FAA/Aviation Industry Agenda for
OpSpec Working Group (OSWG) 2010-01

January 19 – 20, 2010

Tuesday, January 19:  1:00 PM-5:00 PM

Wednesday, January 20: 9:00 AM – NOON

 

Hosted by Amerijet, Miami, Florida

Wyndam Miami Airport

 

 

Tuesday, January 19, 2010—9:00 am – noon Industry Premeeting

 

 

Most items represented by the tables in the draft can be properly placed in other specs.

Meeting Schedule:

Domestic Sessions

January 19 - 20, 2010

OSWG 2010-01

AmeriJet, Miami, FL

Domestic, Joint, and International Sessions

April 20 – 22, 2010

OSWG 2010-02

Washington , D.C.

Domestic Sessions

July 20 – 21, 2010

OSWG 2010-03

 

Domestic, Joint, and International Sessions

October 19 – 21, 2010

OSWG 2010-04

Washington , D.C.

Domestic Sessions

January 19 – 20, 2011

OSWG 2011-01

 

 

Chairpersons:       U.S. Domestic

                              Steve Kuhar, FEDEX, Industry Chair

                              Steve Bush, Horizon Air, Industry Vice Chair

                              Bob Davis, AFS-260, FAA Chair

 

Meeting Location: Wyndam Miami Airport

3900 NW 21st Street

Miami , FL 33142

 

Table of Contents

 

                           Day 1                                                   Day 2

                           Topic                                          pg.     Topic                           pg.

1.  Convene                                              2

11.  Stakeholder Survey          13

2.  Status of Assigned Action Items    2

12.  WebOPSS Update            13

3.  A030                                                     5

13.  A008                                   13

4.  A025                                                     5

14.  D091                                   14

5.  A012                                                     6

15.  D172                                   15

6.  B044                                                    7

16.  C384                                   16

7.  B343                                                    8

17. B036/B054                         16

8.  B342/344 B055                                  9

18.  B032/B034/B035/C063   17

9.  A061                                                  10

19.  A003                                   18

10.  C052/C053/C074/C055              10

20.  B050                                   19

                                                                     

21.  C050                                   20

 

 

1.  Convene .

Roll call—

 

a.  Roster and Roll Call/Introductions:  Please initial to the left of your name when the roster comes to you and provide any corrections to the information.  A copy of this meeting’s Roster will be sent in a separate electronic file to all those on the OSWG email list. 

 

b.  General Information in Regard to Agenda Items:

(1) Proposed changes to a template or to the guidance that would constitute "policy changes" to an authorizing document will generally need to be presented to the OSWG and AFS-260 in “Change” format which includes appendices containing the appropriate revision to the guidance for the OpSpec/MSpec/LOA in 8900 and a sample of the proposed Template revision and/or guidance.

 

(2) If you have a proposal, the template for agenda items is available on the http://www.opspecs.com website.  For the draft template we suggest you use a recently published Change to 8900 that contains at least the 2 appendices and modify it for your proposal.

 

c.  Opening remarks

 

2. Status of Assigned Action Items.

 

Chairpersons discussion.

 

Additional Agenda Items:

 

2a.  NEW AGENDA ITEM:  April OSWG 2010-02 sponsored by FAA, scheduled for Washington, DC.

 

2b.   July OSWG – need a volunteer to host.

 

2c.   MMEL Policy Letter #98:  Navigation Databases.  Bob Davis to Brief.

This has been discussed at the MMEL IG.  Revision to 98 is in work and comments are welcome.  Draft will be available on OpsSpec.com.

FAA is revising Order 8260.19 and Order 7400.2.  When these are updated, FAA will finalize PL #98 through the MMEL IG.

See draft available on Op Spec.com > MMEL > Draft Comments > Policy Letters.

Navigation Databases:

· Process is currently in a FAA safety risk analysis.

· There is a need to coordinate charting rules to Navdata policy.

­ Current policy: A chart will not be changed unless waypoint moves more than 5 nm.

¨ It would be better if this standard were changed to 1 nm.

· A change is slated for the AIM to specify the proper method for pilots to check paper charts.


2d.  OpSpec D085 and Special Flight Authorizations.

AFS-300 is reviewing the language in both the guidance and the template for D085 and A510 (Special Flight Authorization (SFA) for Ferry Flights).

· There are differences of opinion within FAA (and within industry) on the proper method to ferry a new aircraft.

­ This same policy would also apply to an old aircraft being taken off opspecs (ferry to lease return, bone yard, etc.).

· New template is currently in draft form

­ If conflicts in the template can be worked out by all parties, guidance can then be published in the 8900.1

· The group appeared satisfied that this opspec is moving in a positive direction.

 

2e.   From AA: OpSpec A013, Operations Without Certain Emergency Equipment:   Minimum altitude restriction of FL250 for limited overwater equipped aircraft probably dates to older aircraft.  Can we re-analyze for modern aircraft capabilities?

 

Where did the min alt of 25,000’ come from?

May have been tied to:  MEA for VHF voice/nav reception?

1. Glide distance?

2. DC-9 driftdown?

The best historical documentation may be contained in some old Western Airlines documents for their east coast flights.

 

It was proposed that a new analysis be conducted to review the requirements based on current aircraft capabilities and regulations to see if the altitude limitation of 25000’ can be reduced.

 

AFS-200 will research this.

· If possible, it would be helpful to remove or revise the 25,000’ restriction.

· FAA indicated that before the 25,000’ restriction can be removed it must first be understood why it originally became a restriction.

§ It can also be surmised that if it cannot be established why the 25,000’ restriction was initially established, then perhaps the original reason is no longer applicable.


 

2f.  OpSpec C060, Category III Instrument Approach and Landing Operations.  

History: 2009-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

X

X

X

X

X

X

X

 

X

 

 

 

 

FAA Lead :  Mark Fox, AFS-410

Industry Lead:  Steve Kuhar, FedEx

 

AFS-410 plans a revision in 2010.  FedEx has submitted initial comments indicating that the paragraphs stating the requirements for different RVR values (c1 – c4) should all indicate that an operator is issued the lowest authorization, and all higher RVR authorizations are also authorized based on operational equipment for that approach.

 

FedEx comments:

 

Currently OpSpec C060 provides “Required RVR Reporting Equipment” in paragraph c. There are four categories depending on the aircraft capability:

c(1) Fail-passive Landing Systems Not Using Rollout Control Systems

c(2) Fail-passive Landing Systems Using Rollout Control Systems

c(3) Fail-operational Landing Systems Using Fail-passive Rollout Control Systems

c(4) Fail-operational Landing Systems Using Fail-operational Rollout Control Systems

 

These are obviously from least capable to most capable, with c(1) being the least capable and c(4) being the most capable.

 

c(2), c(3) and c(4) all have a paragraph (c) that states: “Operations may be conducted in accordance with the RVR limitations set forth in subparagraph c(1).” This indicates that the higher capable aircraft can always use the lower RVR capability for the least capable aircraft, i.e., Fail-passive Landing Systems Not Using Rollout Control Systems.

 

Following this philosophy of allowing use of lower capable RVR requirements, it appears that paragraph (c) of paragraphs c(3) and c(4) should read: “Operations may be conducted in accordance with the RVR limitations set forth in subparagraph c(1) and c(2).

 

Either this, or paragraph (c) should be deleted from c(2), c(3) and c(4), with the assumption that an operator is always authorized to use a lower capability.

 

As an example. The newer Boeing products have three autopilots and are certified to Fail-operational Landing Systems Using Fail-operational Rollout Control Systems. However, if they have an autopilot and or autothrottles deferred, the aircraft is now a Fail-passive Landing System Using a Rollout Control System. The current wording of the OpSpec would lead one to believe that the only option if the Operator is authorized to utilize paragraph c(4), but loses the fail-operational landing capability, is to revert back to paragraph c(1). In reality, in this situation, the Operator should be able to utilize paragraph c(2).

· C-59/60 general:

­ On initial revision of these opspecs all data input in the tables must be installed manually.

· Opspec C-060:

­ There are 4 levels of RVR requirements corresponding to 4 levels of equipment capabilities.

¨ Essentially, if an operator is authorized for a certain level of CAT III operation, if the aircraft fails down to a lower level of capability that lower level should also be authorize provided the crews are trained for the resultant operation.

¨ Proposed amendment will require internal FAA discussions.

· Table 4 is for irregular terrain runways only.

 

· C-059:

­ Current FAA policy is that CAT II operations at military installations located on foreign soil should be treated and considered as being the same as CAT II in domestic Ops.

· It may be useful if C-059 were updated to state that if the approach is DOD then it should be considered the same as being domestic.

 

 

3.  A 030, Part 121 Supplemental Operations.

History: 2010-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

FAA Lead:  Theo Kessaris, AFS-260; Dave Morton and Leo Hollis, AFS-220

Industry Lead:   Jim Winkelman (AS), John DiPaolo (SW)

 

There are approximately 66 A030 OpSpecs currently issued.  Out of those 66, approximately 15 have nonstandard language which allows for additional authorizations.  AFS-220 is seeking to rationalize the many versions of nonstandard text.  To that end, AFS-220 and AFS-260 will  work to create standard language that takes into account the different versions of nonstandard language in attempt to create a level playing field among operators and also to incorporate the recent legal interpretation regarding the carriage of the manual required by 121.139.

· It appears that FAA headquarters is trying to reign in inappropriate use of non-standard text

­ If it is apparent that similar free text is used repeatedly, then the boiler plate should probably be updated.

· All non-standard language must be coordinated with headquarters.

· FAA Would like to take the best of the non standard text and possibly use that language as either new boiler plate or as a selectable.

· Work on A-030 is in the initial phase of development.

 

4.  A025, Electronic Record Keeping Systems.

History: 2009-03

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

X

 

 

 

 

 

FAA Lead:  AFS-260 – Theo Kessaris

Industry Lead:  Casey Seabright, NWA, Jim Winkelman, Alaska Airlines

FAA is proposing to amend the A025 template include tables for specific approvals such as flight planning systems, training record repositories, and other electronic/software applications.

 

AFS-260 to brief.

  1. A025 is generally considered to be a dumping ground for many assorted items.
    1. Much of Industry’s concern regarding this OpSpec centers around Operators being required to list flight planning software applications, etc. in the OpSpec.
    2. Industry believes that FAA’s concern (whether the software performs the intended task correctly?) will not be resolved by simply listing a software application number in the OpSpec.
  2. The FAA intends ensure that certificate holder’s are using this OpSpec to list only those system  specified in FAA Order 8900.79 and ACs 120.78 and 21.35 (electronic record keeping systems, electronic signatures and manuals). The FAA will work with certificate holders to remove any other electronic systems such as those that provide calculations.
  3. In addition, after conferring with Headquarter Legal Council (AGC) the FAA (Flight Standards) has decided to create a new OpSpec as a method of granting authorization to certificate holders who use electronic systems as a means of compliance with regulations such as 121.645, 121.471 and 121.197, which require calculations of fuel, time and performance.
  4. The FAA will establish this new OpSpec in accordance with 119.49(a)(14) and 119.49(b)(14).

Guidance and an Advisory Circular will also have to be developed to provide information to FAA and industry regarding the substantiation of systems that provide calculations and how a certificate holder obtains authorization to use those systems as well as what the FAA needs to know in order to grant that authorization. 

 

NOTE: The update of A025 and the creation of the new OpSpec (A0xx?) will be delayed for at least 6 months due to the need for further coordination with AGC who has a very busy calendar due to current rule making projects.

· The primary goal for A-025 is to transform it from a dumping ground and keep it only as a depository for primarily electronic record keeping plus an optional storehouse for electronic signatures and electronic manuals.

­ References to EFB in guidance documents will be removed.

­ This project may take a while before much headway is made due to current rule making projects and the availability of AGC.

· The current A-025 template will remain unchanged.

­ A new opspec will be developed for programs such as flight planning, flight/duty times etc

­ Expect process to begin no sooner than June 2010.

 

5.  A012, Domestic Operations to Certain Airports Outside the 48 Contiguous United States

History: 2009-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

 

FAA Lead:  AFS-260 – Theo Kessaris, Leo Hollis, AFS-220, Gordy Rother MSP FSDO

Industry Lead:  Mindy Waham, Alaska;

 

Alaska requests that the FAA remove limitation and provision (4) regarding the carrying of alternate airports from October 1 to May 1.

  1. Current weather reports in the state of Alaska are as accurate as those obtained at destinations of similar size which are located in the lower ’48.
    1. What is it about Alaska that makes the weather reports less reliable?

i. FAA responded by stating they would like to see “data” to substantiate the claim that the reports are just as reliable.

  1. The OpSpec has been updated to replace the maximum 2hrs flight time from the territorial limits of the 48 Contiguous United States to a maximum distance of 2350nm or total flight time of 5 hours, which ever is the lesser.  This change was prompted by an extensive review of the A012 paragraphs currently issued to certificate holders, which revealed lack of adherence to current guidance regarding the issuance of the OpSpec.

· FAA is updating A-012 template to reflect industry current practice.

­ It was determined that current industry practice is safe and reasonable so best course of action is to make the text match.

­ Domestic rules while on flag flights would apply for the lesser of 2350 nm or 5 hrs.

­ The distance and time mentioned above is to be applied from point of departure to destination.

 

6.  B044, Re-Dispatch  

History: 2005-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

 

FAA Lead: Gordy Rother, MSP FSDO, Theo Kessaris and Leo Hollis, AFS-220

Industry Lead(s):   Chuck Schramek, Delta and Jim Winkelman, Alaska Airlines.

 

Background:  Gordy has been reviewing B044.  Currently B044 references Section 121.645(c) which should now be Section 121.645(f). Subparagraph 8 in the OpSpec states that the certificate holder shall not conduct planned re-dispatch/re-release en route operations using fuel less than the fuel supplies required by the basic provisions of Section 121.645, without a deviation.  The reason carriers use B044 is to deviate from Section 121.645 en route reserves, specifically Section 121.645(b)(2).  A quick check in the OPSS deviation database only shows a deviation from Section 121.645(b) for B043.  This should also be amended to allow for a deviation from Section 121.645(b)(2) (4) specifically and not from “1-4”. 

 

Desired Outcome: 

1) Add Section 121.645(b) to the to the deviation authority for B044 and add the deviation from Section 121.645(b)(2) for the 10% calculation.  Have ALL holders of B044 amend A005 to include this deviation.

2) Dispatch group should do some work on the text of B044 in an effort to clarify the text IAW AFS-220 policy for alternates and fuel calculations as previously discussed with Jerry Ostronic.

 

Gordy stated that this paragraph needs to be reviewed by the industry leads

 

DISCUSSION:   The FAA will propose a rewrite of the paragraph to clean up the language and put in the correct FAR references.  More of the guidance will change than the paragraph itself.

 

ACTION/Outcome:

  1. B-044 is essentially finished but will still need a few adjustments from what is now currently on opspec.com.
  2. Outstanding comments will be handled in the guidance materials rather than within the OpSpec.
  3. Comments on the re-dispatch event:
    1. There was ambiguity on whether you should upload a new flightplan to the flight deck for fuel burn based on actual weight.
    2. At the re-dispatch point is there the minimum fuel need by FAR to continue?
  4. Andy newcomer (UPS) has volunteered to review the proposed guidance.
  5. More discussion will continue off line.
  6. This OpSpec is not closed.

7.    Final version of OpSpec along with guidance to be inserted in 8900.1 and an accompanying NOTICE posted on opspec.com

· FAA indicated that all comments received have been incorporated into either the latest B-044 template or in the supporting guidance documents.

­ Guidance documents currently posted are still currently a work in progress.

· When arriving at the re-dispatch point a fuel reanalysis is required. The method whereby that reanalysis is calculated and communicated is approved by the CHDO.

· An operator must have an internal fuel monitoring program:

­ The guidance regarding the fuel monitoring program is a work in progress.  A workgroup consisting of FAA and industry is forming in March to collaborate on the re-write.

­ The guidance will be written to address all operators, e.g. well established major carrier vs. a carrier who has a fleet of 10 aircraft and an inexperienced dispatch workforce.

· FAA stated that comments on opspec templates and guidance materials are very helpful to create a quality end product and to help fill unintended holes.

 

 

7.  OpSpec B343, Fuel Reserves for Flag and Supplemental Operations

History: 2005-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

 

FAA Lead: Gordy Rother, NWA CMO /Jim Ryan and Leo Hollis, AFS-220, Dave Maloy, AFS-430, Dave Burnham, UALA CMO

Industry Lead(s):  Steve Kuhar, FedEx

 

Background:  OpSpec B343 is a nonstandard authorization that has been granted to only a few international air carriers.  This is a performance-based authorization using fuel burn data and statistical analysis within certain criteria as justification. Although the airlines are not experiencing any problems or concerns, a single (minor) low fuel event caused the FAA some concern. Hence, for now the FAA will not consider allowing less than a 5% fuel reserve and, until recently, was not granting any new approvals.

 

Action/Outcome:

Data was provided by FedEx small group.  Analysis showed FEX had a constant underburn, but not as a result of inaccurate flight planning.  Underburn was due to conservative business and operational model.

Question is how do you evaluate the accuracy of the flight plan using a performance base model?

Gordy Rother & Steve Kuhar will continue to work establishing a true mathematical model.

 

FAA has identified a level of safety and would like to tie it to a level of risk.  So, Miter will look at it for them and see if they can support this number.  It needs to be performance based and needs to be validated.

 

ICAO/FAA is working on fuel planning in annex 6

Additionally, work is in progress on “performance based fuel planning”.

  1. The FAA and industry are looking at the European Union metrics for justifying a 3% fuel reserve.
  2. Collection of useful and sufficient data is a major challenge.
  3. B-343 is currently on indefinite hold.
    1. FAA is not currently accepting any new applications for this spec.
    2. FAA will look at the EU numbers to see if they are valid.

i. More Data is sought by FAA.

  1. Questions:
    1. What fuel reserves do part 129 carriers use when operating in the U.S.?

i. Do they use EU fuel reserves or those amounts required by FAR?

    1. FAA should define more clearly exactly what data is needed?

i. En route portion (top of climb to top of descent or CLASS II phase)

1. 121.647 fuel only applies from top of descent to landing.

    1. FAA is willing to show all data that has been collected so far to any carrier who wishes to see it.

· The Industry lead had nothing new to report.

· General question from the group:

­ When will this opspec be opened up to other carriers?

¨ FAA indicated that they will try to get something rolling on this in the next couple of months.

   Based on consensus of the ICAO/IATA working group that is addressing performance based fuel. The FAA indicated that further authorizations under the current B343 template would not be entertained.

 

8.  B342/344  ETOPS /B055, North Polar Operations

History: 2007-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

X

 

 

 

 

 

FAA Lead:  Jim Ryan and Dennis Mills, AFS-220, Theo Kessaris, AFS-260

Industry Lead:  Steve Kuhar, FedEx

 

BACKGROUND:   The previous B042 is now four separate Operations Specification templates.  There are two for Part 121 and two for Part 135 Operations, based upon the number of engines the airplane has.  They are non-standard OpSpecs and are numbered B342 for two-engine operations and B344 for operations with aircraft with more than two engines.  A draft of these was briefed at the last two OSWGs and has been posted to the web site.

 

B042 will be discontinued and replaced by B342 and B343.

 

These four OpSpecs were previously presented with no apparent objection; with the exception of Aircraft Make/Model/Series being duplicated in both ETOPS OpSpecs and D086.  This issue is covered in the instructions contained in the 8900.1.  The applicable part of the handbook as previously reviewed and accepted by the OSWG. 

 

Theo Kessaris has developed the Notice and 8900.1 guidance and the OpSpecs will be rolled as soon as the guidance has completed coordination.  The guidance is currently in coordination and should be published soon.

· Date of compliance for operators to change from B-042 to B-342 is 60 days from Jan 11th (date of notice 8900.106).

· If there is no changes are being made to B-042, the process to authorize B-342 will be streamlined.

· WebOPSS will not auto-load data.  Data must be loaded manually.

· It was again reiterated that coordination with headquarter is not required when making changes to only the ETOPS alternate table.  However, all other changes to this opspec do require coordination.

­ This detail is specified and supported within the guidance documents.

 

B055, North Polar Operations.  This OpSpec has been presented for comment on two previous occasions.  The only item that was presented for discussion was paragraph (8) which requires airplanes be equipped with a minimum of two cold weather anti-exposure suits so that outside coordination at a diversion airport with extreme climatic conditions can be accomplished safety.

The rule gives some relief during those periods of the year when the seasonal temperature makes the equipment unnecessary.  Without scientific data to stipulate a specific period of time when temperatures will remain above hazardous levels, this relief must be given on a case-by-case basis and not included in the operations specification.  

This is an MEL item and should be pursued through that process.  Since no further data has been presented, we have drafted 8900.1 guidance and are preparing to roll the OpSpec.

· No discussion

 

9.  A061, Authorization To Use An Electronic Flight Bag

History: 2009-03

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

X

X

X

X

X

 

 

X

 

 

 

 

FAA Lead: Steve Morrison, AFS-400

Industry Lead(s): Jackson Seltzer, CO

 

Currently only requires Class 3 be listed.  However, once the trial phase is completed for a Class 2 unit, it must also be listed in the Ops Spec.  Where would this be listed?  This needs to be added to the agenda for rewrite. 

Steve Morrison, AFS-400, is planning to update the template to include Class 1 and Class 2.

FAA feels they need to know what specific equipment operators are using for EFB’s and to also monitor for possible improper installations.

 

Update:  A061 has been sent for FAA coordination.  All Class 2 and Class 3 EFBs, as well as Class 1 with Type B software, will be listed in the table in A061.  They need to be listed by model, not by individual unit (50 identical units need only be listed once to denote authorization for that model).  The final version is on OpSpecs.com.

· Template should be done by the April to June timeframe.

· Industry would like to keep this opspec on the agenda until published.

 

10.  C052/C053/C074/C055, Basic Straight-in Non-Precision, APV, and Category I Precision Approach and Landing Minima– All Airports.

History: 2008-03

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

X

X

X

X

X

X

 

X

 

 

 

 

FAA Lead :  Mark Fox, AFS-410, Cathy Majauskas, AFS-470

Industry Lead:  Stanley Finch, Steve Bush

 

C052/C053/C074 will be merged. 

 

8400.13D is closely related to these OpSpecs – signed on October 22, 2009.

 

Will need to explore avenues for reducing T/O minima at certain airports – C078/SMGCS to be addressed in 2010.

 

CURRENT OPSPEC C052 AND RELATED REGULATIONS AND GUIDANCE.

 

An issue has recently come up in the Southwest region involving air carriers who have been issued OpSpec paragraph C052. Specifically, what are the regulatory and policy requirements with regard to recurrent training and checking requirements for pilots using standalone GPS units to conduct GPS and/or RNAV (GPS and GNSS) approaches?

 

ACTION/Outcome:  AFS-470 is continuing to rewrite the Inspector guidance for OpSpec C052.  The old Job Aid and Inspector guidance will be combined.  We are not recommending a new Job Aid for this specific OpSpec.

The OpSpec will also change to include the requirement for GPS approaches during recurrent training, and clarification of RNP APCH (AR).

Questions:

1. Must GPS approaches be demonstrated on every recurrent training or check ride?

Answer:  No; however, a sampling of all non-precision approach types which an operator is approved for should be accomplished.  It is expected that over the course of time an operator will sample each approach non-precision approach type equally.

2. For operators who have panel mount GPS units, must the GPS approaches sampled during recurrent training and check rides use the specific make / model of GPS unit that is installed in the aircraft flown?  What if the operator has several different types of GPS units?

It is not disputed that FAA has a legitimate argument, for those authorized, to sample GPS approach types during recurrent training and checking events, however, it is legitimately questioned by operators, “why must that check be conducted with the identical make/model/series panel mount GPS unit”?

Pressing this requirement places unnecessary burden on those operators affected.  This requirement will also have the effect of pushing operators away from space-based Continuous Descent Approach operations back to the old ground based approach types with the conventional step-down method of descent to minimums…A direction that clearly the FAA and industry would both like to avoid.

 

FAA needs to articulate to industry exactly what their concerns are regarding GPS approaches so that a collaborative solution may be found.

 

In the mean time, Industry would like to explore the following alternatives:

1. Would it be possible to address the FAA’s concerns through the use of some type of training device?

2. Explore possible specific deviation avenues to the rule thus allowing for operators to continue conducting GPS approach operations?   Industry would like to arrange a meeting with FAA (possibly AFS-210/AFS-250) and anyone else concerned to talk through this issue and to explore possible resolutions 

 

C052 guidance has been re-written to reference regulatory requirements and the requirements for training programs:

 

D. Crew Training and Qualification.  Crew training and qualification for all authorized instrument approach operations should meet the requirements in Volume 3, Chapter 19, Training Programs and Airman Qualifications; AC 120-53 (as revised); Crew Qualification and Pilot Type Rating Requirements for Transport Category Aircraft Operated under FAR Part 121; 14 CFR parts 61, 91, 121, 125, 129, and 135; and Advanced Qualification Program requirements, if applicable.

 

AFS-210 will address recent comments from NBAA and Jet Logistics.

 

Other aspects of C052 discussed:

1. Inspector guidance for C052 currently is vague and confusing.

2. The OpSpec is being rewritten to reflect the requirement to sample all NP approach types.

 

C053/C074 Current

 

A revision to C074 should be available by the next meeting.  The 15 knots will then only be a limitation below 1800 RVR.  1400 RVR requirements will be included in the initial draft.

 

Changes to the text that is currently in C053 will implement harmonized CDFA minima when procedures are produced based on TERPS 20 criteria.

 

AFS-410 will distribute a list of runways for reduced lighting CAT II operations (CAT II on Type I, Special Authorization on CAT II) which require equipment upgrades.  We’re looking for support of a business case for replacement of ground equipment at specific sites where upgraded service is desired, in priority order.

 

1. The new draft should have the 15 knot crosswind limit removed for 1800 RVR (Reduced Precision CAT I landing Minima).   The current C-052 draft appears to have this limitation removed.

2. A selectable will provide for 1400 RVR (Special Authorization CAT I).

3. New template will contain a visibility penalty for non-precision approaches if a Continuous Descent Final Approach (CDFA) technique is not used on non-precision approaches which have been recalculated using TERPS 20 criteria.

a. 1/8th for CAT A or B aircraft, or ¼ mile decrement for CAT C or D aircraft.

 

b. Lyle Wink briefed OSWG on this harmonization agreement in 2007.

 

C052 is in FAA coordination, expecting signature prior to April OSWG meeting.

 

· Draft notice is available on opspec.com.

· There is no plan to chart CDFA penalties on U.S. government produced approach charts. It does appear, however, that other commercial chart suppliers will publish these penalties.

· No discussion on NBAA’s paper regarding checking requirement with each specific make & model GPS unit/aircraft combination.

­ If NBAA would like to pursue this further in the OSWG forum, there should be a formal request to place it on the agenda.

 

OpSpec C055 issues:

C055 has been adjusted to state that one piece of concrete will suffice and this will align it to the ETOPS AC.  We also modified the “Alternate Airport IFR Weather Minimums” table to align it with the ETOPS Alternate Minimum table, as recommended by the ETOPS ARAC.  Several questions have been raised regarding the table.  These items have been addressed and accepted by the OSWG and the template has been updated.

 

OpSpec C055 is in FAA coordination – expecting signature prior to April meeting.

· WAAS language added to draft.

 



 

Wed., January 20

9:00 – 12:00

 

 

11.  Stakeholder Survey.   The FAA has asked each meeting participant to fill out an OSWG Customer Survey.  Results of previous survey will be available at the next OSWG meeting.

 

 

General discussion:

Opspec A531 is designed to be used domestic disasters (hurricanes, etc.) allowing operators authorization to go into TFR’s.

With disaster relief efforts underway in Haiti it was necessary to create A-529 to provide a vehicle to authorize air operations by U.S. carriers in foreign disaster areas (no TFR).  FAA personnel associated with and responsible for creating and activating this spec should be commended for their efforts and a job well done.  This opspec is an example that the system can work in an efficient manner when the need is great enough.  Fortunately, it is a rare event that makes the need this great.

 

12.  WebOPSS Update.  Bob Davis, AFS-260, to brief.

The general feeling in industry is that the WebOPSS interface is less than optimum.  This was observation not disputed by any present in the room.  Bob did indicate that he (AFS-260) meets weekly with the contractor in an effort to improve the system. 

There have been some successes with “hot fixes”…Others are often more difficult to address (due to hard coding in the software, etc).

AFS-260 has limited ability to pursue some fixes due to budget issues (money has run out).  A short term contract is being worked on for follow-up fixes (phase 2).

Misc. issues:

· Could a “SORT” function be created?

­ Software not currently set up to do this.  Perhaps possible in the future.

· A-034      No allowance for additional AQP programs (i.e. Dispatch AQP).

­ Phase 2 fix…Requires additional money (pacing item).

· Document compare function does not work well.

­ Currently the document compare looks only at text, not data…Fix in work.

· Contract for phase 3 upgrades has been awarded to Mitre.

· Can WebOPSS be speeded up?

­ Maybe…Type in the IP address of 162.58.34.64

­ Know one was sure why using the IP address would make the program run faster?

¨ May it has something to do with the domain server?

¨ Fire walls?

¨ If typing in the IP address is indeed helps it would be good to know why.

 

 

13. A008, Operational Control

History: 2008-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

 

 

 

 

 

 

X

 

 

 

 

 

FAA Lead:   Dennis Pratte, AFS-250

Industry Lead:   Mike Nickols, NBAA

 

We need to revise A008 to state all required management personnel must be direct employees.  The current version says, at least one must be a full time employee.

 

AFS-250 is currently working on revising the template and the guidance.

 

The FAA is still working on the guidance to match the rule.  A direct employee is not an agent for service, but someone who works for and is paid by the operator.  This employee does not have to be full time.

 

The issue of what is a direct employee is addressed by InFO 08005:

 

http://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2008/info08005.pdf

 

CLOSE. Published as N8900.95, dated October 19, 2009.

No substantial discussion

 

14.  D091, Substantial Maintenance and all other Outside Maintenance Providers

History: 2009-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

FAA Lead: 

Industry Lead:  Mike Keller

 

Published as N8900.102, dated November 25, 2009

· ATA gave FAA a list of 22 questions regarding the new D-091.

­ This list has been subsequently added to and is now up to approx. 46 questions (Send any questions to tim.holt@faa.gov).

¨ Questions may be viewed on the AFS-300 website:

Ø AFS-300 > Flight Standards Service > Air Carrier Maintenance Branch > Resources > Questions.

­ AFS 300 has addressed in writing several of the questions.

­ Industry essentially needs answers to all of the questions in order to proceed.

¨ Once questions are answered and the requirements fully understood, then the process for an operator to comply with those requirements can be initiated.

· Even if all questions were answered today, there would still not be enough time for many operators to comply by the mandatory compliance date of Feb 23rd, 2010.

· Is there an opportunity for an industry wide extension?

­ FAA is currently honoring extension requests on a case by case basis.  There will not be a blanket extension given.

­ Letter requesting an extension must state Reason Cause, facts and input from CMO.

­ FAA was required to contact operators within 10 days.  If this letter was not received within the mandatory 10 day window, that would be cause for an extension.

Misc. Discussion:

· Definition of heavy Mx is no longer tied to the scope or complexity of the work being performed.  Instead, it is purely a time-centric (72 hr) item.

­ This can be problematic, especially when the time involved is unknown.

· There is a meeting with Steve Douglas at ATA headquarters scheduled for February 4, 2010 (1200-1600?).

· Essential Mx = on wing RII

­ RII lists are vastly over encompassing for many operators.  It would be a good exercise to reduce the size and scope of the RII lists down to what is truly RII by regulation.

 

 

15.  D172 Incorporation of Aircraft Electrical Wiring Interconnection System Instruction for Continual Airworthiness into the Operation’s Maintenance Program/ CAMP.

History: 2009-03

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

FAA Lead:  Fred Sobeck, Tim Holt, AFS-300; Dr. Gary Layton, AFS-50

Industry Lead:   Tom Taylor FedEx

 

Part 129, § 129.111 require that operators of transport aircraft with a type certificate (TC) issued after 1958 and a seating capacity of 30 or more seats or a max payload capacity of 7,500 pounds or more incorporate inspections and procedures for the electrical wiring interconnection systems (EWIS) into their maintenance programs by March 10, 2011.

 

The EAPAS/FTS rule requires that operators must submit EWIS maintenance program changes and any later EWIS revisions to the principal inspector (PI) for review and approval. The PI will approve the EWIS maintenance program changes, which include the operator’s initial incorporation and any revisions, on OpSpec D071. Guidance for both principal maintenance inspectors (PMI) and principal avionics inspectors (PAI) to determine operator compliance is contained in Order 8900.1, volume 6, chapter 11, section 24, Evaluate/Inspect Part 121 and 129 Operators’ Electrical Wiring Interconnection System Instructions for Continued Airworthiness/Revisions. The FAA will publish draft Advisory Circular (AC) 120-EAPAS, Incorporation of Electrical Wiring Interconnection Systems Instructions for Continued Airworthiness into an Operator’s Maintenance Program, as a method of compliance for operators.

 

Status: in coordination.

 

AFS-300 to brief.

· AC is complete

· All available ICA’s will be available by end of March (ICA = Instruction for Continuous Airworthiness).

· The OEM will supply a source document to the operator which then can be referenced for task, interval, location, etc.

· It is felt that guidance is not clear and industry is seeking assistance to understand the requirements.

­ FAA has taken an IOU on this

· Many Industry reps present view this Opspec as being unnecessary and provides no value.

 

16.  C384, Required Navigation Performance Procedures with Special Aircraft and Aircrew Authorization Required.

History: 2007-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

FAA Lead:   Cathy Majauskas, AFS-470

Industry Lead:  Mindy Waham, Alaska;

 

There seems to be some inconsistencies with the limitations in Table 1.  Some carriers have a limitation on RPAT / RPA approaches, while others don't have any limitations.  Some of the early obtainers of this opspec were given limitations that were not given to later applicants as the guidance material changed over time as RNP SAAAR developed. 

 

Bob Davis said to apply to POI to remove limitations.  The current limitations that we have are selectables in the new system.

 

There is no guidance on what is required of a carrier to remove the limitation(s).

 

It appears that the first carriers that applied for it have the limitations while others that were a couple of years later do not.  By then the draft AC 90-RNP was replaced by AC 90-101 and it did not mention RPA or RPAT so Nothing was limited in the OpSpec.

 

As the industry lead in RNP it seems odd that Alaska has limitations that Other carriers do not (Continental, American).  Did they provide anything additional in their original applications that we would need to refer to in an request to amend ours?

 

N8900.99 was published.  However, FAA still working on details of releasing OpSpec template and 8900.1 Handbook guidance.

· No Update provided from industry.

· New templates now available on opspecs.com.

­ Updates guidance for foreign approaches

 

 

17.  B036/B054, IFR Class II Navigation Using Long-Range Navigation Systems (LRNS)

History: 2009-01

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

X

X

X

X

X

X

 

 

X

 

 

 

 

FAA Lead: Cathy Majauskas, AFS-470, Mark Fox, AFS-410

Industry Lead(s): OJ Treadway, AA

Background:

 

Discussion:  AFS-470 is in the process of combining OpSpecs B036 and B054 to make a new B036 – IFR Class II Navigation Using Long-Range Navigation Systems (LRNS).    Work continues with this effort.

 

From AA:  Para b.(4) of B036 requires position check using airways nav facilities or ATC radar prior to entering Class II airspace.  I believe this is an outdated requirement from the days of LORAN and OMEGA.  Modern GPS navigation systems are much more accurate than either ground navaids or ATC radar.  It doesn’t make sense to fix a position using less accurate methods.

Industry would like to explore the possibility of adding several alternative methods of validating an aircraft’s position when transitioning into Class II navigation and also when transitioning back to Class I that could be used in addition to those methods currently listed in the opspec.

FAA seemed to be open to this idea.

 

These Specs are also associated with the consolidation effort in item 4 above, however, little progress to report at this time.

· B-036 is for class II navigation using multiple long range systems.

· B-54 is for class II operations using a single long range system.

· Objective is to combine all Class II navigation into on opspec.

­ Simpler said than done

¨ Class II rules include more than just nav systems (i.e. fuel requirements).

¨ Looking at ICAO rules may help to re-define Class I & Class II

· This project appears to be moving in a positive direction.

 

 

18.  B032/B034/B035/C063, IFR Class I Terminal and En Route Navigation Using Area Navigation Systems

History: 2007-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

X

X

X

X

X

 

 

X

 

 

 

 

FAA Lead: Cathy Majauskas, AFS-470 , Mark Fox, AFS-410

Industry Lead(s): Rich Yuknatvich, American & Jim Winkelman, Alaska

 

Background:   B034 is populated with terms of BRNAV or PRNAV, which only apply to Europe.  Recent flight plan filing changes (e.g., Japan) require the annotation of RNAV 1, 2, 5 etc for departure, arrival and en route. It seems this may be the time to consider other terms such that the paragraph will give a broader authorization.  Additionally, paragraphs B034, B035, B036, and C063 seem to overlap in some areas while leaving gaping holes in others.

 

DISCUSSION:   AFS-470 was in the process of combining OpSpec B034, B035, and C063 to make a new B034 – IFR Class I Navigation Using Area Navigation (RNAV) Systems.  An intermediate step was necessary to update B034 with the addition of RNAV 5 .  This is in coordination now and we will continue with the combining of the three OpSpecs when the new B034 is published.

 

The FAA wants to combine all RNP into two groups:  B034/B035/C063 all with class I, and Class II B036/B054.  This would group into a nav class.  Steve Bush will work with the FAA on this.

 

No tangible progress on this effort since last meeting due to the need for FAA to first update B-034 to include RNP-5 operations.

The intent is to combine all en route and terminal RNAV opspecs into possibly just two:

1. RNAV Class I operations.

2. RNAV Class II operations.

· C-63 is being updated to correspond with current AC guidance (90-100A)

· Intent is to eventually merge these opspecs, however in the meantime they must be updated to match current rules individually.

 

 

19.  A003, Airplane/Aircraft Authorization.

History: 2009-04

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

X

X

X

 

 

 

 

X

 

 

 

 

FAA Lead:  Jack Pinto, AFS-260

Industry Lead:   Jim Winkelman, Alaska Airlines

 

Changes to guidance to clarify demonstrated seats versus certificated seats.

 

A draft is posted on OpSpecs.com and it is ready for internal FAA coordination.

 

Jack Pinto to brief.

· Operational use Column has been removed from template.

­ Removing this column causes some possible negative impact for Intl carriers as foreign authorities use this to authorize ops in their country.

­ Even though these columns are redundant, they are helpful to the Intl carriers since ICAO looks at “what can a specific aircraft do” vs “what can the operator do.”

Post OWSG comments from Jack Pinto, AFS-260 (2-3-2010)

o 119.21(a)(1) – Domestic (D)

o 119.21(a)(2) – Flag (F)

o 119.21(a)(3) – Supplemental (S)

o 119.21 (a)(1),(2),(3) –  (D) (F) & (S)

     Eliminating the “Kind of Operation” column will remove the confusion that now exists with the authorization hierarchy question with regard to the “Kind of Operation” column.

 

· Question from the group: 

­ How hard is it to remove a column? 

¨ Answer:  Each column is a data island.  Trouble starts when the structure of a data island is hard coded by the Contractor.  However, FAA should be able to remove this data island (column).

¨ FAA looking at removing Cert seats and Installed seats columns.

¨ Industry would like to remove “installed seats” column.

¨ FAA’s Thought is that with the 3 columns for seats gives a more full picture

¨ Regulatory driver, however, is the number of FA’s and demonstrated seats.

· Question was asked:  “Does FAA require foreign carriers to list in their opspecs any authorizations by N-Number as opposed to by fleet or M/M/S?

 

 

20.  B050, Authorized Areas of En Route Operations, Limitations, and Provisions.

History: 2009-03

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

X

X

X

X

X

 

 

X

 

 

 

 

FAA Lead: Jack Pinto, John Blair, AFS-260

Industry Lead(s): Chuck Schramek, Delta

 

The B050 areas of en route authorization were reorganized for the new WebOPSS application.  The areas of en route authorization have been consolidated, reducing the number of areas from 73 in OPSS/IOPSS to 33 areas in WebOPSS.

· Sample of the WebOPSS B050 showing all available areas attached

· Listing of countries within each area attached

· Order 8900.1, Volume 3, Chapter 18 being updated to reflect the reorganized areas.

 

The B050 WebOPSS area redesign is complete.  Draft Notice, Order 8900.1 guidance and sample B050 template is in coordination with AFS-140. The following draft documents are posted on Opspec.com for comment;

Note:  These draft documents are also available for reference in WebOPSS under guidance tab.

· Total number of “arias of operation” has increased from 33 to 34.

­ Redesign of the areas of operations for WebOPSS is now complete.

¨ Digitized map will be “hot linked” into the guidance documents.

· Changes are close to being ready for FAA internal coordination.

 

 

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

History: Standing Agenda Item

Database:

91

91K

121

121/135

125

125M

129

133

135

137

141

142

145

 

 

X

X

 

 

 

 

 

 

 

 

 

FAA Lead:   Dave Morton, AFS-220

Industry Lead:  

 

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, a Notice will be published, 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.

 

Desired Outcome

 

Notification to certificate holders:

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

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

¨ Change the Special PIC airport List on the http://www.opspecs.com website:

http://www.opspecs.com/ops/SpecialPICAirports/SpecialAirportListRevisionJun2008.doc

 

CURRENT for this Agenda:  

 

Current list is dated July 2009. 

 

American Airlines is working on one Russian airport (Katenburgh) for removal.  They have submitted all required information.  Analysis is available on OpSpecs.com. 

 

Dave Morton, AFS-220, indicated that this will be finished soon.

· Request for removal was by AA was made over a year ago.  Industry is curious how long this process should normally take.

­ FAA is currently creating a process for doing this.

­ In regard to removing airports from the special PIC qualification list, current guidance documents are vague on identifying who is responsible for this task.

­ Question was asked:

¨ Why would a company nominate an airport to be placed on the special qualification list? – Not sure.

It appears, however, to this vice-chair that in the spirit of working together, if Industry wishes for a legitimate voice in removing airports from the special qual list then an honest assessment must also be made regarding airports that do have special considerations for safe operations.  For FAA and Industry to work collaboratively requires that the door swings both ways.

 

 

 

Miscellaneous Discussions:

1. C-300.

a. Mandatory rollover 2008 or 2009 depending on specific template?

b. Original issuance of C-300 for an operator should have been coordinated with Head quarters.

c. Required an operator obstacle assessment.

d. Several operators were issued this opspec inappropriately (no coordination with DC).

e. FAA has allowed operators who hold the old C-300 to continue using it (evidently, there is no longer a compliance date for a mandatory change-over).

i. If a carrier ever update’s their old template, it will not be available for revision and therefore they would have to use the new opspec and comply with the associated requirements.

1. Approx half of the operators who had held C-300 have discontinued it.

f. If an operator wishes to update an existing C-300, their choices are:

i. Fly an overlay of the approach via FMS while monitoring ground based guidance, or

ii. Comply with the current requirements of the opspec, or

iii. Work out a special agreement with headquarters.

1.  Need to get Mark back into this conversation.

 

2. D-095

a. Industry would like to make “D” category MEL’s extendable (120day/extendable).

i. EASA allows this.

ii. This request may have merit; however, will need to be formalized though the proper OSWG processes.

 

 

3. PDX ILS

a. Requirement for monitoring continuity of service for CAT II/III started about 3 years ago.

i. Order JO-6750.57A specifies service specs. Fulfills Annex 6 ICAO requirements.

b. See presentation by Mark Fox on opspec.com.

 

 

4. Operator alert!!...IFLPA bulletin requiring TCAS to be operational (no MEL relief) in Japan, China and India airspace.

a. Possible fine (large $$) for non-compliance.

 

 

5. A-999

a. Industry would like to add to A-999 agenda.

b. How is this opspec intended to be used?

i. A-999 provides a certified true copy of the AOC in the ICAO format.

ii. The digital signature makes the A-999 template a “certified true copy”.

1. Written signature is not required.

2. Name of the original signatory of any specific spec is not required.

3. Notary is not required and provides no additional value.

iii. Guidance documents are now published.

iv. End goal is to develop a database that is compatible with ICAO.

c. Question from Industry:

i. Does FAA have similar requirements for 129 carriers?

1. Curious if there is a little quid-pro-quo in regard to the requirements coming from ICAO.