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Carry-On Baggage Requirements


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Received March 28, 17:30:

Hi Chad

The changes below meet standard.

 

Is your intent to address Cabin Baggage by:

 

Ground crew will ensure your baggage is loaded and unloaded from the aircraft at the Pilot-in-Command’s direction.? Does your visual show that?

 

Please advise

Lisa

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Under CARs 602.86, Can a passenger carry a purse on their lap in a 702/703 helicopter flight in Canada?   Carry-on Baggage, Equipment and Cargo   602.86 (1) No person shall operate an aircraft wit

I would say they have been enforcing it at 705 level (for passenger compartment anyway). The thing is, there is actually a Carry-on Baggage regulation in the 705 CARs. No such regulation exists in 702

I also cc'd your friend Richard Pierce on many of my recent requests for clarification...I know what really goes on in our industry...this is an issue we are discussing with our legal council.

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Sent Mar 28, 2013, 17:30

 

Hi Lisa,

I am sorry, I inadvertently forgot to add “No Carry-On Baggage is permitted in the cabin”. I have made the required changes that you require for approval. Again, I would like to voice my concern that this is not as per the CARs and you are forcing us to do more than the regulatory requirement.

 

When you say does our “visual show that”, what do you mean. Show what? You have advised that under no means is baggage allowed in the cabin so have added “No Carry-on Baggage is permitted in the Cabin”.

 

Also, as discussed, if we were carrying cargo in the cabin there would be a wide range of ways in which we believe we could be compliant. I can’t show all of them. Wrapping an item in bubble wrap might be one way, securing it with a seat belt or strap is another, in a person’s arms is another etc…The entire script is shown on the screen in writing, so It shows the words...it also shows a symbol that passengers must hand baggage to crew.

 

 

As you are aware, the President of HAC has just offered his support for my belief that you are not interpreting the CARs correctly and advised that it is not the way the Regulation is being enforced in other regions and is contrary to the long standing practice in the Canadian helicopter industry.

 

I am going home now and we will commencing operations in Moosonee next week, with or without your approval. We have an important service to provide, and we intend on doing just that.

 

If you have issue with it, you can speak to enforcement and we’ll call our attorneys.

 

Have a Nice Easter Weekend,

 

Chad Calaiezzi

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Sent April 2, 2013:

Hi Lisa,

Thanks for the quick response. I just wanted to confirm, as I was dealing with Janice and Terry throughout the entire process and it seems the requirements for approval keep changing. As you are aware we require approval ASAP and I was just trying to ensure no further delays.

 

I also need confirmation on whether TC Cabin Safety in the Ontario region will be changing its position on the interpretation of Carry-on Baggage in the cabin requirements. Will you be continuing to enforce and apply the Regulations in a manner that is inconsistent with other regions and the long standing practice in the Canadian Helicopter industry? If not we will require clarification on what exactly is TC Ontario’s position on this issue.

Regards,

 

Chad Calaiezzi

Operations Manager

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Received April 16, 2013 from Bell Helicopters Product Support and Engineering:

 

DATE: April 15th, 2013

TO: Mr. Chad Calaiezzi

Expedition Helicopters

Cochrane, Ontario, Canada

 

SUBJECT: Cargo and carry-on baggage inside cabin of 206 series helicopters.

 

Please find comments to the questions you rose as shown below;

1) The marketing data and Product Specifications seem to imply that the aircraft

is approved for carriage of Cargo in the cabin; is this in fact the case?

 

COMMENT: Our engineering has defined loading limits to be in the aft cabin, 75 Lbs per

square inch and in the baggage compartment, of 86 Lbs per square inch, provided the

limits indicated in the 206 series Flight manuals are not exceeded.

 

2) Can Baggage or Cargo be placed on the floor of the aircraft as per the

standards of airworthiness specified in the basis of certification for the

aircraft?

 

COMMENT: BHT considers that some cargo or carry-on baggage can be placed on the

floor as long as limits described above are not exceeded and the aircraft C.G. remains in

the envelope prescribed by the flight manual.

 

3) If so, is there a Maximum Weight that can be placed on the floor (or are we

ok just to use the 75 lbs. per sq. ft. rule).

COMMENT: See comments # 1 and # 2 above.

 

4) Can Baggage or Cargo be carried on the seats of these aircraft?

COMMENT: According to CAR 602.861b, BHT would find acceptable to carry cargo or

carry-on luggage on seats in the aft cabin provided it does not exceed the weight of 100

Lbs per seat as defined in Service Instruction 206-2051 applicable to the 206L series

helicopters. Weight shall be properly secured to meet requirements of the CAR

602.861b. There is no Service Instruction similar to SI 206-2051 which applies to

206A/B/B3. Customers should get local approval for whatever installation they may want

to perform to secure Cargo or get BHT engineering to review their installation and

provide some comments to facilitate local approval by a Certification Delegate. The last

option may have some fees attached to cover our engineering evaluation.

 

5) If so, what are the limits?

 

COMMENT: See comment # 4 above. Note that the weight. Limitation should be spread

over the full surface of the bottom seat cushion and not be localized only in a small area

of the cushion.

 

6) Do you believe a pilot can use a seat belt to secure small baggage in the seat

to comply with CARs 602.86 (2)?

 

COMMENT: YES, provided the seat belt secures the cargo or carry-on baggage

appropriately in order to prevent any movement or weight shift during dynamic flights. It

is the responsibility of the operator/owner and pilot-in-command to ensure this prior to

flight departure.

 

7) If so, Limits?

 

COMMENT: See comment #4.

 

8) Can Cargo nets be secured to seat belt anchor points to secure baggage in

the rear cabin?

 

COMMENT: Possibly but the installation of nets or other devices beside belts to secure

cargo or carry-on baggage using structure attachment points or any other area would

have to be reviewed by our engineering and/or approved by your local aviation authority

for this matter. As specified earlier, some fees may be charged to have our engineering

exercise any kind of evaluation concerning any installation you may want to perform.

 

9) Do you have any other suggestions as to how cargo may be secured in the

cabin?

 

COMMENT: YES. See Service Instruction 206-2051; ”AFT FACING SEATS CARGO

TIE-DOWN PROVISIONS” applicable to 206L series helicopters. As for 206A/B/B3

models, see comments #4 and # 8 above.

 

10) We are aware of the recently released SI for aft facing seats Cargo Tie down

provisions, which permits helicopter operation to carry cargo and passengers

in the rear cabin at the same time, but TC seems to be questioning the ability

to carry cargo in the rear cabin ever based on “the standards of airworthiness

specified in the basis of certification for the aircraft” (unless this SI has been

carried out).The question is can we ever carry cargo in the cabin without

BHT-206-SI-2051 being carried out? (i.e. even with no passengers).

 

COMMENT: As specified in comment #9, any deviation to existing and approved data

released in SI 206-2051 would require concurrence from your local aviation authority

that it meets the requirements of CAR 602.86. As for carrying some cargo in the cabin

area, the structural limitations described in comment #1 above are clear. The regulation

(CAR) is clear also about how cargo can be carried in the cabin area but it is the

responsibility of the owner/operator and pilot-in-command to ensure that the CAR

regulation is met. Securing cargo using the seat belts is a possible method but this

would have to get concurrence from TCCA. Other possible devices or means such as

nets or else would require some sort of approval but again, this has to meet TCCA

requirements. Unfortunately, BHT will not do any interpretation of the regulation as it is

to TCCA to define and concur that their regulation is met.

 

11) The SI, as you are aware, only covers the cargo on the mid-section seats.

What about carriage of Cargo/baggage on REAR FWD facing seats?

 

COMMENT: See the list of comments above which we believe provide answer to this

question.

 

Let me know if you have any other questions concerning this subject.

Thanks you for contacting Bell Helicopter Textron.

Regards,

Noel Paquette

Product Support Engineering

Canada: (800) 361‐9305

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Sent April 26, 2013 to TC Inspectors Lisa Witton, Janice Berling, Richard Pearce, Jamie Bionda, Bill Turcotte, Ken Walsh, Terry Long

 

Hi Lisa/Janice,

As you are aware, I have been inquiring about approval for our COM amendment No.14, which was submitted on March 27, 2014. This amendment contains changes that allow for Passenger Briefings to be conducted by a flight crew member “pre-recorded audio or audiovisual means”. As you are aware, our Operations Inspector and Technical Team lead have advised that they will not approve the manual until you approve our Pre-recorded audiovisual presentation. We have presented a script to your office (which was approved as meeting the standard) and videos for your review. We also made changes to the videos at your request. The only issue remaining seemed to be a disagreement with regards whether or not any carry-on baggage is permitted in the cabin and “where” it is to be stowed or restrained. I have not received further correspondence from either of you since I presented you our last videos.

 

  1. Can you please advise if you are currently withholding approval of our audiovisual presentation?
  2. If yes, on what grounds?

 

As you are aware, we believe the minimum requirements as stated in the CARs do allow for items in the cabin, with the responsibility as to where and how it is retrained are at the discretion of the “Pilot in Command”. This is what we believe our Passenger Briefing currently states.

We have demonstrated that your interpretation is contrary to longstanding industry practices, past (and present) enforcement (and what is currently being practiced across Canada). The HAC has also reiterated these facts and joined us in the opposition of the interpretation your office has been offering. I have also made official requests for clarification on your interpretation of the CARS (with regards to carry-on baggage) on multiple occasions, yet you have chosen not to respond (as many weeks have past).

As discussed, the interpretations that you have presented us, (along with the delays) have a dramatic on our ability to conduct business on a multitude of levels. Furthermore it will have a huge impact on our clientele and a wide variety of industries who require the use of helicopters to conduct business in remote areas.

 

I would like to present to you one more example (of many). I have recently received a Request for Proposal from the government of Ontario to conduct the annual Ontario Geological Survey contract; questions remain as to whether it can even be conducted legally. This contract has been conducted by a Bell 206 on Floats by a variety of operators for approximately 20 years and carries a value of approximately $180,000.00 in revenue to a helicopter company. The purpose is to take sediment samples from the bottom of 2000 lakes within a few weeks; analysis of these samples is then translated into important baseline geological data for the province. This data is then used by thousands of mining companies develop the mineral exploration industry in Ontario (and Environmentalists who monitor the effects of mining on the environment).

 

I invite you to review the following video that demonstrates the operations well. It also demonstrates items being carried in the cabin. It would be likely be impossible to conduct this survey under your interpretation of 602.86, as samples are required to be placed in the cabin. Asking the sampler to attempt to place the sample in the cargo would create much higher risks. Since they made a video and published it all over the web (and elsewhere); I suspect the helicopter company, pilot and the province obviously don’t think they are contradicting the regulations. Neither do we. Keep in mind the province of Ontario has its own Aviation Department and Helicopters that conduct this nature of work; I suspect they would also disagree with your interpretation. Similar videos are posted on the Ministry of Northern Development and Mines website (and elsewhere) advertising for college students to work on the survey; I suspect most of these people expect it is being done safely as well.

It’s also worth noting that this type of work presents specific challenges and risks due to the high number of landings, pressure to be efficient etc. As testament to this, at least one Bell 206 has been destroyed on this contract within the past few years due to a roll over on landing. No passengers were seriously injured (from items in the cabin or otherwise). The pilot and passengers were found floating on the upside down aircraft by SAR. I saw the wreckage personally, it wasn’t pretty.

 

http://www.youtube.com/watch?v=PmCtpV8J4VQ&list=UUJ2EkDUOZQfZ9jmg3nisVfw

 

Regards,

 

Chad Calaiezzi

Operations Manager

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Sent May 2, 2013, to TC Inspectors Lisa Witton, Janice Berling, Terry Long (TTL), Jamie Bionda, Ken Walsh, Richard Pearce, Yves Lemieux (Director of Operations East), Bill Turcotte (TTL), and President of HAC:

 

Hi Jamie/Terry,

I have taken it upon myself to review the 705 CARs for Airline Operations. I am fully aware that the majority of the Operations you inspect are Airline Operations, so have done this in an effort to figure out where Cabin Safety’s interpretations of 602.86 are coming from. After reviewing the airline portion of the CARs, I think I may understand where the confusion has originated.

As you are aware 602.86 is not a Passenger Briefing/Passenger and Cabin safety Regulation in Part 7 of the CARS (for commercial Air Services), but part in Part 6 of the CARS (General Operating and Flight Rules General) . Because of this, I have been a little surprised by the approach taken by our Operations Inspectors. They wish not to comment on your interpretation of CARs 602.86, yet it is clearly an “operations issue”; other than the mention of “When, where, why carry-on baggage must be stowed in the Passenger briefing under 702/703 regulations, I see no discussion with regards to Carry-on Baggage that specifically relates to Cabin Safety.

After reviewing 705 CARs for (Airlines), I have come to see that this, is not the case in 705 operations. I have pasted CARs 705.42 below (which does not apply to us). It seems to state clearly what Janice has been saying to us, since this discussion commenced; unfortunately IT DOES NOT APPLY TO 702/703 COMMERCIAL AIR SERVICES.

Under 702/703 operations, I don’t believe our means of restraint (Carry-on Baggage) is required to be approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual, otherwise it would be stated as such in 702/703 CARs (as it is in 705). I have pasted CARS 705.42 below.

Could it be that Cabin Safety is trying to apply 705 airline regulations to 703 Helicopter Operations? Based on my recent dealings with Cabin Safety in Toronto, I would say yes; now that I reviewed the 705 Regulations this seems more likely. This would not be all that surprising as Cabin Safety’s own web site states: Priority of Inspection

Using risk management principles, inspection resources and efforts are directed where it will have the greatest benefit.

As the greatest numbers of passengers are carried on commercial aircraft, inspection of airline operations (Canadian Aviation Regulation 705) takes top priority.

Janice has also advised that the majority of her experience is with Airline Operations. In the essence of having a clear an open discussion about these issues, (and how they affect 702 Helicopter Operations) I would invite any comments.

I would especially like to hear from our Operations Inspector (or any other) and Technical Team Lead with regards to this issue. Again, I do believe this issue is an operations issue as it directly relates to CARs part 6, General operating and Flight Rules. I also believe the fact they are Commercial Helicopter Pilots is relevant.

Carry-on Baggage

705.42 (1) Every air operator shall establish a carry-on baggage control program that is approved by the Minister in accordance with the Commercial Air Service Standards.

(2) No air operator shall permit a person to carry on board an aircraft any carry-on baggage unless that baggage has been accepted in accordance with a carry-on baggage control program and can be

(a) stowed in a compartment or overhead rack that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual for the stowage of carry-on baggage;
(amended 1999/06/01;
previous version)

(B) stowed under a passenger seat; or

© restrained by a means that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.
(amended 1999/06/01;
previous version)

(3) No person shall carry on board an aircraft any carry-on baggage unless that baggage has been accepted in accordance with a carry-on baggage control program.

(4) All carry-on baggage that is stowed under a passenger seat shall be restrained in a manner that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.
(amended 1999/06/01;
previous version)

(5) All carry-on baggage shall be stowed so that it does not obstruct access to safety equipment, exits or the aisles of the aircraft.

(6) No air operator shall allow the passenger entry doors of an aircraft to be closed for departure until a crew member has verified that all carry-on baggage is stowed in a location that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual or is restrained by a means that has been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.
(amended 1999/06/01;
previous version)

(7) All carry-on baggage shall be safely stowed prior to movement of the aircraft on the surface and during take-off, periods of in-flight turbulence and landing.

(8) No carry-on baggage that may cause injury to passengers in the event of turbulence or an emergency shall be stowed in an overhead rack unless that rack is equipped with restraining devices or doors that have been approved by the Minister in accordance with Chapter 551 of the Airworthiness Manual.
(amended 1999/06/01;
previous version)

 

 

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Received from Transport Canada Associate Director Operations East, Yves Lemieux May 14, 2013:

 

Good afternoon Mr. Calaiezzi,

 

The attached letter summarizes the current status of the issues and clarifies our position and expectations regarding the two regulatory issues that have been the subject of a significant number of emails lately. The requirements for passenger briefing and the securing of carry-on baggage are not new and apply to every segment of air operations regardless of the certificate types.

 

Our responsibility is to ensure that every sector of the aviation industry is compliance with the Canadian Aviation Regulations. To the end, when regulatory non-compliance is uncovered, we work cooperatively with the organization or individual to resolve the issue(s) of non-compliance.

 

Yours truly

 

Yves Lemieux

A/Associate Director Operations

Transport Operations Civil Aviation

Ontario Region

 

Here is the letter that was attached:

4900 Yonge Street Suite 400

Toronto, ON M2N 6A5

 

 

May 13, 2013

 

Mr. Todd Caleizzi, Accountable Executive RDIMS#8419201

Expedition Helicopters

 

 

Dear Sir,

 

 

While the email exchanges may be continuing, I wish to summarize the status of the issues surrounding passenger safety briefing and the stowage of carry-on baggage as they relate to helicopter operations.

 

We are in agreement that the proposed audio visual means to deliver the passenger briefing is acceptable. I concur that the passenger briefing script you submitted meets the regulatory requirements.

 

However, our request for copies of the passenger briefing video for each helicopter has not yet been met. We require the videos to formally verify its fidelity to the approved script. Once approved, the videos will form part of your company approved documentation. We again request that copies of the new videos be submitted on portable electronic means, CD or by e-mail. Note that the use of “YouTube” or similar social media to make submissions is not acceptable.

 

Transport Canada is continuing to assess issues pertaining to the delivery of the passenger standard safety briefing by a person other than a flight crew member to determine if an exemption can be issued, and what conditions would be necessary to ensure an equivalent level of safety for the public.

 

I note that Expedition Helicopters has been provided with the official Transport Canada interpretation of Canadian Aviation Regulation (CAR) 602.86 and requirements for the stowage of carry-on baggage, in writing, several times. CAR 602.86 is a general operating and flight rule, and applies to all aircraft operations.

 

To ensure the safety of every occupant, all carry-on baggage, equipment including tools must be stowed and/or secured. Unsecured articles could be hazardous to passengers and crew. Because each operational environment and conditions may be unique, the operator can choose from a number of acceptable means to meet this regulatory requirement.

 

Note that to avoid confusion or misunderstanding, Transport Canada is not working on an exemption to the minimum requirements for stowage/securing of carry-on baggage and equipment/tools, as was mentioned in one of the e-mail messages from your company.

 

 

In summary, Expedition Helicopters shall ensure that:

 

  1. The passenger briefing requirements contained in Canadian Aviation Regulation 703.39, and method of providing those briefings, are adhered to for all passenger carrying flights; and

 

  1. The requirements of Canadian Aviation Regulation 602.86, pertaining to the stowage or securing of carry-on baggage, equipment and cargo are adhered to.

 

Your contact for these issues is Ms. Terry Long, Technical Team Lead – Specialties.

 

Transport Canada specialists will continue to work with you and company personnel to ensure safe and compliant operations at Expedition Helicopters.

 

Sincerely,

 

Yves Lemieux

A/Associate Director Operations

Ontario Region

Transport Canada Civil Aviation

 

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Reply to Yves Lemieux May 15, 2013:

 

Hi Yves,

Thank you for the e-mail and the attached letter (which I have included for those of you who have not seen it). Could you please try to include me in the e-mails that concern regulatory compliance issues? I am sure you are aware, as Operations Manager, I am the person assigned the duty and responsibility to liaise with regulatory authority on all matters concerning flight operations.

 

With regards to the Passenger Briefings I will forward copies of our Cabin Safety Videos to Terry for review by mail. We have just moved the ELT on Aircraft FJBQ (Bell 206 L1C30) in an effort to standardize the fleet. I have attached a copy of JBQ’s newly amended Safety Features Card. Sarah will be making the ELT changes to the video shortly; I will mail you copies of the audiovisual presentations for each aircraft type on CD.

 

I have to say, your timing is impeccable. When Todd received your e-mail, we were sitting in a board room with 7 of our pilots and a senior official from the OMNR Wildfire Division. He came down to do an Annual Regional Fire Briefing. We were actually discussing the official Transport Canada interpretation of CAR 602.86 (that we have received from Transport Canada Cabin Safety Inspectors) and the requirements for stowage of carry-on baggage. We also discussed the interpretations offered with regards to the requirements for passenger briefings. Everyone in the room agreed that the interpretations offered by TC were not at all in tune with what happens throughout the commercial VFR helicopter industry. The OMNR official commented that the interpretations we received are in complete contradiction to many of the common practices currently occurring on Forest Fires across Canada.

 

While you are right, “that Expedition Helicopters has been provided with the official Transport Canada interpretation of Canadian Aviation Regulation (CAR) 602.86 and requirements for the stowage of carry-on baggage, in writing, several times”, we believe these interpretations are contrary to what is going on throughout the industry and the regulations are not being enforced equally from one operator to the next. We also feel that some of the interpretations offered were not correct.

 

You are also right when you say “Because each operational environment and conditions may be unique, the operator can choose from a number of acceptable means to meet this regulatory requirement”. What we are trying to do here, is have an open discussion about what are the “acceptable means”. I notice you believe there are a number of acceptable means…so let’s discuss them openly. Janice and Lisa have advised that there are very few (if any) acceptable means. I will now ask you a few basic questions and would appreciate an answer to each question.

 

  1. Do you believe carriage of Cargo in the cabin of the Bell 206 helicopters is approved?
    1. Here is what Bell Helicopters has to say: “Our engineering has defined loading limits to be in the aft cabin, 75 Lbs. per square inch and in the baggage compartment, of 86 Lbs. per square inch, provided the limits indicated in the 206 series Flight manuals are not exceeded.

  1. Do you believe baggage can be carried on a seat of a helicopter conducting 702/703 operations?
    1. Janice Says No in her February 21/13 e-mail: approval to use a seat for other than its original function of retaining an occupant will require a demonstration of compliance that the installation meets all applicable requirements in the aircraft basis of certification.” Please review this e-mail from Janice for her explanation in its entirety.
    2. Bell Helicopters says: “According to CAR 602.861b, BHT would find acceptable to carry cargo or carry-on luggage on seats in the aft cabin provided it does not exceed the weight of 100 Lbs. per seat as defined in Service Instruction 206-2051 applicable to the 206L series helicopters. Weight shall be properly secured to meet requirements of the CAR602.86.”

  1. Do you believe a pilot can use a seat belt to secure/restrain small baggage in the seat to comply with CARs 602.86?
    1. Janice Berling says NO (in her Feb 21/13 e-mail): “I am confirming that securing a purse or anything else that is considered as carry-on baggage in a seat with a seat-belt is not permitted: (a) stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo;

Baggage, equipment and cargo that is transported in the cabin of an aircraft must be stowed and restrained in a manner that ensures continued compliance with the applicable operating regulations (such as section 602.86) as well as the standards of airworthiness specified in the basis of certification for the aircraft.” I have asked her to show me where it discussed standards of airworthiness (with regards to means of restraint) in the 702/703 CARs. I agree that under CARs 705.42 this is correct (as it is clearly discusses restraint requirements in 705 CARs…not so for 702/703).

  1. Bell Helicopters Product support and engineering states with regards to 206/407 helicopters:YES, provided the seat belt secures the cargo or carry-on baggage appropriately in order to prevent any movement or weight shift during dynamic flights. It is the responsibility of the operator/owner and pilot-in-command to ensure this prior to flight departure.”

  1. Can Baggage or Cargo be placed on the floor of the Bell 206 aircraft as per the standards of airworthiness specified in the basis of certification for the aircraft?
    1. Here is what Bell Helicopters Product support and engineering have to say “some cargo or carry-on baggage can be placed on the floor as long as limits described above are not exceeded and the aircraft C.G. remains in the envelope prescribed by the flight manual.”

  1. Can small carry on-baggage ever be restrained by a passenger on their lap?
    1. Janice says NO in March 21/13 e-mail: “I am confirming that carrying a packsack on your lap is not in compliance with 602.86”
    2. Lisa says NO in March 28/13 e-mails: “Items held on laps or loose on the floor is not considered as meeting the requirements to be stowed or restrained”

  1. Is a person carrying a pillow on their lap compliant with CARs? Surely it would be restrained to prevent shifting and is “packaged and covered” to prevent injury.

  1. Is a person carrying a small soft covered bag on their laps compliant with CARs?

  1. Is a person carrying a camera on their lap/in their hands compliant with CARs?

  1. Is a person carrying a laptop used for aerial surveying/mapping on their lap compliant with CARs?

  1. Is a person carrying and restraining a Net Gun/Tranquilizer Gun in their arms Compliant with CARs?

  1. Is an MNR fire boss carrying a Fire boss kit/document bag in the front seat compliant with CARs ?

  1. Are you able to provide me with another CARs reference or supporting documentation that supports Janice Berling’s belief that a pilot conducting 702/703 operations cannot secure an item in the cabin or seat of the aircraft if it is not “stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo;”?

 

You are also right: “The requirements for passenger briefing and the securing of carry-on baggage are not new and apply to every segment of air operations regardless of the certificate types”. I can easily demonstrate that the current policy and interpretations being offered by Janice Berling, Terry Long, Lisa Witton MOST CERTAINLY ARE NEW! At least in the Commercial Helicopter sector…

Firstly, these interpretations that you discuss were provided to the President of the Helicopter Association of Canada (Fred Jones). As you are aware, in an e-mail the HAC joined our opposition to these interpretations and referred to them as new and extreme”. Fred also stated: “not only is it inconsistent with other regions, but it is inconsistent with long-standing accepted practice in the Canadian helicopter industry”.

 

When this issue was sent to Tom Grover, Bell Helicopter Sales Representative he had this to say in e-mail: “It has been pretty much industry standard practice to carry operational equipment, spares and personal baggage in the cabin if the baggage compartment is full when ferrying to and from the job site. In addition, you have to respect the maximum weight limits of the baggage compartment and normally operation gear, spares and personal baggage will exceed this limit so some has to be carried in the cabin. I would further suggest this applies to all makes and models of helicopters, not just Bell Helicopter products.”

 

I have also provided several photos and videos at the (end of this e-mail) demonstrating the longstanding industry practice of carrying cargo in the cabin of helicopters. Note that many of these items were posted on the Operator’s Website (by the Operator); they are being used as marketing material. Based on this fact I suspect they feel that they are in compliance of the CARs.

 

It is quite obvious to me, that there are only 2 possibilities here:

 

  • Widespread Non-compliance with 602.86 is occurring industry-wide across Canada; or
  • Transport Canada is not applying the CARs equally to all operators and the interpretations offered are not correct.

 

As for your comment: “Our responsibility is to ensure that every sector of the aviation industry is compliance with the Canadian Aviation Regulations. To the end, when regulatory non-compliance is uncovered, we work cooperatively with the organization or individual to resolve the issue(s) of non-compliance”; I expect you will work co-operatively with operators involved in the photos and videos below to resolve the issues of non-compliance (as per Janice and Lisa’s interpretations). I am sorry, it seems TC is failing miserably at ensuring compliance with in our sector of aviation industry (if the interpretations we have received are correct),and we fail to see TC working co-operatively in our dealings.

 

  1. What actions are you taking to correct what is obviously a much larger systemic issue of widespread non-compliances industry wide?

 

Photo 1: Chinook Helicopters securing a Survival Kit with a seat belt in Bell 47. Photo found On Chinook Helicopters Website at : http://www.chinookhelicopters.com/gallery.php

 

This is common practice throughout the industry and Flight Training Units. The pilot is obviously using the survival kit as ballast. It certainly was common practice in 1996 at Gateway Helicopters/Canadore College when Todd and I trained with former Transport Canada Inspector Rick Kirkwood.

 

Photo 2: Chinook Helicopters Securing pelican case secured to top of battery. Photo found On Chinook Helicopters Website at : http://www.chinookhelicopters.com/gallery.php

 

I doubt that securing items in this fashion is compliant with “the standards of airworthiness specified in the basis of certification for the aircraft.”

Photo 3: Chinook Helicopters Survival Kit on Front Seat of Bell 206. Photo found On Chinook Helicopters Website at : http://www.chinookhelicopters.com/gallery.php

 

Photo 4: FireWeed Helicopters (Yukon) Loading wooden steaks into Rear cabin of Longranger. Photo found on Fireweed Helicopters Website @: http://www.fireweedhelicopters.ca/gallery.htm

 

Photo 5: Fireweed Net Gun Photo found on Fireweed Helicopters Website @:http://www.fireweedhelicopters.ca/gallery.htm

 

 

Photo 6: Fireweed Helicopters with internal load of wood stakes. Photo found on Fireweed Helicopters Website @:http://www.fireweedhelicopters.ca/gallery.htm

 

Photo 7: Coldstream Helicopters Fire Crew Loaded. Photo found on Coldstream Helicopters website @: http://www.coldstreamhelicopters.com/our_media.html

 

Photo 8: Peak Helicopters with internal load of Stakes – Bell 206 Jetranger. Photo found at www.peakhelicopters.ca/gallery.htm

 

Photo 9: TRK Helicopters Large camera secured/restrained by person on-board

 

Photo 10: Glacier Helicopters Large camera restrained secured on persons lap. Photo found on Glaciers website @ : http://www.glacierhelicopters.ca/?q=content/photo-gallery

 

Photo 11: Ontario Ministry of Natural Resources Bell 206 Longranger conducting Fish Stocking Program:

 

Photo 12: Talon Helicopters loading persons and bags into cabin of AS350

 

Photo 13: Bell 206 Longranger (on Fixed Floats) loaded with Spares and operational equipment

 

 

Video 1: Niagara Helicopter Safety Briefing: At the 47 second mark it clearly states: “We suggest bringing only essential items like your camera on-board. Once on-board, remember to tie down any loose items to prevent them from interfering with other passengers or the pilot.” The video clearly demonstrates passengers holding packsacks on their laps (holding them tightly).

http://www.youtube.com/watch?v=tWV-U1T0_2I

 

Video 2: Grey Cup transported to the top of a mountain in BC (in the seat of an R44, secured by a seat belt):

http://www.youtube.com/watch?v=LDdGWj9sUzo

 

Video 3:

Ontario Geological Society being conducted by Provincial Helicopters from Manitoba. The project is conducted in a 206 on floats, a cooler is carried in the back and lake bottom sediment samples are carried in the cabin.

http://www.youtube.com/watch?v=PmCtpV8J4VQ&list=UUJ2EkDUOZQfZ9jmg3nisVfw

 

Video 4: Sky Helicopters conducting rides Squamish, BC, March 30, 2013. No passenger briefing from PIC. Purses and cameras in cabin.

https://www.youtube.com/watch?feature=player_embedded&v=O7--U1xhfZM#!

 

Video 5: Sky Helicopters Pit Meadows Ride (Cameras and carry-on in cabin)

https://www.skyhelicopters.ca/photo-video/videos/video-pitt-meadows-and-river-view-tour/

 

Video 6: National Helicopters with cameras and carry-on in cabin

http://toronto.streaming-video-gratuit.fr/real-wedding-proposal-surprise-video-badmash-factory-productions-stefan-peggy_32424775.html

 

Video 7: Wildcat Helicopters Transporting people with packsacks on lap:

http://www.youtube.com/watch?v=wAvqdunhSvU&feature=youtu.be

 

To infer that the interpretations we have received should be adequate, is unacceptable in my view; particularly when it is clear that we are not being held to the same standard under the law as others. As Fred also stated: “This interpretation has the potential to shut-down many helicopter operations taking place quite safely in our industry today, at considerable expense to the commercial helicopter community and its customers”. Currently, it seems we are one of the few operators who are being forced to bear the brunt of this “considerable expense”. I have advised the accountable executive to discuss how we remedy this unfair treatment from TC through other avenues (with his legal counsel); I feel I have clearly demonstrated my point through countless e-mail and will not continue to waste my time on this issue.

 

Regards,

 

Chad Calaiezzi

Operations Manager

 

Ph#: (866)-572-5755

Fax#:(866)-572-5752

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Exert from e-mail Sent June 5, 2013 to Yves Lemieux and Co.:

 

"..

  1. With regards, to the questions I posed in my e-mail on May 15, 2013 requesting clarification on the interpretation of CARs 602.86, should I expect a response (ever)?

I provided you with several videos and pictures demonstrating industry practice among many of our competitors (from across the country). I would like to present to you one of many others I have found; the following video was created with the use of a GoPro helmet camera on a sampling/staking job in the Yukon. In my mind the footage is very high quality. The operator involved is Trans North Helicopters and the pilot was nice enough to display his name on the back of his helmet.

http://youtu.be/ctxj2CPYRg8

 

Seldom do we see a video that truly demonstrates the reality of what a typical day at work for most Commercial VFR helicopter pilots would be. This video could be typical day at the office for most helicopter pilots in Canada, particularly at Expedition Helicopters Inc. I invite you to review the video at length and consider the wide variety of hazards and challenges the pilot encounters throughout his day. Once again, it is nothing like the challenges a fixed pilot would encounter.

When I review the video, I see a very proficient pilot performing a necessary duty in the safest possible fashion. I also see passengers who are very well briefed and working side by side with the pilot (almost as crew) to ensure safe operations…this is also something that never occurs in the fixed wing world. I hope you can look past the packsacks and samples in the cabin. It would be very difficult to conduct the required hover exits in a safe fashion without allowing some items in the cabin.

The other most important thing to consider is something you can’t see in the video…the pressure the pilot is under (from the client who he rubs elbows with and shares accommodations with) to perform well and efficiently. If they cannot perform the hover exit and drop his gear from the cabin, the only option could be a walk of several Kilometers (through unforgiving terrain) to reach the required area…or worse the pilot would be pressured to conduct landings in less than suitable landing areas. Of course, he could also have them try to access their gear from the Cargo compartment while hovering…this too increases the overall risk. The pressure is further magnified during the winter, when temperatures could mean the death of a client if they are not retrieved before sun down…often this also requires a hover entry to the aircraft at low light (due to shortened daylight hours).

I also find it ironic that these gentlemen are conducting operations under an exemption that allows hover exit which was written by you, Yves Lemieux, in 1996.

 

In my mind, these risks that I am discussing (above) are the real safety issues we should be discussing if we really wish to reduce the number of accidents in our industry…not purses on passengers laps.

  1. Can someone please tell me what causes most accidents in our industry?
  2. Also, when was the last time an accident was caused by carry-on baggage in the cabin of a helicopter in Canada?
  3. When was the last time a passenger was injured by carry-on baggage in a helicopter in Canada?

Why do we spend so much time dealing with insignificant issues? Believe me this ramp check and findings from November 2012 have been extremely time consuming for our organization and frankly we feel our time could have been much better spent dealing with the important safety issues that cause accidents; the end result is an overall decrease in safety.

 

Regards,

 

Chad Calaiezzi

Operations Manager

.

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