Balloon  Safaris

Pilot Seeks Clarification

from UK Civil Aviation Authority;

Awkward questions must be answered

To UK CAA 

To whom it may concern. 

I'd like to enquire about commercial hot air balloon certification, at the same time bring your attention to aircraft modifications.

Please tell me if it is compulsory for passenger balloons to be equipped with what is normally referred to as a Rapid Deflation System. Camerons refer to this simply as RDS. Is there a particular size of balloon where it becomes compulsory to installthis saftey device as opposed to the standard parachute valve. If it is compulsory can you please tell me what date it became so.

How does the UK CAA respond when receiving reports of a UK manufacturer producing aircraft components yet ignoring the certified design process? I am referring to purposely not including fuel pressure gauges on burners. Would I be right in thinking that if such equipment were supplied away from certified design drawings, this would render C of A null and void? 

Given my experience as a commercial pilot and former safety officer, there is much to learn from the following publication,  which I provided you with the necessary link below.

https://www.silencingprofessionalpilots.com/chapters-sbs/sbs-escapes--reach-of-us-law

I'm looking forward to hearing back from you.

Yours sincerely

Ben Roberts

Dear Mr Roberts,

With regard to your questions

The Certification Specification in the UK for manned free hot air balloons, CS-31HB is here: https://regulatorylibrary.caa.co.uk/2018-395/Content/Ballons%20Chapter%202%20HB/CS%2031HB%20AMENDMENT%201.htm This includes the design requirements for envelopes and burners

Reports to the CAA are through the Mandatory Occurrence Reporting system: https://www.caa.co.uk/our-work/make-a-report-or-complaint/report-something/mor/occurrence-reporting/

A C of A is only valid if the aircraft continues to comply with the applicable type design and continued airworthiness requirements [Part 21.A.181].

Please do not hesitate to contact us if you require any further information.

UK CAA. END

Referring to Cameron burners, I am very confident that no applicable type designs are attached to burners that are manufactured without pressure gauges.

I am most grateful to the UK CAA for this clarification. From personal experience, and supported by   SBS pilots (as in Independent expert witness report B)  five balloons operated in the Serengeti continued passenger flight operations with failed certificates of airworthiness (C of A), including the one involved in the fatal accident of 2010.

Could Manufacturer and operator  defended ?

It would be very interesting to see how the manufacturer or operator would propose defending this analysis. ****I have spoken to the manufacturer in the past. Whilst initially agreeing  that the production of aircraft components  as described would normally invalidate any C of A; With Cameron balloons rep instantly diving into panic mode,  the notion was put forward that given that the aircraft was being exported to a Third World country, they didn't necessarily have to comply with such regulations.

Having said that, I believe this is not normal Cameron’s company policy. A highly probable reason for caving into purchasers’ demand might be to secure continued purchases of aircraft from the operator and assist the operator's desire to camouflage fuel pressure anomalies.

**** I hold unchallengeable evidence of that conversation.

Should either operator or manufacture, their representatives; wish to discuss this matter with me in private they can be assured that my door is always open. pilotsafetyofficer@icloud.com  this is on condition that they  keep it polite and nonthreatening,

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