Category: Business Aviation

Get Ready for Revised 2018 IS-BAO Standard

As you may be aware, IBAC is making significant changes to the IS-BAO standard this year. We wanted to share some information about the changes and how they may affect operators. In addition, we have highlighted steps you will need to take in order to be compliant with the new standard.

The 2018 IS-BAO standard was released at the beginning of the year in beta version with the go-live scheduled for July 1, 2018. Operators, however, can continue to use the 2017 standard until July 1, 2019.

Key changes

  • ERP protocols are being added back in and slightly expanded
  • Redundant protocols are being removed or consolidated
  • The International protocols are being removed or merged with the ‘regular’ flight operations protocols
  • The ‘regular’ flight operations protocols are being reorganized to align more closely with the steps of scheduling/planning a trip and phases of flight

What does this mean for you?

Depending on your situation, one of the following scenarios will apply to you:

  1. If your manual has not been updated to the 2017 IS-BAO standard and you have an audit prior to July 1, 2019, you will need to update your FOM at least two months prior to your audit. We can include best practices and any revisions that you may have as part of a standard reissue.
  2. If your manual has been updated to the 2017 IS-BAO standard and you have an audit prior to July 1, 2019, you don’t need to do anything at this time. That said, we still recommend updating your manual with best practices and any applicable revisions.
  3. If you have an audit after July 1, 2019, your manual will need to be updated to the 2018 IS-BAO standard at least two months prior to your audit. Again, we will also include best practices and any revisions that you may need at that time.

You’re in good hands

We recognize this is an unusual IS-BAO update transition; rest assured, we will stay on top of these changes for you.

Please find attached an information sheet that goes into more detail.

Questions? We’re there to help. Get in touch today.

What Should You Do to Respond To the Data Link LOA A056 Changes

The FAA introduced a new template for LOA A056 for Data Link communications in November 2017. The new template adds two pieces of information that were not previously tracked. The changes focus on the PBCS capabilities, in order to meet the March 29, 2018, PBCS implementation, and the name of the service provider used for Data Link services for each aircraft.

Here are four paths to take when responding to the Data Link LOA changes, depending on your status:

I already have an approved LOA A056 and it is in the new format:

  •  You are in compliance with both the PBCS implementation and Data Link mandate already. No further action is needed.

I already have an approved LOA A056, but it is not yet in the new format:

  • Fill out a new A056 application and ask FSDO to reissue your A056 in the new format.
  • In rare cases your FSDO may issue you the new LOA A056 without a full resubmission. Be sure to speak with your inspector to get a better idea of what exactly they would like you to submit.

I do not have an approved LOA A056, but have submitted an application OR I have submitted a request to add a new aircraft to my LOA A056:

  • Be sure your submission has been prepared using the FAA’s newest format.
  • If you submitted prior to November 2017, and your request hasn’t been approved yet, you will need to re-prepare and re-submit.

I do not have an approved LOA A056, and have not yet applied:

  • Be sure to have your aircraft upgraded to meet Data Link requirements as soon as practical if you intend to keep operating in the NAT. Right now, Data Link is required for any NAT operations at FL340 to FL390.  Beginning in January 2020, Data Link will be required for all NAT operations at FL290 and above.
  • Apply for an LOA A056 using the FAA’s newest format.

To learn more about how AviationManuals can help, contact us today.

 

MEL 2017 in Review

With numerous changes to Minimum Equipment Lists (MELs) having gone into effect in 2017 and with more to come in 2018, now is a great time to ensure your MEL is up-to-date and compliant.

The most notable change last year was the enforcement of the ICAO Annex 6 and EASA requirements requiring operators to have a specific MEL for their aircraft when operating to or from EASA member states.

U.S. Part 91 twin turboprops and jets flown in Europe are now required to operate with an MEL developed for a specific aircraft under Letter of Authorization (LOA) D195, rather than with a manufacturer’s aircraft model Master MEL (MMEL) approved by the FAA under LOA DO95.

In addition, there were also a number of required revisions introduced to FAA Master MELs and policy letters during the course of 2017.

Check the list below to see if your aircraft is on it. If so, you will need to make sure that your MEL is up-to-date. Operators have 90 days from the date of the MMEL to revise their manuals.

What’s new in 2018?

This year, we expect to see significant changes to MELs for U.S. Part 91 operators and further updates to MMELs. So far, there have already been two updates to MMELs in 2018, including for the Citation 500 series.

The FAA is reportedly planning to release a Notice requiring all aircraft operating internationally to have an individual MEL and D195 LOA. It is also anticipated that EASA will announce that, while they will continue to enforce the D195 LOA mandate for U.S. Part 91 operators, they will grant a 12-month grace period to allow operators time to comply.

Revised FAA MMELs include:

  • Boeing 737 – Rev 59 – 02/13/2017
  • Challenger 600 – Rev 10a – 01/06/2017
  • Falcon 7X/8X – Rev 11 – 11/06/2017
  • Falcon 900EX EASy, 900DX – Rev 8 – 01/19/2017
  • Embraer EMB-500 (Phenom 100) – Rev 3 – 05/11/2017
  • Embraer EMB-545 / EMB-550 (Legacy 450, Legacy 500) – Rev 2 – 07/28/2017
  • Gulfstream G280 – Rev 3 – 10/31/2017
  • Gulfstream V Series – Rev 9 – 12/18/2017
  • Cessna Citation 500 Series – Rev 10 – 01/03/2018

Policy letter changes include:

  • Navigation Database text – 6/1/2017
  • Protective Breathing Equipment (PBE) – 12/4/2017

Can You Take Off with a Broken Cup Holder?

NEF, MMEL, LOA, MEL, aviation, business aviation

Nonessential Equipment and Furnishings Program (NEF): Allows operators to use the deferral authority granted in the MMEL to provide relief for inoperative, damaged, or missing nonessential items.

Operators who hold an LOA authorizing the use of an MMEL as an MEL or a customized MEL can only defer items listed in their MELs or via their NEF Program. Therefore, if an operator does not have an NEF Program, any inoperative nonessential items must be operative for flight.

Need an NEF Program to cover your cup holders? Let AviationManuals support you.

10 Facts About Letters of Authorization (LOAs)

Just because you have one or two LOAs stored in your aircraft doesn’t mean you understand them. AviationManuals gets to the facts.

Although LOAs are a common requirement for Part 91 operators, there remains considerable confusion as to the details.

To clear the air, let’s look at some LOA facts.

Learn More: LOAs – what they are, who they’re for and how to get them

  1. An LOA is tied to the aircraft and operator, not the documentation.
    Whenever an aircraft is sold or the operator changes, you must apply for a new LOA. If, however, the only change is to the documentation supporting the LOA (i.e., training certificates or operations manuals), then you do not need to apply for a new LOA.
  2. LOAs do not expire.
    Yes, way back when Reduced Vertical Separation Minimum (RVSM) was a new thing, LOAs came with an expiration date. However, this is no longer the case except in rare circumstances. Therefore, you do not need to renew LOAs on a regular basis.
  3. Get it. Store it.
    LOAs are typically ‘one-and-done’. Once you have it, stick it in your aircraft and leave it well enough alone. There’s rarely – if ever – a need to follow up with your Flight Standards District Office (FSDO). In fact, there’s only two reasons to speak to an FSDO about an existing LOA: to add an authorization (such as a new aircraft or capabilities) or to revise its information.
  4. The FAA has authority to pull an LOA.
    The FAA does have the authority to revoke an LOA. However, it is unusual for them to exercise this authority. For example, if you report an incident to the FAA, they could place a hold on an LOA while reviewing your records.
  5. Only an operator (or their authorized representative) and the FAA have the authority to withdraw an LOA.
    In other words, unless specifically authorized to do so, a third party cannot request that your LOA be withdrawn.
  6. Part 91 operators don’t need to have IOMs regularly reviewed by the FAA.
    Part 135 operators must have all changes to the IOM submitted as they happen.
    Although the FAA doesn’t require Part 91 operators to update IOMs, they do expect you to stay current on changing procedures. Therefore, it is highly recommended that you invest in an update service.
  7. You do not have to notify the FAA when you switch manual vendors.
    You can change your vendor to your heart’s content without ever giving notice to the FAA. That being said, it’s always a good idea to inform your Principal Operations Inspector (POI) about any changes.
  8. RVSM maintenance programs are no longer required.
    The days of the RVSM maintenance program are gone, so you can stop maintaining them.
  9. If you’re worried about losing an LOA when switching manuals, consider starting your manual as an additional IOM.
    While the additional IOM is being reviewed, keep your current manual as is. Once you get the ok from the FAA, cancel the old service. This eliminates any ‘gap’ that could be misconstrued as being non-compliant with your LOA. Even though you would never actually be non-compliant, this strategy gives you an additional layer of support.
  10.   If you do run into trouble, seek the advice of an experienced, responsive vendor like AviationManuals.

To learn more about how AviationManuals can help, contact us today.

Part-NCC is here – Are You Compliant?

The European Union’s Part-NCC (Non-Commercial Complex) is a regulation aimed at enhancing safety, training and record-keeping protocols within Europe for companies flying complex corporate aircraft privately. Yet, even though the regulation went into effect on August 25 2016, there remains considerable confusion within the industry.

Let’s try to shed some light on this complex issue.

First, let’s clarify who exactly is affected by Part-NCC. The answer to this comes down to who is the operator and where they are geographically located.

As to the first, although you would be forgiven for thinking that the operator is the owner, it’s not always that easy, since Part-NCC uses a much broader definition. According to the regulation, the operator is the person or entity that effectively manages and oversees the operation of the aircraft and who has the responsibility to commence, terminate or deviate the aircraft’s flight.

Once you determine who the operator is, the next step is to look at the geographic location of the operator. With Part-NCC, it’s not about where the aircraft is registered, but where the operator of the aircraft is established or, in the event of an individual owner, resides. So, if you are a UK-based operator with a Cayman Island registered aircraft, you should be Part-NCC compliant.

Isn’t IS-BAO Good Enough?

IS-BAO is a good starting point, but it only covers around 90% of what Part-NCC is looking for. So, while it’s certainly better than nothing, IS-BAO certification itself cannot be used to show full compliance with Part-NCC.

What About that Last 10%?

The challenge with becoming Part-NCC compliant is that it’s a complex regulation, and many small operators don’t know where to begin – let alone understand what’s required of them. This is a big reason why, nearly a year after coming into effect, compliance levels appear to remain low.

Though some aircraft management companies offer Part-NCC compliance plans, they aren’t usually the best fit for operators. Other solutions are simply software platforms that do not provide sufficient content, regulatory or editorial support. Most operators do not have the financial resources to afford the aircraft management company solutions or the personnel and editorial skills to simply subscribe to a software platform that does not provide any real guidance on regulatory content.

Many operators are thus seemingly taking a wait and see approach, potentially a risky bet.

A Part-NCC Service That Fits Your Operation

To help private aircraft operators comply with all new European regulations, including Part-NCC, AviationManuals has developed affordable, customized solutions. An operator needs to do little more than participate in online development sessions. We take care of providing, managing and editing all Part NCC requirements and more. Our packages include ICAO (International Civil Aviation Organization) Annex 6 Part II content, EASA Part NCC Compliance Content, IS-BAO Standards and Protocols, industry Best Practices, Policies and Procedures and input from literally hundreds of operators and auditors.  It is a simple and affordable process for all operators regardless of size and resources.

Learn more about our Part-NCC service.

You Don’t Need an LOA for RNAV… Unless You Do!

Part 91 operators aren’t required to obtain a Letter of Authorization (LOA) for RNAV or GPS-based ILS procedures (also called RNP APCH). So why does the FAA offer such an LOA – what’s the point? AviationManuals explains.

In the US, RNAV procedures are commonplace. That’s because the FAA’s Wide Area Augmentation System (WAAS) – a Satellite Based Augmentation System (SBAS) that augments GPS to improve its accuracy, integrity and availability – has been helping pilots land at small and regional airports around the country for years. Because of this history, Part 91 operators do not need a Letter of Authorization (LOA) to use RNP APCH procedures within the US.

Outside the US, however, it’s a different story.

As SBAS is so effective at opening up small and regional airports to general and business aviation traffic, many other regions are now building their own SBAS systems. For example, Europe’s EGNOS system is already fully operational and capable of augmenting both GPS and Galileo signals.

First the good news…

For international operators, the good news is your WAAS-capable avionics is most likely fully compatible with many of these other systems, so you can already take advantage of these new satellite-based procedures.

The not so good news, however, is that in order to do so, you first have to show that you are authorized to fly RNAV procedures.

This is because unlike in the US, in Europe, for example, these procedures are a relatively new concept that require not only that an aircraft have the corresponding airworthiness approval, but also that the pilots have the appropriate training, checking standards and operational procedures in place.

You can’t go wrong with an LOA

Although in Europe, EASA is working to amend some of these regulations, as a general rule, all operators are required to follow the necessary operational procedures. CAT operators must therefore amend their operational manual accordingly as part of their air operator approval. But don’t worry, there’s no additional training required. All you need to do is to get an LOA C052 from the FAA, which shows that your aircraft is capable of SBAS-augmented approaches.

If you frequently conduct international operations, it’s probably a good idea to add this authorization to your LOAs. On the one hand, this covers you in any country that does require specific authorization for RNAV procedures, such as Hong Kong. On the other hand, even where such authorization isn’t required, a country, such as the UK, may require you to have a valid state authorization in order to use MDA as a DA/DH with the approach. The MDA as DA/DH authorization is given under LOA C073, and a prerequisite for this is – you guessed it – the C052.

AviationManuals is able to assist you in obtaining both a C052 and C073 authorization. The overall process is simple and affordable and dovetails easily with your existing International Operations Manual. Contact us today for a quote.

5 things you should know about ADS-B authorization

One topic that causes constant confusion for international business jet operators is ADS-B Out: what it is, why you need it and when it’s required. To help clear the air, here are five things you need to know about ADS-B Out.

1.  ADS-B = Automatic Dependent Surveillance-Broadcast

Automatic Dependent Surveillance-Broadcast, or ADS-B, is a satellite-based aircraft monitoring system set to replace today’s radar-based system. The system uses the aircraft’s GPS to determine positioning information, and then sends this information to ATC. Whereas radar is only able to update an aircraft’s position once every 3 to 12 seconds, with ADS-B ATC this happens every second. This transmission of data from the avionics to ATC is called ADS-B Out.

2. Authorization is required in east Asia

Although not currently required for operations over the US, many other countries do require ADS-B approvals from an operators’ civil aviation authority. As this list regularly changes, it is highly recommended to always check with your safety management professional before leaving on any international trip

3. The US will require ADS-B starting in 2020

In 2010, the FAA published new rules that require operators to have ADS-B Out avionics by January 1st, 2020. This regulation applies to:

  • Class A, B and C airspace
  • All airspace at and above 10,000 feet MSL over the 48 contiguous United States and the District of Columbia
  • Within 30 nautical miles of airports listed in 14 CFR sec. 91.225, from the surface up to 10,000 feet MSL
  • Class E airspace over the Gulf of Mexico from the US coastline out to 12 nautical miles, at and above 3,000 feet MSL

4. The LOA – what it is and when you need it

As most new aircraft come ADS-B equipped, you only have to provide the destination country’s air navigation service provider (ANSP) with documentation that shows this. However, the type of documentation can vary from country to country. The most common format is the Letter of Authorization (LOA), which you get from your civil aviation authority. Currently, China, Hong Kong, India, Singapore and Vietnam require an LOA.

According to the FAA, an LOA is required whenever one uses ADS-B outside the US unless otherwise noted. Based on this rather ambiguous regulation, the default assumption is, when operating outside the US, an LOA is required. You can obtain an LOA from the FAA. These were originally issued as an A353 authorization. However, in an effort to streamline the process, the FAA has replaced the A353 with the OpSpec/MSpec/LOA A153.

5. I already have an A353, do i now need an A153?

Rest assured, your current A353 LOA is still valid. If aircraft are added or removed from your LOA, the FAA will reissue your existing authorization as an A153. You may also send the FAA a request to reissue your A353 as an A153. No additional documentation is required to do this.

We Can Help – Contact Us

You can develop ADS-B procedures either as a supplement to your RVSM/International Operations Manual or as a standalone ADS-B document. This, along with supporting documentation, is then simply submitted to your Flight Standards District Office (FSDO) or International Field Office (IFO).

AviationManuals makes applying for ADS-B approvals easy. Just complete a simple questionnaire and one of our experts will quickly assemble an appropriate and thorough application for you. Our support continues until the application package is approved, and our full-time staff are happy to help you gather any additional information that your FSDO or IFO may require.

Are You In Compliance with 2017 IS-BAO Standards?

The New Year has brought a new IS-BAO Standard revision! For operators who are IS-BAO registered, who wish to be IS-BAO compliant, or who just want to ensure they adhere to a widely accepted safety standard, this is a perfect time to review your operation to see if you are in compliance with the updated protocols.

Here are two of the biggest changes of 2017.

1. Annual Review Process

The greatest addition to the IS-BAO Standard this year is a new protocol specifically requiring operators to “establish and maintain a process to ensure that changes to IS-BAO are verified, analyzed and incorporated into the organization’s processes, as applicable.”

While this process was implied in previous years with the compliance monitoring requirements, those protocols did not specifically reference IS-BAO. This year’s new standard heavily implies that operators should be conducting annual reviews of their processes as the IS-BAO Standards are revised every year.

While addressing the new protocol, operators should take the opportunity to review all of their manuals. Manuals should be reassessed to ensure all protocols are addressed and that the procedures described are true to the procedures actually being practiced. Any deficiencies or differences should be resolved through their manual revision or reissue process.

2. Consecutive Audit Limits

In previous years, there was no set limit on the number of consecutive audits a single auditor could perform for an operator, although operators were encouraged to use different auditors.

This year, a new audit procedure standard states that individuals are discouraged from conducting consecutive audits as the lead auditor and prohibited from performing three audits in a row, in any capacity, for an operator. However, this requirement may be waived under certain circumstances if it is deemed in the best interests of the International Standards Programme and approved by the IS-BAO Audit Manager.

The purpose of this change is to help ensure the validity of the audit process and to provide operators with a broader perspective of industry trends and practices and to ensure the IS-BAO does not devolve into a simple box-checking effort.

Operators due for an audit this year may want to start the process a little earlier to leave time for finding and vetting a new auditor.

 

This year’s ISBAO Standards changes center around the periodic review of procedures and documentation and bringing diverse points of view into the auditing process. 2017 can be a great year for operators to establish a regular review process of their documentation and to grow their network of potential auditors.

3 Things to Consider When Flying to an EASA Member State

The August 14, 2016 Part-NCC adoption and the November 26, 2016 deadline for EASA Third Country Operators (TCO) Guidelines have come and gone. It’s been our experience that there is still much confusion or, at the very least some lack of clarity, as to which operators will be required to comply with Part-NCC and/or Part-TCO.

1. Part 135 operators
Get up to speed on InFO 16018, European Aviation Safety Agency (EASA) Third Country Operators (TCO) Authorization

If you’re a Part 135 or other non-EASA member commercial operator doing business in Europe, and landing at any EASA airport, then you definitely must fulfill the requirements found at https://www.easa.europa.eu/easa-and-you/air-operations/tco-third-country-operators. You can also get more information and apply online at the same web address. TCO requires that operators have a GOM, which must include SMS and dangerous goods procedures, among others. For commercial operators merely overflying the EU, compliance is not required.

2. Part 91 or other non-EASA member private operators
Read up on EASA NCC (Regulation (EU) No 965/2012, Annex VI)

For Part 91 or other non-EASA private operators, some of this summer’s Part-NCC requirements may apply if you are subject to the new EASA Part NCC guidelines. For instance, if you have a base in an EASA member country or operational control resides there in some form, you should take measures to comply with Part-NCC. It’s important to be aware that the EASA authorities are conducting ramp checks more frequently to make sure anyone who needs to follow these guidelines are doing so.

In principle, it may be a good idea to take this opportunity to formalize your operation by developing an FOM/GOM, IOM (International Procedures Manual), and an SMS program, and making sure you have an MEL specific to your aircraft rather than simply operating with an MMEL approved for MEL use. These are the fundamental elements that will be looked for and you should be able to demonstrate that you have them in place.

3. Managed aircraft – or private flights operated by commercial operators

Operational control is increasingly being scrutinized, particularly in cases where commercial operators are conducting private flights. The SAO authorizations that are carried on those flights may or may not satisfy the inspectors in EASA member countries. It may be a good idea to take this opportunity to formalize your documentation by developing an FOM/GOM, IOM, SMS program and MEL specific to your aircraft. Developing these does not preclude anyone from continuing to operate under a management company. Management companies continue to provide valuable services, but being able to provide such documentation to inspectors could avoid embarrassing delays.

The important thing to take away is to make sure you’re on top of whether or not you need to do anything additional to continue operating in compliance with these new EASA regulations to ensure your trips run smoothly.