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Changes to the Aircrew Regulation concerning helicopters

The Aircrew Regulation (EU) No 1178/2011 has been amended, introducing changes for helicopter pilots, operators and instructors. The new provisions entered into effect on 30 October 2022. We have summarised the key changes in this article.

The new definitions make it possible to use helicopters certified for single-pilot operation for multi-pilot operation with lighter training and licence requirements. It is hoped that the changes will provide flight operations with the safety benefits of flying with a co-pilot and also increase flexibility.

The simplification of licence entries puts a greater emphasis on the obligations of pilots and flight operators to make sure that the privileges that pilots need for planned flight operations are valid.

For more detailed information on the changes, please see Commission Implementing Regulation 2021/2227 on the EUR-Lex service (External link), for example.

Definitions of multi-pilot operation and multi-pilot helicopter

The Regulation’s definitions of multi-pilot operation and multi-pilot aircraft have been updated. A helicopter is defined as a multi-pilot helicopter if it is certificated for operation with a minimum crew of at least two pilots or if it is required to be operated with at least two pilots in accordance with the Air Operations Regulation (EU) No 965/2012. These types of helicopters are used for so-called mandatory multi-pilot (MP) operations, and their pilots must have multi-pilot type ratings. In addition to this, the pilot in command (PIC) must have an airline transport pilot licence for helicopters (ATPL(H)).

A helicopter that is certified for single-pilot (SP) operation and is not required to be operated with at least two pilots by the Air Operations Regulation (EU) No 965/2012 can still be used by a flight operator for so-called voluntary MP operations. In voluntary MP operations, the PIC only needs to have a commercial pilot licence for helicopters (CPL(H)), but the requirements of point FCL.725(d)(4)(ii) of the Aircrew Regulation must also be taken into account:

  • The pilot must have completed an MCC course or posses prior experience in MCC (see credit in the part of the Regulation below).
  • The privileges can only be used for operations in accordance with Part-ORO.
  • The skill test or proficiency check has been carried out using multi-pilot methods (see Part-FCL Appendix 9).

As a result of the concept of multi-pilot operation changing, the requirements of an ATPL(H) have also been changed so that the applicant for an ATPL(H) is no longer required to have flying experience in multi-pilot helicopters, as having experience in multi-pilot operations (including those carried out in an SP helicopter) is enough. However, the skill test for an ATPL(H) must still be carried out in a multi-pilot helicopter.

Helicopter pilot instrument time under instruction and instrument rating

The requirements for an instrument rating for helicopters (IR(H)) have been updated to better apply to new types of helicopters. As a result, IR(H) training now covers instrument flight in both single-engine and multi-engine helicopters. Because of this, the previous requirement for additional training when extending single-engine helicopter privileges to multi-engine helicopter privileges has been removed. If you want to extend an instrument rating to a new type, type-specific additional IR training is still required, however.

Applicants who before 30 October 2022 commenced training for an IR(H) are allowed to complete that training and, in such a case, be issued with an IR(H) for both single-engine and multi-engine helicopters. Pilot training organisations that provide training for the IR(H) must adapt their training programme to be compliant with the new provisions by 30 October 2023. New courses must be compliant with the provisions that have entered into effect.

According to a transitional provision, instrument ratings for helicopters (IR(H)) issued before 30 October 2022 shall be deemed as IR(H) for both single-engine and multi-engine helicopters and shall be reissued as such when reissuing a helicopter pilot licence for administrative reasons.

Type rating entries on licences

MP entry

  • When a pilot flies a helicopter that is certificated for operation with a minimum crew of at least two pilots or that is required to be operated with at least two pilots in accordance with the Air Operations Regulation (EU) No 965/2012, this is considered mandatory multi-pilot (MP) operation and the pilot’s type rating must be accompanied by the entry MP.

MP only entry

  • When a pilot flies a non-complex single-pilot helicopter and has flown a proficiency check with MP methods only, the pilot’s type rating must be accompanied by the entry MP only.

If a pilot has both SP and voluntary MP privileges or only SP privileges, their type rating will not be accompanied by an SP or MP entry. In other words, the SP entry is no longer used on licences for helicopters.

Determination of pilot privileges

The flight privileges of pilots are determined based on what methods (SP, MP or both) they used to complete their skill test or proficiency check. These privileges are not always displayed on licences, which is why it is important for both pilots and flight operators to make sure that the privileges that pilots need for planned flight operations are valid.

Instructions for examiners

Finnish Transport and Communications Agency Traficom requires a licence to be reissued if the front page of the licence includes a type rating entry according to the old method (SP or MP entry visible) that differs from the new entry method. Examiners must instruct licence holders to apply for the reissue of their licences by submitting the relevant application form to Traficom. The reissue of a licence just for the type rating change is free of charge.

Examiners can issue temporary tempo privileges at the end of proficiency checks so that flight operations do not need to be suspended for the reissue.

Examples of new type rating entries

Example 1: mandatory MP operations

  • If the proficiency check is carried out using MP methods only in a situation where the Air Operations Regulation always requires two pilots (mandatory MP operation), the entry can be e.g. 'Bell 212/412 MP’ (depending on the type).
    • If the applicant also flies other than mandatory MP operations using SP methods and is issued SP flight privileges, these privileges are entered on separate rows 'Bell 212/412'.
    • The periods of validity of SP and MP privileges are determined based on each completed proficiency check.

Example 2: voluntary MP operations (with SP non-complex helicopter types)

  • If the proficiency check is completed with MP methods only in a situation where the operator wants to carry out MP operations, but the Air Operations Regulation does not require two pilots (voluntary MP operation), the entry can be e.g. 'EC135/635 MP only’ (depending on the type).
  • If the proficiency check is completed with both SP and MP methods, the entry is 'EC135/635'.

Voluntary MP operation privileges are no longer entered on licences if SP privileges are valid at the same time. It is important for both pilots and flight operators to take this change into account to make sure that the privileges that pilots need for planned flight operations are valid. Statements on voluntary MP proficiency checks must also be submitted to Traficom. The proficiency check statement must clearly state the entries made to the licence and their periods of validity.