Date: 201404
Local time of day: 1201-1800
Location: ADW.Airport, MD
Light: Daylight
Aircraft: Bell Helicopter Textron Undifferentiated or Other Model
Operator: Military
Flight plan: VFR
Flight phase: Initial Climb
Airspace: Class B DCA
ATC / advisory: Tower ADW
Second aircraft: Bell Helicopter Textron Undifferentiated or Other Model
Reporter organization: Government
Reporter function: Local
Reporter qualification: Air Traffic Control Fully Certified
Human factors: Confusion; Distraction
Anomaly: ATC Issue All Types; Conflict Airborne Conflict; Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Air Traffic Control
When detected: In-flight
Result: Air Traffic Control Separated Traffic; Flight Crew Executed Go Around / Missed Approach
Contributing factors: Procedure
Primary problem: Procedure

Narrative: Aircraft X and Aircraft Y were in the Tower pattern for RWY 1L. Aircraft Y was sequenced behind Aircraft X and traffic was issued. Aircraft Y did not call Aircraft X in sight. When Aircraft X was airborne and climbing out on RWY 1L; approximately 2;000 FT down the runway; Aircraft Y was on short final. The AMASS went off and instructed me to send Aircraft Y around. I complied; turned Aircraft Y inside of Aircraft X. Aircraft Y entered left traffic for the runway and Aircraft X was sequenced behind. The Supervisor entered an MOR into the log. I sent Aircraft Y around because I didn't have the discretion not to. I feel; however; that I complied with the necessary separation requirements and the go-around was not necessary.FAA 7110.65 (3-9-6; departure separation) states that if the succeeding aircraft is a helicopter; visual separation may be applied in lieu of using distance minima. Section 3-10-3; arrival separation; also states that when the succeeding aircraft is a helicopter; visual separation may be applied in lieu of using distance minima. Section 7-2-1 defines visual separation. It categorizes visual separation into two types; Tower-applied; and pilot-applied. Tower-applied visual separation may be used as long as there is no wake turbulence involved; which there was not. I used Tower-applied visual separation between the two aircraft. Section 7-2-1 also states that other approved separation must be assured before and after visual separation. In Class B; however; there is no separation requirement between helicopters (Section 7-9-6): 'VFR helicopters need not be separated from VFR or IFR helicopters. Traffic advisories and safety alerts must be issued as appropriate.' When Aircraft Y was sequenced behind Aircraft X; a traffic advisory was issued. I also had the two helicopters in sight the entire time. Sections 3-11-3 and 4 both state that a departing and/or arriving helicopter must not takeoff/land until a preceding departing helicopter has left the landing area. Aircraft X was airborne and certainly had left the landing area. Section 3-11-5; helicopter simultaneous landings or takeoffs states that simultaneous landings and takeoffs are allowed as long as the landing or takeoff points are at least 200 FT apart. In this case; they were. After the MOR was reported to the Manager and Ops Manager; they; along with a staff specialist; listened to the tape and started discussing the issue. Today; they were still listening to the tape and discussing the issue. I did not listen to the tape and was not involved in their discussions; however I did hear various comments such as: was the go-around timely before the landing threshold; there must be approved separation before and after any visual separation; there is no separation between helicopters; there was no visual separation because Aircraft Y did not report Aircraft X in sight; that I intended to let the operation go if the AMASS had not gone off; there must be visual separation to have 200 FT between takeoffs and landings; etc. I found these comments very interesting; both because I did not agree with most of them and because they exposed how unnecessarily complicated helicopter requirements are.If the requirements of 3-11-5 are used; the landing threshold is meaningless as long as the landing or takeoff points are at least 200 FT apart. If the requirements of 3-9-6 and 3-10-3 are used; the landing threshold is also meaningless because there is no required minimum distance that must be ensured between the helicopters prior to the landing threshold. The individual who questioned whether the go-around was timely; prior to the threshold; assumed that because the AMASS went off; there must have been an error. This; however; is not true. Helicopters can be only hundreds of FT apart and still be separated. The AMASS software does not recognize this and will go off every time helicopters are that close on the runway. The requirement of approved separation before andafter visual separation does not apply because there is no need for separation of helicopters in Class B airspace. Aircraft Y need not have reported Aircraft X in sight because Tower-applied visual separation could have been used in lieu of pilot-applied. Section 3-11-5 does not require visual separation as long as surface markings can be used to determine the 200 FT minimum. I used Tower-applied visual separation between the helicopters to ensure a safe operation. In accordance with Sections 3-9-6 and 3-10-3; there was no minimum distance required between them.Controllers should be allowed to use their discretion to ignore an AMASS go-around when it concerns helicopters and is not valid. It does no good to allow helicopters to be in close proximity of each other; within hundreds of feet; if the AMASS will go off every time and force a go-around. Helicopter separation is needlessly complicated. Various sections of the 7110.65 are ambiguous. There is no consistency between the various sections that affect helicopter operations. Sections 3-9-6 and 3-10-3 require no minimum distance on the runway between VFR helicopters if visual separation is applied. Section 3-11-3 allows a departing helicopter to depart after a preceding helicopter has left the takeoff area; or a preceding arrival aircraft has taxied off the takeoff area. Section 3-11-4 allows an arrival helicopter to land when a preceding arriving helicopter has landed and stopped on the landing area or taxied off; or a preceding departing aircraft has left the landing area. The definition of landing area in the glossary states that a landing area is any locality on land; including airports/heliports; which is used; or intended to be used; for the landing and takeoff of aircraft. When the 7110.65 states that a preceding departing helicopter must have left the landing area prior to a departing/arriving helicopter landing/taking off; does that mean that when the helicopter is airborne; it has left the landing area; or; in the case of a runway; must the departing helicopter be thousands of feet away past the end of the runway? If a helicopter departs a helipad; it leaves the landing area almost immediately and there is very little distance between helicopters. Section 3-11-4 allows a succeeding arriving helicopter to land when a preceding helicopter has landed and stopped on the landing area. Does this mean that a helicopter can land on a runway; stop; and then another helicopter can also land on the runway? Section 3-11-5 allows for simultaneous landings or takeoff if the landing or takeoff points are at least 200 FT apart. Does this include a runway? Can helicopters conduct operations at the same time; on a runway; as long as their takeoff or landing points are at least 200 FT apart? Section 7-9-6 states that VFR helicopters need not be separated from other helicopters. Section 7-9-4 states that VFR aircraft must be separated from aircraft that weigh more than 19;000 LBS by 1 1/2 miles. What about helicopters that weigh more than 19;000 LBS. Do they receive separation or not? Section 7-5-3 (SVFR Separation) requires either 1/2 or 1 mile separation between a SVFR helicopter and an IFR aircraft based on their distance from the airport; but makes no mention of weight. Does this mean that when the weather is good; a helicopter must be separated by 1 1/2 miles from an aircraft that weights more 19;000 LBS; but when the weather is bad; the same helicopter need only be separated by 1/2 or 1 mile from an aircraft that weighs more than 19;000 LBS; depending on the distance from the airport?Helicopter separation requirements in the 7110.65 appear to be a patchwork of rules. Their needs to be clarification concerning separation requirements based on the weight of an aircraft/helicopter. The separation requirements concerning landing areas should be cleared up so as not to be ambiguous. A better definition is needed for landing areas and the requirements should be betterexplained concerning runways; helipads; taxiways; and other movement areas. Are the requirements the same for all of them?




Synopsis: Reporter questions AMASS procedures and separation requirements involving helicopters.