FAA/Aviation Industry Agenda for
OpSpec Working Group (OSWG) 2007-04

October 23-24, 2007

Tuesday, October 23:  1 PM-5 PM

Wednesday, October 24:  8:30 AM-Noon

Hosted by Nat. Business Aircraft Assn (NBAA)

Independent Sector conference room

18th Street, NW , SUITE 200, Washington, DC

Tuesday, October 23, 2007--9:00 am – 10:30 am Industry Premeeting (18th St NW)

Wednesday, October 24, 2007 – 1 pm-3 pm Stopping Distance (18th St. NW)

 

This is the Ten-Year Anniversary of the FAA/Aviation Industry OSWG

 

Meeting Schedule:

October 23-24, 2007          OSWG 2007-04

NBAA/NATA @ Washington, DC

January 22-23, 2008            OSWG 2008-01

AmeriJet @ Miami

April 22-23, 2008                  OSWG 2008-02

NetJets, Savanna, GA

July 22-23, 2008                  OSWG 2008-03

United Airlines, Denver

Chairpersons:  John Cowan, UALA, Industry Chair

                           Jackson Seltzer, CALA, Industry Vice Chair

                           Connie Streeter, FAA Chair

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.   Review and finalize the OSWG Procedures Guide for the upcoming year.  The OSWG SPEC is now called the OSWG Procedures Guide.  It is on the www.opspecs.com website under POLICY/OSWG Meetings.  The OSWG Procedures Guide is available with the change marks on.  All are encouraged to review this procedures guide. 

 

c.  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 Notice format which includes appendices containing the appropriate revision to the guidance for the OpSpec/MSpec/LOA in 8400.10/8300.10 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 www.opspecs.com website.  For the Notice template we suggest you use a recently published Notice that contains at least the 2 appendices and modify it for your proposal.

 

d.  Opening remarks :  

 

2.  Status of Assigned Action Items :    

Chairpersons

Reviewed, amended, and adopted agenda

Additional Agenda Items:

2. A.  ICAO standardized OpSpec format

 

2. B .  D091/D491—Joel Schlossberg—add to Tuesday agenda at 2 pm.

 

2. C. 

 

3.  Bruce Ryerson has requested time on the agenda to discuss the FSIMS.

On 09/27/2007, the FSIMS program office approved the release of FSIMS v3.0.  In order to bring v3.0 to FAA and the public, the Office of Quality, Integration and Executive Services, the Information Technology Branch (AQS-250) began the process of moving data from the test environment to production.  This process may cause some interruptions in service.  For example, FSIMS v2.1's ability to conduct either Quick Search or Advanced Search will be temporarily disabled during the transition.

 

 

4.  OpSpec/MSpec/LOA B034, IFR Class I Terminal and En Route Navigation Using Area Navigation Systems   [OSWG 2007-04]

Ø          Applicability: Parts 121, 125, 125M, 135, 91K

FAA Lead: Madison Walton/Mark Steinbicker, AFS-470

Industry Lead(s): Jim Johnson, AALA

 

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 enroute. It seems this may be the time to consider other terms such that the paragraph will give a broader authorization. Additionally, paragraphs B34, B35, B36, and C63 seem to overlap in some areas while leaving gaping holes in others.

 

Desired Outcome Review the possibility of reorganizing these paragraphs consolidating all authorizations for en route navigation using RNAV in B034 and all terminal area navigation using RNAV (SIDS and STARS) in C063. Address the potential need for a straight-forward paragraph addressing RNAV approaches. During this review and possible reorganization, update the RNAV terms to better reflect today’s broader RNAV environment.

 

 

DISCUSSION:  

 

Action/Outcome:

 

 

5.  OpSpec A055:  Carriage of Hazardous Materials [ OSWG 2006-01]

Ø            Applicability:  Parts 121 and 135

FAA LEAD:  AFS-250 Mike Frank/Connie Streeter, AFS-260, Rick Clarke, AFS-220,

Industry LEAD : FedEx and AmeriJet

 

Background:  It has been suggested that if Dry Ice Hazmat is being carried it will have an operator approved training program that covers it.  However, if you are carrying up to 5 pounds of dry ice, you are now a WILL CARRY.  It was always an exception before and now the only thing that is being carried is dry ice.

 

 

Desired Outcome Industry requests a selectable that states WILL CARRY FOR DRY ICE ONLY.  The entire paragraph would need to be re-rolled for this to change. 

 

DISCUSSION:   There are three different dry ice exceptions that used to appear together in 49 CFR 175.10. 

The exception for dry ice used in the galley during flight was never associated with any weight limit and still isn't.  It is now properly located in 49 CFR 175.8 along with other operator equipment exceptions. 

The "5 pound exception" in the former 175.10 never really specified the words "baggage" so, by default, it became two different exceptions-- one for baggage AND one for cargo.  The 5-pound "cargo" exception is now in 173.217 and the 5-pound "baggage" exception remains in 175.10 which is now exclusively passenger/crew exceptions.

 

It is the 5-pound CARGO exception that the Will-Not-Carry operators cannot carry.   Dry ice used by the operator during the flight for food service is not "cargo" in this sense and therefore the Will-Not-Carry operators can take advantage of this exception (perhaps a moot point considering the scarcity of meal service on regional flights).

 

The Hazmat folks have been actively trying to assist Will-Not-Carry operators with the transition to Will-Carry status in order to carry dry ice as cargo.  Some have made the transition, but others have not, even though the difference in training time would not be significant if the carrier chose to limit its hazmat carried to dry ice. 

 

Action/Outcome :  Any part 121 or 135 operation that carries dry ice must be a Will-Carry operator and comply with the requirements of 49 CFR 175, the specific 121 and 135 regulations relative to Hazmat, and issue A055 as it is.  It is not necessary to revise A055.

 

 

 

6.  OpSpec C355, Exemption to §121.619 for Domestic Destination Alternate Airport Requirements- [OSWG 2005-2 ]

Ø            Applicability:  Part 121

FAA Lead:  Ed Duchnowski, AFS-220/ Bob Reich, AFS-220

Industry Lead:   Chuck Schramek, DALA, Jim Stieve, Manager Dispatch ASAP and Ops Performance Southwest Airlines/

 

Background :  C355 authorizes those with the appropriate exemption to dispatch flights in accordance with the exemption which grants relief from 14 CFR Sections 121.619(a)(1) and (2) for domestic operations.  All operations under the exemption are subject to compliance with the conditions and limitations set forth in the exemption and this operations specification.

 

In accordance with the provisions and limitations of one exemption, the certificate holder is allowed to reduce the destination airport weather requirement of Section 121.619(a)(1) and (2) for designating an alternate airport from the current CFR requirement of at least 2,000 feet ceilings and at least 3 miles visibility to at least 1,000-foot ceilings and at least 2 statute miles visibility based on the limitations and provisions of this operations specification.

 

Desired Outcome:   The FAA & the industry have worked together to revise the OpSpec to contain all the requirements since some of the requirements are in the OpSpec and some are in the exemption.  None of the requirements are in conflict but it would make it clearer to have them all in one place rather than two places. 

 

DISCUSSION:   The roll out of a revision to this paragraph has been delayed by the fact that two airlines have applied for an exemption that allows 1-1-3 with only CAT I versus the 1-1-2 with CAT II/III approval.  If approved, the C355 OpSpec will be revised to accommodate both authorizations.

 

ACTION/Outcome:  

 

 

7.  OpSpec B043, Special Fuel Reserves in International Operations  [OSWG 2005-04]

Ø            Applicability:  Parts 121 and 125

FAA Lead: Gordy Rother, NWA CMO / Ed Duchnowski/AFS-220/Jack Pinto, AFS-820 (part 125)), Dave Maloy, AFS-430

Industry Lead(s):  John Cowan, UALA/Jim Johnson, AALA

 

Background:   A draft revision clarifying reporting requirements and correcting the requirement for an alternate during supplemental operations is available on http://www.opspecs.com.

 

Desired Outcome:  

Obtain final comments, work towards a group consensus and republish the updated paragraph. Gordy Rother would like for the fuel language in B043 to mirror the reformatted requirements of C355. 

 

Gordy incorporated the comments from the website into his draft.  He will work with Ed Duchnowski, Jack Pinto, and Dave Maloy to resolve the issue.  The rewrite harmonizes the reporting for minimum and low fuel reporting requirements for C043 and C343.  Also, any carrier using CDM will need to report when an aircraft is moved ahead of other company flights. 

 

DISCUSSION :  

 

Action/Outcome:

 

 

8.  OpSpec B044, Re-Dispatch  [OSWG 2005-04]

Ø          Applicability:  Part 121

FAA Lead: Gordy Rother, NWA CMO / Ed Duchnowski/AFS-220/Jack Pinto, AFS-820 (part 125)), Dave Maloy, AFS-430

Industry Lead(s):  John Cowan, UALA/Jim Johnson, AALA

 

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 :  

 

ACTION/Outcome:

 

 

9.  OpSpec B343 Fuel Reserves for Flag and Supplemental Operations [OSWG 2005-4]

Ø            Applicability:  Part 121

FAA Lead: Gordy Rother, NWA CMO / Ed Duchnowski, AFS-220, Dave Maloy, AFS-430, Dave Burnham, UALA CMO

Industry Lead(s):  Jim Johnson, American Airlines

 

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.

 

A more rigorous approval process is now being tested.  It shows promise in terms of the quality of data being provided and the duration of the approval process.

 

Desired Outcome: 

  1.  Provide FAA with higher quality data
  2.  Shorten the approval process time for new applicants
  3.  Develop metrics to more accurately determine performance levels and establish a routine review and analysis process that ensures continuous improvement, thus higher levels of safety.

 

The FAA (Ed Duchnowski) asks that currently approved operators provide data in a revised format that will more accurately determine the usage of en route and reserve fuel, both actual and planned.  The same format will be required for new applicants.

 

The FAA is still looking at revising the paragraph for reserve fuel.  It will go to a performance-based fuel reserve that will allow for routine trend analysis.

 

Down the road after they get into this, the FAA would also like to meet with CALA, DALA, and AALA at discuss how this paragraph will change and how will it affect each airline..

 

 

DISCUSSION:

 

Action/Outcome: 

 

 

10.  OpSpec A332, Ultra Long Range Flag Operations in Excess of 16 Hours Block Time [OSWG 2007-01]

Ø            Applicability:  Part 121

Industry Lead:  Chuck Schramek, Delta Air Lines; Jim Johnson, AALA

FAA Lead:  Rick Clarke, Rick Huss, Larry Youngblut, AFS-220; Jodi Baker, AFS-210

 

Background:   Current Part 121 flag flight duty time and crew rest regulations are old and have not kept pace with aviation technological advances.  

CALA and AALA and their unions met with the FAA in Washington to discuss this issue.  The FAA had a choice to either remain silent or manage it—the FAA choses to manage the issue by being proactive. 

This is still an on-going work in progress.  Presently, CALA, AALA, and DALA are the only carriers using it.

How to get into the paragraph, the lay over time, the crew complement, and rest facilities for flight attendants are still being discussed. 

 

Desired Outcome:  The development of a policy by the FAA and the affected Flag carriers that provides an acceptable resolution.  The outcome is to have a standard template as a non standard authorization for all carriers.  This should be in place in a couple of months.

 

 

DISCUSSION: 

 

ACTION/Outcome

 

 

11.  OpSpec C078/C079 , Lower Than Standard Takeoff Minima [forever]

Ø          Applicability:  Parts 121, 135, 125, 129, AND 91K

FAA Lead: Coby Johnson, AFS 410

Industry Lead:  John Cowan (United)

 

BACKGROUND :   Significant past efforts to provide harmonization with ICAO guidance is included in HBAT 99-17 and subsequent OpSpec revisions; to include C-078. The goal of this harmonization (as documented in the HBAT and C078) was to change RVR 1200 to RVR 1000 and RVR 600 to RVR 500 with all other requirements remaining the same. See the background section of HBAT 99-17 (e.g., “…the FAA has agreed to permit U.S. air carriers and air operators to now use JAA JAR-OPS-1 minima…in the U.S. for those airports where these minima as published.”)

 

CFR Part 139 now has language that can make some of the provisions of AC 150s mandatory.  A new SMCGS FAA Order is being written; Previously it was an AC)

 

Desired Outcome:   Provide revised guidance and revised OpSpec C-078/C079 lower than standard takeoff minimums to provide support and oversight to help insure accurate publication of C-078/C079 authorizations. Specifically, regardless of runway length, when at least two RVR reporting systems are available, C-078/C079 allows 500 RVR if CL and RCLM are available and 1000 RVR if only CL are available.

 

AFS-410 continues to work on a draft Notice with AFS-200/800 that contains updated guidance for all operations under Parts 121, 135, 125, 129, AND 91K.  This notice will also update the C078 and C079 OpSpecs with mandatory changes.

 

Coby Johnson, AFS-410 needs the following from the carriers:

1) identify the 1800 RVR airports that that carriers want that are on the list

2)Identify the airports that are not on the list that you want to be on the list.

 

DISCUSSION :  

 

ACTION/OUTCOME: 

 

12.  B042 ETOPS /B055, North Polar Operations/C055, Alternate Airports [OSWG 2007-01]/

Ø            Applicability:  Parts 121 and 135

FAA Lead– Bob Reich and Jim Ryan, AFS-220

Industry Lead: 

 

BACKGROUND:   This is not a not a change to policy but a codification of existing stuff.  Also, 3 & 4 engine all cargo operations are not affected by this rule.  180 minute is the extent of the new rule.  However, they kept the 207 minute for the North Pacific and did expand it a little bit. 

The polar policy has now been extended to the South Pole.  It is for all operations whether they are ETOPS or not. All operators have one year from the date of the rule to comply.  The aircraft that are used in ETOPS have 8 years to be certified. 

Three (3) and 4 engine aircraft that will be used in ETOPS are not required to have an ETOPS maintenance program due to their redundant engines and systems and reliability.

Ops Spec C055 ETOPS issues:

The guidance from the draft ETOPS AC, table "ETOPS Alternate Minimum", states: "For airports with at least two operational navigational facilities, each providing a straight-in approach procedure to different suitable runways."

 

"Different suitable runways" can be opposite ends of the same piece of concrete.

 

Ops Spec C055, for ETOPS states:

"For airports with at least two operational navigational facilities, each providing a straight-in non-precision approach procedure or a straight-in precision approach procedure to different, suitable runways. (However, when an airport is designated as an ER-OPS En Route Alternate Airport in these operations specifications, the approach procedures used must be to separate, suitable runways)."

 

"Separate suitable runways" are different pieces of concrete.

 

Thus, the draft AC guidance does not require separate pieces of concrete, but the Ops Spec does.

For more information, you can read the rule at http://www.faa.gov/regulations_policies/rulemaking/recently_published/.

B055, North Polar Operations. 

Desired Outcome:  An INFO should be out within 7 days that will describe a macro view of the new ETOPS rule.  The ETOPS advisory circulars should be out by the end of the first quarter 2007.  The original AC is over 20 years old and needed to be updated for the new regulation.  There will be a 121 AC, a 135 AC, and an aircraft certification AC.

ETOPS – B042, deviation from 121.161 in database, should this remain?

Deviation from 121.161 will be removed from the deviation DB when the AC and the OpSpecs for ETOPS change.

DISCUSSION  

ACTION:  

 

 

13.  OpSpec/MSpec C077, Terminal Visual Flight Rules, Limitations, and Provisions [OSWG 2006-04]

Ø          Applicability:  Parts 121, 135, 91K

FAA Lead:  AFS-220/AFS-250/AFS-820—Tom Walsh

Industry Lead:  Jim Johnson, AALA

 

Background:   OpSpec C077 allows Part 121 and Part 135 Turbojet operators to accept a visual approach or a CVFP provided when specific conditions exist.

 

Desired Outcome The draft Notice is in formal coordination and is available on the www.opspecs.com web site.  Removing the word reported would not solve the problem.  Instead, it is suggested that a “or” statement needs to be added.  The words are TBD by the April meeting, but the intent is that if you have the runway in sight that the aircraft could legally land. 

 

 

DISCUSSION:  Publication is delayed due to an FAA glitch.

 

ACTION/ Outcome:

 

14.  OpSpec A395, Operator-Approved MEL [OSWG 2007-03]

Ø          Applicability:  Parts 121, 125, 135, & 91K

Industry Lead:  John Cowan, UALA

FAA Lead:  Ed Duchnowski, AFS-260

 

Background:  Ed has worked with John Cowan at United and others to come up with the draft that is found on the www.opspecs.com website.

 

Desired Outcome:  Provide guidance and authorization to provide for an operator-approved MEL.  A Notice as well as a draft Ops Spec have been completed and are being circulated in the FAA.  This was originally scheduled to be included with the paragraph but will now be put out as nonstandard OpSpec/MSpec A395.  This would allow someone at the operator to approve their own MELs.  The operator would have subject matter experts and a committee to review and comment on the decisions.  A395 is a nonstandard authorization which requires the nonstandard request process be followed.  The nonstandard request will be submitted to the Air Transportation Division, AFS-200 for concurrence.  The POI will then be able to make the final approval. 

 

 

DISCUSSION:  The draft guidance is posted on the www.opspecs.com website.

 

ACTION/Outcome: 

 

15.  OpSpec/MSpec/LOA D095, MMEL [OSWG 2007-03]

Ø          Applicability:  Parts 121, 125, 135, & 91K

Industry Lead:  

FAA Lead:  AFS-260

 

Background:  Over 20 years ago the FAA put an MMEL/MEL process into place within its mainframe.  AFS-260, the AEGs and thousands of operators have depended upon this electronic system.  Now the mainframe system is being brought down and will be replaced with a web-based MMEL/MEL process.  In the meantime, the MMELs are posted in a Word format on the www.opspecs.com website.

 

Desired Outcome:  Publish guidance that tells the inspectors about the transition and to go to the http://www.opspecs.com/ website until the MMEL system is converted to WebMMEL.

 

DISCUSSION:  Not all FAA nor operators know about the transition and are dismayed when they fail to receive the notification of a MMEL change.

A draft notice for the temporary MMEL process is posted on www.opspecs.com website.

 

ACTION/Outcome: 

 

 

 

 

Day 2

Begin at 8:30am

 

 

16.  Customer Survey.   Connie Streeter asked each meeting participant to fill out an OSWG Customer Survey.  This is a new requirement for FAA personnel.  Results of previous survey will be available at the next OSWG meeting.

 

17.  OpSpec/MSpec/LOA C300 RNAV with RNAV RNP /C063 [forever on the agenda]

Ø            Applicability:  Parts 121, 135, 125, 125M, 91K

Industry Lead:  Alaska Airlines, Jim Winkleman, CALA, Jackson Seltzer, Steve Bush Horizon, Netjets, John Trolan

FAA Lead:  Mark Steinbicker, AFS-410, Mike Frank, AFS-250/AFS-820, Coby Johnson, AFS-410 , Bob Reich, AFS-220

 

Background :   Recent events with NAVAID outages (e.g., JAC, EGE) have highlighted a disconnect between OPSPEC authorizations (both standard and and non-standard text) other FAA agencies (e.g., AVN, ATC). If NOTAMs are issued saying the procedure is “NA”, that effectively eliminates RNAV substitution capabilities.

 

Desired Outcome:  The FAA must define the equipment and training requirements and appropriate approval text for authorizing RNAV substitution.  It is necessary to understand the issues and guidance so as to appropriately revise operational publications (e.g., FOM/FM).

Aviation Safety inspector’s guidance and appropriate authorization need to be developed and published in a Notice. 

 

AFS-200 (in coordination with AFS-410) will determine if additional NOTAM language can be incorporated allowing final approach coarse guidance RNAV substitution as authorized in OpSpec C300.  It was suggested that the C300 be replaced with standard language for RNAV substitution. 

A subcommittee with Alaska Airlines, Delta Airlines, NetJets, & Horizon Airlines and Tom Walsh agreed continue to explore how to standardize the implementation of NAVAID substitution with aircraft that have some advanced NAVAID technology.

Tom Walsh: 

 

Mark Steinbicker is trying to identify mitigations (equipment, procedures, training, and/or processes) for C300 to allow more operations than provided by general FAA policy on "substitution."  Some sort of enhanced data "validation" program appears to help in this regard.

Please review this new version (posted on the www.opspecs.com website) and comment between now and the OSWG meeting on 10/24.  I plan to brief this issue as well as C063 on that date.

 

 

DISCUSSION:  

 

New Action/Outcome:  

 

 

18.  A028, Aircraft Wet Lease Agreements

Ø          Applicability:  Parts 121 and 135

FAA Lead: Rick Clarke, AFS-220

Industry Lead: Ron Priddy, NACA

 

BACKGROUND:   There has been considerable interest in the application of the terms “wet lease” and “operational control” to certain commercial arrangements involving U.S. operators and foreign air carriers.  There are some international agreements with the DOT in progress at this time that may affect the definition of a “wet lease”.  In addition, some foreign countries may be unwilling to accept the existing OpSpec A028 as it is written.

 

Desired Outcome:   When the international agreements are finalized, update the guidance in the inspector’s handbook and revise the OpSpec A028 accordingly.

 

DISCUSSION

 

ACTION/OUTCOME: 

 

 

19.  OpSpec C074, Cat I ILS, MLS, or GLS [Precision] Approaches/OpSpec C359, Special Authorization for Certain Category II Operations at Specifically Approved Facilities/new OpSpec C047 proposed [too long]/C359

Ø          Applicability:  Parts 121, 135, 125, 125M, and 91K

FAA Lead : Coby Johnson, AFS-410/AFS-220/AFS-250/820

Industry Lead:   Mindy Waham, Alaska Airlines

 

Background:   This has been discussed for so many years…..

 

Desired Outcome:   1.  Need to sort out autopilot versus autoland in 8400.13B.  Also need to sort out SAAAR (only for RNP) and SAACR.  Need to remove subparagraph c from C074.

 

2.  Need to revise the present C359 to match the revisions to 8400.13B.  And, Bruce Montigney requested that the subparagraph c be removed for “training and checking” because he felt the real intent was not to train this separately which that statement implies. 

 

3.  Order 8400.13 appendices provide the Checklists for requesting runway approvals. 

 

4.  Update the table in paragraph b of the specification to meet the current guidance in AFS-400 list of CAT I (1800 RVR) Runways. There was concern about airports that were on the list of airports approved for operations below normal Category I minimums being removed from the list.

 

5.  The FAA wants to open up low visibility landing for other than just HGS or autoland.  This will allow the RJs to use these procedures.

 

CAT II on Type I approved runways list updated on AFS-400 website and in the OPSS guidance subsystem associated with OpSpec C359(?).  Coby Johnson will check on the lists of airports and see which is accurate and try to get the airport list straightened out.  He will also look at the definitions.  Revise Order 8400.13C and have the draft available by the April 2007 meeting.  Develop a draft Notice to remove subparagraph c.

 

DISCUSSION:   

 

Action/Outcome:  

 

 

20.   OpSpec/MSpec/LOA C059/C060--Obtaining Foreign CAT II/III Approvals [OSWG 2007-04]

Ø            Applicability: Parts 121, 125, 125M, 135, 91Subpart K

FAA Lead: Coby Johnson ?

Industry Lead(s): Steve Kuhar, FedEx

 

Background:   The new policy with regard to obtaining foreign CAT II/III approvals is not well understood.

Desired Outcome Please ask Coby Johnson to provide a briefing highlighting recent changes and the preferred approval process.

 

DISCUSSION:  

 

ACTION/Outcome:

 

21.  OpSpec C048, Cat I Enhanced Flight Vision System (EFVS) [OSWG 2007-04]

Ø          Applicability:  Parts 121, 125, 135 & 91K

Industry Lead:  TBA

FAA Lead:  Terry Stubblefield

 

Background:  14 CFR 91.175 (l) and (m) permits the use of EFVS to descend below DA/H or MDA to 100 feet above the touchdown zone elevation on Category I straight in standard instrument approach procedures.  Draft Advisory Circular 90-EFVS was published June 5, 2007 and public comments are currently being dispositioned.  An OpSpec and inspector guidance is currently being developed.

 

Desired Outcome Obtain comments and work toward group consensus in publishing the new paragraphs for C048.

 

DISCUSSION The proposed OpSpec/Mspec will apply to Parts 121, 125, 135 and 91K operators.

 

ACTION/Outcome:  

 

 

 

22.  OpSpec C382, Landing Performance Assessment At Time Of Arrival For Turbojet Operators.  [OSWG 2005-04]

Ø            Applicability:  Parts 121, 135, 125, 125M, 91K

Industry Lead:  John Cowan, UALA/NATA/NBAA/UPS

FAA Lead:  Jerry Ostronic, AFS-220/AFS-250/AFS-260/AFS-820

 

Background:   Lessons learned from the Southwest Airlines accident on a slick runway at Midway Airport have led the FAA to issue SAFO 06012.

 

Desired Outcome Encourage as many operators as possible to use the standardized braking action table and comply with the voluntarily SAFO 06012. ( A quick survey of carriers represented at the October 2006 meeting indicated that most all carriers plan to comply with the SAFO with one exception; carriers operating older fleets for which manufacture data is not available plan to “exempt” those fleets.  At this time, no carrier is planning on applying for OpSpec C382.)

 

Bob Reich stated that the ARC charter has been sent to the 10th floor for signature.  From there it goes to the Federal Register.  The Administrator will then appoint members of the ARC.  This is probably a 2 to 3 year process.

 

Status Report on the following:

·                What is the status of officially replacing the term “Fair” with “Medium”? Estimated completion date?

·                What is the status of officially issuing “Braking Action Advisories” when PIREPs less than Good are received? Estimated completion date?

·                Will a very close version of the working groups Braking Action table be issued in time for next winter?

The AIM needs to change for braking action Fair to Medium.

 

DISCUSSION:  

 

ACTION/ Outcome:

 

23.  OpSpec A041,Authorization for 14 CFR Part 135 Airplane Operators to Conduct a Pretakeoff Contamination Check [OSWG 2007-01]

Ø          Applicability:  Part 135

Industry Lead:  Name, Operator

FAA Lead:  Jerry Ostronic/Cliff Fiscus, AFS-200

 

Background:  Recent changes to most Aircraft Flight Manuals (AFM) for hard wing aircraft (no wing leading edge devices) require an outside the aircraft tactile (feel) pretakeoff contamination check five minutes prior to takeoff unless an alternate ground deicing/anti-icing procedure exist.  FAA policy for high wing aircraft have the same requirement although this check maybe visual, instead of tactile, based on the aircraft manufacturers procedures or as approved by the FAA.  This pretakeoff contamination check requirement has been found to be operationally impossible to accomplish in many locations.

 

Desired Outcome:    Provide guidance and standardized procedures and limitations for CFR Part 135 Certificate Holders to use an approved alternate ground deice/anti-ice procedure.  This alternate procedure will authorize the use of current FAA published fluid holdover/anti-ice times in-lieu of conducting a pretakeoff contamination check within five minutes of takeoff when within the Hold Over Time (HOT)/ Allowance Times.

 

DISCUSSION: 

 

ACTION/Outcome: 

 

 

 

24.  OpSpec B032, IFR En Route [OSWG 2007-03]

Ø          Applicability:  Parts 121, 125, 135, & 91K

Industry Lead:  John Cowan, UALA

FAA Lead:  Bob Reich, AFS-220/AFS-250/AFS-820/AFS-400 Nav specialists

 

Background:  B032 does not have adequate guidance associated with it—thus it is not easy to understand as it is written. John Cowan has worked on this and came up with a proposed change.  His draft attempts to make the OpSpec easier to understand.  He believes his change would not constitute a policy change and would be editorial only. 

 

Desired Outcome:  A revision to OpSpec B032 that is easier to understand; maybe even more explicit guidance.

 

DISCUSSION: 

 

ACTION/Outcome: 

 

 

25.  OpSpec/MSpec A061 Electronic Flight Bag [OSWG 2007-01]

Ø            Applicability:  Parts 121, 135, 125, 125M, 91K

FAA Lead : Hank Cabler, AFS-400/AFS-220/AFS-250/AFS-820

Industry Lead:   Steve Kuhar, FEDEX

 

Background:  Notice 8200.98 was published containing the JobAid for the electronic flight bag.  The class 3 with type certificated software are the only ones that have a certification requirement.  These are installed in the aircraft and can send and receive data.

 

The AC for the EFB is approximately four years old.  Problem is that technology has passed this guidance.  A Notice N8400.XXX (Revised Guidance for Authorizing the use of Electronic Flight Bags) is in coordination and will trump the AC.  It will also explain the new paragraph A061 for the EFB.  A revised AC will be completed at a later date.

 

***The paragraph is propose to be changed to include type “C” software with a Class I or II unit. ?????

 

Desired Outcome:   The Notice 8200.98 for EFB is 65 pages long and deals mostly with certification.  The AC is 120-76A and the Order is the companion piece for it.  A new OpSpec/MSpec A061 allows the use of Class I & II EFB (and associated software) to be selected by the operator with the CMO accepting its use for a distinct purpose. 

 

Notice 8000.353 was cancelled but the OpSpec C061 was not.  Any class 3 EFB now approved in A025 should be rolled into A061.  This should only list the device.  Any description and details should be in the operator’s manual.  Guidance is still forth coming for class 1 and 2.  The revision to the Notice 8000.353 may also contain the on own-ship position issue for ground operations.  A draft of the revision is on the www.opspecs.com website.

 

The FAA is working diligently to revise the notice to effectively explain what the principal inspectors should do to authorize the USE of an Electronic Flight Bag. This will entail no change to OpSpec A061. 

 

DISCUSSION: 

 

Outcome/Action: 

 

26.  OpSpec B035, En Route below 18,000 Ft. [OSWG 2007-03]

Ø          Applicability:  Parts 121, 125, 135, & 91K

Industry Lead:  

FAA Lead:  AFS-220/AFS-250/AFS-820/AFS-400 Nav specialists

 

Background:  In reviewing the guidance for updating B034, it was realized that B035 guidance was seriously inadequate.

 

Desired Outcome:  Revise B035 and the corresponding guidance.

 

DISCUSSION: 

 

 

ACTION/Outcome: 

 

27.  [Standing agenda item]  OpSpec C050, Special PIC Qualification Airports—14 CFR Section 121.445 Airport List Review & Recommendation of OSWG to AFS-220:

Ø          Applicability:  Part 121

Industry Lead:   Casey Seabright, NWA

FAA Lead:   AFS-220/260

 

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.

 

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

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:

¨      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

¨      Send email message to OSWG members

¨      Discussion of each individual assessment

¨      Recommendation for AFS-200

The C058 “Lite” list will be published in the same process as the Special PIC Qualification Airport List.  The C058, Special Restrictions for Foreign Terminal Instrument Procedures “Lite List” will be posted on http://www.opspecs.com website and in the OPSS guidance subsystem in association with OpSpec C058.

 

FAA Lead : AFS-220 branch

Industry Lead:   All

 

CURRENT for this Agenda:  No requests were received since the last meeting.

 

Desired Outcome

 

DISCUSSION

 

ACTION/Outcome :

 

No new airport(s) to review for this meeting.


Additional agenda items:

28.  OpSpec B055, North Polar Operations   [New]

Ø            Applicability:  Parts 121 & 135

Industry Lead:  Emil Lassen, United

FAA Lead:  

 

Background:  

Operational experience suggests the need to include what constitutes reasonable MEL relief for the provisions concerning required communication equipment and exposures suits. Revising the OpSpec with such specifics will also ensure an Industry wide standard.

 

Desired Outcome: 

Revise the OpSpec to include the following new language (highlighted in yellow):

 

c. The certificate holder shall conduct all north polar operations in accordance with the following limitations, provisions, and special requirements:

(1) The north polar area of operation for this operation is defined as the area that lies north of latitude N 78o 00’.

(2) The certificate holder must also have approval for operations in areas of magnetic unreliability (OpSpec B040).

(3) Communications capability effective under normal operating conditions for all portions of the flight route must be available for entry into the north polar area of operations.

          i. MEL relief for use of SATCOM voice for an inoperative HF radio is authorized for operations South of latitude 82 degrees North. This includes Polar 4 and routing via NIKIN, G226.

              ii. MEL relief for use of CPDLC for an inoperative HF radio is authorized for operations on Polar 3.

(4) A sufficient set of en route polar diversion alternate airports must be identified in Table 1 of this operations specification, such that one or more can be reasonably expected to be “suitable” (as defined for ETOPS alternates in OpSpec paragraph B042) during each flight.

(5) Airplanes are to be equipped with a minimum of two cold weather anti-exposure suits.

              i. MEL relief is authorized for dispatch without cold weather anti-exposure suits from 1 May through 30 September when polar diversion alternate minimum temperatures are forecast to exceed -25 degrees C (-13 degrees F).

(6) Except for all cargo operations, the certificate holder must have an expanded medical kit to include automated external defibrillators (AED) on board each aircraft listed in Table 1 above.

DISCUSSION: 

 

ACTION/Outcome: 

 

29.  OpSpec D091, Substantial Maintenance/D491 QUR [2007-04]

Ø            Applicability:  Part 121

Industry Lead:  Dave Lotterer, RAA

FAA Lead:  Dave Cann, AFS-300/Joel Schlossberg

 

Background:   Dave L. sent the following message to Dave Cann AFS-3:

I want to know from AFS-3 if there is any truth to the rumors that the FAA wants operators to list all approved vendors in their D091 Ops Spec; not just the substantial vendors presently listed. This would include maintenance gate providers that may only be used to MEL something or to inspect a tire, etc.

And he replied:

Your information is partially correct. There is a discussion that there is probably going to be an ops spec requirement to list the "maintenance" providers on the ops specs or in a manual or listing that is referenced on the ops specs. This is already a requirement in 14 CFR part 121.369(a) so the only difference would be that these maintenance providers are referenced on ops specs. This is a result of the OIG report and Congressional testimony during a hearing.

 

RAA is very concerned that if this occurs (Dave states "probably") this will be HUGE issue for operators.  OpSpecs must be approved by the PMI and the PMI can create any condition(s) that they deem appropriate for approval. Therein is the problem.  There is absolutely no limit to the "conditions" that can be created by the CMO and associated with approval of the OpSpec.  One of our members has already been told that on-call maintenance providers will have to attend their maintenance initial training class and be audited by QA (just like their engine overhaul vendor) as a condition of approval of the rumored OpSpec, so it's already started.  Who knows what other "conditions" they will come up with?  §121.369 (a) states: The certificate holder shall put in its manual a chart or description of the certificate holder's organization required by §121.365 and a list of persons with whom it has arranged for the performance of any of its required inspections, other maintenance, preventive maintenance, or alterations, including a general description of that work.

 

If the FAA adopts this policy, RAA believes that documents referenced in the Ops Spec will be treated the same as if they were in the Ops Specs; namely prior FAA approval is required for all activity associated with an airline contracting with service and maintenance vendors.

David Lotterer, VP, Technical Services

Phone: 202 367-1252; FAX: 202 367-2252

E-mail: Lotterer@RAA.org