Meeting Minutes for the Aviation Industry/FAA OpSpec Working Group (OSWG) 2003-04
October 21 (Tuesday, 1 pm-5 pm)/22 (Wednesday, 8:30-noon), 2003
FAA host (Washington, DC)
AMTI HQ, Floor 11
1515 Wilson Blvd ,
Arlington , VA
January 20-21, 2004
American Airlines - Dallas
April 27-28, 2004
ATA - Washington, DC
July 20-21, 2004
Comair - CVG
October 19-20, 2004
v Casey Seabright donated a new gavel to the OSWG chairs. Thank you, Casey! Casey Seabright will become the Industry co-chair in January. Please provide Jim Johnson with the names of nominees for the Vice-chair.
v Dave Burr gave an update on the web-based OPSS. It is on schedule for FY04 if the money is allocated.
v Jim McKie provided an update to the Air Transportation Association (ATA) Counsel Committee review. In further discussions the OSWG, as an industry group, is considered to be outside direct ATA guidance. The ATA has indicated that groups such as the OSWG should continue as an industry working group if the ATA decides not to provide the banner as an “ATA Group”. The ATA agrees that the OSWG provides an important forum for FAA/Industry discussions but is looked at as providing more individual air carrier positions than an official “ATA position” per se. It was expressed that if an ATA position was found to be necessary on any particular issue, that the ATA members could pursue that through normal ATA protocol.
III. OPSPEC PARAGRAPHS DISCUSSIONS:
1. OpSpec A013
Discussion: An FAA CMO determined that there was a need for a ditching demonstration (Section121.291) 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.”
ACTION: 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.
2. OpSpec C050/C067, Special PIC Qualification Airports—14 CFR Section 121.445
Discussion: The new paragraphs C050 has been issued with related guidance found in HBAT 03-07. Draft paragraph C067 has been available on Opspecs.com for comment. Status of the proposed paragraph and comment will be reviewed.
ACTION: HBAT 03-07 with new Opspec C050 and related guidance was issued effective 10/16/03. The FAA will formally cancel the Advisory Circular. The draft guidance and revision to C067 is on the www.opspecs.com website for comment. All comments should be submitted as soon as possible.
3. C058 Special Restrictions for Foreign Terminal Instrument Procedures
Discussion: OSWG representatives have been participating in conference calls with the Terminal Area Operations Aviation Rulemaking Committee (TAOARC) and FAA to resolve issues with the draft Order 8260.31. OSWG comments were presented to the FAA through the TAOARC for review and recommended action. The FAA has requested further comments with suggestions of specific language.
ACTION: The OSWG representatives to the TAOARC met Monday pm and Tuesday am to consolidate the OSWG comments. The comments were reviewed and submitted to the TAOARC by the deadline of October 31. Closed.
4. OpSpec C059/C359, CAT II Approach Authorization
Discussion: Jackson Seltzer 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.
Steve Kuhar stated that he was confused about the language in subparagraph b(1)(a)(i)—Required 6-6-6RVR Fail Passive—No Rollout.—The confusion is that: Rollout cannot be inop but can be zero if rollout is inop, cannot make approach.
ACTION: Dick Temple, AFS-410, explained that the other 2 RVR are controlling for the fail passive; he advised that we review the RVR order and AC to see what they say in regard to “Operative” since that is the language for relevant RVR. Dick Temple agreed to take the issue off-line with Steve.
5. E096, Weight and Balance/ E001, Wt. & Balance Control Procedures for All Cargo Operations
Discussion: Darcy Reed, AFS-300 is addressing the possibility of E096 being spilt into 3 separate paragraphs. Review any change to the status or available drafts of E096. HBAW 03-06, Operations Specification E001 Weight and Balance Control Procedures for All Cargo Operations. This bulletin has since been withdrawn.
ACTION: Darcy Reed did not attend as the policy is still in discussion. Nothing to report at this time. Follow-up to be provided at January 2004 meeting.
6. OpSpec B055, Polar Operations
Discussion: Chuck Guy (UAL) proposed an amendment to B055 to allow dispatch without polar suits when temperature at en route alternates is forecasted to be at or above 20 degrees F. Eric Van Opstal from the FAA addressed the issue.
ACTION: Question withdrawn. Closed.
7. OpSpec B042 a. (4) (ETOPS alternates) .
Discussion: Bruce Montigney (FAA) proposes revising the OpSpec. He states that if a carrier is authorized ETOPS of 120 minutes or more, there should not be a reason to issue b. (Special Provisions for Western Atlantic and Caribbean Sea ER-OPS if authorized). He believes that this section should be issued to a carrier who only conducts ER-OPS with a maximum diversion time of 75 minutes in this area. All other ETOPS operators would be covered by referencing in B050, paragraph B042 for the Western Atlantic, Caribbean, and Gulf of Mexico. He contends that “b.” should be a selectable paragraph. (Alternate airports listed in C070 [as a blanket statement] may not meet all of the requirements for an ER-OPS alternate.) AFS-200 did not agree to remove the statement, “The certificate holder shall not use any other ER-OPS en route alternate airports.”
ACTION: AFS-220 and Eric Van Opstal agreed to revise subparagraph a (4) in B042 to read: “ER-OPS En Route Alternate Airports. In addition to a flight’s departure and destination airport, regular, refueling, or provisional airports specified in paragraph C070, the certificate holder is authorized to use the ER-Ops en route alternate airports listed below. The certificate holder shall not use any other ER-OPS en route alternate airports.”
At this time, it is not possible to make subparagraph b, Special Provisions for Western Atlantic and Caribbean Sea ER-OPS, a “selectable”—but if it is not authorized, N/A must be entered in both of the cells. Maybe for web-OPSS it can be. We will put it on “the list for web-OPSS considerations.”
8. OpSpec C089/C090, RNP RNAV Instrument Approaches
Discussion: Review and discuss the proposal from Jackson Seltzer and Jim Enias to incorporate RNAV RNP authorization as a selectable item in paragraph C052. Jim Enias presented a sample of his proposal for OpSpec C052 to incorporate “RNAV (RNP)” and “RNAV (RNP) LNAV/VNAV” approaches.
ACTION: Those present are to review his proposal and send him your comments within the next few weeks. Connie agreed to present the proposal to AFS-410 and AFS-200 for comment. She will present FAA comments at and Jim Enias will present any industry comments at January 2004 meeting.
9. OSWG Spec
Discussion: Connie Streeter, Casey Seabright, and Jim Johnson to report on the following items of discussion which were brought up during the OSWG Spec review at the OSWG 2003-03 meeting:
Annual Progress Report – Members suggested the OSWG Industry Chairman submit an annual progress report to AFS-1 outlining the accomplishments of the OSWG as well as any impediments to progress on significant issues.
OSWG Industry/FAA Lead Assignment – Several members felt the ops spec lead assignments have become irrelevant. This list changes frequently and becomes outdated as new issues on specific paragraphs occur. It was suggested that a database be created and updated after each meeting to track the status and lead of each paragraph.
ACTION: The annual progress report is in a draft letter and will be submitted to AFS-1 prior to the 2004-01 OSWG meeting. The current Chairmen of the OSWG felt that a database would be burdensome to keep up in addition to the other responsibilities currently required of the OSWG leadership. Therefore, the meeting minutes should be consulted for lead assignments on particular issues. All lead assignments have been removed from the OSWG spec. New draft of OSWG Spec. will be posted by November 15 on the http://www.opspecs.com/ website.
10. OpSpec D485, Aging Airplane Inspection and Review
Discussion: This new paragraph is put into place for data collection and verification of required inspections for certain airplanes operated in Part 121, 129, and 135 operations. FAA focal: Rusty Jones, AFS-300.
ACTION: Connie will forward to OSWG members a copy of Rusty’s power point presentation when official notification is signed out. Any questions, you may contact Rusty directly at 202-267-7228.
11. OpSpec A010, Aeronautical Weather Information
Discussion: Jim Johnson to report on follow-up with Met Committee on past discussions regarding this paragraph. Russell Gold from the ATA MET committee addressed the group. At the present time, there are only 2 QICP that are available. It appears that this will affect the smaller operators more than the large air carriers. The large air carriers do not use the “internet” but their own “intranet” to get their weather.
ACTION: If you have questions/concerns, contact Russell Gold at 202-626-4010.
12. OpSpec C066, Turbojet Airplane Takeoff Operations in Tailwind Conditions Not to Exceed 15 Knots
Discussion: Chuck Schramek to report on follow-up with FAA performance specialists on the reasons for additional restrictions for 15 kt tailwind takeoff authorization. AFM performance penalties are already restrictive. Chuck Schramek addressed the group with details from the Delta engineering dept.
13. OpSpec B032, En Route Limitations and Provisions (Industry proposed revision)
Discussion: John Cowan of UAL submitted a proposed revision to B032. AFS-220 stated that the paragraph contains restrictions that are only eased by other paragraphs and that there will be no significant revision to this paragraph at the current time. John Cowen provided a copy of his proposed change to Tom Penland. Connie provided a status update. Connie and Jerry Ostronic met with Jerry Davis who wrote the original paragraph. He offered some minor revisions could be made and maybe the paragraph could be re-organized - it was agreed that it might help if the guidance was better developed.
Several members suggested development of a new class of navigation (Class III) that would conform to aircraft capabilities rather than ground based nav aids.
ACTION: Connie will draft of the proposed revisions and work with Mr. Davis in an attempt to improve the guidance. OSWG should consider forming a subgroup to work a potential Class III navigation solution.
14. B039/B059, MNPS-Santa Maria FIR, ICAO Annex 6
Discussion: Connie Streeter reported that OpSpec authorization for Canadian MNPS would probably be made a separate authorization in the part 135 DB and maybe a selectable option in B059. This is because there are part 135 operators that need only the Canadian MNPS authorization and not the NAT/MNPS.
AFS-800 and AFS-400 are now actively engaged in getting the Part 91 regulation changed to show the correct boundaries of the NAT/MNPS with the addition of the Santa Maria FIR. The proposal would not change existing requirements. Connie Streeter will provide a status update.
ACTION: B039 was revised to include the Santa Maria FIR so the air carriers would not have an OpSpec that was in conflict with ICAO boundaries nor with CFR Part 91. All air carriers will need to re-issue B039.
15. CRAF Deviations
Discussion: Connie Streeter to provide a brief statement/update on these deviations.
ACTION: The FAA is awaiting negotiations with AMC to determine whether the deviations were still necessary. She will announce findings to the group when able and provide an update at the January 2004 meeting.
16. C078. Lower Than Standard Take-Off Minimums. (Re-rolled because of typo in the 600 RVR selection)
Discussion: 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.
ACTION: 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
FAA CSET-Bob Januzzi
Jerry Ostronic, AFS-220
Dick Temple, AFS-410
Jack Wilkes, ALPA
Connie Streeter, AFS-260
17. C073, IFR Approach Using Vertical Navigation (VNAV)
Discussion: Revised and re-rolled for clarification and expansion.
ACTION: C073 must be re-issued by CMO’s.
18. IOPSS and Web-OPSS.
Discussion: Cindy Logan, AFS-260, gave an update on the number of new carriers that have been added to IOPSS—8 Mexican carriers
ACTION: Send Cindy Logan any suggestions for WEB-OPSS
19. B036, Class II Navigation
Discussion: Bob Tegeder, AFS-430, announced the implementation of the RNP-4 routes by the ICAO and separation panels. Right now no IRUs are allowed—only FANS 1/A; Requires ADS and CPDLC.
ACTION: See the Air Traffic web page for draft guidance and the new ICAO manual 9613—B036 will be used for authorization.