Bulgaria acquired its first medical helicopter after numerous administrative vicissitudes in February this year – but our air ambulance is not on missions yet and according to critics of the Ministry of Transport, and of its incumbent in both the regular and official offices, Georgi Gvozdeikov, this will not change soon.
At the same time, the Bulgarian General Directorate of Civil Aviation issued a license to the company HEMS Bulgaria in March, and according to the Ministry of Transport, the training of the first helicopter pilots will be completed in the coming days.
In front of Club Z, first the aviation specialist capt. Todor Penev reported irregularities with the helicopter, stating that the license was illegal and the procedures for issuing it were not followed. Days later, Penev was dismissed from his post at Plovdiv Airport, under the care of the Ministry of Transport, but Gvozdeikov denied having issued the order.
Today, another aviation engineer and pilot – former director of DG “GVA” Zahari Alexiev – voiced the same criticisms in article in the online publication “Banker”. And he emphasizes that if such irregularities are found by the European agency EASA, this could have serious consequences for the entire Bulgarian aviation.
According to Club Z, a report about the alleged irregularities was sent by an MP from the former ruling coalition to President Rumen Radev.
Club Z examined in detail the conditions for licensing a new air operator and sent a series of questions to the Ministry of Transport. The ministry answered them in detail and sent the license itself to HEMS Bulgaria, which actually clearly states that the company is licensed to carry out passenger and cargo flights and medical missions.
Here are the responses of the Ministry of Transport:
According to the list of aviation operators on the website, DG “GVA” HEMS Bulgaria has a license for aviation operator BG 71 only for the carriage of passengers. It was announced on 18 March that an air ambulance license was available. What is the approved license and can it be sent to us and posted publicly?
With Aviation Operator’s Certificate (AOC) No. BG 71 (Form 138 EASA), issued by DG GVA on 13.03.2024, “Bulgaria Heli Med Service” EAD was granted rights to carry out commercial air operations according to the requirements of Regulation (EC) 2018/1139. Part of each CAO are the so-called Operations Specifications (EASA Form 139) specifying additional details of license conditions – aircraft details, types of operations, specific rights, limitations and approvals. In the Specifications of operations to CAO No. BG 71 in “Types of operations” the category “Passengers” is indicated with a tick in “Others” – HEMS. In the list of special approvals, “Emergency medical insurance flights by helicopter” is noted.
On March 18, the page of the Ministry of Transport and Communications announced that the “first training flight” with the new HEMS Bulgaria helicopter had taken place. On his personal page, Minister Georgi Gvozdeikov announces that a “DEMO flight” has taken place. Which of the two was done and did a HEMS Bulgaria pilot fly the helicopter during the flight?
On March 18, two flights were completed, which marked the start of the flight part of the operator conversion training and checking program approved in Part D of the operating manual. This operator course is carried out in accordance with the requirements set out in ORO.FC.220 of REGULATION (EU) No 965/2012. Within these flight sectors, the first demonstration flight (Demonstration flight) was performed in front of representatives of DG GVA, demonstrating the possibilities of operation with flight characteristics class 1 in the conditions of a densely populated hostile environment. The flight was carried out to a hospital heliport registered by DG GVA in St. Ekaterina UMBAL and according to the procedures approved in Part C of the operator, which are in accordance with Regulation (EU) No. 965/2012 (CAT.POL.H .205, AMC1 CAT.POL.H.205(e), CAT.POL.H.210, CAT.POL.H.220 and AMC1 CAT.OP.MPA.105). The flights were performed by a crew consisting of an operator pilot and a TRI (H) instructor on the manufacturer’s A109 S Trekker helicopter type. The pilot has a valid airworthiness certificate issued by the DG GVA with an entered qualification for type A109 S Trekker. He is the flight director of “Bulgaria Heli Med Service” EAD.
According to EASA requirements, AMC1 ARO.GEN.310(a), (a) 3, in order for an air operator to obtain a licence, one or more demonstration flights conducted as actual flights must be completed. Such a flight constitutes the final examination of a helicopter pilot. Did such a flight take place on March 18?
The demonstration flight is part of the air operator certification procedure, not a final pilot exam. According to the requirements for initial certification (below is the original text of the requirement in English) this flight or series of flights can be carried out at the final stage of the licensing process or at the earliest opportunity after the issuance of the CAO. The purpose of this flight is for the aircraft operator to demonstrate how to perform the procedures described in the operator’s operations manual.
ED Decision 2017/006/R
VERIFICATION OF COMPLIANCE
(a) Upon receipt of an application for an air operator certificate (AOC), the competent authority should:
…….
(3) for the purpose of verifying the organization’s compliance with the applicable requirements, conduct an audit at the organization’s facilities. The competent authority should require the conduct of one or more demonstration flights operated as if they were commercial flights, or an in-flight inspection should be conducted at the earliest opportunity.
Editorial translation:
Decision of the European Aviation Safety Agency (EASA) 2017/006/Р
COMPLIANCE CHECK
(a) Upon receipt of an application for the issue of an air operator certificate (AOC), the competent authority shall:
…….
(3) in order to verify the organization’s compliance with the applicable requirements, to audit the organization’s facilities. The competent authority should require that one or more demonstration flights be conducted as commercial flights or an on-board inspection should be carried out as soon as possible.
Does HEMS Bulgaria have a helicopter pilot who completed his full training on March 18 and demonstrated this with a demonstration flight? Was there an instructor in person who inspected this flight?
The demonstration flight is not related to flight crew licensing. The first six pilots have successfully completed a type rating course at an approved training organization as required by PART-FCL. All of them have passed a skill test and have the type entered in their licenses as early as the end of 2023.
The flight on March 18 was performed by a crew consisting of an operator pilot and a TRI (H) instructor on a Leonardo A109 S Trekker helicopter. The pilot has a valid airworthiness certificate issued by DG GVA with an entered qualification for type A109 S Trekker.
On April 9, on bTV, Minister Gvozdeikov announced that four pilots are expected to be tested on April 24. Does this mean that until this date there is not a single pilot of HEMS Bulgaria who is licensed to fly the helicopter?
The first six pilots have successfully completed a type rating course at an approved training organization as required by PART-FCL. All of them have passed the skill test and have the type entered on their certificates of competency as early as the end of 2023. At the end of April, the pilots are expected to complete the approved Part D of the operations manual ) program for retraining and checking by the operator (Conversion training and checking), which includes an operator qualification check (OPC) and a check in flight conditions, which will be performed by a TRE (H) examiner for the type.
If there is no such pilot on April 9, how does HEMS Bulgaria get a license more than 20 days earlier, given the requirements of EASA?
As of 03/13/2024, when the SAO of “Bulgaria Heli Med Service” EAD was issued, the operator has six licensed pilots. In order to be allowed to perform actual HEMS operations, they must complete and complete in full the above-described Part D program.
After the completion of the conversion training and checking program approved in Part D of the operation manual (Part D) and after the training flights with the medical teams, a second demonstration flight will be performed in front of representatives of DG GVA, with crew entirely from Bulgaria Heli Med Service and medical personnel on board. Prior to the operation of this flight, the operator has not operated and will not operate commercial air transport (HEMS).
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From the answers of the Ministry of Transport, it follows that everything is fine with the license of HEMS Bulgaria, and the pilots will complete the full training program by the end of April.
The license of HEMS Bulgaria:
Tags: HEMS Bulgaria medical helicopter
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