It was great getting to see everyone in person again at BACE 2021 for the first time since 2019. It’s been a long road, but it was a great show with lots of useful information. Here are a few topics that came up during the week that we think you will find uniquely interesting.
International and Regulatory Updates
LOA Streamline Process
The FAA, OEMs, and industry stakeholders have been working together over the past year to simplify the LOA application process. Through this process an operator would receive three statements of compliance (SOCs): ASOC from the aircraft manufacturer, TSOC from their training provider, and PSOC from their procedures provider. The three statements of compliance along with a simple form constitute the application and could be used to apply for 10 different LOAs. Once submitted to the FSDO the inspector would not need to review any further documentation which should bring approval times down from months to days.
The program is expected to incorporate the following LOAs:
The FAA is currently working on draft guidance and is hoping to have something official in the first half of next year. They plan on initially rolling out the program to Part 91 operators who are applying for LOAs for brand new aircraft with approved ASOCs.
North Atlantic Errors
Errors related to large height deviations, lateral deviations, and coordination events were specifically mentioned during one of the sessions. As operators start making NAT crossings after such a long hiatus, it’s important to review your procedures again and familiarize yourself with requirements and best practices. This self-study should include your operations procedures manual and ICAO’s Oceanic Errors Safety Bulletin. Crews may want to also consider recurrent international procedures training prior their next oceanic crossing.
Also, remember that best practices are often just as important as the required procedures. Though things like recording navigation readings or doing navigation sensor checks may not always be strictly required, they are still a good practice that can help prevent deviations.
If you run into an issue that would be classified as an oceanic error, then be sure to consult your operations manual for error reporting procedures and, if necessary, incident reporting procedures. Additionally, you will want to submit a report to your SMS to record the issue and allow for appropriate mitigations to be put into place.
Discontinuance of Oceanic Clearances
In 2019 ICAO held a workshop with their NAT planning group to discuss priorities for upcoming mandates and airspace redesign. They set a 2030 Vision “To achieve an interoperable global air traffic management system, for all users during all phases of flight, that meets agreed levels of safety, provides for optimum economic operations, is environmentally sustainable and meets national security requirements.”
Additionally, they set 2030 Vision Principles, seven sets of goals and objectives, and listed numerous potential improvement considerations. One of the items for improvement considerations was the discontinuance of oceanic clearances. ICAO is just starting work on this initiative and is expected to continue development through 2023.
Although not specifically mentioned at BACE, additional improvement considerations of interest include:
- SATVOICE permissibility and requirements for migration from HF to SATVOICE as a backup to FANS communication.
- RVSM expansion to include airspace above FL410.
- ADS-B ITP expansion.
- Expanding PBCS / PBN requirements.
As far as we know, specifics on these topics are not yet available, but we are keeping an eye out for updates.
Current Approval Process
If you are currently waiting for approval of an MEL you are not alone. With the increase in operators requesting MELs and the complex nature of the manuals, reports at BACE were that on average D195 LOA approvals were between 4 days to 16 months. From our own experience we have seen most falling between 2-3 months, but with a notable amount in excess of 4 months. With increasing international pressure to operate with a customized MEL, it’s advised that operators submit for their MELs well in advance of any upcoming trips.
Guidance Change Reminders
The MEL guidance session picked out a few key regulatory reminders, including:
- AC 91-67
This AC originally provided guidance on acceptable methods of operation with inoperative equipment. This was canceled on November 3, 2017 as the AC was no longer in compliance with ICAO standards. An updated version of this has been drafted and is pending final release.
- Policy Letter PL-25
This PL was recently revised to Revision 22 and includes significant changes that clarify definitions and remove information about usage in an MEL from the definition itself. Operators using the MMEL as an MEL should download the most recent version and keep it onboard with their other required MMEL documents. Those with approved MELs can update the Policy Letter during their next MEL update.
Upcoming Guidance Changes
- AC 91-67A. After the original version of this AC was canceled, AC 91-67A was drafted to bring the guidance in line with current ICAO standards. Although the final version of this AC has not been released yet, the most notable item in the AC is the discontinuance of LOA D095, use of an MMEL as an MEL, for Part 91 operators. It’s estimated that there are around 11,000 of these LOAs currently in use that would need to be migrated to a customized D195 MEL. Operators currently using the MMEL as an MEL are strongly encouraged to begin the development and submission process of a customized MEL as soon as possible.
As expected, SMS continued to be a hot topic at BACE. As many departments are recognizing the importance of SMS and starting to incorporate programs, there is much to write about. Here we will just mention some of the key questions that came up during the event but stay tuned for future posts with in-depth discussions about the issues and how to solve them.
- How to get everyone involved.
SMS is most effective and easiest to execute when the entire organization is participating in the process. Getting everyone involved including pilots, HR, admin, maintenance, schedulers/dispatchers, accountants, etc. is challenging. Including all departments during the development and implementation of your SMS will help ease buy-in.
- How to maintain your SMS as personnel and roles change.
Two major challenges operators are facing right now are turnover and shifting of roles within their organization. Ensuring the responsibility for your SMS is appropriately handed off to the next person while still continuing to participate in the program is difficult if succession and depth planning have not been established. Documenting your SMS procedures is a first step to making it easier for someone new to pick up and continue the program management.
- How change impacts your operation.
The steps you need to take to manage change and the impact it can have on safety is a topic not discussed enough. Operators need a set process in place to identify the risks a change may have and determine ways to mitigate those risks so they have a clear path for managing and evaluating changes small and large.
- What does SMS look like for the single pilot, single aircraft operator?
From small to large, SMS is necessary for every operator; however, the program should be tailored to fit the characteristics of a particular operator. While a single pilot, single aircraft operation doesn’t need complex approval flows, they will still need a process for recording safety and risk data, implementing mitigations, and analyzing effectiveness of mitigations.
We hope that those who were able to attend BACE had a great time and that those who were not able to be there in person find our recap helpful in getting a taste of what was discussed. Of course, if you have any questions on these topics or other items you heard at BACE, feel free to reach out.