International notes from February 2014 OSWG
(Joint and international sessions)
Joint session (Part 129) OSWG
Convene. Opening remarks/welcome by industry Chairs and self-introductions by attendees to include: Aeroflot Airlines, Antonov Airlines, Airbridge Cargo Airlines, Air Canada, Emirates Arab States, Copa Airlines, Volga Dnepr Airlines, Biman Bangladesh Airlines, TAM, Insel Air International, Aeroflot Russian Airlines, Virgin Atlantic Airways Ltd., A4A, IATA, NBAA, Delta, United, FedEx, American, Southwest, Atlas, Spirit, Alaska, Executive Jet, Wicks Group, Eckert Seamans Cherin & Mellott, LLC, consultants/agents for service for numerous foreign carriers, AFS-50, AFS-200, AFS-400, NY IFU, ANC IFO, MIA IFO.
Stakeholder Survey and Future Meetings.
Due to bad weather no survey was handed out.
International (Part 129) – next annual joint and international session to be held in March of 2015.
U.S. Domestic (Part 121 and 135) –will hold 3 meetings per year, one of which will include a joint session with International (Part 129). Next domestic session expected around August/October time frame.
FAA Lead : Monica Grusche – AFS-260
Background from 2012 OSWG: no major changes, existing budget only allows day to day operational maintenance of the system, waiting on new budget to see if it is sufficient to allow the addition of new features.
ICAO Register of AOCs –
FAA Lead: Danuta Pronczuk (AFS-52) for Part 129,
Industry Lead : Henry Defalque, International Civil Aviation Organization, ICAO
Background from 2012 OSWG : Progress Recent Developments: International Register of AOCs. (Yuri Fattah, International Civil Aviation Organization, ICAO updated the group on the full OASIS project). Presentation available on http://fsims.faa.gov/PICResults.aspx?mode=Publication&doctype=OSWG
Refer to OSWG 2011-04 Meeting Notes for further background discussion
The system is operational. Press release scheduled for October 20, 2012. As of October 19th 2012 AOC data base is empty. Canada, UAE, Singapore started entering data. ICAO is looking to see if they can relax the ICAO standard that requires that a certificated copy of the AOC be carried on board be relaxed for those operators whose information is in the ICAO data base. Yuri confirmed that only States could upload the information to the database. US domestic industry asked if this could be expanded to operators uploading information as some States have differences – a State of the operator may not require the information/or a document that another State is requiring off the operator in order for them to operate in their State. Yuri noted the comment; at this time, this feature is not available.
2013 Notes: Progress Recent Developments: International Register of AOCs. (Yuri Fattah, International Civil Aviation Organization, ICAO updated the group on the full OASIS project). ICAO registry of AOC has data from UAE, Iceland, Brazil, Singapore and is inviting all States to participate. States may allow an air carrier to whom they issue the AOC and associated OpSpecs to upload the information to the ICAO registry. States may also allow the operator to have restricted view of its own information. Validation of the data would need to be done by the State which issued the AOC. ICAO invited feedback on what is keeping regulators from putting the information into the data base, alternatives, system improvements, reviewed the advantages of a single data base. Yuri noted that when an operator wishes to operate to a foreign State it is the operator that needs to provide the necessary information to the foreign State, the information exchange is between an operator and a foreign State and not between two foreign States. ICAO is looking at making a recommendation for mutual recognition of AOCs, similar to the mutual recognition of pilot certificates in the Articles to the ICAO convention. FAA noted: that a decision at a higher level than a policy office within AFS would need to be made before an upload of any U.S. AOC data was attempted, this is not a simple tasking, would require significant funding and there are competing priorities. AFS-50 is looking at how it can provide relief to foreign air carriers/use the data from the registry, continues its review, meet with ICAO and subject matter experts to discuss.
EASA Third Country Operators – Edmund Bohland, EASA 2913 update.
FAA Lead: John Masters, Danuta Pronczuk
Industry Leads: Brian Miles Part 129 Chairman/Emirates Airlines.
Background: In 2012, Arthur Beckland (EASA rulemaking directorate) provided a Status Report on EASA intention to implement an assessment requirement for all Third Country Operators performing commercial air transport operations (for example: United, FedEx, UPS, Emirates, China Southern Airlines, ANA, Quantas, (Non-European Union member commercial air transport carriers.) Following are a few highlights from Arthur’s briefing:
Arthur’s presentation is available on http://fsims.faa.gov/PICResults.aspx?mode=Publication&doctype=OSWG .
For more detailed information and status updates,
Arthur recommended the following EASA website:
OpSpec C056 and C057: IFR Takeoff Minimums – Airplanes
FAA Lead: Bryant Welch (AFS-410), Chris Hope (AFS-410), Danuta Pronczuk (AFS-52)
Industry Lead: Brian Miles
Issue: 400/400/400 RVR takeoff with HUD – can the FAA drop the HUD requirement?
Background August 2013 OSWG: Brian, the international industry chair questioned the HUD limitation below 500/500/500; stated that EASA and ICAO both have provisions for 400/400/400 takeoff without a HUD. [125 meters= 400 feet]. Bryant (AFS-400) took the IOU to review the issue. Chuck, the domestic industry chair asked if the FAA permits international industry to do a 400/400/400 takeoff without a HUD will the domestic industry be permitted as well. Bryant confirmed – yes.
2014 OSWG update: EASA confirmed that establishment of lower take-off minima was based on a simulator study performed on a KLM B747. Bryant advised that the FAA has requested a copy of the study and is still waiting. Without a copy of the study the only way the FAA would consider the proposal would be to conduct its own simulator study. For the FAA to consider conducting its own study there would have to be proof of a need. US and foreign air carriers who feel that there is such a need are requested to between todays OSWG and the next joint session (scheduled for March 2015) to track to which airports and how many takeoffs at those airports they could not do because the weather was less than 500 RVR. Bryan M. commented that EASA only authorized Category A, B, C, for 400 takeoff without HUD. Bryant commented that this will be easier to review once we have a copy of the study.
Post meeting additional item/issue for next joint OSWG: 2 engines or less limited to 1 sm mile – can the FAA drop to ½ sm if the foreign CAA authorizes? Question to industry how many commercial operators operate with one engine? Is there a need? What are the mitigations? [New technology/more reliable engines…]
Regulatory reference 91.175 (f) - unless otherwise authorized by the FAA [more than 2 engines ½ sm, 2 engines or less – 1sm].
C091: Airplane Authorization/Operational Requirements Airplane Design Group VI (ADG-VI) Airplanes.
FAA Lead: Danuta Pronczuk and David Henthorn, George Legarreta (AAS-100)
It is necessary for carriers to analyze and coordinate with airports prior to operating Group VI aircraft into group V airports, specifically the B747-8 and the A-380.
Ops Spec C091 is required for anyone operating an A380. To date, only foreign air carriers were operating the A380. Foreign air carriers are already operating the B-747-8, Bob added that although no U.S. operator has a need for it currently; AFS-200 expects that to change in the future and as such will be adding this template to the Part 121 data base of available Ops Specs.
In the 2011 Joint OSWG meeting, Danuta briefly reviewed the background on C091/the study of the group VI aircraft, (A-380 and B-747-8), operating into group V airports, issues surrounding group VI aircraft operating into group V airports, specifically the B-747-8 and the A-380. The limitations language has been agreed upon by both AFS-050 and AFS-200. After many hours of review, both divisions have agreed to keep the limitations on group VI aircraft operations into group V airports in Ops Spec C091. The existing limitations for the A-380 have been rewritten into plain language, and the B-747-8 limitations language will be added. A revised draft Ops Spec C091 is expected to be posted in the next few weeks. Limitations are based on the results of a study that was conducted – can the A-380 and B-747-8 safety operate on group V airports and under what conditions.
2012 OSWG Discussion:
Danuta briefly reviewed the issues, goal, and updated the group on status of the change. Namely, the OpSpec, and the associated inspector guidance was drafted, and informal FAA coordination had been initiated. In the process of this informal coordination, the following issue was raised. The existing limitation in OpSpec C091 states in part:
For runways with a threshold elevation greater than 4,000 ft. MSL the hold short lines or hold position must be expanded outward from the 280 ft. point by 1 ft. for every 100 ft. the runway threshold elevation is above sea level.
The issue with the above limitation is that the AC airport design criterion starts adding the 1 foot per 100 feet at 0 MSL. For example: if using the AC criteria for runways with a threshold of 3000 ft. MSL the hold short lines or hold position must be expanded outward to 310 feet = 280+ 30. If using the OpSpec criteria for that same scenario the hold short lines or hold position must be at 180 feet. For example: if using the AC criteria for runways with a threshold of 3000 ft. MSL the hold short lines or hold position must be expanded outward to 310 feet = 280+ 30. If using the OpSpec criteria for that same scenario the hold short lines or hold position must be at 180 feet. AFS-50 continues to meet and discuss with airports and subject matter experts in AFS-400, AFS-200… to settle the issue.
2013 OSWG Discussion: No industry comments from posting. Informal FAA coordination completed, Document Control Board (DCB). OpSpec went out for FAA formal coordination. FAA is processing disposition of formal coordination comments. Completion expected by next OSWG.
2014 OSWG update: Made one additional guidance edit to where MOS information may be found. (Added the airports link to where the most up to date information may be found). The OpSpec and associated inspector guidance were signed off for publication. The new template is expected to be available for issuance in the March/April time frame. MOS posted on the following link:
This link offers only the "listing" and not the actual MOS conditions. This approach better serves the airline/cargo operator that wishes to operate at a specific U.S. airport. Airports advise that the air carrier contact the airport directly to obtain a copy of the airport's Approved Taxi Operational Plan.
Taxi Operational Plan
is between the airport mgr and the local ATCT Mgr (and any other party that
may be involved like local ramp controllers). Contact the airport directly to
obtain a copy of the airport's Approved Taxi Operational Plan.
That Plan provides the airline/cargo operator the designated runway(s) and designated taxi routes that ATCT/Local Control will use for A380/B747-8 operations. That Plan will also list the specific operational conditions, if any that the airline/cargo operator needs to follow. This is all that is needed by such customers. Ex. contact DFW to get a copy of the latest A380 Taxi Operational Plan. That Plan (1) designates the runway and taxi routes plus parking locations agreed to by DFW and ATCT, Local Control plus (2) will list any A380 operational restrictions via Mod-to-Standards. Such as, taxi speed restriction if any.
Airport treats alternates airports as emergencies therefore it does not require an MOS or an Approved Taxi Operational Plan for alternate airports. Flight Standards does not treat alternate airports as emergencies. Air carriers planning on using an airport as a regular destination alternate must ensure that not only can the pavement structure be sufficient for the weight of the aircraft (information the airport will have available) but also that all of the OpSpec requirements are met and the operation can be conducted safely.
Post meeting additional detail/clarification from airport safety:
The taxi ops plan includes the conditions of the MOSs. This Plan could have more than the MOS. For example the airport operator or the tower mgr may have added additional operational requirements, restrictions.
To fulfil airports requirements the air carrier needs at least the taxi ops plan. Airport recommends that air carriers ask for a copy of the approved MOSs to see the details used to arrive for approval.
There was one type MOD early on that said renew at 5 years but airports let those MOSs continue on. Old MODs are in effect until operations change. If the new ops contradict the MOS conditions, then airports require a new approval. Same situation for new construction or renovations that do not meet full design std... For example: air carrier b wants to start scheduled service to an airport with an old MOD that was created for air carrier a. If air carrier b airplane is different than air carrier a airplane, (air carrier b airplane has a longer fuselage, wider wingspan, heavier taxi weight) then a new MOD for air carrier b would be required. Airports will create a new MOD for air carrier b. This scenario could happen if for example a new model of A-380 comes out. If air carrier b airplane is the same as air carrier a airplane then no need for a new MOD. Air carrier a will be permitted to continue operating under the old MOD until such time as its operations change or new construction/renovation is not to full design std.
New Charting format for Cat III - Update
FAA Lead: Chris Hope, Bryan Welch,
Industry Lead: David Oliver
Bryant Welch reviewed the proposed change, draft OpSpecs, and the final rule – removal of definition of Cat IIIa, IIIb, and IIIc. The FAA still using the same definitions, they are just not going to be defined in the FAA’s regulations. In the future, expect the NOS Charts to depict only one minimum for Cat III. New chart will just have the lowest CAT III mins. Bryant showed what the new charts would look like, compared the existing Jepps and NOS to what can be expected as a progressive change starting in the summer of 2014.
D485: Aging Airplane Inspection and Records Review.
FAA Lead: Frank Wiederman (AFS-300)
Issue: can we decommission? 14 CFR part 129, 91.105 applies only to airplanes, not helicopters. If we cannot decommission then the part 129 OpSpec should be made into an optional template (airplanes only) and the last four columns should have dropdowns, same as the 121 template minus the 135 on demand. The 121 template refers to part 129 and has directions within the template. Should there be a job aid for both the 121 and 129 templates and should the directions and references to part 129 in the 121 templates be deleted?
2013 OSWG update: AFS-300 reviewing possible decommission as the collected data has not been used for the last 7 years. For the interim Mark reviewed the amendment to the part 129 templates which has been initiated. A helicopter is not an airplane and since the rule is for aging airplanes the D485 requirement is being removed for helicopter only operators. Inspector guidance has been drafted to reflect the change. If a policy decision is made to decommission D485 for all CFR parts before the draft OpSpec, Notice and inspector guidance completes processing then all documents will be amended accordingly to reflect decommission.
2014 OSWG update: industry (domestic and international) have requested that the FAA decommission D485. Nick Petty from executive Jet Management also commented that they are required to have D485 yet D485 says it does not apply to 135 on demand. Danuta briefed that for now the FAA will be continuing to process the previously briefed change to D485 for 129. If it is agreed by upper management that the FAA can decommission then instead of making the change the FAA will decommission D485 for 129 as well. Danuta introduced new AFS-300 lead and took IOU to pass on industry recommendation to decommission. Industry requested that since Frank is expected to retire in the next 6 months that AFS -300 assign a backup POC. Danuta took the IOU to communicate the request to AFS-300.
SAFO aircraft RECAT for wake turbulence
FAA Lead: Wayne Gallo, AFS-430
BACKGROUND: FAA wake turbulence research, headed by AJT-2A, in conjunction with Volpe, NASA, MITRE, and other contractors/scientific organizations, has concluded that previous wake turbulence aircraft separation standards were extremely conservative and in some cases safely decrease the interval between aircraft.
ISSUE STATEMENT: Aircraft wake turbulence separation re-categorization (RECAT) now has six categories (labeled A-B-C-D-E-F) to allow better fidelity with respect to wake characteristics.
INTENDED OUTCOME : Increased capacity at airports by decreasing separation distance between lead/follower aircraft when applicable.
OpSpec C059: Category II Instrument Approach and Landing Operations- U.S. Airports.
FAA Lead: John Blair, Chris Hope, Bryant Welch
Issue Statement: Controlling RVR needed to be clarified. Specifically 0 MID or 0 Rollout was never acceptable. In the amended OpSpec it will specify that all RVRs are controlling vs. just touchdown. Also specified minimum values for Mid (600 RVR) and Rollout (300 RVR) for CAT 2, (1200/600/300). The OpSpec was also rearranged, first step toward combining with C060.
2013 OSWG update: Changes in the controlling minima. For CAT II currently touchdown zone is controlling and mid and rollout is advisory. Changing to all available RVRs are controlling. Specifying minimum values for rollout so you cannot land with 200 RVR in rollout. Result of looking at several company manuals that 0 rollout is OK. Went through DCB, out for formal coordination. Following this change AFS-400 plans on combining C059 with C060.
2014 OSWG update: Bryant updated that inspector guidance for part 129 needed for the issuance of the foreign air carriers OpSpecs is delayed, being processed and expected to be out in the next few months. The OpSpec template is already out. The compliance date will be 120 days from the date of the international inspector guidance being published. Bryant emphasized that if all three RVRs are available then they are controlling. Comment from the floor was that the N/A for mid and roll out in the table next the touchdown 1600 RVR row was confusing and requested an amendment to the OpSpec. Bryant confirmed that the way N/A in that row (mid and rollout) was supposed to be interpreted for was: if reported then 1600 or above, if not reported then 1600 touchdown is all that is required. Bryant took the IOU to make the requested editorial for both the foreign air carrier and U.S. domestic templates.
Data Link Communications
FAA Lead: Mark Patterson
Industry Lead: David Oliver
Background from 2012 OSWG: Trent briefed the group on the OpSpec the FAA currently issues on Data Link Communications. Currently there is no OpSpec for Part 129. Trials are underway for Data Link Communication over US airspace. Michael clarified that for US registered aircraft pending results of the trials; data link over US airspace there may be a need to amend D OpSpecs as they relate to the maintenance program and data link communications. (References to the issuance of OpSpecs or an amendment to existing OpSpecs for data link communications prior to the foreign air carrier operating a data link communication-equipped aircraft in domestic U.S. airspace reference any future changes).
AFS-400 is aware that AC is out of date, will update as appropriate. References to the issuance of OpSpecs or an amendment to existing OpSpecs for data link communications prior to the foreign air carrier operating a data link communication-equipped aircraft in domestic U.S. airspace.
The Fans Operations Manual (FOM) was replaced by Global Operational Data Link Document [GOLD] over a year ago. (GOLD is the source document for Controller Pilot Data Link Communication (CPDLC) and ADS-C. OpSpec A056 issued to US operators covers ADS-C (oceanic, US operators going to Europe). OpSpec A353 issued to US operators covers ADS-B (Gulf of Mexico, Hudson Bay, Greenland and Island)
2013 OSWG update: Mark Patterson new FAA lead briefed: expects a new optional OpSpec for 129 wishing to conduct data link communications within the U.S. International industry chair questioned why? Mark responded – many countries use data link over ACARS and the FAA is issuing data link communications clearances over FANS. Trials at Newark and Memphis are underway. Foreign air carriers wishing to participate in the trials are invited to contract their PI. AC is in the process of being revised.
2014 OSWG update: The Federal Aviation Administration (FAA) is conducting Departure Clearance (DCL) Trials using FANS-1/A at various airports within the United States (U.S.). These trials will help identify the requirements for replacing voice communication between pilots and air traffic control with data link at all U.S. airports. Three foreign air carriers expressed interest and are expected to be participating once approval from each state of the operator is received: British Airways, Lufthansa, and SAS. Any other foreign air carriers interested should contact Mark.Patterson@faa.gov. Once the trials are over, it is expected that foreign air carriers who want to receive their departure clearance using data link, will need to apply for an amendment to their 129 OpSpecs.
Convene. Opening remarks/welcome by industry Chairs and self-introductions by attendees to include: Aeroflot Airlines, Antonov Airlines, Airbridge Cargo Airlines, Air Canada, Emirates Arab States, Copa Airlines, Volga Dnepr Airlines, Biman Bangladesh Airlines, TAM, Korean Airlines, Domincan Republic CAA, Insel Air International, Aeroflot Russian Airlines, Virgin Atlantic Airways Ltd., Saudi Arabian Airlines, A4A, IATA, NBAA, Delta Airlines, Wicks Group, Eckert Seamans Cherin & Mellott, LLC, consultants/agents for service for numerous foreign carriers, AFS-50, AFS-200, AFS-400, NY IFU, ANC IFO, MIA IFO.
OpSpec B034 and B035: IFR Class I En Route Navigation Using Area Navigation Systems and Class I Navigation in the U.S. Class A Airspace Using Area or Long-Range Navigation Systems
FAA Lead: Trent Bigler (AFS-400), Danuta Pronczuk (AFS-50)
Industry Lead: Capt. Harold Cardona Henao
New Issue: addition of advanced RNP/RNP 2 domestic affects the following OpSpecs issued to international B035, C063, C052.
Background : at the last international session (2012) Mike reviewed as follows: Ops Spec B034 does not apply to part 129, needs to be decommissioned. (B034 designed for US operators operating in Europe). Ops Spec B035 needs further review. RNAV below 18000 feet not addressed in B035. Reviewing to see if we need Q – route identified?
OpSpec Change goes together with the proposed D092 draft change.
2013 OSWG update: New draft not ready yet, in process.
2014 OSWG update: Trent updated that he recently took over the review of the draft B035, expects to have more details at next OSWG. He confirmed that Q routes would need to be identified so an additional column is expected. Trent added: FAA is working on harmonizing the AC 90-105 internationally with the ICAO Doc 9613 PBN Manual. The FAA approves US domestic operators for RNP operations and barometric vertical navigation in the U.S. National Airspace System in accordance with AC 90-105A. A revision to the AC is in process and the FAA is inviting comments/input from foreign air carriers as well so that it can be assured that the AC is equivalent to what other States may be doing/there is maximum harmonization. AFS-400 has initiated discussions with AFS-50 on what amendments to 129 OpSpecs will be required with RNP 2 in U.S. airspace and Advanced RNP Functions. Advanced RNP requires the following avionics box capabilities: scalability, radius to fix (RFs), and parallel offset. The affected part 129 OpSpecs would be C052, B035 and C063. Brian (international industry chair) asked if the FAA could add some automatic functionality wherein if an operator is authorized for the most advanced technology/C384 then they get everything, so not have to apply for separately for less advanced items. Trent confirmed that is a worthy goal.
C384. RNP SAAR – Area Navigation (RNAV) Required Navigation Performance (RNP) Instrument Approach Procedures With Special Aircraft and Aircrew Authorization Required (SAAR)
B039: Operations in North Atlantic Minimum Navigation Performance Specifications (NAT/MNPS) Airspace with U.S. Registered Airplanes
B046: Operations in Reduced Vertical Separation Minimum (RVSM) Airspace of the United States and Operations in RVSM Airspace by U.S. Registered Aircraft.
FAA Lead: Madison Walton, Danuta Pronczuk
Industry Lead: Brian Miles
At the last international session (2012) Danuta updated no change, still planning to decommission, waiting on completion of OpSpec A003 so that all changes can be processed together, less overall work for the inspectors and foreign air carriers. Inspector guidance and relevant job aid (D092) drafted.
2013 OSWG update: Guidance Notice and OpSpecs went through DCB to AFS-140 being formatted for formal coordination. Changes since last time: mostly to inspector guidance. Took out one of the limitation in A003 (not a limitation) - RVSM operation (see current edition of AC 91-85, JAA Temporary Guidance Leaflet (TGL) 6 or equivalent guidance). Added to A003 a selectable limitation for aircraft without an MEL that identifies which aircraft do not have an MEL. (Need to know if an aircraft does not have an MEL for the purpose of ramp inspections). Change to D092 in:
- OpSpec number (will be D108) so as not to confuse with 121 and 135 OpSpec templates which are slightly different (the 129 OpSpec has a broader scope) and
-a slight change in title/word reversal so as not to confuse with CAMP. [Previous title was - Continuous Airworthiness - Maintenance Program – U.S. Registered Airplanes]
2014 OSWG update: the OpSpec and associated inspector guidance were signed off for publication. The new template is expected to be available for issuance in the March/April time frame.
C060 Category III Instrument Approach and Landing Operations - U.S. Airports
FAA Lead: Chris Hope, Bryan Welch, Danuta Pronczuk
Industry Lead: David Oliver
Background from 2012 OSWG: Bryant Welch reviewed the proposed change, draft OpSpecs, and the final rule – removal of definition of Cat IIIa, IIIb, and IIIc. The FAA still using the same definitions, they are just not going to be defined in the FAA’s regulations. In the future, expect the NOS Charts to depict only one minima for Cat III.
A003: Aircraft Authorization for Operations to the United States
FAA Lead: Danuta Pronczuk, Madison Walton
Industry Lead: Brian Miles
Background from 2012 OSWG : Danuta reviewed the new draft for incorporating OpSpecs: A014, B031 and C080; expects to have a draft for OSWG review by next meeting; iniated review with office of chief counsel, and AFS-400. The proposed draft will eliminated a significant number of cross referencing between OpSpecs and as such clarify the limitations to IFR and VFR enroute, correct the issues with B031.
2013 OSWG update: Delayed C080, B031 and A014 incorporation until the B039 and B046, D092, A003 change is processed. Reason – it would be too confusing/too many changes which pose a danger of missing something. Discussed as part of B039 and B046 update; see details in update to B039 and B046 above.
2014 OSWG update: Discussed as part of the B039, B046, D092, B031 discussions.
OpSpec A001 (129.14): Issuance and Applicability
FAA Lead: Danuta Pronczuk
Background from 2012 OSWG: Danuta reviewed the change since last meeting. Namely: Removed the requirement to carry on board U.S. issued OpSpecs to 129.14. It is the State of the Operator’s responsibility to issue AOC and associated OpSpec to be carried on board. (See ICAO Annex 6, 4.2.1 and Appendix 6).
Danuta also reviewed a new proposal submitted to AFS-50 and requested OSWG feedback - Add responsible FSDO/IFO/IFU details to include office name, addresses and principal inspectors (PI) details. Feedback from the floor was to go ahead and add as proposed. Danuta took IOU to incorporate as recommended and post the OpSpec for comment within the next few weeks at http://www.faa.gov/aircraft/draft_docs/129opspecs/ .
2013 OSWG update: Added responsible FSDO/IFO/IFU and PI details. No comments from posting. OpSpec has been issued, notice and associated guidance published. [See FAA Notice 8900.220]
The A001 129 templates (issued to foreign air carriers operating within the U.S.) was amended. Reason– change in Special Interest Flights, (SIF) compliance date. The reason for the change is a change in policy on foreign air carriers that impacts surveillance/safety oversight of foreign air carriers from U.S. State Department designated special interest countries to whom the FAA issues 129 OpSpecs effective July 1, 2013. Exception for SIF [operators from China, Russia] nonscheduled flight notification was removed from OpSpec and inspector guidance revised. All nonscheduled operators to whom the FAA issues 129 OpSpecs must notify the responsible FSDO/IFO/IFU of nonscheduled operations. The change is out for formal coordination, due back 8/9/2013, expected to be available in WebOPSS in the next few weeks.
This is a mandatory change affecting PIs with responsibility for the issuance, am endm ent, and oversight of OpSpe cs for part 129. PIs m ust reissue all previously issued OpSpec A001 tem plates to foreign air carriers from U.S. S t ate Departm ent designated special inte rest cou ntries with in 2 weeks f rom the date o f this Notice . At this time, Russia an d China are the only special interest countries to whom the F A A has issued 129 OpSpecs. The PI m ust accom plish this action within 120 day s from the ef f ective date of this notic e for all o t her foreign air carriers o perating to the U.S.
2014 OSWG update: Notice and inspector was published. No questions from the floor.
Part 129 Rulemaking - Update
FAA Lead: Danuta Pronczuk
Industry Lead: Brian Miles
Background from 2012 OSWG : No changes in status, except that Mike Frank is the FAA lead with Danuta as his backup. Rulemaking is currently on hold due to other priorities. FAA internal rulemaking team continuous to meet. Only the US agent for service in the US must be listed in OpSpecs. No dual delivery at this time.
2013 OSWG update: On August 9, 2010 the project [AFS-06-147-R] was closed because of HR 5900. International industry chair questioned what happened to the Aviation Rulemaking Committees recommendations from the rulemaking that was closed. Danuta clarified that the FAA has a copy of those recommendations and is expected to review when the rulemaking activity is reinitiated; FAA looking at 2015. Danuta is the new FAA lead. Any new comments… should be directed to Danuta.Pronczuk@faa.gov.
2014 OSWG update: no changes
OpSpec C050 [Special Pilot In- Command Qualification Airport List], and C067 [Special Airplane Authorizations, Provisions, and Limitations for Certain Airports ]: Special Airport Authorizations, Provisions, and Limitations
FAA Lead: Gordy Rother, Scott Stacy, Danuta Pronczuk, Dan Roneberg
Industry Lead: John Conlon
Background from 2012 OSWG: Gordy reviewed the OpSpecs proposed change. OpSpec C067 is used to authorize special airport operations if the airport has special requirements beyond the PIC qualification requirements of C050 and to establish the requirements for the use of certificated U.S. land airports and any authorization to use uncertificated U.S. land airports. OpSpec C050 must also be issued for “special PIC qualification airports” authorization. An example of an airport with a special airport Authorization (C050) is San Francisco. Gordy already completed a first draft of the combined OpSpec. John Conlon volunteered to be industry lead. Danuta took IOU to review/work with Gordy the draft that Gordy put together for Part 121, to tailor it to Part 129. Expect to have the draft of the combined OpSpec at the next OSWG meeting.
2013 OSWG update: adding that link to the AIP for the list of special airports – AIP, GEN 1.7-56, ICAO Annex 6 part I, chapter 9, section 220.127.116.11. Reviewed preliminary draft of C067 (removed dated limitations, selectable for limitations, expected future job aid, a query of the existing data found that inspector guidance for the OpSpec was in particular need of revision, data captured was not what was intended). Once the link to special airports is added to the AIP, C-050 will be decommissioned, any pertinent portions added to C067. Expected timeline for posting for comment– next OSWG.
2014 OSWG update: Gordy, Scott and Danuta updated the OSWG on status of change, background, intent and differences between the 121 and 129 templates. Briefly for US air carriers the OpSpec serves to identify airports with special provisions and limitations in Alaska where for 3 months out of the year it is dark. Pat C. from Anchorage added a few examples of airports to which he knows operations are conducted in Alaska and use flare pots, runway reflectorization systems. For foreign air carriers the OpSpec is more than about Alaska. It is first about operating to an airport that is appropriate for the type of operation and aircraft. Furthermore the OpSpec specifies the special provisions and limitations associated with airports with mountainous terrain, A-380 and B-747-8 operations to group V airports, operations at airports not certificated under part 139, airports with unpaved runways etc.
Question from the floor was how would an air carrier know is an airport needs to be listed. Gordy advised that there is a list of special qualification airports in FSIMS and a link to it will be added to the AIP. Due to weather the FAA lead on adding a link to the AIP for the list of special airports was unable to make it to the meeting and update the OSWG on status. Danuta added that for the purpose of this OpSpec the listing in the AIP is not an exclusive list of airports that would need to be listed in the new C067. Airports that have flare pots, runway reflectorization systems, an unpaved runway, an MOS for an A-380 or a B-747-8 would also need to be added. A job aid and inspector guidance to this effect was drafted. There are still a few details that are being reviewed as the existing guidance is very old. Danuta added that the foreign air carrier is responsible for knowing and reviewing the content of their authorizations and preflight planning. A statement from the floor was that for nonscheduled operators most flights are last minute therefore nonscheduled operators should not be required to list airports with special provisions/limitations. Danuta responded that all foreign air carriers are responsible for preflight planning, the nature of the type of operation (nonscheduled) does not mean that a foreign air carrier can land at an airport without proper planning, and being knowledgeable on what they are authorized in their OpSpecs. She added that foreign air carriers must comply with all OpSepcs, the FAA is aware that cross referencing between OpSpecs makes it more challenging to understand all of the limitations and requirements and as such the FAA continues to combine OpSpecs. Brian Miles advised that San Francisco (SFO) would be an example where you need to complete special training if you will be conducting closely spaced parallel approaches using Precision Runway Monitor (PRM). Scott advised that when the A-380 comes into Atlanta everyone clears out. Bottom line some airports require additional planning and for safety reasons closer scrutiny.
13. OpSpec C083: IASA Category 2 Special Operational Restrictions- Scheduled and Non-Scheduled Operations, Additional Aircraft and Special Authorizations
FAA Lead: Danuta Pronczuk
Background from the 2012 OSWG: Danuta presented new draft language:
Look for the updated draft to be posted for comment in the coming weeks at http://www.faa.gov/aircraft/draft_docs/129opspecs/
2013 OSWG update: delayed in processing, more details next OSWG.
2014 OSWG update: additional inspector guidance is being informally coordinated to address seasonal operators. It is expected that for seasonal and nonscheduled operator the look back will be 1 year from the date of downgrade. A question from the floor was: what is the difference between seasonal and nonscheduled operation. Danuta explained that a seasonal foreign air carrier may operate for example only 3 months out of the year and those operations may have a schedule. Pat provided examples of current seasonal operators out of Anchorage, Alaska who fit the above mentioned description. Danuta emphasized the importance of notifying responsible FSDO/IFO/IFU of nonscheduled operation to the U.S. She reminded that if the State of operator gets downgraded to IASA category 2 and there is no record of any notifications of nonscheduled operations to the U.S. by a foreign air carrier within the specified time frame mentioned earlier then that foreign air carrier’s operations will be frozen at zero until such time as the state of the operator regains category 1 status. Danuta briefed no change to scheduled operators. The foreign air carrier must have provided scheduled service to the listed city pairs either at the time their home country was determined to be CAT 2. Question from the floor was what happens if a scheduled air carrier changes its schedule. Pat reminded that the air carrier can always petition to manager of AFS-50. Danuta confirmed that an air carrier may petition.
OpSpec D092: Maintenance Program Approval for U.S. Registered Airplanes
FAA Lead: Danuta Pronczuk, Madison Walton
Background from the 2012 OSWG: Danuta reviewed the revised draft, additional edits since last meeting, gave credit to Michael for his research into last meetings proposal, update to last column, and coming up with a single word (Maintenance) to automatically load aircraft M/M/S, Registration, and serial numbers into the table without interfering with other templates.
To go along with new ICAO terminology, see Annex 6, navigation specification rephrased the heading for the last two columns to: For Operation requiring a lateral navigation specifications. Also rephrased the last column in the OpSpec to: Performance specification, again this to go along with the new ICAO terminology.
ICAO has multiple references to maintenance program and continuous airworthiness. The FAA uses the term CAMP – Continuous Airworthiness Maintenance Program. To rename the OpSpec as proposed could create confusion with CAMP and give the impression that the OpSpec was only for dry leased aircraft that are U.S. registered. The FAA is looking at the following title: “Continuous Airworthiness – Maintenance Program – U.S. Registered Airplanes.”
In coordination with Madison the associated inspector guidance and OpSpec job aids have also been drafted. The updated drafts are expected to be posted for comment in the next couple of weeks at http://www.faa.gov/aircraft/draft_docs/129opspecs/
2013 & 2014 OSWG update: Discussed as part of B039 and B046 update; see details in update to B039 and B046 above.
OpSpec B031: IFR En Route Limitations and Provisions
FAA Lead: Danuta Pronczuk
Industry Lead: Jorge I. Londono
Background from the 2012 OSWG: Danuta briefed the draft change. Incorporation of B031 into A003, (this cuts down on 6 references to other OpSpecs which helps to understand the limitations more readily, and eliminates the VFR issue for some 60 foreign air carriers that are not authorized IFR enroute), and the accompanying decommissioning of A014. Meetings with the chief counsel had been initiated, and continuing. Danuta expects to finalize the draft in the next couple of months.
2013 OSWG update: Discussed as part of B039 and B046 update; see details in update to B039 and B046 above.
2014 OSWG update: now that A003, B039, B046, D108 have been signed off for publication we can proceed. Expect more details at the next OSWG.
OpSpec A028: Aircraft Wet Lease Arrangements
FAA Lead: Danuta Pronczuk
Industry Lead: Brian Miles
Background from the 2012 OSWG: Put the processing of the change on hold until OpSpec A029 is finished processing, and the provision of aircraft with crew guidance is out to prevent any confusion in inspector guidance, specifically version control. No adverse comments on the draft OpSpec posted for comment.
2013 OSWG update: provision of aircraft with crew guidance has been issued, will be initiating processing shortly.
2014 OSWG update: delayed due to other priorities.
OpSpec D095 – Minimum Equipment List Authorization – U.S. –Registered Aircraft
FAA Lead: Danuta Pronczuk (AFS-50), Frank Wiederman (AFS-300)
Issue: FAA no longer authorizes a foreign air carrier operating with U.S. registered aircraft to use an FAA-approved MEL via letter of authorization.
Danuta advised that in March 2011 the FAA published a final rule which stated in part that the MEL approval will be via OpSpecs. Processing of the amendment to the OpSpec has been initiated and it is expected to be out for comment shortly. Additional clarification reference single extension is expected.
Terms of reference.
FAA Lead: Danuta Pronczuk
Industry Lead: Brian Miles
Danuta reviewed updates to terms of reference relating to annual part 129 OSWG meetings, FAA AGC reorganization and new FAA vice chair. No comments from the floor. In view of the 129 industry chair retirement Danuta also reviewed the roles and responsibities of the industry chair and vice chair.
Elections for Industry Chair.
FAA Lead: Danuta Pronczuk
Industry Lead: Brian Miles
Brian Miles, international industry chair confirmed his plans to retire within the next few weeks. Brian reviewed his experience as industry chair and asked who/which foreign air carrier would like to volunteer to take over his role at the OSWG when he retires. Since there were no volunteers from those attending, and no positive confirmation from the Industry Vice Chair if he would like to assume the role of industry chair Brian took the IOU to:
- coordinate with Jeff Miller (IATA) to send out an announcement to the remaining foreign air carriers on the OSWG roster asking for volunteers.
-follow up with the industry Vice Chair on his intentions.
Closing remarks/From the Floor - industry expressed that the speed of processing aircraft additions to A003 is still a problem for some foreign air carriers. It was requested that the FAA review its processes to see if the addition of same M/M/S can be revised so that such request can be processed faster. Danuta advised that differences in processing speed from one office to another are influenced by many factors to include workload, a very tight budget, and resources. Brian Miles advised the OSWG that he has brought the issue to John Allen and is awaiting a response.