Viewpoint: After The Lull: Operators Must Review Procedures
As more countries around the world loosen travel restrictions, it’s exciting to see business aviation activity on the rise once again. But after such a long lull, it is important that operators review their procedures to make sure they are up-to-date and in compliance, as well as to ensure they have the latest authorizations.
So as not to miss anything, updates to manuals and authorizations should ideally be part of a change management process. This could simply be in the form of bulletins or change notifications, which can be managed internally or via a third-party vendor.
International procedures change frequently and should be reviewed first. As an example, oceanic contingency procedures were harmonized to a 5-nm offset just last November. In the U.S., several LOAs (Letters of Authority) were recently decommissioned for Part 91 operators, such as A153 (ADS-B Out) and B034 (P-RNAV/B-RNAV). North Atlantic authorization B039 was also updated to reflect the new NAT HLA terminology.
Operators flying to specific areas may need to account for additional LOA considerations; for instance, trips to Hawaii are required to have both LOAs B046 (RVSM) and B036 (RNP-10 approval) for flights occurring between 29,000 ft. and 41,000 ft.
Everyone flying the North Atlantic should also be aware that the CPLDC (controller pilot data link communication) mandate, requiring CPDLC equipage and authorization, which was temporarily suspended during the peak of the pandemic, has now resumed.
For operators flying in Australia, RNP-2 capability and authorization are currently mandated for en-route continental operations. This can also be obtained through an authorization for Oceanic and En route Continental RNP (required navigational performance) (B036 for U.S. registered operators).
If you need LOAs, there is good news on the horizon. A joint FAA/industry working group is developing a new LOA Streamlined Program. The aim is to create a simplified operational approval process for Part 91 Operators. Eligible applicants will be able to use a single application to request up to ten authorizations and can expect expedited LOA approvals when bringing on new aircraft.
Another current topic is the Minimum Equipment List (MEL). Operators flying internationally should have an MEL. It is both a superior resource to an MMEL and is required as part of the Safety Assessment of Foreign Aircraft (SAFA), a part of EASA’s Ramp Inspection Program. This also aligns with ICAO Annex 6 requirements. Failure to have an MEL could result in a finding that is reported to the state of registration (e.g., the FAA).
Beyond MELs, there are 53 additional inspection elements in the SAFA program which cover items including the flight deck (documentation, emergency equipment, etc.), cabin safety equipment, general aircraft condition, the cargo compartment, and more. We highly recommend performing a periodic run-through of the SAFA inspection elements to make sure you meet these requirements.
Common SAFA inspection findings include:
• Fuel planning issues (such as reserve fuel not meeting requirements);
• Condition of the cabin (obstructed emergency exits, etc.); and
• Defect Notification and Rectification (improper defect deferral, no MEL, etc.).
In general, since many operators have not traveled internationally recently, it is also crucial to make sure your basic travel documentation is in order.
While it is indeed vital to ensure crews and passengers meet any Covid-19 vaccination protocols, do not neglect other vaccination requirements. Check that passports and visas are valid for the full duration of the trip. Timeframes to receive your renewed documents may be delayed with government services still recovering from the effects of the pandemic, so it is important to coordinate this well in advance.
Finally, after your procedures and documents are set, you need to review some essential trip planning considerations for your flight. Research the countries you plan to overfly and visit for any ongoing health crises or geopolitical tensions.
Pay close attention to your route to ensure it does not overfly areas of restricted operations and your intended landing and diversion airport(s) have the resources you may need, such as fuel, maintenance, and security services.
Lastly, your crews and passengers should be briefed on what to do during an unexpected event while at their destination. An up-to-date ERP can help you accomplish this.
There are a number of elements to consider and review; start early so you will have the time, options, and the know-how to handle the unexpected and to ensure a safe and smooth trip.
Viewpoint by Mark Baier, CEO of AviationManuals, a Washington D.C.-based provider of operations manuals and Safety Management Systems for business aviation flight departments, aircraft management companies, owner-operators, FBOs and commercial drone operations.