FAA/Aviation Industry Agenda for
OpSpec Working Group (OSWG) 2008-1
January 22-23, 2008
Tuesday, January 22: 1 PM-5 PM
Wednesday, 23: 8:30 AM-Noon
Hosted by AmeriJet, Miami, Florida
Independent Sector conference room
18th Street, NW , SUITE 200, Washington, DC
Tuesday, October 22, 2007--9:00 am – 10:30 am Industry Premeeting (18th St NW)
January 22-23, 2008 OSWG 2008-01
AmeriJet @ Miami, FL
April 22-23, 2008 OSWG 2008-02
NetJets, Savanna, GA
July 22-23, 2008 OSWG 2008-03
United Airlines, Denver, CO
October 9-10, 2008 TH/FR OSWG 2008-04
NBAA/NATA, Orlando, FL
Chairpersons: John Cowan, UALA, Industry Chair
Jackson Seltzer, CALA, Industry Vice Chair
Bob Davis, FAA Chair
1. Convene :
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 “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 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.
d. Opening remarks :
2. Status of Assigned Action Items :
Reviewed, amended, and adopted agenda
Additional Agenda Items:
2a. Are flights from the contiguous 48 states to/from Hawaii and Alaska considered International under this recently enacted law?
‘‘(c) LIMITATION FOR INTERNATIONAL FLIGHTS.—
‘‘(1) APPLICABILITY OF ICAO STANDARD.—A pilot who has attained 60 years of age may serve as pilot-in-command in covered operations between the United States and another country only if there is another pilot in the flight deck crew who has not yet attained 60 years of age. Thanks for your help. Casey Seabright, NWA
3. ICAO standardized OpSpec format.
For your information. The draft ICAO documents posted on the www.opspecs.com website still need to be adopted by the ICAO Council, with other amendment proposals (Performance-based navigation and RVSM material). This is normally a formality once the ANC has completed the final review.
A standardized ICAO OpSpec A404 will be made available for those to use if they so choose. It should be available sometime within the next 30 days from the date of this meeting. It will not be as user-friendly as we would like it to be for the time-being for the following reasons:
a. The M/M (or M/M/S) of aircraft—If the authorizations and limitations are identical for two or more models, these models may be grouped in a single list.
b. Otherwise, you will have to “pull over” a new available template for an M/M aircraft that have in order to have an accurate OpSpec for each M/M that has different authorizations and limitations.
c. It is cumbersome to say the least—we hope that one day in the future (probably far future J ) we can build it so it is “automatically” filled out when your OpSpec authorizations are issued.
4. OpSpec/MSpec/LOA B034, IFR Class I Terminal and En Route Navigation Using Area Navigation Systems [OSWG 2007-04]
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 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.
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. Unfortunately, these are complex issues to be able to resolve quickly. The FAA policy divisions recognize that it would be beneficial to be able to combine these authorizations but the time and resources have not yet been available to do so.
We currently have 6 paragraphs that authorize RNAV type operations and 4 of these are en route. Jim Johnson presented a chart that shows a representation of the ICAO requirements and how it incorporates all the information together. It would replace B34, B35, and B63.
However, Connie pointed out that paragraph B035 is not an IFR required paragraph. It is only to allow for operations to reach 18,000 but not IFR.
NOTE: New AFS branch 470 has all RNP, SAAAR, etc. The new AFS-470 is just cranking up. Mark Steinbicker is the new branch manager. It is dealing with all performance based navigation (RNP), ETOPS, etc. They are also working on an RNAV-5.
Jim Johnson will work with Mark Steinbicker to come up with a proposal for the next meeting.
5. OpSpec A055: Carriage of Hazardous Materials [ OSWG 2006-01]
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 : Clarify whether or not the carrier would be required to have a full Will Carry program to carry the 5# of dry ice.
DISCUSSION: The HazMat division has made the determination that a ny part 121 or 135 operation that carries dry ice (5#) must be a Will-Carry operator and comply with the requirements of 49 CFR 175 and issue A055. They suggested that the operators may have to petition for an exemption from the HazMat requirements of 14 CFR part 119 for any exceptions.
An internal ASH/ADG policy memo regarding the transition from a Will-Not-Carry hazmat training program to a Will-Carry program is posted on the www.opspecs.com website and the A055 JobAid provides the following link: http://www.opspecs.com/FAAInfo/Policy/HazMatInfo/Final/. In particular, it addresses those situations where an air carrier wants to become a Will-Carry operator but limit the types of hazmat it carries--thus limiting the content/depth of its hazmat training program.
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.
Desired Outcome: C355 was revised to version 4 (mandatory revision) per the agreed changes with the OSWG. Then it was revised (nonmandatory to 4a) to accommodate the additional exemption that allows 1-1-3 with only CAT I versus the 1-1-2 with CAT II/III approval to accommodate date both authorizations.
7. OpSpec B043, Special Fuel Reserves in International Operations [OSWG 2005-04]
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: An updated draft revision clarifying reporting requirements and correcting the requirement for an alternate during supplemental operations is available on http://www.opspecs.com.
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.
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. The draft document is in formal coordination.
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. (Was this done?)
9. OpSpec B343 Fuel Reserves for Flag and Supplemental Operations [OSWG 2005-4]
Ø Applicability: Part 121 only
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.
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. The FAA is changing the reporting requirements for new entrants. This will make if easier and more meaningful. Initial application required 3 to 5 years of data. FedEx is now applying with less data points as this should be sufficient. The FAA is hoping that a 6 month time frame will allow for a shortened and better approval process.
Additionally, there is no set percentage for the paragraph. It could be a reduction of anywhere from 1% to 5% dependent upon the carriers ability to meet the requirements.
One of the reasons for the change is that the FAA current data collection does not actually tell them much. So far, there has only been one minimum fuel but no fuel emergency.
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
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, it is only applicable to CALA, AALA, and DALA.
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.
11. OpSpec C078/C079 , Lower Than Standard Takeoff Minima [forever]
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.
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.
The FAA wants to harmonize the requirement for center line lights (CL) with the JAR numbers.
Coby Johnson, Casey Seabright (NWA), John DiPauolo (SWA), and Chuck Schramek (DAL) will work on some language for the guidance documents for this paragraph as it refers to 121.637.
With the new language, this item should be closed but we have no word from AFS-410 for the agenda.
John Cowan writes:
Based on the draft C078 and our desire to have pilot friendly 10-9A publications, see what you think of the attached draft 10-9A page formats. The goal is to provide Jeppesen with an approved format template. If acceptable, then once we get C078 finalized I will visit Jeppesen in person and make sure they understand the OpSpec and our desired format.
Two issues concerning HUD authorizations:
1. One of the pieces to the puzzle is that we will need to provide Jeppesen with access to a listing of 3E4 ILS facilities so they can correctly chart them down to 300 RVR. Where do we find this information?
2. While we tried to clear the waters by de-linking takeoff minimums and SMGCS requirements; we did include a requirement for HUD operations below 500 RVR to ensure they had access to the runway via taxiways equipped with centerline lighting. During my review of the DEN airport the only runway access lacking such lighting is that for 35R, yet it is currently published down to 300 RVR for HUD equipped airplanes. Are we sure we want to muddy the 300 RVR waters by including this requirement? Also, the way we have the wording in the draft, it would appear that if a HUD is being used to assist the T/O, then runway access via taxiways equipped with centerline lighting is required regardless of the RVR (e.g., even with RVR 1600). We need to fix that logic.
12. B042 ETOPS /B055, North Polar Operations/C055, Alternate Airports [OSWG 2007-01]/
FAA Lead– Bob Reich and Jim Ryan, AFS-220
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.
Jim Ryan, new to the FAA for ETOPS, came from Delta. The Advisory Circular is about to be published.
B042 will now be four templates for the different types of operations and equipment. A rough draft of these will be put up on the web site.
C055 will be adjusted to state that one piece of concrete will suffice and this will align it to the AC.
Relief for inoperative communication equipment is not to be listed in the OpSpec. It needs to be in the MEL.
There needs to be a change to the definition for NOPAC operations as it applies to Seattle departures.
The EROPS Advisory Circular, paragraph 205, ETOPS Areas of Operations, paragraph A & B needs to be reviewed. Delta Airlines would also like to review this for the purpose of when a validation flight is required.
· OpSpec 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.
· OpSpec 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 OpSpec does. (?)
For more information, you can read the rule at http://www.faa.gov/regulations_policies/rulemaking/recently_published/ .
i. FAA agreed to give some relief in a revised B055 for this: 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).
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 section 121.161 in database, should this remain?
Deviation from section 121.161 will be removed from the deviation DB when the AC and the OpSpecs for ETOPS change.
13. OpSpec/MSpec C077, Terminal Visual Flight Rules, Limitations, and Provisions [OSWG 2006-04]
FAA Lead: AFS-220/AFS-250/AFS-820—Mike Frank
Industry Lead: Jim Johnson, AALA
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---but should be soon.
14. OpSpec A395, Operator-Approved MEL [OSWG 2007-03]
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 the operator have an approved program to allow the operator to approve its 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.
The Notice and Inspector Guidance has been in coordination for a while. There were no substantial comments from the industry. The new title is OMEL, Operator Approved MEL. The draft is on the web site.
The reason that you cannot combine D095 and D395 is because the operator-approved MEL must go through the nonstandard OpSpec request process. Because it is an “operational” request, the nonstandard authorization is put into Part A (A395) of the OPSS. For operators conducting operations under 121 and 135, the request must be sent to the Air Transportation Division at headquarters; for part 91K operations, the request must be sent to the General Aviation and Commercial Division at headquarters.
DISCUSSION: The draft guidance is posted on the www.opspecs.com website.
15. OpSpec/MSpec/LOA D095, MMEL [OSWG 2007-03]
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. Until the MMEL system is re-engineered, the web site is where to find the MMELs.
DISCUSSION: Not all FAA nor operators know about the transition and are dismayed when they fail to receive the notification of a MMEL change.
16. OpSpec/MSpec/LOA C063, IFR area navigation (RNAV 1) Instrument Departure Procedures (DPs) and Standard Terminal Arrivals (STARs) published in accordance with 14 CFR Part 97. (OSWG 2008-01)
Industry Lead: Casey Seabright, NWA
FAA Lead: Mark Steinbicker, AFS-470/Bob Davis, AFS-260/Terry Pearsoll, AFS-300
Background: OpSpec/MSpec/LOA C063 has been revised several times in the past few years. The FAA and some of the airlines have been working together to try and come up with a reworked paragraph. All VORs and NDBs substitution should be covered. However, TACAN is still questionable. This would be for domestic use only, but the FAA would not prohibit an airline from using it if the foreign state allowed. All operations would require a GPS type feed.
There is an allowance for DME-DME-Inertial. However, there is no process in place to verify the NAVAID performance.
Some operators have a data validation process and this will need to be included for all operations. This is the big hand-up right now. The RNAV alternate question comes up often. The FAA is looking at the Canadian model, which has an either or rule. This means that you could use substitution for the destination or the alternate but not both. However, in the long run, they need to have both, but the FAA has no time frame for this. This means that you could not shoot an RNAV approach at the destination that uses the GPS feed and then use an alternate using substitution.
The FAA is looking at a RAIM prediction process and tool for the industry. This will be required for any type of GPS feed. C063 – This will allow for different runway selections for the same arrivals. The different boxes do it differently.
Desired Outcome: Casey Seabright proposed a draft issue statement and a draft notice for the change. The highlighted proposed changes (included in the notice) are in red. There are other changes but subtle and not of substance of policy change.
Northwest Airlines believes that the current method of reporting RNAV system status data in Operating Specification C063 creates an unnecessary burden on the operator and does not provide the operator or the Certificate Management Office with the most rapid and reliable means to determine the state of RNAV capability of the respective fleets. We understand and fully appreciate the need for the operator to show that its RNAV-capable aircraft meet the provisions of AC 90-100a, but we believe that this can be accomplished in a more efficient manner with reduced workload.
Northwest Airlines and other air carriers currently track hardware and software changes through an electronic modification tracking system and electronic software configuration tracking system or similar systems. Through these means, air carriers are able to monitor the current state of all hardware and software changes to their fleet of aircraft. We believe that use of these systems provide both air carriers and their Certificate Management Offices/FSDO's with an efficient and rapid means to verify the hardware and software states of our aircraft and thus meets the intent of Table 1 in the Ops Spec.
Therefore, we request/propose that the requirement to track software versions via Ops Spec paragraph C063 be revised to include the use of “other suitable means” for tracking software revisions.
17. 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.
18. OpSpec/MSpec/LOA C300 RNAV with RNAV RNP [forever on the agenda]
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.
Mark Steinbicker: I won't be able to attend the upcoming OSWG meeting but would like to get your thoughts prior to the meeting with regard to the draft (previously attached) for C300. It is my understanding that we have 3 remaining points of contention:
1. GPS requirement (this has been included since the original draft
revision with few arguments against it)
2. Accuracy of 0.3 nm (this is a change from current ops for some
carriers, although it is consistent with RNAV(GPS) and some RNAV (RNP)
approaches, so there may be a training benefit)
3. Data validation program (I attempted to address concerns that were described at the last meeting by providing a number of options and additional flexibility).
Absent feedback with regard to the most current draft, my recommendation will be to implement this revision (with a compliance date TBD for operators with C300).
Coming to closure on this issue will 1) help me devote some resources toward the RNAV/RNP OpsSpec rationalization and reorganization effort, 2) provide some material that may be used in international operations forums in order to advance this capability outside the U.S, and 3) allow other operators to apply and gain authorization for C300.
Mark Steinbicker, FAA, Manager, AFS-470, Performance Based Flight Systems Branch
470 L'Enfant Plaza Suite 4102
Washington , DC 20024
19. A028, Aircraft Wet Lease Agreements (OSWG 2007-03)
FAA Lead: Rick Clarke, AFS-220
Industry Lead: Ron Priddy, NACA
BACKGROUND: The FAA guidance was not very clear and this has been cleaned-up. There is also a European Agreement, called “Provision of Aircraft with Crew.”
The A028 text has been fixed and will go into effect March 1, 2008. The FAA definition of “wet lease” is not the same as DOT, but it will not change. This is because the FAA definition is about operation and the DOT’s is about economic authority and ownership. If the industry wants it changed it will have to go to FAA General Counsel office.
The new A028 will look at lot like the current A328. However, the A328 will stay until the new A028 has been reviewed and put into place. Once the new A028 is published the nonstandard A328 will be archived as it will no longer be necessary.
Desired Outcome: When the international agreements are finalized, update the guidance in the inspector’s handbook and revise the OpSpec A028 accordingly.
20. 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 C359 (too long)
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(?).
ACTION: 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.
Coby gave a presentation on the 1800RVR for CAT II on Type I. The lists for the approaches are on the web site. The 8400.13C is now on the web site for review. The lower minimums will require a flight director, autoland, or HUD.
The list of available airports is on the website. From this list, the airlines need to send the airports in order where they want to have the lower minimums to:
Also, Coby Johnson also needs list of personnel that can help Miter with the proof of concepts for lower ILS minimums.
The FAA has come to an internal agreement, SAAAR will be for RNP only. SAACR will only be for ILS.
Coby wants to close this item so that he may finish the work on 8400.13C.
21. OpSpec/MSpec/LOA C059/C060--Obtaining Foreign CAT II/III Approvals [OSWG 2007-04]
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.
22. OpSpec C048, Cat I Enhanced Flight Vision System (EFVS) [OSWG 2007-04]
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.
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.
The 135 operator can elect not to fly in icing, have a full up Section 121.629 icing program, or use a PCC.
Title 14 CFR Section 135.221 allows for an alternate procedure. The FAA will now allow a 135 to use the 121 hold over times. This will require a 121.629 program without the additional training and extensive oversight of the contractors as long as they use a provider who has a real section 121.629 program. The PIC would then be required to supervise (watch) the application of the fluid.
24. OpSpec D070, Integration of Aircraft Fuel Tank Maintenance and Inspection Instructions Into the Certificate Holder / Foreign Person’s / Foreign Air Carrier’s CAMP (OSWG 2008-01)
Industry Lead: Name, Operator
FAA Lead: Frederick Sobeck, AFS-300, Mario Giordano, AFS-300, Jack Pinto, AFS-820, Lou Garrido, AFS-300, Bob Reich, AFS-220
Background: Each applicable aircraft make/model/series listed in the operator’s operations specification D072, Continuous Airworthiness Maintenance Program (CAMP), has FAA engineering-approved fuel tank system, type certificate (TC) and supplemental type certificate (STC) base-line instructions for continued airworthiness (ICA) incorporated into their CAMP. These ICA consists of fuel tank system maintenance and inspection instructions as required by §§ 121.1113 and 129.113, as applicable.
25. OpSpec B032, IFR En Route [OSWG 2007-03]
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. Publication of the new B032 and the revised guidance…however, some comments were received that need to be researched by the specialists before the changes can be made.
26. OpSpec/MSpec A061 Electronic Flight Bag [OSWG 2007-01]
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.
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.
The PowerPoint presentation will be put on the website. AFS-400 does not have a process for the approval of a piece of hardware to use on an aircraft. Only Aircraft Certification can do this. They can however approve your use of the equipment.
The FAA is scheduled to do a field test at Executive Jet Management of their new Job Aid for approval of an EFB. It will start with a couple of conference calls and then conclude with an on site test. Once this is complete, the information will go into handbook guidance. Steven Morrison (FAA AFS-430) is leading this process.
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.
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.
27. OpSpec B035, En Route below 18,000 Ft. [OSWG 2007-03]
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.
28. [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 :
No new airport(s) to review for this meeting.