U.S. Department of Transportation 

FEDERAL AVIATION ADMINISTRATION

REGULATORY EVALUATION 

Air Ambulance and Commercial Helicopter Operations, Part 

91 Helicopter Operations, and Part 135 Aircraft Operations; 

Safety Initiatives and Miscellaneous Amendments

NOTICE OF PROPOSED RULEMAKING 

(14 CFR PARTS 1, 91, 120, AND 135) 

Office of Aviation Policy and Plans 

Operations Regulatory Analysis Branch, APO-310 

April 1, 2010 
TABLE OF CONTENTS 

Section Page No.

Executive Summary ................................................................................................. i 

I. Benefits ................................................................................................................... 1

 A. Overview........................................................................................................... 1 

 B. Accident History ............................................................................................... 1 

 C. Monte Carlo Simulation .................................................................................... 2 

C.1. Assumptions............................................................................................. 3 

C.2. Simulation Model..................................................................................... 5 

 C.3. Results ...................................................................................................... 7 

II. Costs........................................................................................................................ 8 

 A. Helicopter Air Ambulance Operations ........................................................... 10 

A.1.a. Medical Personnel ............................................................................... 10 

 A.1.b. Operations Control Center (OCC) ...................................................... 10 

 A.1.c. Operational Requirements................................................................... 13 

 A.1.d. Risk Analysis ...................................................................................... 15 

A.1.e. Safety Training.................................................................................... 16 

A.2.a. Helicopter Terrain Awareness and Warning Systems (HTAWS)....... 21 

 A.2.b. Light-weight aircraft recording system (LARS)................................. 22 

 A.3.a. Pilots with Instrument Rating.............................................................. 23 

 A.3.b. Flight and Duty Time.......................................................................... 24 

 

 B. Commercial Helicopter (Including Air Ambulance) Operations.................... 24 

B.1.a. IFR Alternate Weather ........................................................................ 24 

B.2.a. Radio Altimeter ................................................................................... 25 

 B.2.b. Over water........................................................................................... 26 

 B.3. Competency in Instrument Meteorological Conditions (IMC).............. 28 

 C.1. Part 91 Weather...................................................................................... 29

C.2. Load Manifest ........................................................................................ 30 

III. Comparison of Benefits and Costs........................................................................ 32 

IV. Appendix A – Accident History ........................................................................... 33 

V. Appendix B – Selected Distributions and their Best-Fitting Parameters.............. 39 
EXECUTIVE SUMMARY 

The FAA is proposing to amend the regulations that pertain to helicopter air ambulance 

operations to implement operational procedures, provide for additional flight crew and 

medical personnel, and require additional equipment on board helicopter air ambulances. 

In addition, the FAA would amend regulations pertaining to all commercial aircraft 

operations conducted under part 135 to include equipment requirements, pilot training, 

and alternate weather minimums. 

The estimated mean benefit value for the air ambulance provisions would be $270 

million or $160 million present value over ten years. The estimated mean benefit value 

for the commercial provisions would be $193 million or $115 million present value over 

ten years. The FAA estimates the cost of this proposed rule for the air ambulance 

provisions would be approximately $210 million ($136 million, present value) over 10 

years. The estimated cost of the proposed rule for the commercial provisions would be 

approximately $145 million ($89 million, present value) over 10 years. 

i
I. Benefits 

A. Overview 

Benefits would accrue from amending the regulations that pertain to helicopter air 

ambulance operations to implement operational procedures, provide for additional 

requirements pertaining to flight crew testing and medical personnel briefing, and require 

additional equipment on board helicopter air ambulances. The estimated mean benefit 

value for these benefits would be $270 million or $160 million present value over ten 

years. 

In addition, the FAA would amend regulations pertaining to all commercial aircraft 

operations conducted under part 135 to include equipment requirements, pilot training, 

and alternate weather minimums. The estimated mean benefit value for these benefits 

would be $193 million or $115 million present value over ten years. 

B. Accident History 

FAA’s Office of Accident Investigation, AAI-220,1 provided 173 historical air 

ambulance accidents and 1,048 controlled flight into terrain (CFIT) accidents occurring 

from 1983 through 2009. Of those accidents, FAA’s Flight Standards Service, AFS-2502

identified 75 commercial helicopter accidents from 1994 through 2008 and 135 

helicopter air ambulance accidents from 1992 through 2009 with causal factors that are 

addressed in this proposal. In the Monte-Carlo Simulation, which is addressed in the next 

section, we used data from 1994 to 2008 for the helicopter air ambulance accidents and 

 

1

 Joe Mooney and Brad Wacker, Program Analysts, Safety Analysis Branch. 

2

 Edwin D. Miller, Part 135 On-Demand Branch- Aviation Safety Inspector. Other credentials: Air Force 

Accident Investigator, Helicopter Expert, and State of Florida Law Enforcement Officer. 

1
the commercial helicopter accidents. AFS-250 reviewed each of the accidents and 

provided an effectiveness measure along with the proposed section in the NPRM rule 

language that would address each accident. 

For the accidents involving commercial helicopter operations, 28 (about 37%) involved 

one or more fatalities and 47 (about 63%) had no fatalities. These accidents resulted in 

88 fatalities, 29 serious injuries, and 42 minor injuries. For the accidents involving air 

ambulance operations, 50 (about 37%) involved one or more fatalities, and 85 (about 

63%) had no fatalities. These accidents resulted in 134 fatalities, 57 serious injuries, and 

45 minor injuries. 

In addition to the injuries and fatalities, there was also significant damage or complete 

hull loss for these accidents. Appendix A provides the accident date, location, number of 

casualties, provisions, casualty costs, and rule effectiveness3

 for commercial helicopter 

and air ambulance accidents. 

C. Monte Carlo Simulation 

The possibility of similar accidents over 10 years can be estimated by performing MonteCarlo simulation.4

 We performed one simulation for air ambulance accidents and 

another one for commercial accidents. The assumptions that follow were used 

simulations: 

in both 

 

3

 The effectiveness measure assesses how effective the proposed rule might have been in averting the 

accident at the time of the accident. 

4

 A Monte Carlo simulation randomly generates values for uncertain variables over and over to simulate a 

model, which is meant to imitate a real-life system. 

2
C1. Assumptions 

 The rule is expected to take effect in 2012. The time horizon for these potential 

benefits is 10 years, 2012 through 2021. 

 All monetary values were expressed in constant 2009 dollars. The present value 

of the potential benefit stream was calculated by discounting the monetary values 

using a 7 percent interest rate from 2012 to 2021. 

 In the simulation, the value of a statistical life (VSL) was computed using a 

lognormal distribution with a mean of $6 million and a standard deviation of $2.6 

million.5 

 The value of a serious injury was $521,000.

 The value of a minor injury was $12,000. 

 The estimate for averting aircraft damage was $1.7 million per event, representing 

a blended replacement value of aircraft potentially affected by this proposal. The 

FAA uses the average value for the unit replacement and restoration cost of an 

aircraft to approximate the value of an airplane with substantial damage and we 

conservatively assume there would be no collateral damage. 

 

5

 U.S. Department of Transportation Memorandum, Treatment of the Economic Value of a Statistical Life 

in Department Analyses, dated February 5, 2008, p 7. 

3
 Under the proposal, certificate holders would have three years from the effective 

date of the final rule to comply with equipment requirements. To account for the 

compliance period, we adjusted our benefit estimate accordingly. To be 

conservative, we assumed that 1/3 of the benefits would be realized in 2012 

because only 33% of the affected entities would be in compliance during 2012. 

Also, we assumed that 2/3 of the affected entities would come into compliance in 

2013 and full compliance would begin in 2014. 

 We assume an effectiveness measure of 59% for air ambulance accidents and 

50% for commercial accidents. Table 2 illustrates how these measures were 

calculated. 

Once we identified all appropriate accidents in the two categories of operations, 

we evaluated each event in terms of effectiveness had the requirements in the 

proposed rule been in effect before the accident took place. Based on the analysis 

of causes and factors, we assigned the following: 

 Low effectiveness (0-33%)--16.5% median estimate--where the requirements 

would prevent 16.5% of the forecasted accidents. 

4
 Medium effectiveness (34-67%)--50.5% median estimate--where the 

requirements would prevent 50.5% of the forecasted accidents. 

 High effectiveness (68-100%)--84% median estimate--where the requirements 

would prevent 84% of the forecasted accidents. 

Once the values were assigned in order to estimate the effectiveness of the entire 

proposed rule, we calculated the weighted average for the 2 categories. These 

numbers were then applied as overall effectiveness numbers to the total potential 

benefits for each category. 

 

C.2 Simulation Model 

To develop a model for the air ambulance and the commercial simulations, first we 

selected distributions that best described the characteristics of the accident history from 

1994 to 2008.6

 We only considered the most recent history because it is the most 

relevant to the type of accident that might occur in the absence of the rule. 

We fitted distributions to number of fatal accidents, number of nonfatal accidents, 

casualty costs for fatal accidents and casualty costs for nonfatal accidents. We did this 

for both the air ambulance and the commercial operators. A mathematical fit was 

performed to determine the set of parameters for each distribution that best described the 

characteristics of the particular data set. The distributions with the highest ranking fit 

were chosen to represent each particular data set (e.g., an exponential distribution was 

chosen to represent fatal accidents for air ambulance operators). In ranking the 

 

6

 We did not consider 2009 because we do not have all of the accident data yet. 

5
distributions we used the Chi-square goodness-of-fit test. 7 The selected distributions and 

their corresponding parameters for air ambulance operators are shown in table B1 

(Appendix B) and those for commercial operators are shown in table B2. Using these 

distributions, the average cost for averting aircraft damage, and the effectiveness 

measures, we developed a model for the air ambulance and the commercial simulations. 

The relationships of the model may be summarized as follows: 

Benefits [( CFTL FTL  () CNFTL NFTL  (() FTL   )])  EDNFTL

where: 

FTL = number of fatal accidents; 

NFTL = number of nonfatal accidents; 

CFTL = casualty cost for fatal accidents;

CNFTL = casualty cost for nonfatal accidents; 

D = damage cost; 

E = effectiveness measure. 

The simulations first forecast the number of fatal and nonfatal accidents which are 

multiplied by their corresponding casualty costs. Next, the simulations calculate the 

damage to aircraft by multiplying the number of fatal and nonfatal accidents by the 

damage cost. Finally, the total cost (which includes casualty cost and damage cost) is 

 

7

 This test is the oldest and most common of the goodness-of-fit tests. It gauges the general accuracy of the 

fit. 

6
multiplied by an effectiveness measure, which produces the benefits for air ambulance 

and commercial operators. 

C3. Results 

The results of the air ambulance simulation are displayed in the next histogram. 

The proposed air ambulance provisions are expected to produce safety benefits of $104 

million to $2.6 billion ($62 million to $1.5 billion, present value) over ten years, with an 

estimated mean benefit value of $270 million or $160 million present value. 

The results of the commercial simulation are displayed in the next histogram. 

7
The commercial provisions are expected to produce safety benefits of $39 million to 

$838 million ($21 million to $480 million, present value) over ten years, with an 

estimated mean benefit value of $193 million or $115 million present value. 

II. Costs 

From 2012 to 2021, the cost to helicopter air ambulance operators would be 

approximately $210 million ($136 million, present value) and the costs to commercial 

helicopter operators would be approximately $145 million ($89 million, present value) as 

shown in Table 3. 

8
General Cost Assumptions

 Monetary values are expressed in 2009 dollars, unless noted otherwise. 

 Discount rate applied is 7 percent as suggested by the Office of Management and 

Budget. 

 We use the following costs per hour as the burdened wage rates for this evaluation. 

9
The societal costs include the overhead costs that are allocated to labor as well as the 

direct cost. The basis for the labor rates are from the 2008 data on the mean burdened 

hourly labor rates for specific categories of staffing data for air medical aircraft. We 

incorporate figures as reported by the Bureau of Labor Statistics (BLS) to aid in 

determining the incremental cost impact that could result from this proposal. We use 

the mean hourly wage rates from BLS, as they are the most suitable and 

representative number across all of the industry. Once the wage rates are established, 

to assess the incremental cost to society, we burden the mean wages with fringe 

benefits and overhead to calculate the actual employer costs of employee 

compensation. 

A. Helicopter Air Ambulance Operations

A.1.a. Medical Personnel

The FAA is proposing to require that all helicopter air ambulance operations with 

medical personnel on board be conducted under part 135 instead of part 91. These more 

stringent requirements may result in operators turning down flights that would meet only 

part 91 requirements, for example if weather conditions do not meet the part 135 

requirements, or if the flight would put a flightcrew member over the maximum daily 

hours of flight time. The FAA does not have enough information to quantify the impact 

of this requirement and calls for comments from affected entities, including the extent of 

the impact on the availability of air ambulance services. The FAA requests that all 

comments be accompanied by clear and detailed supporting economic documentation. 

A.1.b. OCC 

10
The FAA is proposing to add a requirement for certificate holders with 10 or more 

helicopters engaged in helicopter air ambulance operations to have an Operations Control 

Center (OCC). These OCC’s would be staffed by operations control specialists trained 

and equipped to communicate with pilots, advise pilots of weather conditions, and 

monitor the progress of flights. 

Certificate holders would be responsible for establishing and implementing an FAAapproved initial and recurrent training program for operations control specialists. We 

estimate 288 operations control specialists8

 would be required to receive 80 hours of 

initial training and to pass a 2 hour practical examination. Additionally, the operations 

control specialists would need to complete 40 hours of recurrent training and pass a 1 

hour examination. 24 hours9

 per year would be needed for a clerical person to maintain 

records of their training and examinations. We estimate that approximately 96 chief 

pilots10 would be needed to administer the training and exams. The operations control 

specialist’s loaded salary expressed as an hourly wage rate is assumed to be $30 per hour; 

the chief pilot’s hourly rate with benefits is assumed to be $53 per hour; and a clerical 

person’s hourly rate with benefits is assumed to be $26 per hour. The FAA estimates that 

the total cost of the training would be about $6 million or $4 million present value, as 

shown in Table 5. 

 

8

 90 operations control specialists positions x 3.2 specialists per position (includes annual and sick leave) = 

288 specialists. 

9

 288 operations control specialists x 5/60 hours. 

10 We assume one chief pilot is assigned to a group of 3 operations control specialists. 288 operations 

control specialists / 3 = 96 chief pilots. 

11
Besides the training, the FAA estimates that this proposed provision would require hiring 

144 new permanent operations control specialists.11 We assume their hourly rate with 

benefits at $30 per hour and they would be compensated 2080 hours per year. The total 

cost over 10 years for these permanent positions would be $90 million. Additionally, we 

believe that 288 new computers and televisions would be needed in the first year at a cost 

of approximately $2,000 per television and $2,000 per computer for a total cost of $1 

million. Finally, five percent of operations control specialists would be tested at random 

for drugs and alcohol on an annual basis for approximately 30 minutes at a cost of $65 

per test for a total cost of about $12,000 over 10 years. The FAA believes the cost for a 

clerical person to maintain drug and alcohol testing records would be negligible. 

Therefore, the FAA estimates the sum of all these costs at about $91 million or $56 

million present value, as shown in Table 6. 

 

11 (90 operations control specialists positions x 3.2 specialists per position) / 2 = 144 new operations control 

specialists 

12
A.1.c. Operational Requirements 

Increase VFR weather minimums (§135.607)

This provision would require helicopter air ambulance operations to comply with more 

stringent VFR weather minimums in uncontrolled airspace than those currently 

established in part 135. This requirement increases the safety margin and has a minimal 

cost impact because it utilizes existing infrastructure and implements requirements of 

Operations Specification A021. 

 

Allow IFR operations at airports and heliports without weather reporting (§135.609)

The FAA is proposing to allow helicopter air ambulance operators to conduct IFR 

operations in certain circumstances at airports or heliports without a weather reporting 

facility. Currently, the regulations permit only IFR operations into and out of airports 

with an on-site weather reporting source. This requirement would increase the use of IFR 

flight by helicopter air ambulance operators which would result in more aircraft operating 

13
in a positively controlled environment and within the existing infrastructure. As such, we 

estimate that this requirement would result in no additional costs. 

 

Specify procedures for VFR/visual transitions from instrument approaches (§135.611)

The FAA is proposing to allow a helicopter air ambulance pilot to fly IFR to a point in 

space (PinS) within 3 nautical miles of the flight’s destination, at which the pilot would 

be able to continue an approach to a heliport or landing area under VFR conditions, 

weather permitting. 

 

The requirement would benefit pilots by enabling them to access more destinations by 

flying within the IFR structure, and then continuing VFR along approaches that have 

been flight checked for obstacles by the FAA. We estimate no additional costs associated 

with this requirement. 

Require additional VFR flight planning (§135.613)

This provision is intended to prevent obstacle collisions by requiring pilots to be aware of 

the terrain and highest obstacles along a planned route. The FAA is proposing to require 

helicopter air ambulance pilots to perform preflight planning to determine the minimum 

safe altitude along the planned en route phase of flight when conducting VFR operations. 

Pilots would be required to evaluate, document, and plan to clear terrain and obstacles 

along the planned route of flight by no less than 300 feet for day operations, or 500 feet 

for night operations. 

14
The proposed requirement could require pilots to look at a sectional map, plan their 

course, and determine specific altitudes which could be completed in conjunction with 

the proposed risk assessment. The flight planning would be required prior to take-off for 

all helicopter air ambulance operators and is estimated to take an additional 5 minutes. 

With an hourly pilot cost of $48, the cost for 5 minutes of planning would be an 

additional $4.00 per operation. To calculate the annual cost of $1,451,852, we multiply 

the estimated additional cost ($4.00) by the number of affected air ambulance helicopters 

(989) and then by the estimated operations per year per aircraft (367). As summarized in 

table 7, when summed over the period of analysis, the total cost of the flight planning 

requirement is $15 million or $9 million present value. 

A.1.d. Risk Analysis

This proposal rule would require operators to implement an approved preflight riskanalysis program resulting in two cost categories. First, the operator would develop a 

15
risk-analysis program, and then the operator would implement and perform a risk 

analysis before each flight in order to mitigate the risks. 

We estimate that it would take an operator a total of 60 hours to design and implement an 

approved pre-flight risk analysis program. With a burdened hourly labor rate of $48, the 

estimated cost per operator is $2,880. When we multiply this cost per operator by the 

number of operators (73), the total industry cost is $210,240 ($171,618 present value). 

In evaluating the minimum proposed requirements for a pre-flight risk analysis program, 

we estimate there would be roughly 362,963 affected flights per year and that the 

accompanying risk analysis would take an additional 10 minutes per flight.12 This 

equates to 60,494 hours on an annual basis. When multiplied by the hourly cost of a pilot 

($48), the annual cost is $2.9 million. For the period of analysis, the total cost for the 

operators to perform the risk analysis is $29 million ($18 million present value). 

A.1.e. Safety Training

This proposed rule would require that medical personnel on board a helicopter air 

ambulance flight receive a supplemental safety briefing. As an alternative to a pre-flight 

safety briefing, certificate holders would be able to provide training to medical personnel 

that would allow them to work safely in and around the aircraft. To be conservative, we 

estimated the training costs as opposed to the costs of the safety briefing. We estimate 

these costs at $8 million or $5 million present value. To comply with these requirements, 

 

12 Depending upon the level or risk, the 10 minutes might be divided between pilot, director of operations 

or the operational control specialist. 

16
various categories of medical personnel would undergo appropriate ground training and 

static training. We estimate the accompanying cost for the specified categories. 

Ground Training

We estimate the number of medical personnel employed by operators that would be 

affected by this proposed rule and the accompanying cost of training. We multiply the 

hourly cost of medical personnel by the number of affected employees. We estimate 

roughly 25% of medical personnel would need additional training (the other 75% already 

receive adequate training and would not be affected by the proposal). That product is then 

multiplied by the hourly estimate (4 hrs) that would occur every other year for ground 

training. As shown in table 9, when summed over the period of analysis, the ground 

training cost is $3 million or $2 million present value. 

17
Static Training

In addition to the ground training, static training of roughly 2 hours would also be 

required every 2 years. The hourly cost of medical personnel is multiplied by the number 

of affected employees, and then by the estimated 2 hours of static training per year. The 

total estimated cost of static training is $1.4 million or $1.0 million present value and is 

shown in table 10. The same categories of medical personnel and estimated quantities 

would be affected. 

18
Equipment

In order to comply with the static training requirements, operators would need a 

helicopter/equipment to be available for the training. The total weighted average fixed 

cost for equipment is $1,067.13 For the industry, we estimate 2,741 medical personnel 

would need training and roughly 4 medical personnel are able to be trained per hour. At 

this training rate, equipment would be required for 685 hours every other year with a cost 

of $730,871. As shown in table 11, the total equipment cost is $4 million or $2 million 

present value. 

 

13 We calculate the weighted average cost for affected aircraft from Economic Values for FAA Investment 

and Regulatory Decisions, A Guide, December 31, 2004. 

19
Recordkeeping

Once the training has been performed, the operator would document the training provided 

to medical personnel employed by the certificate holder. With a total of 10,965 potential 

medical personnel for 73 operators, there are approximately 150 medical personnel per 

operator. We estimate it would take a secretary/record keeper (with a burdened hourly 

cost of $26) roughly 5 minutes per employee per year to document the training which 

would total 914 hours. When multiplied by the burdened hourly cost ($26) and summed 

over the period of analysis, the total recordkeeping costs are $238,000 or $146,000 

present value. 

20
A.2.a. HTAWS 

The FAA is proposing to require that all helicopters used in air ambulance operations be 

equipped with HTAWS. 

 

We estimate there are 989 air ambulance helicopters. Of these helicopters, we believe 

that approximately 200 are already equipped with HTAWS. The remaining 789 

helicopters would incur the cost of this provision. Because certificate holders would have 

three years from the effective data of the final rule to comply with this requirement, we 

assume that from 2012 through 2014 approximately one-third of the helicopters would 

come into compliance with this requirement on an annual basis. We estimate the unit 

cost to be equipped with HTAWS at $35,000.14 Additionally, we estimate 2 days of 

equipment downtime15 and a revenue loss of about $7,000 per helicopter per day. 

 

14 This cost includes installation. 

15 About 40 hours are needed to install HTAWS. Of those hours only 16 hours represent equipment 

downtime because the rest of the installation would be done during an interval maintenance inspection. 

21
Using the preceding information, the FAA estimates that the total cost of this provision 

would be about $39 million or $30 million present value, as shown in Table 13. 

A.2.b. LARS

The FAA is considering requiring certificate holders conducting helicopter air ambulance 

operations to install LARS , which comprises a system or combination of systems that 

record a helicopter’s flight performance and operational data. Because installing LARS 

systems is not a requirement of the proposed rule, we did not consider it a cost of the 

proposed rule. However, we estimated its cost as described in the following paragraphs. 

 

We estimate 989 air ambulance helicopters would incur the cost of this provision. 

Certificate holders would have three years from the effective date of the final rule to 

comply with this requirement. Therefore, we assume that over 3 years approximately 

one-third of the helicopters would come into compliance with this requirement on an 

22
annual basis. We estimate the unit cost to be equipped with LARS at $6,450 and $750 

per year for the LARS software. Additionally, we estimate 2 hours of equipment 

downtime16 and a revenue loss of about $7,000 per helicopter per day. 

One approach the FAA is considering would require certificate holders to document and 

establish procedures of how they intend to evaluate, analyze, and use the LARS data in 

support of proactive safety initiatives in their operations manuals. In the event this 

approach is adopted, we estimate 2 hours of a chief pilot and 6 hours of a record 

keeper/secretary to do so at burdened rates of $53 and $26, respectively. We assume 73 

operators would incur this one-time cost. 

The FAA estimates that the total cost of installing the LARS would be about $15 million 

or $10 million present value, as shown in Table 14. 

A.3.a. Pilots with Instrument Rating 

 

16 About 8 hours are needed to install LARS. Of those hours only 2 hours represent equipment downtime 

because the rest of the installation would be done during an interval maintenance inspection. 

23
The FAA is proposing to require helicopter air ambulance pilots to hold a helicopter 

instrument rating. Although pilots would have to complete some cross-country flight 

time as well as actual or simulated instrument time to obtain the instrument rating, the 

FAA believes that most pilots already have an instrument rating. Therefore, this 

provision would result in negligible, if any, additional cost to air ambulance operators. 

The FAA calls for comments on this determination and requests that all comments be 

accompanied by clear and detailed supporting economic documentation. 

A.3.b. Flight and Duty Time

The FAA is proposing to require helicopter air ambulance operations with medical 

personnel on board to count towards a pilot’s daily flight time limitations. This 

requirement could put some flightcrew members over their maximum daily hours of 

flight time resulting in the inability to continue flying, or to accept new flights, until the 

pilot has received adequate rest. The FAA does not have enough information to quantify 

the impact of this requirement and calls for comments from affected entities. The FAA 

requests that all comments be accompanied by clear and detailed supporting economic 

documentation. 

B. Commercial Helicopter (Including Air Ambulance) Operations

B.1.a. IFR Alternate Weather

This provision would increase the alternate airport weather minimums for IFR operations. 

This additional margin for weather at the alternate airport would increase the likelihood 

that a pilot would be able land under IFR at the alternate airport if weather conditions at 

24
the destination airport deteriorate below the IFR weather minimums while the aircraft is 

en route. 

The FAA estimates that the overall cost of this proposed requirement would be minimal, 

as it would not prohibit flights from occurring and partial flights would still be able to 

occur. There is a possibility that some flights may be affected (potentially requiring more 

time) as a result of this requirement. However, we believe when operators are faced with 

inadequate and unsafe weather minimums, they would explore alternatives and plan 

appropriately. Accordingly, the FAA estimates that with the proper planning this 

requirement would generate only minimal additional cost. 

B.2.a. Radio Altimeter 

The FAA is proposing to require radio altimeters for all rotorcraft operated by part 135 

certificate holders. 

 

We estimate there are 989 air ambulance helicopters, 1,493 on demand helicopters, and 

201 air tour helicopters. Of these helicopters, we believe that this provision would 

impact approximately 30% of air ambulance helicopters, 25% of on demand helicopters, 

and 25% of air tour helicopters. Because certificate holders would have three years from 

the effective date of the final rule to comply with this requirement, we assume that from 

2012 through 2014, approximately one-third of the helicopters would come into 

compliance with this requirement on an annual basis. We estimate the unit cost to be 

25
equipped with radio altimeters at $5,250.17 Additionally, we estimate 2 hours of 

equipment downtime18 and revenue losses of about $7,000 and $1,700 per helicopter per 

day for air ambulance operators and air tour operators, respectively. 

Using the preceding information, the FAA estimates that the total cost of this provision 

would be about $6 million or $4 million present value, as shown in Table 15. 

Although on demand operators may also incur the cost of equipment downtime, we do 

not have enough information to quantify the impact of these costs and call for comments 

from affected entities. The FAA requests that all comments be accompanied by clear and 

detailed supporting economic documentation. 

B.2.b. Over water 

 

17 This cost includes $1,500 for installation. 

18 About 8 hours are needed to install radio altimeters. Of those hours only 2 hours represent equipment 

downtime because the rest of the installation would be done during an interval maintenance inspection. 

26
The FAA is proposing to require safety equipment for over-water operations. 

 

We estimate there are 989 air ambulance helicopters and 1,493 on demand helicopters. 

Of these helicopters, we believe that this provision would impact approximately 5% of air 

ambulance helicopters and 15% of on demand helicopters. Because certificate holders 

would have three years from the effective date of the final rule to comply with this 

requirement, we assume that from 2012 through 2014, approximately one-third of the 

helicopters would come into compliance with this requirement on an annual basis. We 

assume on average 4 people per air ambulance helicopter and 6 people per on-demand 

helicopter. We estimate a cost of $2,850 per emergency locator transmitter, $269 per life 

preserver, and $4,829 per life raft.19

Using the preceding information, the FAA estimates that the total cost of this provision 

would be about $2 million or $1.8 million present value, as shown in Table 16. 

 

19 Includes survival kit with pyrotechnics. 

27
B.3. Competency in IMC

Current rules do not require a pilot to demonstrate safely maneuvering an aircraft back 

into visual meteorological conditions (VMC) following an inadvertent flight into 

instrument meteorological conditions (IMC) during a §135.293 competency check. The 

FAA proposes pilot testing on recovery from inadvertent flight into IMC to include flatlight, whiteout, and brownout conditions. This testing would occur every two years and 

would include a demonstration of the pilot's ability to maneuver the rotorcraft solely by 

reference to instruments. 

In order to demonstrate compliance with this requirement, we estimate that each 

additional IMC recovery on an approach would take an additional 20 minutes. 

To be in compliance with this proposed requirement, all pilots for air ambulance 

operators would need to perform an additional IMC recovery every year. We 

conservatively estimate that all the other part 135 pilots (on demand, and air tours) would 

require an additional 20 minutes to demonstrate compliance with the additional IMC 

recovery on an approach each year. 

We estimate the total weighted average “blended” total hourly cost to operate an affected 

aircraft at roughly $1,400. With an additional 20 minutes required to perform an IMC 

recovery, additional costs per pilot would be $467 annually. 

28
We multiply the estimated affected number of pilots in the appropriate categories by the 

estimated annual cost per pilot of $467. When summed over the period of analysis, the 

total costs are $25 million or $15 million present value. 

C.1. Part 91 Weather

This requirement would increase the weather minimums for helicopters operating under 

part 91 in Class G airspace. This proposal would provide a greater margin of safety for 

operators because pilots would be required to maintain a fixed amount of visibility, rather 

than merely remaining clear of clouds. 

The FAA estimates that the overall cost of this proposed requirement would be minimal, 

as it would not prohibit flights from occurring and partial flights would still be able to 

occur. There is a possibility that some flights may be affected (potentially requiring more 

time) as a result of this requirement. However, we believe when operators are faced with 

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inadequate and unsafe weather minimums, they would explore alternatives and plan 

appropriately. Accordingly, the FAA estimates that with the proper planning this 

requirement would generate only minimal additional cost. 

C.2. Load Manifest

This proposed rule would require the preparation of a load manifest detailing information 

such as aircraft weight, center of gravity, crewmember identification, and other aircraft 

information. The requirement would apply to all aircraft, not just multiengine aircraft. 

We estimate that 108 air ambulance aircraft and 3,752 commercial aircraft make an 

average of 3 takeoffs daily making the paper burden for technical time approximately 5 

minutes per takeoff. We assume the hourly cost of a single-engine pilot at $38. 

Using the preceding information, the FAA estimates that the total cost of this provision 

would be about $134 million or $82 million present value, as shown in Table 18. 

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Over 13 years, the FAA identified 7 accidents (see table 19) in which over-weight, 

weight and balance may have played a role. 

Of the 7 single-engine, 135 operator accidents, 2 involved one or more fatalities and 5 

had no fatalities. These accidents resulted in 11 fatalities and 10 minor injuries. The 

estimated casualty cost of all these accidents was approximately $66 million.20 We 

evaluated each accident in terms of effectiveness had the requirements in the proposed 

rule been in effect before the accident took place. We assumed an effectiveness of 65 

 

20 The FAA used $6 million as the statistical value for avoiding a fatality, and $12,000 for avoiding a minor 

injury. 

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percent for load manifest accidents based on a weighted average of the effectiveness of 

the accidents. 

 

To compare the benefits and costs of the load manifest, a uniform PV benefit was 

calculated over 10 years using the $66 million of undiscounted casualty costs and 

multiplying it by the 65 percent effectiveness. The result ($20 million) was compared to 

the PV costs of the rule, as shown in table 20: 

The load manifest responds to NTSB Safety Recommendation A-99-61. That 

recommendation followed the October 8, 1997 accident that killed the pilot and all eight 

passengers. This proposal addresses the NTSB contributing factor of the pilot’s improper 

in-flight planning and decision making. 

III. Comparison of Benefits and Costs 

Table 21 shows a comparison of benefits and quantified costs of the proposed rule. 

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APPENDIX A 

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APPENDIX B 
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