Meeting Agenda FAA/Aviation Industry

OpSpec Working Group (OSWG) 2004-02

April 27 (Tuesday, 1 pm-5 pm)/28 (Wednesday, 8:30-noon), 2004

Air Transport Association,

1300 Pennsylvania Ave.,

Washington, DC

 

Meeting Schedule/Location

 

January 20-21, 2004

American Airlines – Dallas

April 27-28, 2004

ATA

1300 Penn Ave– Washington, DC--

July 20-21, 2004

COMAIR – Cincinnati

October 19-20, 2004

Washington, DC

January 18, 19, 2005

 

 

Topic

 

1.        Convene                                                              Chairpersons

Casey Seabright, NWA, Industry Chair

John Cowan, UALA, Industry Vice Chair

Connie Streeter, FAA Chair

Roll call

Set January2005 meeting location.

SPEC revision is available on www.opspecs.com website.  The revision adds the “standing agenda item” for OpSpec c050, Special PIC Qualification Airports.

 

2.  Status of Assigned Action Items                                        Chairpersons

Review, amend, and adopt agenda

2.5.  Other Misc. Agenda Items:

Aeronautical Charting Forum.  This request is to add clarity to takeoff minimums currently being charted in mutable place.

 

 

3.  OpSpec B343, Fuel Reserves in International Operations

Background:   OpSpec B043 allows for a deviation to the fuel reserve requirements for international flight operations. 

FAA Lead = AFS-220 (Jerry Ostronic)/AFS Dispatch Specialists
Industry Lead – Jim Johnson, AA

Desired Outcome:   American Airlines requested further reduction in the fuel reserve requirements from B043 for international flight operations.

 

Action/Outcome:  Jerry Ostronic and others at FAA HQ prepared the nonstandard OpSpec B343 and it was put into the OPSS.  Any carrier that would want to use it must submit its request in accordance with the nonstandard OpSpec request process.  A jobaid is associated with OpSpec B343 that explains the requirements for the request.

 

5.  OpSpec C089/C090/C052, RNP RNAV Instrument Approaches

 

Background:    The Industry leads suggested and provided example of providing RNAV RNP approach authorization as a selectable item in paragraph C052.

FAA Lead = AFS-410, Vinny Chirachello/Rich Gastrich/AFS-200

Industry Lead = Jim Enias, ATA/Jackson Seltzer, Continental

 

Desired Outcome:  Need standard authorization for RNAV RNP approaches .

Action/Outcome:  AFS-410 answer: 

I have three major problems with the proposed OpSpec C052.

1. The added items (4) through (8) do not appear to replace or even closely resemble the authorizations of C089/C090.

2. The approaches added in the tables under a. do not exist to my knowledge.

RNAV (GPS) approaches are the only approaches that I know of. I have never seen any  RNAV(RNP) approaches. Way back, when we started to work on this RNP and RNP RNAV project I remember this being discussed as an option for procedure naming, but to my knowledge it never matured.

3. Manually loading waypoints to construct procedures is against current policy as I know it.

Modifying airspeeds, altitudes, or RNP values at waypoints may be an option of some FMS systems, but procedures being built by manual entry of waypoints, even by name, is not safe.

Rich Gastrich, AFS-410

4.  Order 8260.51 is being developed by the TOARC for the STAARS for RNP approach development.

5.  Applicable Part 97 RNAV SIAPS are being altered to include “or GPS or FMS” in the title without otherwise reviewing or modifying the procedure.  (Once a standalone GPS or FMS procedure is developed, the procedure title will be altered to remove “or GPS or FMS” from these non-localizer, non-precision instrument approach procedure titles).  NOTE—this is for U.S. Part 97 approaches only. 

The certificate holders must comply with the requirements of foreign State of authority if conducting foreign operations.

Current SIAPs intended for use by RNAV equipped aircraft can be flown by aircraft utilizing various other types of navigational equipment. 

However, if there is an AFM limitation stating that the underlying navigation aids must be monitored for the approaches, the FMS cannot be used for the approach (either domestic of foreign). 

Federal Register/Vol. 66, NO. 56/Thursday, March 22, 2001, pg. 15995-996.

Bottom Line:  C052 already provides adequate authorization for the standard approaches.  It is not acceptable to develop OpSpec language to exempt a certificate holder from the AFM requirements or from the requirements of any foreign State of authority.

 

ACTION:  Jim Enias and Jackson Seltzer have been requested to contact AFS-410 representatives directly as a subworking goup for further clarification and action on this issue.

6. 

Background:   

Industry Lead =  FAA Lead = AFS-200

Desired Outcome: 

Action/Outcome:  .

 

7.  OpSpec C059, CAT II Approach Authorization

Background:

a.  Jackson Seltzer (CAL) to provide update/report on questions raised regarding the question of lighting equivalents, i.e. allowing a CAT II using MALSR.  The final draft of updates to 8400.10 for CAT II all weather operations, the revision to paragraph C059, and the new OpSpec C359 available on opspecs.com and will be reviewed and discussed.

b.  An official revision to C059, CAT II, was published with an ambiguity in the airport/runway authorized.

 

Industry Lead = Jackson Seltzer

FAA Lead = AFS-410/AFS-200

 

Desired Outcome:

a.  Determine if MALSR is sufficient for CAT II operations. Clarify language and/or guidance for 6-6-6 inop. 

b.   Correct discrepancies for CAT II airports. 

 

Action/Outcome:

a.  Action – Jackson Seltzer will provide a status report to the group re: MALSR. Dick Temple agreed to take the RVR issue off-line with Steve Kuhar

Action —Connie Streeter, AFS-260 Lead—Revise OpSpec C059:

"The certificate holder is authorized to conduct Category II (CAT II) instrument approach and landing operations to the airports and runways listed in Table 3 of this operations specification using the procedures and minimums specified in this paragraph and shall conduct no other CAT II operations under this authorization."  [okay]

....................

b.  The certificate holder is authorized to use the airplanes listed in Table 1 below using the following CAT II straight-in approach and landing minimums. at 14 CFR Part 97 CAT II runways and the authorized foreign airports and runways listed in Table 3 of this operations specification, provided all the applicable limitations and provisions of this operations specification are met.” [okay]

 

**AFS 200 will also look at revising C060 in a similar way.  However, the guidance also needs to change accordingly.

 

8.  OpSpec C359, Special Authorization For Certain Category II Operations at Specifically Approved Facilities

 

Background:   Order 8400.13 was published November 2002.  When OpSpec C059 for CAT II operations was revised, OpSpec C359 was put into place because of the requirements of Order 8400.13 for CAT II operations.  Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization.s published November 2002.  When OpSpec C059 for CAT II operations was revised, OpSpec C359 was put into place because of the requirements of Order 8400.13 for CAT II operations.  Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization.r CAT II operations.  Even though this OpSpec is in the “300” series, for authorization the operator does not have to follow the “nonstandard OpSpec process” for its authorization.

FAA Lead:  AFS-410/AFS-200

Industry Lead:  Jim Johnson, AA

Desired Outcome:  Explanation of how to be able to use C359.

Action/Outcome:  8400.13 Checklist for approvals is the required method.

Dick Temple will work with Lyle Wink on the status of these—which ones are now published as Part 97s.

Item for April Agenda… C359 Special Authorization for Certain Category II Operations at Specifically Approved Facilities - Dick Temple (AFS-410) tasked to work with Lyle Wink on the status of procedures - determine which ones are now published as Part 97 procedures?  For 1800 RVR operations I have complied a list of acceptable facilities, provided by Flight Inspection regarding their usability, and can provide the list prior to the meeting, if desired.  The only "special" CAT II on Type I facility approved is Houston Hobby runway 4.

 

9.  OpSpec C070. Airport Listing

Background:  OpSpec C070 is used for listing the airports approved for scheduled passenger-carrying operations.  Since the publication of 14 CFR part 119 there is still confusion about the definitions of airports and which ones should be listed.

FAA Lead:  AFS-200/AFS dispatch specialists

Industry Lead:  Jackson Seltzer

Desired Outcome:  

a.  Explanation of airports that must be listed. 

b.  How can we show the CMO which airports we have changed when we ask them to sign the revision?

Action/Outcome: 

b   AFS-260 is providing a draft of the changes that probably should be made to the OpSpec and to the guidance.   The airport definitions and guidance is not as complete as the group would desire. Gordy Rother and Dave Burnham will work to revise guidance to 8400.10 VOL 3, 1185 so as to clarify guidance.

b.  Use the “Document Compare” feature—copies of the instructions were available.  These instructions are also in the guidance subsystem in association with OpSpec C070.

 Use of the document compare function was described to assist users of OPSS.

 

Day 2

 

10.  OpSpec C050, Special PIC Qualification Airports—14 CFR Section 121.445 Airport List Review & Recommendation of OSWG to AFS-220:

Background :   Advisory Circular 121.445 was cancelled and replaced with OpSpec C050 and guidance that directs the OSWG members to present additions and deletions to the 14 CFR Section 121.445 Special PIC Qualification Airport List.  The recommendation must include the airport information on the completed Airport Assessment Form found in association with OpSpec C050 and on the www.opspecs.com website.  The OSWG members should review the assessment and make a recommendation to FAA Headquarters, specifically AFS-220.  This recommendation will become a part of the OSWG minutes and presented to AFS-220 within 2 weeks of the quarterly OSWG meeting.  The Airport Assessment Form for each specific airport recommendation will also be forwarded to AFS-220.  AFS-220 will make the final determination in regard to the request and recommendation.  If a change in the Special PIC Qualification Airport List is to be made, the OSWG members will be notified by email, the revised List will be posted on the public website at http://www.opspecs.com and in the OPSS guidance subsystem in association with both OpSpec C050 and C067, and reported at the next quarterly OSWG meeting.

 

Industry Lead:  Casey Seabright, NWA

FAA Lead:  AFS-220/260

 

Desired Outcome:  A known process for updating the Special PIC Qualification Airport List. A consistent process for updating the Special PIC Qualification Airport List.

Action/Outcome: 

Additional processes that are included in the FAA/Industry SPEC for this process:

1) Should have a minimum of 1 week lead time before the OSWG quarterly meeting

2) OSWG Members can vote at the meeting or they can send their recommendation to Connie Streeter for submittal at the meeting.

3) Notification to certificate holders:

Ø            Put a Note on the OPSS Splash Screen for first line of notification

Ø            Change the Special PIC airport List in guidance subsystem in association with OpSpecs C050 and C067

Ø            Change the Special PIC airport List on the www.opspecs.com website

Ø            Send email message to OSWG members

 

11.  OpSpec C078/C079, Lower Than Standard Takeoff Minimums.  Parts 121, 125, and 135

Background:

Industry Lead =

FAA Lead = Dick Temple, AFS-410, & Connie Streeter, AFS-260

Desired Outcome:  To finally get the RVR requirements established for 2, 3, & 4 RVR system runways as they relate to the length of the runways .

Action/Outcome:  A draft of the proposed changes was made available to the OSWG members prior to the meeting and comments were requested.

 

12.  OpSpec A013, Operations Without Certain Emergency Equipment (deviation)

Background:

a.  An FAA CMO determined that there was a need for a ditching demonstration (14 CFR Section 121.291) for its cert holder, even though it would be greatly abbreviated due to no life raft installed to demo.  Current guidance does not make this connection and apparently some carriers that have this deviation have not done a ditching demo.  That CMO requests that the ditching demo be added to the requirement for this deviation.

Perhaps the IOPPS A013 paragraph drop down menu guidance could include a note something to the effect that "ISSUANCE OF THIS PARAGRAPH AND PARAGRAPH A005 DOES NOT PRECLUDE THE NEED FOR AT LEAST AN ABBREVIATED DITCHING DEMONSTRATION."

b .  A regulatory change to 14 CFR Part 135 now allows for a similar deviation for Part 135 certificate holders.

FAA Lead =  Alaska CMO/Connie Streeter

Industry Lead = Jim Winkleman, Alaska Airlines (part 121))/ Dave Hewitt, Part 135

Desired Outcome:

a.  It was suggested that we do not change the OpSpec but consider updating the guidance to suggest that a demo may need to be done if a ditching demo has never been done with the make/model of airplane IAW Section 121.291 that is proposed for the A013 operation. 

b.  Provide similar OpSpec & guidance for the Part 135 certificate holders.

Action/Outcome: 

a.  AFS-260 has added the following statement to the OpSpec JobAid for A013 and will revise the Order 8400.10 guidance for A013 accordingly:

Issuance of OpSpec paragraphs A013 andA005 may not preclude the need for at least an abbreviated ditching demonstration.   Depending upon the circumstances, the CMO may require an abbreviated ditching demonstration before submitting the request to HQ.

b.  Dave Hewitt, Industry Lead:  Design an OpSpec A013 specifically for the Part 135 database to provide the same/similar deviation for 14 CFR Part 135 certificate holders .

c .   Jim Winkleman will provide a definition of an “abbreviated ditching demo” for passenger-carrying operations and Bill Cook will provide his input for all cargo.  The definition will be provided to the group for review at the next quarterly meeting.

13.  OpSpec C058.  Foreign Instrument Procedures.

Background:   The FAA is revising Order 8260.31 which is the guidance for OpSpec C058.  The OSWG representatives provided comments last October.

 

Industry Lead = Casey Seabright, NWA

FAA Lead = AFS-400/AFS-200

 

Desired Outcome:  Agreement between the FAA and the affected operators on the requirements.

 

Action/Outcome:  Casey Seabright updated the group on the progress of the draft order and the OSWG involvement within the TAOARC. (If you want copies of the Attachments, please request them from Casey).  The TOARC continues to work on the revision to Order 8260.31 and intends to resolve the major conflicts before final publication

 

Basically, the industry feels they are at impasse with the FAA on the revision to Order 8260.31.—Status--stalled

 

14.  OpSpec C066 , Turbojet Airplane Takeoff Operations in Tailwind Conditions Not to Exceed 15 Knots

Background:   Chuck Schramek presented (at previous OSWG meeting) the reasons for additional restrictions for 15 kt tailwind takeoff authorization.  AFM performance penalties are already restrictive.

 

Industry Lead = Chuck Schramek, Delta AirLines

FAA Lead = AFS-400/AFS-200

 

Desired Outcome:  Chuck will provide a copy of his proposal to anyone that contacts him; Connie agreed to pose the question to the FAA’s expert, Don Simpson; FAA There should also be a review the OpSpec paragraphs themselves to see if they are presented for authorization correctly.

 

Action/Outcome: 

If carrier has certification data not to restrict then they should not be restricted as it should be performanced-based; Chuck Schramek plans to have results of proposed changes within 60 days.

 

 

15.  OpSpecs C059/C060—CAT II/CAT III Lists on AFS-410 Website

Background:  Frustration in regard to the CAT II/III list not being updated in a timely manner—and the requirement for the CAT III domestic airports to be listed in OpSpec C060 before an air carrier can conduct CAT III operations at that runway

Industry Lead = Casey Seabright, NWA      FAA Lead = AFS-400/AFS-200

Desired Outcome: Hooper Harris, AFS-400 has requested that the OSWG work with him to overhaul the CAT II/III procedure authorization process.

Action/Outcome:  Casey Seabright to provided background for discussion and continues to work with AFS-410 to improve the process. 

Propose that the domestic part 97 CAT II and CAT III approaches are published they do not have to be on the website in order for the cert holder to conduct those operations; AFS-410 is anticipating having NOTAM ability.

For these runways, when the SIAP is published, it is able to be use per the effective date on the chart.  The AFS-410 website is for information purposes only;  AFS-410 may transfer the CAT II/III approvals to the regional AWOs

When AFS-260 changes those OpSpec paragraphs, notification will be;

Emailed to the OSWG and Splash screen notification

Change the paragraphs, C059 & C060

Change the AFS-410 website

Change the JobAid for C059 and C060

16.  C078.  Lower Than Standard Take-Off Minimums. (Re-rolled because of typo in the 600 RVR selection)

Background: 

At the last quarterly OSWG Chuck Schramek discussed the issue for takeoff and departure operations at Las Vegas. 

Question also about SLC:   Runway 17/35 at KSLC is not included in their SMGCS Plan so no operations below 1200 RVR are authorized on that runway.  I therefore asked Jepp to change the takeoff minimums at SLC rwy 17/35 to 1200 RVR since the runway infrastructure supports takeoffs down to at least 1200 RVR.  OpSpecs and SMGCS do not agree.  OpSpecs addresses 1600, 1000, 500 and below 500.  NO SMGCS limits to 1200 or above.  SMGCS cutoffs are below 1200 to 600, then below 600 to 300.  Allowable take off minimums are the maximum of any limits, OpSpecs, SMGCS, etc.

SLC rwy 17/35 is soon to be included in their SMGCS plan down to 600 RVR.  Once that happens I will ask Jepp to change the SLC rwy 17/35 takeoff minimums to 600 RVR. Norm Lefevre, (425) 227-1737.

 

Industry Lead = Chuck Schramek, Delta AirLines & John Cowan, United

FAA Lead = AFS-400/AFS-200

The following group agreed to get together to resolve the effect of the SMGCS issue:

Tom Schneider, AFS-420

Chuck Schramek, DALA

Kelly Dixon, Skywest

Jeppesen Representative

FAA CSET-Bob Januzzi

Jerry Ostronic, AFS-220

Dick Temple, AFS-410

Jack Wilkes, ALPA

Connie Streeter, AFS-260

 

Desired Outcome:   

a.  Resolution of the 4 RVR requirements

b.  How is official notification made to the public that a runway has 4 RVR?

 

Action/Outcome: 

John Cowan will meet with Jeppesen in February

AFS-410 will come up with appropriate change in the language for the 4 rvr systems and provide guidance on these systems other than in the OpSpecs.

This affects other OpSpec paragraphs as well.

AFS should publish a Notice with information if necessary.

17.  Other Miscellaneous Items:

a.  SMGCS plans on web

Desired Outcome Carriers would like to query the FAA (appropriate departments) to find out if it is possible to have FAA-approved SMGCS plans available to the carriers electronically.

Discussion: 

Action:  Removed from Agenda without discussion

 

b.  Viewing Other OpSpecs.

Background:   Only FAA personnel have ever been able to view all certificate holder’s operations specifications.  Because these documents are non-proprietary, there is no legal reason that this viewing must be restricted.  Until now, the air carriers have chosen to not have this feature available to them.  However, because we now have IOPSS and the certificate holders can process their own OpSpec paragraphs, the question comes up from time-to-time as to whether or not it is time to make it possible for the air carriers to be able to see other air carrier’s OpSpecs. 

Discussion: Casey Seabright would like to reopen the discussion regarding the ability to view other U.S carriers OpSpecs via the IOPSS system.

Action:   At this time, the air carriers want it to remain as it is and they can see only their own OpSpecs.

 

c.  Part 145, Repair Stations.  

Background:   Part 145 regulation revision is scheduled to be published by the end of January 2004.

Action:  Information--Part 145 OpSpecs [several but not all] will be revised when the new Part 145 rule is published—estimated to occur by the end of January 2004.  The paragraphs that change will need to be re-issued.  A revision will be published by Feb 1, 2004

d.  OPSS Portal for FAA personnel.   Portal information was given to those FAA people that were in attendance;  Connie Streeter will have information sent to the other FAA folks on the OSWG mailing list.  The Portal is only available on the FAA Intranet.

 

18.  Additional Information in regard to Operations Specifications paragraphs:

a.  Changes in Part 135

Background .  Changes in Part 135 resulted in the necessity of two new Part 135 OpSpec paragraphs. 

Desired Outcome :  To provide a standard vehicle for the eligible on-demand authorization and to provide t he eligible on-demand certificate holder a vehicle for authorization to use the Destination Airport Analysis Program.

Action :  OpSpec A057, Eligible On-Demand and OpSpec C049, Destination Airport Analysis Program, were developed and published in the OPSS.  Guidance for Order 8400.10 is pending.

 

b.  OpSpec A301, Acquisition and Mergers,

Background.  As the OPSS develops, it is necessary to revise old policy to accommodate changes that are being made.  The “500 series” of OpSpec paragraphs is now the area where we put “time-limited” authorizations and documents.  Revised guidance for acquisitions and mergers is in coordination. 

Desired Outcome.  Thus, it became apparent that OpSpec A301 was not longer considered to be “nonstandard” and that it is a “time-limited” authorization and should be moved to A502.

Action:  OpSpec A301 will be moved to OpSpec A502, Acquisitions and Mergers, because it is a time-limited paragraph.  However, in processing this paragraph the POI of the gaining certificate needs to coordinate the acquisition/merger process with the appropriate Flight Standards regional office, as necessary. 

 

c.  Part 125, New OpSpec A051

Background .  Ongoing investigations of part 125 certificate holders is resulting in the FAA revising its guidance and requirements for the operations that part 125 certificate holders can conduct.

Desired Outcome :  Part 125 certificate holders conducting operations in compliance with Part 125…..and to ensure that they are not conducting operations that must be conducted under part 121.

Action:  Adding a new paragraph A051, Currently Held Contracts, in an attempt to ensure that a part 125 operator has appropriate contracts for the kind of operations they are conducting.

 

d.  Part 121, new OpSpec A048.  Verification of Personnel for Access to Flightdeck

Background :  Originally the FAA published guidance that the electronic databases to be used for the verification of personnel for access to the flightdeck should be authorized in OpSpec A025. 

Desired Outcome :  As AFS-200 is in the process of incorporating that guidance into the Order 8400.10, it was decided that it would be better for this authorization to have its own OpSpec paragraph. 

Action:  The new OpSpec A048 will read something like:

a.  The certificate holder is authorized to allow appropriate persons access to the flightdeck using an approved method of verification of employment status and eligibility.

 

b.  The following is a description of the approved method or the manual reference that describes the approved method:

 

TEXT01

TEXT99

 

A004 statement:  The certificate holder is authorized to allow access to the flightdeck using an approved method of verification.

 

 

e.  New OpSpec B029.  Driftdown or Fuel Dumping for CFR Terrain Clearance Requirements.

Background:  Order 8400.10, Selected Practices, provides guidance for driftdown or fuel dumping.  It also states that for the FAA to authorize this, it will be authorized in an operations specification.  None was ever developed.  It was requested by the FAA that we provide an OpSpec for this purpose.

 

FAA Lead:  Bruce Montiguey….

Industry Lead: 

Desired Outcome:  The FAA provide the mechanism for authorization per guidance in Order 8400.10, Selected Practices.

ACTION:  AFS-260 put the following OpSpec B029, Driftdown or Fuel Dumping for CFR Terrain Clearance Requirements, into the OPSS as a standard optional paragraph.  The paragraph reads:

 

a.   The system described or referenced in this paragraph is used by the certificate holder for its approved driftdown or fuel dumping procedures, limitations, and data that are used to demonstrate compliance with CFR terrain clearance requirements.

CLOSED.

**********

f.  B034  

Background :  Proposal to revise B034 to accommodate PRNAV—Already use it for BRANV .

Desired Outcome :  As AFS-400/200 are in the process of developing guidance into the Order 8400.10, and to provide for the required PRNAV authorization. 

Action:  Revise B034—Proposal is planned to be available at next OSWG meeting in April 2004.

 

g.  Henceforth , if you request items for the quarterly OSWG agenda, the item will need to be submitted to Connie Streeter & Casey Seabright with the following information:

   Background:  

Industry Lead =

FAA Lead =

Desired Outcome: 

h.  It was suggested by one of the industry that if a representative of a carrier is going to write a letter to the FAA that they consider the “frame” of the letter to be very important; be careful not to shut the doors for future requests; take the common sense approach—maybe a simple phone call will suffice.