What Program Manuals Are Now Required For An Aircraft Operator Or Owner For Complete Compliance With CFR 91 For The FAA And Annex 6 Part II For ICAO For US And International Flight Operations?
1. RVSM & SAO Airspace Operations & Equipment Manual with authorizations (LOAs) for RVSM / NAT-HLA / RNP 1, 2, 4, & 10/ B-RNAV-RNAV5 / P-RNAV / CPDLC (mandated in the NAT-Track System FL350-FL390) / ADS-B (mandated in certain countries & FIRs).
2. For US: Use of FAA MMEL as MEL with a Maintenance Procedures Document with (LOA D095)
3. For ICAO, Europe, & European Member States: Serialized/Custom for Aircraft serial number specific MEL with (LOA D195).
4. Operations Manual (ICAO Compliant and SMS (Safety Management System) operators must comply with the requirements of each ICAO state that flight operations are conducted in (An FAA LOA is not required).
For Domestic U.S.?
1. RVSM Airspace Operations & Maintenance Manual with authorization (LOA) for RVSM. An RNP 4 or 10 authorization (LOA) is recommended if you plan transition across the Gulf of Mexico (GoMex) CTA.
2. For Aircraft that are ADS-B Out Equipped and Certified with DO-265B V2 Tranponders and 1090ES and operating within the 48 Contiguous US States, an RVSM LOA B046 is not required.
3. Aircraft FAA MMEL with a Maintenance Procedures Document or custom serial number specific MEL with (LOA) is always required.
What Are Some Of The Myths About RVSM & SAO Airspace Manuals And The FAA Approval Process?
One Day Manuals: Despite all the promises you may receive, RVSM Manuals, Aircraft MELs, and most Serial Number Specific Manuals that require information that is specific to an aircraft serial number and component configuration cannot be written in a day. An early Falcon 2000 varies considerably from a Falcon 2000LX EASy II as the advancements and combinations of avionics components are quite more complex on the newer 5th generation module type models than on the “black box” type components and it is the same case for the aircraft MEL. There is no “cookie cutter” approach as each OEM or STC holder dictates as to which components are critical for RVSM and part numbers can vary considerably by serial number. The FAA performs a conformity check with a list of supporting documents for the Aircraft and Flight crew – providing a complete, accurate and complete application is the key factor for a smooth approval process and is usually the most challenging aspect for an older aircraft that has been brought into RVSM airworthiness by an STC or Service Bulletin.
Short Term LOAs: for repositioning, demo, and flight research require the exact same supporting documentation as Long Term as the FAA Job-Aid requirements are the same for both LOAs and will serve each operator in practical way if a Long Term LOA is not required. The restriction usually imposed by the FAA & ICAO is 30 days.
It is strongly recommended that a new Owner or Operator apply for the long-term which is the normally issued FAA LOA for the cost-savings and more importantly avoiding a duplication of the FAA approval process.
How Long Does The RVSM & SAO Airspace LOA/MSpec/OpSpec Approval Process Take?
This depends on each individual FAA FSDO, IFO, or IFU’s workload. The FSDOs, IFUs, and IFOs have an allocation of up to 60 days (Government shut-downs or sequestration, and FAA employee layoffs can cause delays beyond the 60 day allocation) for CFR Part 91 Operator RVSM and SAO airspace approvals although we have experienced much less. Our recommendation is to contact the appropriate FAA office for your region and ascertain their current completion times. Neither the Operator, Manual Preparation Company, or the Aircraft Manufacturer has any impact on the duration of this process. Our Manuals are technically correct and reflect the latest Advisory Circulars and regulations, thus we have had excellent results. Every office varies and the FAA RVSM and SAO Airspace approval process can take as little as a few days and in most cases longer. If you receive a promise from another company that states their RVSM and SAO Airspace Approval Process takes less time – We would definitely recommend that you obtain that in writing.
What Is The First Step In The RVSM & SAO Airspace Authorization Process?
A Pre-Application Meeting with the FAA via Phone or if the FSDO, IFU, or IFO requires it, scheduling a meeting with an FAA Inspector in person. This will help achieve the desired results as some FAA regional offices have their own special requirements especially for Foreign Based N-Registered Aircraft. What Is DRVSM? Domestic U.S. RVSM (DRVSM) refers to RVSM policy/procedures to be applied in the lower 48 states, Alaska, Gulf of Mexico, Atlantic High Offshore Airspace, and the San Juan FIR on January 20, 2005 or basically North America. What Airspace Does An DRVSM Manual Cover? Due to harmonization, this manual contains guidance for Canada, Mexico, Atlantic & Gulf of Mexico High Offshore Airspace, and the Caribbean which would be considered as North America. Is RVSM Aircraft And Pilot Authorization Worldwide? Yes, but there are restrictions due to area navigation (RNAV) or Required Navigation Performance (RNP) requirements such as MNPS, RNP 4-10, B-RNAV/RNAV5, & PRNAV, for North Atlantic, Pacific, WATRS Plus, Oceanic, and European airspace which requires additional LOA’s or Opspecs for the Aircraft, Crew, and additional training requirements for Part 91 Operators and Air Carriers under FAR Part 135 or 121. Operating Procedures are specific for Oceanic /SAO Airspace.
What Are The FAA Requirements For A Foreign-Based N-Registered Aircraft To Obtain An FAA Letter Of Authorization (LOA) For Operations In RVSM, SAO Airspace, and/or MEL?
An aircraft is eligible for U.S. Registration if it is not registered in another country and it is owned by:
- An individual who is a United States citizen,
- Holds an FAA Certificate,
- A partnership each of whose partners is an individual who is a U.S. citizen,
- A corporation or association:
- organized under the laws of the U.S. or a State, the District of Columbia, or a U.S. territory or possession,
- of which the president and at least two-thirds of the board of directors and other managing officers are U.S citizens, and
- in which at least 75% of the voting interest is owned or controlled by persons that are U.S. citizens,
- An individual citizen of a foreign country lawfully admitted for permanent residence in the U.S.,
- A U.S. governmental unit or subdivision
- A non-U.S. citizen corporation organized and doing business under the laws of the U.S. or one of the States as long as the aircraft is based and primarily used in the U.S. (60% of all flight hours must be from flights starting and ending within the U.S.)
When Should I Start The RVSM, SAO, CPDLC, MEL, & SMS Application With SourceOne Aviation Compliance?
If you are purchasing an aircraft, you should start as soon as the sale is finalized. If you are having your aircraft equipped for any of the above – start when you have an equipment installation appointment and SourceOne Aviation Compliance can then start working with you and the installer to get the correct paperwork. We for sure would like to start when the aircraft is physically in the completion center so we have an interface with them.
We Fly Internationally, Does Our Flight Department Need To Purchase A Separate Oceanic & International Operations Manual?
Yes. ICAO and the FAA require current and accurate Operational Policy and Procedures for each LOA issued for SAO or Special Areas of Operation aka Oceanic and International Airspace.
What Authorizations Will We Receive For SAO (Special Areas of Operations) Airspace?
This depends on how the aircraft is equipped. Except for the Gulf of Mexico, dual Installation of Long Range Navigation Equipment such as FMS, FMC, INU’s, INS, GPS, and any other LRN’s each have capabilities specifications from the manufacturer for NAT-HLA / RNP 2, 4 or 10 / B-RNAV / P-RNAV. For CFR Part 121 & 135 Operators will be required to apply for each Specific Area of Operation.
A CPDLC & ADS-C is required in the NAT-HLA and some Pacific FIRs at FL290-FL410 on January 30, 2020.
ADS-B Out is required Worldwide on January 30, 2020.
Who Has To Interact With The FAA?
The FAA requires a relationship with you as an “Agent for service.” FAA offices now have a specific Letter of Application format they want followed and they insist that it must come from the Operator or Owner and not from a third party unless the FAA makes an exception during the process as has sometimes occurred.
How Long Am I provided With Support On The RVSM & SAO Airspace Approval Process?
Our Team provides continuous support throughout the FAA RVSM and SAO Airspace FAA approval process.
What Are Some Issues Or Challenges With The RVSM Approval Process?
New Aircraft. The Operator has just purchased the aircraft and has not designated a Director of Maintenance or Maintenance Representative. We can give direction and support in this area. Incomplete documentation. We will thoroughly review the supporting documentation such the ASC, STC, SL, SB, and AFM Supplements and or other documents that was submitted to us. We may require additional supporting maintenance information. Lack of a Maintenance Inspection Tracking Program. The operator does not have an inspection tracking program and uses the Aircraft Maintenance Manual chapters to determine what task is required to be completed at any given inspection. The FAA may require and may come to your facility to review your maintenance records pertaining to RVSM that you have and to be sure you have an adequate inspection tracking program that has incorporated the AVTrak, FlightDocs, CMP.Net, CAMS or CESCOM-CAMP items from the RVSM installation documents. AOG. The aircraft is coming out of the RVSM installation and leaving on an international flight and there is no RVSM approval that can be used in the NAT-HLA, CPDLC, ADS-B Out, RNP 2, 4. or 10, and European airspace. This will have to be reviewed by the FSDO and it depends on their workload.
What About Renewals?
The new RVSM and SAO Airspace authorizations are issued under the FAA’s Operations Specifications System (OPSS) and they do not have a renewal requirement as long as the registered owner, operator, and base of operation remain the same, though they can be altered by the FAA for just cause. Older RVSM & SAO Airspace LOAs that did expire are simply converted to the new OPSS system. You need to contact the FAA at least 30 days in advance of the expiration of your original RVSM and SAO Airspace LOAs.
Do I Need An MEL or Can I Use The FAA’s MMEL As I Have Been Doing?
For Part 91 Operators we offer a MMEL to supplement your RVSM Application if you do not currently possess an MEL. This is to get each Operator started but the FAA LOA D095 in all case requires the operator to have a maintenance procedures document in place after they received the LOA as well as other components that are required/ We can provide and FAA MMEL program or a custom aircraft type with serial number specific MEL, and we tie the MEL into the aircraft support documents to help with decisions about contingencies and other problems. These MELs are then directly tied together to be sure you are always operating within a known parameter of approval, to include RVSM, MNPS, RNP-5 and RNP-10 issues. However, if you are a Part 91 operator then we should be able to get you an MMEL approval initially as some FAA FSDO’s will require an MEL specific to your aircraft and equipment with Maintenance & Operations Procedures (M’s & O’s) and for FAR Part 135 operators – a NEF (Nonessential Equipment and Furnishings) program.
What Does Serialized Aircraft Specific MEL Contain That The FAA MMEL Does Not?
Your fleet aircraft and or serial number specific MEL will contain the Maintenance, Operations (M&O) and Placarding documents. Where the MMEL states “As required by 14 CFR”, your MEL will list the particular regulation by part and section or describe the actual 14 CFR requirement applicable to your particular operation. The FAA requires that these documents be on board the aircraft and accessible to the flight crew during operations. If the FAA approves your company to use the MMEL as your MEL, you will need to have these areas (O & M, and CFR) covered and it is the owner/operators responsibility. When you purchase an MEL, it will have all these documents current and updated all in one convenient binder. A serialized or fleet MEL complies with the FAA Order 8900.1 Volume 4, Chapter 4, and the applicable section for the NEF, 14 CFR 91, 91K, 135, and the current FAA Advisory Circular 91-67.
How Do I Renew My Letter Of Authorization (LOA)?
If your LOA was issued after February 6, 2006, you do not need to renew your LOA. This LOA is valid until the aircraft changes ownership or if you change the way you operate the aircraft. LOAs issued prior to February 6, 2006 are determined to be invalid after 24 months and you may be required to submit a new approval application to the FAA. Please contact your issuing office to determine whether you need to submit a new application. We recommend you start this process at least 60 days prior to the expiration date.
How Do I Complete The Task of a Height Monitoring Flight?
Within Six (6) months of issuance of your RVSM LOA, complete the ADS-B an RVSM height monitoring flight if it hasn’t already been completed by the previous owner. There are two choices: Over fly one of the AGHME (Aircraft Geometric Height Measurement Element) constellations, which is a no cost service. The AGHME system does not require any special monitoring devices be installed on your aircraft in order for it to be monitored. If your aircraft is equipped with a Mode S transponder, the AGHME can simply be flown over. AGHME constellations are currently operational in Wichita, KS, Atlantic City, NJ and Cleveland, OH. Click on the icon below to link to the AGHME website for locations, procedures and a height monitoring application form. North American Approvals Registry and Monitoring Organization. Complete a “GMU” (GPS-based Monitoring Unit) flight. The technician performing the monitoring flight carries onboard a small, portable GPS unit with two antennas which will suction cup to two interior windows. The GMU flight requires you to fly above FL290 and hold LEVEL for 30 minutes while the GPS unit records flight data. Contact CSSI or ARINC on our News Page.
Can I Get Electronic Manuals For Laptops, Electronic Flight Bags (EFB) And IPADs?
Of Course. We can provide an EFB and IPAD Version. The EFB, iPad (iOS), & Surface Pro (Windows OS) versions utilize our viewing Application with secure PDC files and may be used for the RVSM Manuals, Oceanic & International Operations Manual, General Company Operations Manual, GMM and the MEL/MMEL. See our “Purchase” page via our website for more information.
What training requirements must be completed by the Flight Crewmembers for RVSM, Oceanic, & International Airspace?
Generally, only Pilot training certificates are required and these may be from an on line training source, a training center program or your own program. Sometimes the FAA is going to ask for a training syllabus, which you can obtain from any of the sources, including the online training sources that are FAA Approved. Training from an FAA approved source as appropriate for authorizations and areas of operation in the form of a specific Training Certificate or Records for RVSM, MNPS, RNP 1, 2, 4, & 10, B-RNAV/RNAV 5, P-RNAV or an International Procedures Course (IPC).
Is There A Charge For Technical Support From SourceOne Aviation Compliance?
No, not within the course of getting your original LOA’s or OpSpec.