Data Link and RNP-4 LOAs: What You Need to Know

Clear communication between aircraft and Air Traffic Control (ATC) is especially important when conducting operations over oceanic airspace. To ensure safe passage, the International Civil Aviation Organization (ICAO) released regulatory guidelines mandating that crews flying over much of the North Atlantic (NAT) must have Letters of Authorization for Data Link and RNP-4 by January 30, 2020. With these regulations already in effect, we want to make sure you have all the information you need to obtain your LOAs and keep your operations running smoothly.

What Are RNP-4 and Data Link and Why Do You Need Them?

The only way to permit more aircraft in a high-use airspace is to lower the separation standards between them. ICAO has mandated RNP-4 and Data Link to keep up with the growing air traffic in the NAT. This equipment helps to ensure efficient communication and minimum navigation performance allowing the distance between traffic to be reduced.

  • RNP-4: More accurate navigation equipment, which is certified in accordance with ICAO’s “Require Navigation Performance” specifications, ensures that aircraft can fly accurately to a centerline.  The lower the RNP value, the more accurate the equipment.  This is especially important in oceanic or remote airspace where control centers are not available. In a highly trafficked airspace such as the NAT, it is critical that as many aircraft be certified with the most precise navigation equipment possible.
  • Data Link: Navigation is only part of the equation; ATC still requires position reporting information from aircraft to properly track and control flights.  Relying on pure voice communications for those position reports would be impractical as traffic expands — enter Data Link.  By automating position reports with Automatic Dependent Surveillance — Contract (ADS-C) and Controller Pilot Data Link Communications (CPDLC) technology, ATC can ensure that critical position information is transmitted quickly and reliably.

What Should I Do Before Applying for These LOAs?

  1. Make sure you have completed any necessary upgrades to your aircraft. Check your Airplane Flight Manual and consult with your maintenance team to ensure the aircraft is actually capable of both RNP-4 and Data Link. This is typically outlined in the “limitations” section of the AFM.  If a Service Bulletin / Change or STC is required, schedule those installations as soon as you can.  It might be possible for the FAA to begin reviewing an LOA request while maintenance is still in progress, but it is definitely impossible to get an LOA for something your aircraft can’t currently do.
  2. Review your current RNP LOA, if any. Your flight department may or may not have an LOA for oceanic RNP operations already.  Check if the FAA has already issued you a paragraph B036 LOA, and if so, check whether it lists “RNP-4.”  Most non-NAT oceanic operations only require RNP-10, and for many years that was the only authorization given. It’s possible that you might only have RNP-10 even if your aircraft was capable of RNP-4 when you first applied for LOAs. 
  3. Make sure your pilots’ training is up to date. For Part 91 operators, training requirements are a bit more relaxed than for the rest of the aviation world. This means you can take some liberties with training schedules and deadlines. However, to ensure that pilots are familiar with current procedures in the NAT, the FAA will likely hold you to a 24-month currency for your international / RNP training, if not even less.  If your training is older than 24 months, it is recommended that you schedule a recurrent course ASAP.
  4. Contact a flight planning service to obtain a sample flight plan. For both the RNP-4 and Data Link LOAs, the FAA will require that you provide a complete sample flight plan.  Note that this sample should reflect both a full crew plan (i.e., the computer printout, including the fuel block, waypoints, ETPs, etc.) and the one-page ICAO flight plan.  The FAA may check your plan for any number of potential issues, including compliance with fuel requirements, the equipment codes used, or even just that you’ve selected an appropriate destination alternate.  So, it is important to choose a flight planning vendor that you trust to provide an accurate and suitable plan. Check out our top tips and tricks for ensuring your flight plan is ready in our Flight Planning Codes Demystified article.

LOA Applications Now Will Yield Cost Savings in the Long Run

While LOA applications may seem like a lot of work, shirking them can have real-world consequences. There are significant financial penalties for being caught flying without required LOAs and the alternative — flying around, above, or below the airspaces with these mandates — isn’t much better. You may be forced to fly hours out of the way, incurring unnecessary additional fuel costs and delays.

The applications can be a process, but the time and cost of applying for these LOA applications does not compare to the price of flying an additional four or five hours, or the fine for avoiding them altogether.

Once approved, your LOAs likely won’t need to be considered again until the FAA releases new regulations and guidelines. But if there ever is a reason to resubmit an LOA application, subscribing to our manual revision service can help you stay on top of such changes. When we hear about new regulations that could affect operators’ LOAs, we can push news out to our subscribers, detailing what those changes are and what actions departments will have to take. What LOAs look like now is not what they looked like five years ago, and most likely not what they will look like five years in the future, so it is best to have the tools to react quickly.

Contact us for any LOA support, and check out our free LOA Guide for more information.

5 Things You Should Do at the End of The Year

With the new year swiftly approaching, it’s time to review how up to date your department’s operations and safety management are. Here are 5 key items to consider when going through your end-of-year to-do list.

1. Take stock of what you have and how old it is

 

  •  Are your manuals up to date?

Aviation is a dynamic industry requiring continual improvement. This means regulators and organizations often need to change and update guidance every year. It’s a good time to check if your manuals are still up to date in the areas of regulation, accepted standards, and best practices. If you don’t have an automatic update subscription, you will want to make a list of all the year’s changes and incorporate the applicable items into each of your manuals. You will want to review revisions from the FAA, ICAO, industry best practices, and country-specific regulatory authorities.

  • Review your ERP

An outdated Emergency Response Plan (ERP) is of no help in an emergency. Track any personnel, facility, and operational changes that have occurred and make sure they’re reflected in your ERP. Role changes, additional personnel, updates and modifications to facilities, and changes or expansions in flight operations will all affect your ERP procedures. Your ERP should be reviewed at least on an annual basis – you can read more about keeping your ERP up to date here.

  • Get a customized MEL versus an MMEL

Although the U.S. allows Part 91 operators to use a Master Minimum Equipment List (MMEL) as an MEL, if you travel internationally, especially to areas of Europe, having a customized Minimum Equipment List (MEL) LOA for your aircraft will ensure that you don’t run into any issues with overseas authorities. In addition, an MEL is more concise and in general easier to use than an MMEL. If you haven’t made the transition yet, now is a great the time.

2. Check your LOAs

 

  • Are your LOAs current? Especially your Data Link A056 LOA.

LOAs don’t usually expire, but they do need to be updated from time to time. Take stock of your LOAs and check that they’re still valid for the coming year and whether you need any new ones for new aircraft, updated avionics installations, or new types of operations. Be sure to check your A056 LOA, as it’s been updated numerous times by the FAA in 2018, and your version might not be the most recent one. You can read about the most recent requirements here.

  • LOA and aircraft planning

If you’re planning on purchasing a new aircraft next year, keep track of the LOAs you might require – it could take anywhere between one to six months to get your LOA approved, so be sure to insert that timeline into your planning. Sometimes FSDOs will allow submissions of LOA applications prior to completion of the aircraft transition so that you can start to reduce the time that it takes to get the aircraft operational.

  • Review upcoming mandates

Although certain mandates are still a while away (like the ADS-B mandate set for January 1, 2020), don’t wait until the last minute to get your LOA. As the deadline approaches more and more operators will be applying for the authorization, which may cause the FAA’s approval timeline to increase. It’s best to beat the crowd and get approved now.

  • Don’t forget your procedures that support your LOA

Most operators keep their associated procedures in an RVSM Operations Manual or International Procedures Manual. When applying for a new LOA, the FAA may expect to see that this manual is up to date with the latest guidance, so keep that in mind when planning your to-do’s and timeline.

3. Conduct an internal audit

 

An audit can either be a fully detailed process of your entire organization and all manuals or a spot-check of your operation. You want to ensure that the procedures outlined in your manuals are actually being followed. If you find areas where this is not the case, you need to uncover the specific reasons why and implement corrective actions accordingly. Keep in mind that there may be times where procedures are not being followed as the result of changes to your operation that make the procedure redundant. In these cases, they should either be updated or removed from your manuals.

4. Review what your SMS is telling you

 

  • Are you getting the most out of your SMS?

Have you been using your Safety Management System (SMS)? Review the information that has been entered into your system including reports, risk assessments, and safety profiles. Ideally your entire organization should participate in safety, so check to see if your contributors represent all areas of your operation and not just pilots or top-level management.

  • Reviewing data and trends

With a year’s worth of data, now is a good time to analyze it. See if you recognize any trends, both negative and positive. If you’ve spotted anomalies, try to figure out how and why these happened. Once you have determined root causes you can implement corrective actions for things trending in the wrong direction and keep doing what you’re doing for those headed in the right direction.

  • Check your safety goals

Now’s a good time to check how far along you are in your safety goals and to review goal setting for next year. Have you achieved what you planned? Are there certain things you want to focus on in the new year? Consider what roadblocks you ran into this year or what elements helped you along so you can work these into your plan for next year. If you want to know more about setting safety goals, we’ve got you covered.

  • Conduct a safety culture survey?

In order to keep a pulse on the organization, you should consider conducting an anonymous safety culture survey for your department every year. This way, you can get an honest opinion from everyone about their feelings toward the state of your safety program. You can then plan training and meetings for the next year to tweak the current procedures or communications regarding your SMS.

5. Think about going digital

 

Now might be the right time to think about putting a digital system in place to help streamline your entire SMS process. Consider the effort involved in reviewing paper based SMS data, conducting internal audits, and administering surveys. A digital system can allow you to do all of these with the simple click of a button. Additionally, an SMS app can boost engagement as users can simply fill in their reports through the app when on duty or right when the event occurs rather than hours later.

By considering the above list, you can ensure you’ve thoroughly reviewed all the hard work you did this year as well as actually utilized the data you took the time to collect. You will be prepared for the new year and may find you already have a head start on a number of new year’s resolutions.

The team at AviationManuals wishes you a happy holiday season – please be sure to contact us if you have any questions. We’re always happy to help review your manuals or provide you with more information on ARC, our digital SMS platform and app.