International Ops 2018

Flight Service Bureau | OPSGROUP

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That MMEL thing: here’s an update

The FAA is set to issue new guidance to provide a resolution to the long-running MMEL vs MEL debacle. However, it may not be the one we were expecting!

Last year, ramp checks on some US aircraft in France highlighted an important issue – EASA and the FAA have different interpretations of the ICAO standards regarding deferring aircraft discrepancies.

In the US, with FAA authorization operators can use a master minimum equipment list (MMEL) to defer repairing certain equipment. But in Europe, MMEL cannot be used in lieu of an MEL specific to each aircraft or fleet.

The European Aviation Safety Agency (EASA) began requiring all aircraft transiting European airspace to have an approved Minimum Equipment List (MEL) for each, individual aircraft. An MEL that references the MMEL was not acceptable.

This was a pain for US operators, as to get an individual MEL approved under the Letter of Authorisation (LOA) from the FAA takes time – but by not doing so, they ran the risk of failing a ramp check in a European country.

At the start of 2018, we understood that the FAA had reached an agreement with EASA: the FAA would start requiring international operators to obtain new D195 LOA’s, and in return EASA would halt any findings for a period of 12 months to allow for these new LOA’s to be issued.

But now we understand the FAA have decided that making operators get new D195 LOA’s will be far too much work for everyone involved!

Instead, they intend to just continue to issue the D095 approvals – but they will more vigorously validate the required components (such as the Preamble and M&O procedures).

This certainly appears to present a reversal of the previous commitment to EASA, who may very well not accept these LOA’s. If that happens, then the approval won’t be valid over in Europe – meaning ramp checks of N-reg aircraft in European countries will once again throw up the old MMEL finding, just like before.

We expect the FAA to officially issue this updated guidance to inspectors in the very near future, to be followed by a FAA InFo Letter to Part 91 Operators. The NBAA have said they will issue a bulletin to share the guidance as soon as it is released.

How to prepare for a ramp check in Europe?

We wrote a 2017 article all about how to make a ramp check painless.

We have also updated the FSB SAFA Ramp Checklist. Download it here.

Keep a copy with you and run through it before you head towards the EU.

 

 

Further reading

Runway? Who needs one when you have a taxiway!

It’s happened again.

Around midnight on a perfectly clear night last week in Riyadh, a Jet Airways 737 tried to take off on a taxiway. The crew mistaking a new taxiway for a runway!

The crew, with thousands of hours experience, took off on a surface that didn’t have runway markings or runway lights. Thankfully no one was seriously hurt.  It’s too early to exactly say why this happened, but it’s clear that some sort of “expectation bias” was a factor. Expecting to make the first left turn onto the runway. One has to ask – was ATC monitoring the take off?

After the tragic Singapore 747 accident in Taipei, technology was developed to audibly notify crew if they were about to depart “ON TAXIWAY”. This is known as the Runway Awareness and Advisory System (RAAS).

Sadly the Riyadh incident is not isolated. There have been a plethora of near misses in the past few years (more details in Extra Reading below).

There have also been more than a few “incidents” of aircraft from C17’s to 747s landing at the wrong airports! The most notable near miss recently was that of an Air Canada A320 nearly landing on a taxiway full of aircraft at KSFO/San Francisco. But it’s happened to Delta and Alaskan Air recently too.

It is an even bigger issue at a General Aviation level (and not just because Harrison Ford did it!). The FAA safety team recently noted;

The FAA Air Traffic Organization (ATO) has advised of an increase in, “Wrong Surface Landing Incidents” in the National Airspace System (NAS).

Incidents include:

  • Landing on a runway other than the one specified in the ATC clearance (frequently after the pilot provides a correct read back)
  • Landing on a Taxiway
  • Lining up with the wrong runway or with a taxiway during approach
  • Landing at the wrong airport

The FAA published some shocking statistics:

  • 557wrong surface landing/approach events” between 2016-2018. That’s one every other day!
  • 89% occurred during daylight hours
  • 91% occurred with a visibility of 3 statue miles or greater


So what to do?

There are numerous ‘best operating practices’ pilots can use to help avoid such incidents.

  • Be prepared! Preflight planning should include familiarization with destination and alternate airports to include airport location, runway layout, NOTAMs, weather conditions (to include anticipated landing runway)
  • Reduce cockpit distractions during approach and landing phase of flight.
  • Use visual cues such as verifying right versus left runways; runway magnetic orientation; known landmarks versus the location of the airport or runway
  • Be on the lookout for “Expectation Bias” If approaching a familiar airport, ATC might clear you for a different approach or landing runway.  Be careful not to fall back on your past experiences.  Verify!
  • Always include the assigned landing runway and your call sign in the read back to a landing clearance
  • Utilize navigation equipment such as Localizer/GPS (if available) to verify proper runway alignment

It’s worth spending a few minutes watching this.

Extra Reading

 

Why are you still getting the Ruudy6 wrong? Stop at 1500!

If you’re departing Teterboro any time soon, make sure you stop at 1500 feet – and have a good look at the rest of the RUUDY 6 departure. That’s the message from NY ATC, and the Teterboro Users Group.

The FAA has reported over 112 pilot deviations on the KTEB/Teterboro RUUDY 6  SID.

The Teterboro Users Group has asked us to remind all pilots that strict compliance is required, especially vertically.

“The most common error being a climb straight to 2000’ without honouring the requirement to cross WENTZ at 1500” – Capt. David Belastock, President, TUG

This week the FAA issued the following notice which explain the issue and the serious consequences of non-compliance, namely the reduced vertical separation with KEWR/Newark arrivals:

Teterboro Airport SID Deviations

Notice Number: NOTC7799

The Ruudy Six departure continues to incur both lateral, but in particular, vertical pilot deviations. Due to the proximity of Newark and other area airports it is imperative to follow the RNAV(RNP1) departure procedure to Performance Based Navigation (PBN) standards. Do not drift left off course to avoid noise monitors. Do not climb above 1500 until passing Wentz intersection. There is only 1000 feet of separation with overhead traffic at Wentz. When issued the clearance to “climb via the SID” all altitude restrictions must be complied with as depicted on the chart.

Attached are excerpts from the Aeronautical Information Manual and the Controllers handbook explaining the Climb Via procedure. An expanded explanation is in chapter 4 and 5 of the AIM.

Further information can be found on the Teterboro Users Group website http://teterborousersgroup.org and in KTEB Notice to Airmen (Letters to Airmen section)

There has been an extensive education campaign underway for a long period including guidance material, pilot meetings, educational podcasts and even a FlightSafety International eLearning course. Despite these efforts, pilot deviations continue to occur.

A great guide has been created by Captain Belastock and its very useful for any crews operating out of KTEB.

Know of any other procedures with unusually high non-compliance?

Let us know!

Don’t forget to file MACH number in NY Oceanic Airspace

KZWY/New York Oceanic FIR last month published a NOTAM requiring Flight Plans to be submitted with MACH crusing number, rather than TAS in Field 15A for the flight plan. So far, most operators are not doing this. But you should!

This includes flight departing TXKF/Bermuda.

A0178/18 – ALL ACFT ENTERING THE NEW YORK OCEANIC FIR (KZWY), INCLUDING THOSE DEPARTING BERMUDA (TXKF) , MUST FILE A MACH NUMBER INSTEAD OF A SPEED OF KNOTS IN THE EXPECTED CRUISE SPEED FIELD (FIELD 15A) OF THEIR FPL. 03 MAY 17:08 2018 UNTIL 31 MAR 23:59 2019. CREATED: 03 MAY 17:09 2018

Reports are that compliance so far has been low.

So why do it?

NY ARTCC tell us:

This minor adjustment enables the ATC computer system to effectively probe flight plans and proactively offer more favorable routes and/or reroutes.

Help ATC out! Thank you.

 

Who is still flying over Syria?

We have reported recently on the complex airspace picture and dangers associated with the ongoing Syrian conflict.

Most major carriers have taken the advice of numerous government agencies to avoid Syrian airspace altogether; the FAA going as far as calling on all operators flying within 200 nautical miles of the OSTT/Damascus FIR to “exercise caution”.  Today, the only airlines flying over the airspace are locally based Syrian airlines, Iraq Airlines and Lebanon’s Middle Eastern Airlines.

These MEA overflights are of interest. The airline is a member of the SkyTeam alliance and has codeshare agreements with several high-profile airlines (Air Canada, Air France, etc.) Despite the repeated warnings of the ongoing dangers associated with overflights of this conflict zone, the airline has chosen to schedule more than half-a-dozen flights over the airspace each day.

Some of these flights have the usual codeshare practise of other airlines booking their passengers on MEA flights. Our research shows that Etihad Airways, Qatar Airways (Oneworld Alliance) and Royal Jordanian Airlines (Oneworld Alliance) passengers are still being booked on MEA flights to/from Beirut; likely unbeknown to their customers of the increased flight risk. All three airlines continue to service Beirut with their own aircraft, but all three avoid Syrian airspace, naturally accepting the best advice to avoid the area completely.

Something isn’t right here: no warning anywhere about these flights being flown over Syria.

So why is it safe for passengers to overfly Syria on an MEA flight, but not on any of the other airlines? And more importantly, why is MEA still operating over Syria anyway?

It looks like Kuwait Airways will be the next codeshare partner of MEA, so it will be interesting to see whether the issue of the overflight of conflict zones will be discussed.

As always, keep an eye on our Safeairspace map for the latest worldwide updates.

Last minute ATC grab in Congress

On Friday Apr 27, the US House of Representatives approved a long-delayed bill to authorize funding for the FAA, after GA advocates had mobilized earlier in the week to fight-off a last-minute attempt to privatize US ATC.

Late on Tuesday Apr 24, Republican Bill Shuster, chairman of the House Transportation and Infrastructure Committee, introduced a “managers amendment” to the proposed five-year FAA funding bill.

His amendment called for two things:
1. Remove the US ATC system from the FAA and instead make it part of the Transportation Department.
2. Allow it to be run by a 13-member advisory board made up mainly by airlines.

“Both of these provisions were drafted in the dark of night, without any opportunity for public debate,” said NBAA.

After last minute lobbying by GA advocates, the two contentious items in the bill were removed.

While Shuster agreed to remove the measures, he reiterated that he “strongly believe[s] Congress must pass real air traffic control reform” and that he sees that happening “somewhere down the line.”

“We are pleased to see this legislation pass the House,” said NBAA President and CEO Ed Bolen. “While the bill is not perfect, a long-term reauthorization is critical to advancing our shared priorities. Equally important, this bipartisan bill will modernize, not privatize air traffic control. We are grateful that members of Congress heard their constituents’ concerns about ATC privatization, and reflected those concerns in bringing this legislation to final passage.”

Saudi – Yemen Airspace Update

In Short: Avoid Yemen & Southern Saudi airspace, and monitor risk for OERK/Riyadh. The armed conflict continues with regular ballistic missile launches from Yemen.

Once again there is increased missile activity in the southwest of Saudi Arabia, with a reported 35 missiles launched from rebels in Yemen this year. 14 of these were in April – about the same amount as August 2016 and December 2015, but most are now being shot down by Saudi Patriot missiles; only 3 have struck Saudi soil this year.

OERK/Riyadh continues to be on the radar for the Houthi’s. Of most concern, an F-15 was hit by a SAM over Yemen on 21 March, fired from OYSH. There is definitely a risk to operations in Saudi airspace, even outside the Scatana area.

So far the only missile attack known to have resulted in any casualties was on Mar 25, when seven ballistic missiles were fired toward Saudi Arabia from within Yemen. Yemeni forces said they were targeting OERK/Riyadh Airport and other sites in the capital. The Saudi government said that all seven missiles were intercepted and destroyed, although one person died and two more were injured by falling fragments of one missile over a residential neighbourhood in Riyadh.

Much of the information comes from state media and cannot always be independently verified. As the propaganda campaign continues, a New York Times investigation suggested that at least one of the most high-profile attacks from 2017 may not have been “shot-down” or intercepted by Saudi defense systems at all.

 

The conflict and insurgency on the ground remains complex and volatile. Safeairspace continues to provide up-to-date information for both Saudi and Yemen airspace.

Yemen is still at FSB Risk Level: One – DO NOT FLY – We strongly recommend avoiding this airspace entirely. The FAA and several other agencies have amended their advice and the current airspace advice map looks like this at present:

SCATANA rules are active in the southern part of Saudi Arabia, due to the current Saudi-led Intervention in Yemen.

This NOTAM, published by authorities in Yemen for the OYSC/Sanaa FIR, can definitely be taken with a grain of salt:

A0026/17 – ALL YEMEN AIRPORTS EXCEPTS TAIZ HODEIDAH AND MUKALLA INTERNATIONAL AIRPORTS ARE AVAILABLE AND READY TO HANDLE ALL FLIGHTS INTENDING TO FLY TO OR FROM YEMENI AIRPORTS ALSO SANAA ACC IS COMPLETELY READY TO PROVIDE ATC SERVICES TO ALL FLIGHTS OVER FLY SANAA FIR AND BASED ON THE DECLARATION OF DECISIVE STORM TERMINATION WE CONFIRM THAT SANAA FIR AND YEMENI AIRPORTS ARE SAFE EXCEPT THOSE MENTIONED ABOVE. 03 APR 18:00 2017 UNTIL PERM. CREATED: 01 JUL 15:24 2017

Extra Reading:

Kenya airspace threat downgraded

The FAA has revised its warning for Kenyan airspace – the area to ‘exercise caution’ is now limited only to that airspace east of 40 degrees East longitude below FL260 (i.e. the border region with Somalia, and 12nm off the east coast of Kenya). Prior to this, their warning applied to all airspace in Kenya below FL260.

Published on 26 Feb 2018, the warning maintains the same wording to clarify the type of weapons and phases of flight that the FAA is concerned about, specifically:

  • fire from small arms,
  • indirect fire weapons (such as mortars and rockets), and
  • anti-aircraft weapons such as MANPADS.

The scenarios considered highest risk include :

  • landings and takeoffs,
  • low altitudes, and
  • aircraft on the ground.

The updated guidance is intended for US operators and FAA License holders, but in reality is used by most International Operators including EU and Asian carriers, since only four countries currently provide useful information on airspace security and conflict zones.

The Notam uses FL260 as the minimum safe level, though we would suggest, as usual, that a higher level closer to FL300 is more sensible.

You can read the NOTAM in full on our Kenya page on SafeAirspace.net, a collaborative and information sharing tool used by airlines, business jet operators, state agencies, military, and private members of OPSGROUP.

RWSL: Red Means STOP!

As you may know, the FAA is working on Runway Status Lights (RWSL). It’s a new system that’s live at 20 airports in the US. Basically, you get a nice set of red lights (embedded in the ramp) that tell you whether it’s safe or not to proceed. These lights are installed (or placed or located) at the entrance of the runway and at the start of takeoff. If any of these lights are red, you don’t go. Simple as that.

Diagram of RWSL

These lights are fully automated and completely independent of ATC, which means they do not have a clue if the lights are red or not. This is intentional. If you get clearance from ATC, and you see red lights, the red lights take precedence over the controller. The FAA has issued SAFO17011, stating:

There have been several instances at RWSL airports where flightcrews have ignored the illuminated red in-pavement RWSL lights when issued a clearance by Air Traffic Control (ATC). Illuminated RWSLs mean aircraft/vehicles stop or remain stopped and contact ATC for further direction, relaying to ATC that the RWSLs are illuminated.

This system will be expanding throughout the United States, and you can read more about the system here: FAA Runway Status Lights.

Overflights without a full Airworthiness Certificate

For many countries, if an aircraft is operating normally, no Overflight or Landing permit is required. Sometimes, however, the aircraft will not meet full airworthiness requirements but is still safe to fly.

New deliveries, ferry flights to a new operator, maintenance flights, or positioning to storage, may all have special circumstances that normally result in the aircraft operating with a Special Airworthiness Certificate.

DSC00010

Special Airworthiness Certificates

The most common type of Special Airworthiness Certificate is a regular Ferry Permit. The FAA call this a ‘Special Flight permit’, EASA’s term is a ‘Permit to Fly’. It is issued by the Country of registration and allows an aircraft to be flown on a specific route and date, eg. for delivery, maintenance, transfer of ownership.

Other types of Special Airworthiness Certificate categories are Restricted (eg. modified special purposeaircraft like NASA’s 747SP with a telescope, or Pratt & Whitney’s 747 engine testbed), Experimental (like the Lockheed Martin X-55.

SAC

 

Special Permit (Flight Authorisation)

Every aircraft operating on a Special Airworthiness Certificate requires a Special Authorisation from each country being overflown or landed in. This is normally requested from the Ministry of Transport for that country, or the technical department of the Civil Aviation Authority. Official processing times are up to 20 days.

Specific to foreign operators flying to or over the USA, the FAA term for this is ‘Special Flight Authorization.

EU Blacklist – Special Permit

For Operators that are on the current EU Blacklist under Annex A (airlines that are banned from operating in the European Union) and Annex B (airlines that are permitted to operate in the European Union only under specific conditions), a Special Permit can also be obtained to allow flights that are required to operate to the EU for maintenance or other reasons. A separate permit is required from each EU country enroute.

Together with obtaining a Special Permit for each EU country overflown, SAFA must be notified, and the standard Eurocontrol FPL Alarming system must be deactivated for your flight.

Processing Fees

The cost to obtain a Special Permit is different for each country, according to complexity and Civil Aviation and Ministry of Transport charges.

What’s the easiest way to file a request for a Special Permit? 

Many can now be done online through the Flight Service permit tool.

Special Permit

 

 

You can also contact service@fsbureau.org for any questions.

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