Post-Pandemic Planning Part 2: The Most Important Things You Should Be Doing with Your Manuals

An increasing number of countries are beginning to ease COVID-19 restrictions. While we will be feeling the aftermath of this global health crisis for quite some time, all industries, including aviation, should prepare for when lockdowns lift. Make the most of this time to prepare your operation for the bounce-back.

In the first part of this series, we encouraged you to use this time to close the gaps in your emergency response plan. It’s important to have the necessary tools in place to handle future emergencies, but without updated manuals, your whole enterprise may be at a disadvantage. The second part of this post-pandemic series is centered on updating your operations manuals. In-house reviews, such as updating your manuals, conducting internal audits, and checking your LOAs should be on your annual to do list anyway, so why not take the opportunity during this down time and get a head start?

Catch Up on Paperwork

If you are operating without a digital toolkit, it can be a headache to manage required paperwork. So now is a great time to catch up on all those documents you were previously too busy to complete, finish the manuals you were already working on, and get started on some new ones that have been on your to do list for far too long.

  • If you don’t have an Operations Manual yet, it’s time to get one. Whether you’re an FBO, drone operator, or flight department, an Operations Manual supports your organization by standardizing your guidelines, making it that much easier for new and existing employees to perform their duties in line with the way you do  things. Without this internal guide, you may be vulnerable to safety or efficiency issues. Keep in mind that an Operations Manual is a lot less daunting than most people realize – it should simply reflect the complexity of your organization.
  • Ensure you have the right documents in place to make it easier to stay in compliance with your LOAs.  For most LOAs, operators are required to continually ensure their crews have been trained on, have knowledge of, and/or have access to applicable procedures. Having a manual that contains the relevant procedures and is continually kept up to date is the easiest way to demonstrate compliance and avoid findings or even potential fines.

For global operations, this means getting an International Operations and Procedures Manual .

You may also need to consider an Enhanced Flight Vision Systems manual, Part NCC Compliance solutions, or an MEL.

Check When Your Manuals Were Last Issued

When was the last time your manuals were reissued? Since regulations, procedures, and best practices are constantly changing and being revised, it’s essential to make sure your manuals are up to date and you are being notified of important changes. Documentation should be updated on an ongoing constant basis, but certainly at the very least annually.

For example, new regulations became effective just earlier this year requiring RNP-4 and Data Link Letters of Authorization to fly in certain transoceanic airspaces. Have your manuals been updated with this newest guidance?

What about the latest expansions to National Security Sensitive Locations and LAANC for Drones? Both of these were updated with new locations in late 2019.

Audit Your Flight Plans

Flight plans are an essential part of your operation, but the FAA is increasingly finding flight plans have not been filled out correctly. On top of needing them for every flight, your organization must also provide a sample flight plan to obtain certain LOAs. When submitting an LOA application, the FAA will review flight plan codes, specifically in items 10 and 18. Having correct flight plans is critical to ensure uninterrupted flights and smooth LOA applications.

Find out more on how to evaluate your operation with an Internal Audit Program to ensure a culture of continual improvement. For organizations looking to audit their current flight plans, the International Operations and Procedures Manual is a great place to start to review applicable codes and requirements.

Work on Your Letters of Authorization

Applying for LOAs can be a lengthy process – don’t wait until you need one to apply for it. During COVID-19 the FAA and inspectors are still reviewing applications and issuing authorizations. Since it can take several weeks, or even months, to be granted an LOA, start your application before operations are back to full speed.

When applying for an LOA, you’ll need paperwork such as a cover letter, documentation of proper operations procedures, and copies of AFM pages and training certificates, to name a few. Luckily, after these applications are approved, LOAs do not usually expire. This means that unless there are significant operational changes, you will not have to go through this application process for the aircraft again.

The first step is to understand what your organization needs: not every flight department needs every LOA. If you are unsure what to apply for and how, download our free LOA Guide for clear guidance.

Feel free to contact us with any questions –we’re always ready to help.

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.

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.