RVSM Authorization: Requirements, Best Practices,...

RVSM Authorization:

Requirements,

Best Practices, and

Industry Update

NBAA On Demand Education | March 6, 2012

Presenters

• Mark Larsen, NBAA

• David Norton, Shackelford, Melton & McKinley, LLP

• Madison Walton, FAA AFS-470

• Charlie Fellows, FAA AFS-360

• Bill Driscoll, FAA AFS-820

• Lucille Fisher, Quality Resources, LLC

2

NBAA Certified Aviation Manager

• Must reply to all polling questions

3

Recertification Credit

David Norton

• High Level Overview of RVSM Requirements

• Overview of Several Key Issues and NBAA Response

• Key “Predicate” Issues

NBAA Domestic Operations Committee

Shackelford, Melton & McKinley, LLP

4

High Level Overview of RVSM

Requirements

• Background – Will Be Discussed in Detail by FAA

• Part 91 – Receipt of Letter of Authorization

• Part 135 – Authorization through OpSpecs

5

Overview of Several Key Issues and

NBAA Response

• Issue: Lack of Clarity on Who Obtains Authorization

• Issue: Timing and Requirements for Authorizations

• NBAA: Multiple Meetings with FAA – Advancements Have Been

Made!

6

Which of the following best describes

the operation of your aircraft?

• It is exclusively operated by one Part 91 operator

• It is operated by more than one Part 91 operator

• It is operated by one or more Part 91 operators and a Part 135

operator

• It is exclusively operated by a Part 135 operator

• It is exclusively operated by a Part 125 operator

• I/we don’t operate aircraft

7

Key “Predicate” Issues

• Who is the Operator?

• Who gets the Authorization?

• What about Multiple Operators?

8

Do you/does your operation use a flight

plan filing service?

• Yes, we use a flight plan service provider to do all of our flight

plan filing

• Yes, we use a flight plan service provider to file all of our

international trips, but we file domestic trips in-house

• Yes, we use a flight plan service provider for some trips, but file

others in-house

• No, we do all of our flight plan filing in-house

• I/we do not operate aircraft

9

NBAA RVSM Webinar

By: Madison Walton

FAA Performance Based Flight Systems

Branch - AFS-470

Date: 03/06/2012

Federal Aviation Administration

RVSM Letters of

Authorization

11 Federal Aviation Administration

NBAA RVSM Webinar

3/6/2012

What is fundamentally different about

FL290 & above? • Reduction in pressure-sensing accuracy of

barometric altimeters with increase in altitude

• 2000’ (600m) above FL290 became ICAO global vertical separation minimum in 1966

• FL 290 chosen empirically because few A/C flew higher – Douglas DC-7 service ceiling 25,000’

– Lockheed Constellation service ceiling 25,300’

– Martin 404 service ceiling 29,000’

– Boeing 307 Stratoliner 26,200’


NBAA RVSM Webinar

3/6/2012

Why are RVSM LOA’s Necessary

• Systematic approach to ensure the airplane is operated & maintained within prescribed safety limits for RVSM airspace

• Critical to the continued safety of RVSM operation that airplane altitude-keeping performance and Altimetry System Error (ASE) be maintained within RVSM standards – Maintenance program vs. inspection program

• ICAO Standard provides for safe operations world-wide – Annex 6 (Operation of Aircraft), Part 2 (International General Aviation

Operators) “…an aeroplane shall be authorized by the State of Registry…”

• FAA operator and aircraft authorization for RVSM – 14 CFR Part 91 sections 91.180 (domestic U.S.),

– Part 91.706 (operation outside the U.S.) and

– Part 91 Appendix G (Operations in RVSM Airspace)


NBAA RVSM Webinar

3/6/2012

LOA Requirements

• RVSM LOA requirements are explained in FAA AC

91-85, in general;

– Documents indicating that the aircraft is RVSM compliant

– A configuration list of all components and equipment related to

RVSM operations

– Operations manuals, checklists and documents that show

knowledge of RVSM policies, practices and training

– An operating history, if applicable

– A RVSM maintenance program for approval

– Operators that operate under an MEL, submit an MEL adopted

from the MMEL

– A plan for participating in an RVSM monitoring program


NBAA RVSM Webinar

3/6/2012

Operations Manuals and Training

• Operators should demonstrate they are familiar

with RVSM practices and procedures

– AC 91-85 Appendix 4 for Operational Procedures

– Include contingency and procedures unique to RVSM in area

of operations, e.g. China, Russia, etc.

– Submit operations manual and checklist for FAA review and

acceptance

• 14 CFR Part 91 vs. 14 CFR Part 135

– Part 91 operators submit 14 CFR 142 training certificates

without further evaluation, or other certificates which may be

reviewed

– Part 135 Operators (and others) submit training syllabi and

other appropriate materials for approval


NBAA RVSM Webinar

3/6/2012

RVSM Monitoring Programs

• Individual RVSM monitoring program provides

“quality assurance” of altitude-keeping

performance

• Airplanes have been identified with non-compliant

altitude keeping; operator action required to bring

airplane back into compliance with RVSM criteria

• ASE Studies indicate that long term monitoring is

warranted


NBAA RVSM Webinar

3/6/2012

RVSM Monitoring Programs

• On 18 May 2011 the FAA implemented the following

RVSM monitoring policy:

• “Operators that have been issued an U.S. RVSM authorization will

be required to conduct initial monitoring within six months of date

of issue and must conduct monitoring every two years or within

intervals of 1,000 flight hours per aircraft, whichever period is

longer, in accordance with the aircraft categories as presented in

the current version of the (North American) RVSM Minimum

Monitoring Requirements chart.”

• ICAO Annex 6 (Operation of Aircraft), Part 2

(International General Aviation Operators)

• Operators have until November 2012 to comply


NBAA RVSM Webinar

3/6/2012

RVSM vs. nonRVSM authorized

• Aeronautical Information Manual - Sections 4-6-n

• Equipment suffixes alert ATC which separation minimum to apply to maintain safety (AIM 4-6-4)

• Pilot/Controller Phraseology (AIM 4-6-8)

• Access to RVSM airspace (AIM 4-6-10)

• nonRVSM airplanes Climb/Descend through RVSM without level off (AIM 4-6-11)


NBAA RVSM Webinar

3/6/2012

InFO 12001 - Flight Planning Responsibilities When

Conducting Reduced Vertical Separation Minimum

(RVSM) Operations


NBAA RVSM Webinar

3/6/2012

Background

• FAA RVSM Documentation Webpage

– Single source for RVSM information

– Latest guidance

– RVSM LOA job aid available

As an operator, do you provide a copy of

your RVSM program to third-party

maintenance providers working on your

aircraft for inspections or other work?

• Yes, we provide a copy of the program to them

• No, our RVSM maintenance program only references the

manufacturer’s program, and we only use OEM service centers

• No, we don’t provide that information to third-party providers


20

NBAA RVSM Webinar

By: Charles Fellows

Flight Standards Service – Avionics

Branch - AFS-360

Date: 03/06/2012


Continued

Airworthiness

RVSM Program


NBAA RVSM Webinar

3/6/2012

Significance of Continued Airworthiness

• 1988 Report, ICAO Review of General Concept of Separation Panel (RGCSP) Concluded safe implementation of 1000-foot separation standard technically feasible

• Major elements for safe implementation include design, operational, and continued airworthiness consideration.

• A requirement for operator authorization is an approved RVSM maintenance program.


NBAA RVSM Webinar

3/6/2012

RVSM Maintenance Program

• Fundamental Purpose

– Control of Altimetry System Error (ASE)

– Difference between pressure altitude displayed to

flight crew and the actual pressure altitude of aircraft

– Must be maintained less than 245 feet

– Failure to adhere to required RVSM maintenance

practices and procedure can lead to altimetry

system errors (ASE) greater than 245 feet


NBAA RVSM Webinar

3/6/2012

Altimetry System Error (ASE)


NBAA RVSM Webinar

3/6/2012

Altimetry System Error (ASE)

ASE= TVE – ADD Total Vertical Error (TVE)

Assigned Altitude Deviation (ADD)


NBAA RVSM Webinar

3/6/2012

Approved Maintenance Program

FAA Order 8900.1 Volume 4 Chapter 10, Paragraphs 4-135 D1 through D10


NBAA RVSM Webinar

3/6/2012

Inspector Evaluation

• Properly written MP will include at a minimum all of the 15 elements.

• Inspector should evaluate each element on its own merits.

• Certain elements that have a low SOQ may not need much of a supporting explanation and their presentation form could be that of present and accounted for.

• Other elements from Table 1, notably 4, 6, 7, 8 and 9 most certainly need more of a supporting explanation.

• Specifically there needs to be a method or a procedure listed, which has a starting and ending point with logical steps in between, and the text of the method must meet the highest SOQ of ensuring, (make certain) which is almost a guarantee


NBAA RVSM Webinar

3/6/2012

Additional Concern

• Policy Statements communicate the company’s official position on an array of subjects and sets standards and may give instructions on how the company wants to handle certain situations.

• Some manuals incorrectly use headings that include the words procedure or method but continue with a list of policy statements.

• The words procedure and method have nearly the same definition and are a listing of progressive steps that will achieve a specific goal when performed correctly. Procedures can be followed by any qualified person and be reliably-repeated and successfully-completed. The characteristics of a procedure include a logical progression of steps that have a starting and ending point. Procedures may include standards of quality and the measurement of limitations. Procedures supply the reader with some combination of relevant details such as the Who, What, Where When, Why and How as appropriate.


NBAA RVSM Webinar

3/6/2012

Additional Concern

• Operators without an approved aircraft maintenance program are

required to develop and obtain approval of an RVSM maintenance

program.

• The approved RVSM maintenance program is not required to

include elements not related to RVSM maintenance.

• Inspection programs such as Approved Aircraft Inspection

Program (AAIP) or manufactures recommended inspection

program do not satisfy RVSM requirements because they do not

contain procedures to maintain RVSM aircraft.


NBAA RVSM Webinar

3/6/2012

Maintenance Program Development

• Don’t measure the value of this requirement by how much or how

little work it required for you

• Measure the value in the assurance you have that the aircraft

flying towards you is maintained and at the correct altitude

During your most recent RVSM approval,

what authorization area proved most

difficult to satisfy?

• Operational Procedures

• Training

• Maintenance Procedures

• Other


31

NBAA RVSM Webinar

By: William (Bill) Driscoll

Commercial Operations Branch

AFS-820

Date: 03/06/2012


RVSM Letters of

Authorization


NBAA RVSM Webinar

3/6/2012

Guidance for RVSM authorizations is contained on

the FAA RVSM Documentation website at:

http://www.faa.gov/about/office_org/headquarters_offic

es/ato/service_units/enroute/rvsm/documentation/

http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/enroute/rvsm/documentation/









NBAA RVSM Webinar

3/6/2012

QUESTION: When should an operator begin the process for

approval, and how can operators aid inspectors in the

process?

• Per AC 91-85; Each individual operator should plan to present these programs to the FAA at least 60 days before commencing the proposed operation.

• Per FAA Order 8900.1 Vol.4, Ch.1, Sect.5: AC 91-85 provides guidance on the inspector’s determination that aircraft are RVSM compliant.

• For most in-service aircraft, the RVSM airworthiness documents take the form of SBs, SLs, or STCs. For aircraft manufactured RVSM compliant, the AFM or TCDS must contain statements that show the aircraft to be eligible for RVSM operations.

• Inspectors and operators are encouraged to use JOB AID: PART 91 OPERATOR APPLICATION TO CONDUCT RVSM OPERATIONS. The Job Aid is formatted to allow the operator to indicate inclusion of each section, and where the reviewing inspector can find each item in the operator’s document.


NBAA RVSM Webinar

3/6/2012

QUESTION: What is required if the operator changes base of

operations to a different FSDO Region?

Per the Letter of Authorization (LOA) paragraph A001-1:

1. These documents are issued to _____ , whose principal base of operation is located at:

Primary Business Address:

2. A change in the aircraft base of operations location constitutes an administrative change only to this Letter of Authorization (LOA) A001 and would not require nor preclude a new inspection.

a. The existing authorizations, deviations, waivers, etc., are still valid and not intended to be reissued due to a change in the operator’s base of operations.

b. If the operator relocates its principal base of operations (address) listed in subparagraph 1 above, it must notify, in writing, the losing Flight Standards District Office (FSDO) of its new location and mailing address within 30 calendar days following relocation and, advise the losing FSDO of the receiving FSDO where the operator proposes to do business.


NBAA RVSM Webinar

3/6/2012

QUESTION: What is required for changes of aircraft

ownership?

Per LOA paragraph A001-1: 3. The attached waivers, authorizations, and/or deviations are effective as of the

“Date Approval is Effective” listed in each authorizing document, and those issued without an expiration date shall remain in effect as long as the party listed in subparagraph 1 above continues to meet all appropriate Parts of the CFR or until any of the following:

a. It is voluntarily surrendered by the operator, b. The operator ceases to be the operator of the aircraft listed in the

applicable authorization, c. It is surrendered or revoked for cause by the FAA, d. The person signing the authorizing document relinquishes responsibility, e. The aircraft changes ownership and should be removed from the

authorizing document,


NBAA RVSM Webinar

3/6/2012

QUESTION (continued)

f. An aircraft or listed equipment is no longer used for that operation and should be removed from the authorization,

g. An aircraft or other equipment needs to be added to the existing authorizing document,

h. An aircraft listed on the authorization changes nationality numbers,

i. An aircraft listed on the authorization is issued an experimental, special airworthiness certificate for research and development (R&D) or changes projects associated with an experimental, special airworthiness certificate for the purpose of R&D.

4. If the Responsible Person as the signee changes for an authorization, the Responsible Person or the operator should notify the issuing office of the change within 30 days and request an updated LOA.

A001 - 1


NBAA RVSM Webinar

3/6/2012

QUESTION: How should operator work through the FAA

Consistency and Standardization Initiative (CSI) to

resolve disagreements?

• Contact the Flight Standards office that

made the decision you’d like to question or

dispute, and notify them you’d like to

initiate the CSI process.

• FAA.GOV CSI link:

http://www.faa.gov/about/office_org/headquarters_

offices/avs/consistency_standardization

• CSI Brochure link:

http://www.faa.gov/about/office_org/headquarters_offices/avs/

consistency_standardization/media/csi_brochure.pdf

http://www.faa.gov/about/office_org/headquarters_offices/avs/consistency_standardization

http://www.faa.gov/about/office_org/headquarters_offices/avs/consistency_standardization

http://www.faa.gov/about/office_org/headquarters_offices/avs/consistency_standardization/media/csi_brochure.pdf

http://www.faa.gov/about/office_org/headquarters_offices/avs/consistency_standardization/media/csi_brochure.pdf

How long did your most recent RVSM

authorization application take to get

approved?

• Less than 1 week

• 1 week to 2 weeks

• 3 weeks to 4 weeks




• 13 or more weeks


39

Lucille Fisher

• RVSM Approval Process Events

• Content of Application

• Submit Timely

• Do Your Homework

NBAA Domestic Operations Committee

Quality Resources, LLC

40

RVSM Approval Process Events

• Pre-Application Meeting: Operator contacts the responsible

Flight Standards District Office (FSDO) or Certificate

Management Office (CMO)

• 60 days in advance submit application

41

Content of Application

1. Airworthiness Documents.

2. Description of Aircraft Equipment.

3. Operations Training Programs and Operating Practices and procedures.

4. Operations Manuals and Checklists.

5. Past Performance.

6. Minimum Equipment List (only if operating under an MEL).

7. Maintenance Program.

8. Plan for participation in Monitoring Programs.

9. Plan for reporting altitude-keeping errors.

42

Submit Timely

• Submit a letter detailing what you are requesting; airspace and

equipment relevant

• Do not appear at the FSDO without an appointment

• Get the letter stamped if you drop it off (take an extra copy to

have the stamp)

• Make sure you provide accurate contact information

43

Do your Homework

• Do not simply resubmit something that worked before

• Make sure your information is accurate, part numbers, etc.

• Maintenance programs are approved, not accepted

• Complete the job aid to make sure you meet the requirements,

KNOW YOUR MATERIAL.

44

Additional RVSM Resources

45

Downloads included in today’s webinar:

• Presentation Slide Deck (as a PDF file)

• FAA Advisory Circular 91-85

• FAA Information for Operators (InFO) 12001 Flight Planning

Responsibilities When Conducting Reduced Vertical Separation

Minimum (RVSM) Operations

FAA RVSM Web Site:

http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/

enroute/rvsm/

NBAA RVSM Web Pages:

http://www.nbaa.org/member/ops/cns/rvsm/

/

http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/enroute/rvsm/

http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/enroute/rvsm/

http://www.nbaa.org/member/ops/cns/rvsm/

Questions and Answers

46

Webinar Critique

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RVSM Authorization: Requirements, Best Practices,...

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