August 15, 2013
A notice of proposed rulemaking (NPRM) published by the Federal Aviation Administration (FAA) in June would dramatically expand operational flexibility for operators of aircraft equipped with enhanced flight vision systems (EFVS), while simultaneously imposing new training and currency requirements for pilots of those aircraft.
Currently, under Part 91 of the FARs, an EFVS can be used in lieu of natural vision to descend below minimum descent altitude or decision height to 100 feet above the touchdown zone elevation without specific FAA authorization.
Under the proposal, all operations will require FAA authorization to ensure the airworthiness of vision systems, as well as pilot training and currency, with one exception for Part 91 (other than subpart K). The authorization will allow for operations to 100 feet above touchdown zone elevation or, if additional requirements are met, to touch down and roll out in visibilities no lower than 1,000 feet runway visual range.
NBAA will be commenting to the NPRM regarding the one exception for Part 91 (other than subpart K) operations to 100 feet, as a letter of authorization is required for foreign authorizations.
The NPRM also would permit certain operators to dispatch aircraft under IFR and to initiate and continue an approach when the destination airport weather is below authorized visibility minimums for the runway of intended landing.
Comments are due by Sept. 9, 2013.
Need for Standards and Training
John Kernaghan, a Gulfstream 450/550 pilot and member of NBAA’s Airspace, ATC and Flight Technologies Subcommittee of the Access Committee, said the FAA is “trying to bring the current equipment that’s out there, along with future equipment, into a more standardized setting.”
The new rule will be particularly important for operators who fly to international destinations, as FAA authorization is required to obtain approval from foreign regulatory authorities.
Kernaghan, who along with fellow subcommittee members and other NBAA Members spent considerable time reviewing, analyzing and discussing the details of the NPRM after it was published in June, said it is important to introduce any operational changes in a standardized manner.
“You don’t want to see Part 91 operators that have the equipment just go using it without proper training… it needs to be thoughtfully taught and regulated as far as its use,” he said.
Currently, Part 61 does not mandate any training or recent flight experience requirements to conduct EFVS operations. But “to ensure that an appropriate level of safety is maintained for all EFVS operations,” the FAA said it is proposing amendments to Part 61 “to require initial training as well as new recent flight experience and proficiency requirements for persons conducting EFVS operations.”
The NPRM says pilots could use EFVS “only if, within six calendar months proceeding the month of the flight, that person performs and logs six instrument approaches under any weather conditions as the sole manipulator of the controls using an EFVS.” Those six approaches could be conducted in an aircraft or an approved simulator.
Kernaghan said the Flight Deck Subcommittee feels that since those six approaches don’t need to be conducted in actual IFR conditions, “there should be [a requirement for] at least one approach within the last calendar month using the EFVS.” This would assure the EFVS is being used in the aircraft, and not just the simulator, prior to an actual minimums EFVS approach, he said. “It ensures the EFVS and associated SOPs have been used more recently than almost seven months prior to a minimums operation. And this would work across all applicable operators – 91, 135, 121. It would almost require pilots to use them [the EFVS units] religiously instead of just when they are ultimately needed.”
Since it last addressed the issue of EFVS in rulemaking in 2004, the FAA said the number of persons conducting EFVS operations “has significantly expanded. The FAA believes the [new] proposal would further increase the number of operators conducting EFVS operations,” particularly since it would permit EFVS use in low visibility conditions to touchdown and rollout. Therefore FAA said the proposed training, recent flight experience and proficiency requirements for EFVS operation are necessary “to provide an appropriate level of safety for the conduct of these operations.”
Kernaghan observed that the NPRM “would definitely improve an operator’s ability to dispatch, particularly if your alternate airports were far away. This would definitely improve the ability of Part 135 operators to be able to use it for dispatch, provided the pilots are comfortable with it. Just because the tool is there doesn’t mean everybody’s going to do it.”
More Streamlined Certification Process
In addition to the new training requirements for operators, the NPRM proposes to change the way it certificates EFVS systems. Up until now, that has been accomplished by establishing “special conditions,” a process that the agency noted “can impose significant delays on the certification process.” The NPRM therefore would amend Parts 23, 25, 27 and 29 of the FARs “to establish certification requirements for vision systems with a transparent display surface located in the pilot’s outside view thereby eliminating the need for issuance of special conditions.”
In developing the NPRM, the FAA said it “attempted to use regulatory language that is performance-based and not limited to a specific sensor technology. The FAA believes this action would accommodate future growth in real-time sensor technologies used in most enhanced vision systems” and would “maximize the benefits of rapidly evolving instrument approach procedures and advanced flight deck technology to increase access and capacity during low visibility operations.”
The rule “is not just limited to forward-looking infrared, which is the predominant technology that’s out there right now,” Kernaghan said, “but is also written for millimeter-wave technology, which is up and coming, as well as synthetic vision technology.” Eventually, “I think what you’re going to have…is aircraft flying around using head-down synthetic vision technology,” which will transition to an EFVS image as the aircraft approaches minimums.”
International Business Aviation Council Ltd.