Operations at Non-Towered Airports

The FAA has released a draft of a new edition of AC 90-66B: Non-Towered Airport Flight Operations (PDF). This is the first update of this topic in ACs since the 1990s. Comments on the draft are due December 20, 2017. More information, including a link to submit comments, is available at the FAA website, here.

The draft AC mostly clarifies existing procedures and recommendations, but it adds specific examples and addresses several topics that have continued to cause confusion to pilots operating at so-called uncontrolled airports. In particular, the updated text includes several helpful, specific examples of radio communications.

For example:

9.6 Instrument Flight Rules (IFR) Traffic. Pilots who wish to conduct instrument approaches should be particularly alert for other aircraft in the pattern so as to avoid interrupting the flow of traffic, and should bear in mind they do not have priority over other visual flight rules (VFR) traffic. Non-instrument-rated pilots might not understand radio calls referring to approach waypoints, depicted headings, or missed approach procedures. IFR pilots often indicate that they are on a particular approach, but that isn’t enough information for a non-IFR-rated pilot to know your location. It’s better to provide specific direction and distance from the airport, as well as the pilot’s intentions upon completion of the approach. For example, instead of saying, “PROCEDURE TURN INBOUND V-O-R APPROACH 36,” it should be “6 MILES SOUTH… INBOUND V-O-R APPROACH RUNWAY 36, LOW APPROACH ONLY” or “6 MILES SOUTH … INBOUND V-O-R APPROACH RUNWAY 36, LANDING FULL STOP.”

And section 10.3 addresses the fingernails-on-the-blackboard phrase “Any traffic in the area please advise.”

10.3 Self-Announce Position and/or Intentions. “Self-announce” is a procedure whereby pilots broadcast their position, altitude, and intended flight activity or ground operation on the designated CTAF. This procedure is used primarily at airports that do not have a control tower or an FSS on the airport. If an airport has a control tower that is either temporarily closed or operated on a part-time basis, and there is no operating FSS on the airport, pilots should use the published CTAF to self-announce position and/or intentions when entering within 8–10 miles of the airport. When referring to a specific runway, use the runway number and not the phrase “Active Runway,” because there isn’t an official active runway at a non-towered airport. To help identify one airport from another when sharing the same frequency, the airport name should be spoken at the beginning and end of each self-announce transmission.

Note: Pilots are reminded that the use of the phrase, “ANY TRAFFIC IN THE AREA, PLEASE ADVISE,” is not a recognized self-announce position and/or intention phrase and should not be used under any condition. Any traffic that is present at the time of your self-announcement should reply without being prompted to do so.

Section 10.4 offers additional helpful recommendations:

10.4 Confusing Language. To avoid misunderstandings, pilots should avoid using the words “to” and “for” whenever possible. These words might be confused with runway numbers or altitudes. The use of “inbound for landing” should also be avoided. For example, instead of saying, “MIDWEST TRAFFIC, EIGHT ONE TANGO FOXTROT TEN MILES TO THE SOUTHWEST, INBOUND FOR LANDING RUNWAY TWO TWO MIDWEST,” it is more advisable to say, “MIDWEST TRAFFIC, EIGHT ONE TANGO FOXTROT TEN MILES SOUTHWEST OF THE AIRPORT, LANDING STRAIGHT IN RUNWAY TWO TWO, MIDWEST,” so it does not confuse runway 4, runway 22, or the use of an instrument approach procedure on arrival.

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Airworthiness and Inoperative Equipment Under 14 CFR Part 91

Many pilots struggle with the regulations and procedures to follow when a preflight inspection or other before-takeoff check reveals a burned-out position light, a non-functional autopilot, or other inoperative equipment. Here’s a basic guide to help you through the thicket of FAA regulations and policies.

This discussion assumes you are operating a typical light GA aircraft under 14 CFR Part 91 and you’re not using a minimum equipment list (MEL). MEL are typically available only for multiengine and large aircraft, and they’re most often used in commercial operations. Note also that as of November 3, 2017, AC 91-67 – Minimum Equipment Requirements for General Aviation Operations Under FAR Part 91, has been canceled, pending a revision that “align[s] with the latest ICAO guidance.”

Before you begin the preflight inspection, review 14 CFR §91.7 Civil Aircraft Airworthiness:

§91.7 Civil Aircraft Airworthiness
(a) No person may operate a civil aircraft unless it is in an airworthy condition.

(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.

Simply put, as PIC, you–not your mechanic, or the FBO from which you rent an airplane, or the partner(s) with whom you share an aircraft–are responsible for determining whether the aircraft you’re about to fly is legally airworthy and safe to operate.

CessnaPreflight

Assume that during the preflight inspection, you discover that one of the wingtip position lights has burned out. The key questions to ask are:

  • Can you fly the airplane?
  • How can you comply with the applicable FAA regulations?

Many pilots think that such minor malfunctions require nothing more than recalling the required equipment regulations for day or night, VFR or IFR flight (14 CFR §91.205), and, if necessary, putting an “inoperative” sticker near the appropriate switch or gizmo before taking off.

InopLightSticker

The proper procedure, however, involves methodically tracing your way through several FAA regulations and references, including the aircraft flight manual (AFM) and associated aircraft documents.

Key FAA Regulations (14 CFR Part 91) and Documents

  • §91.7 Civil Aircraft Airworthiness
  • §91.205 Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements
  • §91.213 Inoperative instruments and equipment
  • §91.405 Maintenance required
  • Aircraft approved flight manual (AFM) or operating handbook (POH)
  • Applicable STC supplements
  • Aircraft Type Certificate Data Sheet (TCDS)

The process you must follow is described in §91.213 (PDF flow chart here). You are allowed to continue with the flight provided:

§91.213

(2) The inoperative instruments and equipment are not—

(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;

(ii) Indicated as required on the aircraft’s equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;

(iii) Required by §91.205 or any other rule of this part for the specific kind of flight operation being conducted; or

(iv) Required to be operational by an airworthiness directive

(3) The inoperative instruments and equipment are—

(i) Removed from the aircraft, the cockpit control placarded, and the maintenance recorded in accordance with §43.9 of this chapter; or

(ii) Deactivated and placarded “Inoperative.” If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and

(4) A determination is made by a pilot, who is certificated and appropriately rated under part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft.

Here’s a flow chart that outlines the basic process described in §91.213.

InopEquipment-02.jpg

Procedure for dealing with inoperative equipment under 14 CFR Part 91

Throughout the following discussion, note that if the defective or inoperative item is required at any of the decision points, maintenance or obtaining a ferry permit (technically a Special Flight Permit) is required before you can fly.

Begin by determining whether inoperative item is required under the basic regulations for VFR or IFR flight during the day or night (§91.205), including key engine instruments, altimeter, airspeed indicator, magnetic direction indicator, and so forth. Operations at night and under IFR (regardless of prevailing weather conditions) require additional instruments and equipment, such as lights (night) and radios and gyroscopic instruments (IFR).

If the item isn’t specifically listed in §91.205(a)-(d), next determine if it’s required by the AFM/POH equipment list or kinds of operations list (examples below).
C172-EquipmentList-01

C172-EquipmentList-02

DA40-KOA.jpg

DA40-OperationalEquipment-01.jpg

If the item isn’t required by those equipment lists, or if you have an old AFM/POH that doesn’t include equipment lists, next confirm that the item is not required by the aircraft’s type certificate data sheet (TCDS). You can download PDF versions of TCDS from the FAA website, here. These data sheets are usually long and not easy to read, but you can search the PDF for your aircraft to help you locate specific model/serial numbers or items.

C172S-TCDS.jpg

If the item isn’t required by the TCDS, review any STC supplements that apply to your aircraft. For example, if you’ve installed new avionics or electronic instruments in the panel, the STC under which that equipment was installed may contain specific limitations, such as additional sources of electrical power.

GarminSTC.jpg

G500 AFMSupplement-02

Next, you must confirm that the item isn’t required by an airworthiness directive (AD). You can find ADs on the FAA website, here. Again, ADs can be difficult to parse. If you have questions, it’s best to consult a maintenance technician. Aircraft type and owner clubs are also good sources of information about ADs.

If you’ve answered “no” at each step of the process, you can proceed–but you must follow the proper procedure to deactivate or remove and then placard the item. And you must record the discrepancy and action taken in an appropriate record (§91.405 and §43.11).

Options at this point include disabling a switch, pulling and collaring a circuit breaker, or removing the equipment following the appropriate procedure. If the inoperative item is controlled by anything other than a simple switch, it’s best to consult a maintenance technician.

Finally, as PIC, you must determine that the aircraft is safe to operate under the conditions expected for the flight.

Note that you can’t continue to operate indefinitely with inoperative/defective equipment. See §91.405(c) and the De Joseph letter (2017) from the FAA chief counsel. In general, at the next required inspection the item must be repaired, replaced, or removed and the action properly documented by a maintenance technician.

FAA-DeJosephLetter-02

The process described here is cumbersome, especially when you’re away from your home airport without easy access to references and technical advice.

But here’s a good rainy-day project. Create a list of equipment in your aircraft that isn’t clearly required by §91.205 for a typical day or night VFR flight, such as lights, avionics, accessories (seats, cabin heat, power plugs, speakers, etc.). Follow the flow chart, consult the resources described here, and note whether those items would be necessary for a flight under those circumstances.

If you fly IFR, add or note the equipment, beyond the basics in §91.205, that is required by the documents for your aircraft–regardless of the weather–to operate under those rules.

Keep those lists in your aircraft (or on your tablet or phone) so that you can quickly and easily determine whether you can proceed.

Additional References and Resources

 

Z, Y, X in Approach Titles

I’ve recently noticed questions popping up about the letters Z, Y, X appearing in the titles of instrument approach procedures. Titles that include “-A,” “-B,” or “-C” are familiar–they designate procedures that have only circle-to-land minimums, such as the VOR-A at Olympia, WA (KOLM). But letters from the other end of the alphabet puzzle many pilots.

KPAE-ILSorLOCDMEYRWY16R-Title

For example:

The most detailed explanation of this naming convention is in “Straight-In Procedures” in Chapter 4 of the Instrument Procedures Handbook (updated in October 2017):

When two or more straight-in approaches with the same type of guidance exist for a runway, a letter suffix is added to the title of the approach so that it can be more easily identified. These approach charts start with the letter Z and continue in reverse alphabetical order. For example, consider the (RNAV) (GPS) Z RWY 13C and RNAV (RNP) Y RWY 13C approaches at Chicago Midway International Airport…Although these two approaches can be flown with a global positioning system (GPS) to the same runway, they are significantly different (e.g., one is a Required Navigation Performance (RNP) Authorization Required (AR) … one has circling minimums and the other does not; the minimums are different; and the missed approaches are not the same). The approach procedure labeled Z has lower landing minimums than Y…

In this example, the LNAV MDA for the RNAV (GPS) Z RWY 13C has the lowest minimums of either approach due to the differences in the final approach required obstacle clearance (ROC) evaluation. This convention also eliminates any confusion with approach procedures labeled A and B, where only circling minimums are published. The designation of two area navigation (RNAV) procedures to the same runway can occur when it is desirable to accommodate panel mounted GPS receivers and flight management systems (FMSs), both with and without vertical navigation (VNAV). It is also important to note that only one of each type of approach for a runway, including ILS, VHF omnidirectional range (VOR), and non-directional beacon (NDB) can be coded into a database. (4-9)

FAA Order 8260.3C (i.e., TERPS) includes additional information:

Alphabetical suffix. When more than one procedure to the same runway uses the same type of navigation system for lateral guidance within the final approach segment, differentiate each procedure by adding a non-repeating alphabetical suffix using the letters “S” through “Z.” Suffixes are normally assigned in reverse order starting with “Z,” but may be assigned as needed to meet operational needs [for example, all RNAV (RNP) approaches at an airport assigned “Z” suffix, all RNAV (GPS) approaches assigned “Y” suffix, etc.]. (1-9)

As noted above, approaches to the same runway can be labeled Z, Y, or X… for several reasons.

For example, consider the ILS RWY 27 at KYKM, which is published as both the ILS Y RWY 27 and ILS Z RWY 27.

The Z version requires a non-standard climb gradient of 250 ft/nm on the missed approach procedure (see the note in the plan view), but it provides a DA of 1268 (200 AGL) with RVR 2400.

KYKM-ILSZ-Plate

KYKM-ILSZ-PlanView

The DA on the Y version of the approach is 1725 (657 AGL) with visibility of 2 sm. So you can go much lower and to the equivalent of 1/2 sm visibility if you can achieve the steeper climb gradient on the miss.
KYKM-ILSY-Plate.jpg

There are two versions of the ILS RWY 16R–but for a different reason–at Snohomish County–Paine Field (KPAE) north of Seattle.

Both procedures offer the same basic DA and visibility minimums (although the Z version allows a reduction to RVR 1800 with a flight director, autopilot or HUD). But the FAF (ITIPE) for the Y edition is 4.4 nm from the PAE VOR.

KPAE-ILSorLOCDMEYRWY16R-Plate

The Z version, which also has published minimums for category C and D aircraft, has a FAF (JUGBA) at 7.6 nm from the VOR.

KPAE-ILSorLOCDMEZRWY16R-Plate

If you’re flying a typical light GA aircraft, the Y version is much more efficient, while the Z version is better suited to jets (like the shiny new Boeings emerging from the factory at KPAE) that need more room to get established on final.

As pointed out earlier, Z, Y, and X versions of the same basic procedure may require different equipment or missed approach segments. For example, using your favorite chart-viewing app, compare the ILS Y or LOC RWY 20 and the ILS Z or LOC/DME RWY 20 at Walla Walla, WA (KALW).

The key to flying such approaches is a careful review of the entire procedure, including notes lurking on the chart. When you contact ATC, it’s also important to request the specific procedure–including the letter–that you want to fly.

And, if you’re using an IFR-approved GPS–even for situational awareness or to act as a substitute for DME or ADF  when flying a ground-based approach– ensure that you load the correct procedure and verify the key fixes before you begin flying the approach.

New Simulation and Training Rules Due in December 2017

The November/December 2017 issue of FAA Safety Briefing (dedicated to flight simulation) indicates that new FAA regulations proposed in May 2016 will be published in December 2017. In particular:

With another new rulemaking effort in the works, expected in December 2017, the FAA proposes to allow pilots to accomplish instrument currency pilot time in a FFS, FTD, or ATD without an instructor present to verify the time, as well as allow ATD time to accomplish instrument currency requirements to be identical to the tasks and requirements described for an aircraft, FFS, or FTD.

The other big change for many flight schools is allowing TAA to be used for commercial/CFI training in lieu of aircraft with retractable landing gear. The new rules would define TAA as “including a PFD, MFD and an integrated two axis autopilot.”

You can read more about the NPRM published in May 2016 at my blog, here.

 

 

My Prescription for Stall/Spin Training

My feature about stall and spin training in the November issue of AOPA Flight Training is now available online, here.
AOPAFT-Stall-Spin

RVR 1800 with AP, FD, or HUD

On May 30, 2017, FAA updated Order 8400.13D to allow “CAT I approaches with a DH of 200 feet and visibility minimums of RVR 1800 [a reduction from the typical 2400 RVR value] at runways with reduced lighting, using an aircraft flight director (FD) or autopilot (AP) with an approach coupler or head-up display (HUD) to DA.”

This change applies to ILS and RNAV (GPS) approaches with LPV minimums. (GBAS approaches are also included, but those procedures are, at present, rare.)
RVR1800-SatNews

The policy update was announced in the summer 2017 edition of SatNav News.

Here’s an example of the RVR 1800 minimums on the chart for the ILS or LOC Rwy 20 at KALW (Walla Walla, WA).

KALW-ILS-RWY 20-full

This typical category 1 ILS approach has an RVR of 2400 and a DA of 200 ft (1394 MSL).

KALW-ILS-RWY 20-mins
But as the notes for the procedure explain, the # symbol next to the S-ILS 20 minimums means that RVR 1800 is authorized with use of a flight director (FD) or autopilot (AP) or HUD to the DA.

KALW-ILS-RWY 20-notes
FAA Order 8400.13D adds the following information about reducing CAT 1 minimums to RVR 1800:

  • To be eligible for CAT I approaches to RVR 1800, runways must have or be qualified for a Title 14 of the Code of Federal Regulations (14 CFR) part 97 Standard Instrument Approach Procedure (SIAP).
  • Runways must have or be qualified for CAT I DH of 200 feet or less and visibility minimum of not more than 2400 RVR.
  • The runway must have a declared landing distance of 5000 feet or greater.
  • The runway also must have a simplified short approach lighting system with runway alignment indicator lights (SSALR), medium intensity approach lighting system with runway alignment indicator lights (MALSR), or approach lighting with sequenced flashing lights (ALSF-1/ALSF-2)
  • HIRL
  • TDZ sensor of an RVR reporting system.

The order adds that:

Any existing part 97 CAT I SIAP which did not qualify for 1800 RVR due to the absence of TDZ or RCL lighting can be amended to include 1800 RVR visibility.

When 1800 RVR operations are authorized, FAA will update the approach chart. If RVR 1800 minimums are authorized before a chart is updated, a NOTAM will be issued which authorizes RVR 1800. CAT I operations to RVR 1800 will be added to existing CAT I SIAPS in accordance with a schedule established by the Regional Airspace and Procedures Team.

The ILS OR LOC/DME RWY 21R at KPSC (Pasco, WA) is another example of RVR 1800 minimums authorized for an ILS.

KPSC-ILS-RWY 21R

The S-ILS 21R minimums line includes two asterisks that point to the notes section, which authorizes RVR 1800 with use of a FD, or AP, or HUD to DA.

KPSC-ILS-RWY 21R-Mins
KPSC-ILS-RWY 21R-Notes
The RNAV (GPS) Y RWY 21R at KPSC, updated in August 2017, shows the RVR 1800 minimums applied to an RNAV approach with LPV minimums. On this chart, the # note reference appears next to DA.

KPSC-ILS-RNAV 21R-Mins
KPSC-ILS-RNAV 21R-Notes

New Edition of Instrument Procedures Handbook

FAA has published a new edition of the Instrument Procedures Handbook (FAA-H-8083-16B). You can download a PDF of the IPH at the FAA website here.

The IPH is a complement to the Instrument Flying Handbook (FAA-H-8081-15B), available for download here.

A summary of changes in the new edition of the IPH is available as a PDF in my Aviation Documents folder, here.

IPH-Cover-2017