The vast majority of the nation’s heliports epitomize the “normalization of deviance,” according to Rex Alexander, a vertical flight infrastructure expert and the CEO of consultancy Five Alpha. “Just because somebody painted an ‘H’ in a parking lot does not mean that it meets any standard, anywhere,” Alexander counseled during a Helicopter Association International (HAI) webinar in January. The session occurred mere days after the FAA released its latest advisory circular (AC) on heliport design (see sidebar).
Alexander noted that most of the nation’s heliports have design, lighting, marking, and airspace issues related to size, obstructions, and approach slopes and are antiquated. He also said that pilots have received no training or poor training on what constitutes a proper heliport/helipad. At the heart of the problem is the lack of proper regulation and the voluntary nature of heliport standards, he added.
“According to the FAA, there are 6,104 heliports on record in the U.S.," Alexander said. "Fifty-seven of those, or 1 percent, are public use, and 6,047, or 99 percent, are what we refer to as private use. The FAA has absolutely no enforcement authority over private-use heliports. That means that 99 percent of the heliports in the U.S., the FAA can't shut down. They can enforce operations, but not the infrastructure. There is no certification for heliports." That includes all hospital heliports in the lower 48 United States.
Another problem is that hospitals and other facilities do not properly future-size their heliports, Alexander said. “The first question we ask all of our clients is, 'What is the largest helicopter that you're intending to use at this facility? Not just today, not next week, but...in the next 10 to 20 years?' And we base our design criteria on that geometry. We're looking at the maximum load and gross weight, what's the overall length, tail rotor arc, undercarriage dimensions, and so forth.” Alexander noted that when the Maryland State Police, which routinely flies medevac missions, upgraded from the Airbus AS365 to the Leonardo AW139, the weight and dimensions of the latter meant that several hospital helipads in the state could no longer be used.
While heliport standards are voluntary for private-use facilities, there is guidance mentioning “airport operations” for Part 135 operations, rules that govern most air ambulance operations in the U.S. But the guidance is imprecise and murky at best, Alexander said. “No certificate holder may use any airport unless it is ‘adequate,’" he noted. "Now, that's a very subjective word, and I could ask 10 pilots what adequate is and get 10 different answers but when we're looking at this, it's adequate for the proposed operation, considering things such as size, surface obstruction, and lighting. So, they do give you criteria, but what is adequate is very subjective and we've seen that somewhat misused in the Part 135 world.”
Pilot training is the other missing link, Alexander said, noting that the Helicopter Flying Handbook, the Helicopter Instructor’s Handbook, and other relevant literature contain nothing about proper infrastructure save for a passing reference to the lighting in the instructor text. “We don't test pilots. So, pilots do not get an education on what infrastructure is supposed to look like. When they're presented with infrastructure that is substandard, they don't know any better. We haven't taught them when to say ‘no.’ I always tell people that pilots generally don't read advisory circulars, and that's where all of this information is, generally.”
But pilots would be well-advised to expand their knowledge on the topic, Alexander said. “I always tell pilots, just because you can land there, it doesn't mean you should. Because when something gets broken and you bend metal, that's your license on the line. It's very, very rare that the operators are held responsible, or the owner of the infrastructure is held responsible. It's always the pilot. The NTSB does that routinely. I wish they wouldn't. I wish they'd hold the individuals that actually run the infrastructure and own the infrastructure just as responsible as the pilots.”
Alexander knows better, however. “In 2009, I was one of the parties involved in the NTSB HEMS [air ambulance] accident hearings. I remember bringing up heliports and was told, “It's not a big deal, it's not a problem. It was never identified because nobody was investigating it correctly. We don't have good documentation, so we can't learn from our past screw-ups. That is something we're trying to change.”
And the price of bad infrastructure design can be expensive, even for minor scrapes such as tail-rotor strikes, which can cost up to $400,000, he said. “By the time you get the components replaced, [pay for] all the AOG shipping, all the out-of-service time, and all the extra man-hours, it gets real expensive really quick. I can build you a heck of a heliport for $400,000. You know, that's the disparity.
Continued Alexander: “What's the safe thing to do? What's the right thing to do? You should follow the minimum standards [in] that Advisory Circular the FAA publishes.” And that applies to both pilots and those responsible for the infrastructure, particularly hospitals, Alexander said. He finds it ironic that “most states have a requirement in place that helicopter air ambulance [programs] teach first responders how to set up and design landing zones for scenes—how big, how to mark them, and communications” but yet “there is no standard in place that asks that we teach hospitals anything” with regard to helipad/heliport design.
But the new AC, coupled with mandated safety management systems (SMS) for Part 135 operators, improved state regulations, and the forward march of advanced air mobility, could eventually change that. Right now, insurers aren’t ready to tackle the issue, Alexander said, but wider promulgation of some state rules could show the way toward a solution.
“On the regulatory side," he concluded, "I think there’s the opportunity to come up with something that [some] states have been using for years—and that’s commercial. It [the heliport/airport] may be private, but if you're doing commercial operations, the state says you need to meet a higher standard. I think the FAA would be wise to look at adopting some additional categories [in addition to private and public use], commercial being one of those. SMS is required for an airport, required for Part 121 [air carriers]. Soon it will be required for [Part] 135 operators. It makes sense I think, to have it required for vertiports.”
The vast majority of U.S. heliports epitomize the “normalization of deviance,” according to Rex Alexander, a vertical flight infrastructure expert and the CEO of consultancy Five Alpha. “Just because somebody painted an ‘H’ in a parking lot does not mean that it meets any standard, anywhere,” Alexander counseled during a Helicopter Association International (HAI) webinar in January. The session occurred mere days after the FAA released its latest advisory circular (AC) on heliport design.
Alexander noted that most of the nation’s heliports have design, lighting, marking, and airspace issues related to size, obstructions, and approach slopes. He also said that pilots have received no training or poor training on what constitutes a proper heliport/helipad. At the heart of the problem lies the lack of proper regulation and the voluntary nature of heliport standards, he added.
“According to the FAA, there are 6,104 heliports on record in the U.S.," Alexander said. "Fifty-seven of those, or 1 percent, are public use, and 6,047, or 99 percent, are what we refer to as private use. The FAA has absolutely no enforcement authority over private-use heliports. That means that 99 percent of the heliports in the U.S., the FAA can't shut down. They can enforce operations, but not the infrastructure. There is no certification for heliports." That includes all hospital heliports in the contiguous U.S.
Alexander explained the fact that hospitals and other facilities do not properly future-size their heliports presents another problem. “The first question we ask all of our clients is, 'What is the largest helicopter that you're intending to use at this facility? Not just today, not next week, but...in the next 10 to 20 years?' And we base our design criteria on that geometry," he said. "We're looking at the maximum load and gross weight, what's the overall length, tail rotor arc, undercarriage dimensions, and so forth.” Alexander noted that when the Maryland State Police, which routinely flies medevac missions, upgraded from the Airbus AS365 to the Leonardo AW139, the weight and dimensions of the latter meant that operators could no longer use several hospital helipads in the state.
While heliport standards are voluntary for private-use facilities, the FAA has issued guidance mentioning “airport operations” for Part 135 operations, rules that govern most air ambulance operations in the U.S. But the guidance is imprecise and murky at best, Alexander said. “No certificate holder may use any airport unless it is ‘adequate,’" he explained. "Now, that's a very subjective word, and I could ask 10 pilots what adequate is and get 10 different answers but when we're looking at this, it's adequate for the proposed operation, considering things such as size, surface obstruction, and lighting. So, they do give you criteria, but what is adequate is very subjective and we've seen that somewhat misused in the Part 135 world.”
Pilot training presents the other missing link, Alexander said, noting that the Helicopter Flying Handbook, the Helicopter Instructor’s Handbook, and other relevant literature contain nothing about proper infrastructure apart from a passing reference to the lighting in the instructor text. “We don't test pilots," he noted. "So, pilots do not get an education on what infrastructure is supposed to look like. When they're presented with infrastructure that is substandard, they don't know any better. We haven't taught them when to say ‘no.’ I always tell people that pilots generally don't read advisory circulars, and that's where all of this information is, generally.”
Alexander advises pilots to expand their knowledge on the topic. “I always tell pilots, just because you can land there, it doesn't mean you should," he said. "Because when something gets broken and you bend metal, that's your license on the line. It's very, very rare that the operators are held responsible, or the owner of the infrastructure is held responsible. It's always the pilot. The NTSB does that routinely. I wish they wouldn't. I wish they'd hold the individuals that actually run the infrastructure and own the infrastructure just as responsible as the pilots.”
Alexander knows better, however. “In 2009, I was one of the parties involved in the NTSB HEMS [air ambulance] accident hearings. I remember bringing up heliports and was told, “It's not a big deal, it's not a problem. It was never identified because nobody was investigating it correctly. We don't have good documentation, so we can't learn from our past screw-ups. That is something we're trying to change.”
Meanwhile, the price of bad infrastructure design can be expensive, even for minor scrapes such as tail-rotor strikes, which can cost up to $400,000, he said: “By the time you get the components replaced, [pay for] all the AOG shipping, all the out-of-service time, and all the extra man-hours, it gets real expensive really quick. I can build you a heck of a heliport for $400,000. You know, that's the disparity.
Continued Alexander: “What's the safe thing to do? What's the right thing to do? You should follow the minimum standards [in] that Advisory Circular the FAA publishes.” And that applies to both pilots and those responsible for the infrastructure, particularly hospitals, Alexander said. He finds it ironic that “most states have a requirement in place that helicopter air ambulance [programs] teach first responders how to set up and design landing zones for scenes—how big, how to mark them, and communications” but yet “there is no standard in place that asks that we teach hospitals anything” with regard to helipad/heliport design.
But the new AC, coupled with mandated safety management systems (SMS) for Part 135 operators, improved state regulations, and the forward march of advanced air mobility could eventually change that. Right now, insurers aren’t ready to tackle the issue, Alexander said, but wider promulgation of some state rules could show the way toward a solution.
“On the regulatory side, I think there’s the opportunity to come up with something that [some] states have been using for years—and that’s commercial," he concluded. "[The heliport/airport] may be private, but if you're doing commercial operations, the state says you need to meet a higher standard. I think the FAA would be wise to look at adopting some additional categories [in addition to private and public use], commercial being one of those. SMS is required for an airport, required for Part 121 [air carriers]. Soon it will be required for [Part] 135 operators. It makes sense I think, to have it required for vertiports.”