator.
• The RVR of 550m is aligned with ICAO Standards, which also achieves consistency with related Aerodrome regulations.
• The proposed wording for SPA.HOFO.125 (a)(1) has been amended with the intention that it should accommodate alternative technologies other than radar.
• With regards to clarifying “real time obstacle clearance”, the CAA’s proposal to the Department for Transport has been changed to enable real-time obstacle environment information for obstacle clearance to be obtained by OEMS certified approach systems, in addition to weather radar.
• The proposed changes to NCC.OP.148(a) are being introduced without amendment as this introduces planning minima required for any destination alternate aerodrome.
• The increase in weather limits  are because of the change from considering cloud base to cloud ceiling, and the CAA does not propose to amend them following consultation.

• The UK CAA has elected not to adopt Part-SPA Subpart N: Helicopter Point-in-Space Approaches and Departures with Reduced VFR Minima (PINS-VFR). This amendment, introduced by EASA in 2023, allows the use of reduced VFR minima for the VFR segment of a PINS approach under certain circumstances. The decision not to adopt does not preclude the use of PINS approaches for helicopter flights, merely the use of reduced VFR minima. This decision was taken to maintain safety as the use of PINS approaches by UK Operators is very immature. As experience is gained of such operations further consideration will be given to the introduction of a similar amendment.