David Mumford

Author: David Mumford (page 1 of 8)

Your top three PBCS questions answered

PBCS has been an ongoing PITA for some time now. We wrote about it back in March. Here are the top three questions we’ve had on it since then – and now we finally have some answers!

Question 1: What happens if I still haven’t received my updated A056 LOA?

After the PBCS tracks were introduced in March 2018, the FAA published a Notice requiring all N-reg operators to update their A056 LOA authorization – regardless of whether or not they intended to fly these PBCS tracks. For private (Part 91) operators, the deadline to submit the application was 30th September 2018.

There was a barrage of applications, and the FAA still seem to have a bit of a backlog, as even now some operators have still not received their updated approvals.

The FAA’s unofficial policy is that as long as you have applied for a revised LOA, you can continue to use your old authorization after September 30th, while you wait for the new one to be issued.

Bottom line: This means you are allowed to keep flying in the North Atlantic, just not on the PBCS tracks.

Question 2: What about that problem with aircraft with Honeywell systems installed?

Back in March, a latency timer issue with certain Honeywell FMS systems meant that there were bunch of aircraft which weren’t able to get the PBCS approval.

In June, Honeywell issued a service bulletin fix for the issue, available at varying times for different aircraft. Since then, the FAA has been issuing the updated A056 LOA approvals to those aircraft with the Honeywell systems that reflect the new capabilities but the still don’t meet the PBCS requirement of RCP240 due to the latency timer issue.

Bottom line: Now those affected aircraft are able to receive the updated A056 LOA approvals, just with a PBCS restriction – meaning they can continue to operate in the North Atlantic, just not on the PBCS tracks.

Question 3: What the heck is PBCS anyway?

PBCS stands for ‘performance-based communication and surveillance’.

PBCS involves globally coordinated and accepted standards for Required Communication Performance (RCP) and Required Surveillance Performance (RSP), with the goal being to allow the application of reduced lateral and longitudinal separation to aircraft which meet the criteria.

To be PBCS compliant, you basically need CPDLC capable of RCP240 and ADS-C capable of RSP180; this effectively means having a 4 minute comms loop, and 3 minute position reporting.

PBCS has been implemented in various different chunks of airspace around the world, but most notably in the North Atlantic, where the three core daily NAT Tracks are assigned as PBCS tracks between FL350-390. To fly those, you will need to be PBCS compliant (read above) but also have RNP4 (the rest of the NAT only requires RNP10).

Feeling queasy? That’s okay, reading about PBCS makes us feel that way too. If you’re still hungry for more though, check out our recent article on all things PBCS!

New rules at Russian airports to combat cabotage abuse

20 September, 2018 / David Mumford / 0 Comments

There’s a new Customs restriction in place, reported at bothULLI/St Petersburg and UUWW/Moscow Vnukovo airports. The standard block of text doing the rounds is as follows:

STARTING FROM 19/09/2018, IT WILL NOT BE POSSIBLE TO CHANGE THE ROUTE IN CUSTOMS DECLARATION FOR THE DOMESTIC LEG (E.G. IF THE NEXT POINT AFTER ULLI IS LOWW, IT WILL NOT BE POSSIBLE TO CHANGE IT FOR UUWW; IF THE NEXT POINT AFTER ULLI IS UUWW, IT WILL NOT BE POSSIBLE TO CHANGE IT TO URSS). DUE TO CUSTOMS CONTROL RESTRICTIONS WE REMIND YOU REGARDING PASSENGER AVIATION CABOTAGE ON THE EACU TERRITORY.

There are two important points here:

Once you have completed the customs declaration and it was for an international destination from ULLI/UUWW, you can’t change it to a domestic one; also if there was domestic destination after ULLI/UUWW you can’t change it to a different domestic airport; but changing the destination to a non-Russian airport is still allowed (i.e. LSZH instead of URSS).
‘EACU Territory’ means the Euroasian Customs Union countries – that’s Russia, Belarus, Kazakhstan, Armenia, Kyrgyzstan. Watch out if you’re planning on flying between ULLI and any these other countries, as Customs may now consider it to be a domestic flight!

Local handlers have confirmed these new restrictions have been brought in to try to combat abuse of cabotage rules by some operators.

Russian cabotage rules are complicated. Their AIP GEN 1.6.2.4 attempts to define it, in language typical of AIPs the world over, as follows:

Foreign air transport enterprises, international operating agencies and foreign individual enterprises have no right to take passengers, baggage, cargo and mail aboard on the territory of the Russian Federation for air transportation within the territory of the Russian Federation without permit from the Federal Air Transport Agency issued in accordance with procedure established by the Government of the Russian Federation.

THE BASIC RULE

So the wording above basically translates to a fairly standard definition of cabotage which we’re probably all familiar with: foreign aircraft are not allowed to carry passengers domestically inside our country. Fair enough.

RULE BEND #1

In reality, the basic rule is not strictly enforced. The unofficial position of the Russian Customs Service is that a single domestic flight will be permitted as long as it’s part of an international roundtrip of the same passengers.

RULE BEND #2

We checked with the authorities, and in practice, the whole “as long as it’s part of an international trip” thing doesn’t actually have to be strictly followed either. Domestic flights with passengers onboard are permitted as long as those passengers either fly in to Russia on that aircraft, or fly out of Russia on that aircraft.

For example, both of the following trips would be allowed (as long as the passengers onboard are the same actual people):

LSZH-UUWW (0 pax)
UUWW-URSS (2 pax)
URSS-LSZH (2 pax)

LSZH-UUWW (2 pax)
UUWW-URSS (2 pax)
URSS-LSZH (0 pax)

RULE BEND #3

Not content with the significant amount of rule-bendery already available, there are plenty of reports out there where none of the above is adhered to whatsoever – where operators do multiple domestic legs, or change the passengers onboard on different legs, or declare charter flights as private to avoid the cabotage rules altogether. Much seems to depend on which particular airports you’re flying to/from, who your handler is, who your VIP on board is, and who makes the phone calls behind the scenes!

As Derek A. Bloom says in his article on ‘Avoiding the Substantial Legal Risks Involved in Grey Cabotage Flights in Russia’ – “For the last several years, it is an open secret that there are a very substantial number of illegal cabotage flights in Russia of chartered corporate aircraft. False customs filings are regularly made indicating that foreign-registered aircraft are being flown in Russia for private, and not for commercial purposes, and even that the owner of the aircraft is actually on board the aircraft when he is not.”

But with the new rules imposed this week, the authorities seem to be fighting back. Currently, we only have information that this is being applied at ULLI and UUWW, but if you know of any other locations, or have any other information, please let us know!

Further reading

That MMEL thing: here’s an update

8 August, 2018 / David Mumford / 0 Comments

The FAA is set to issue new guidance to provide a resolution to the long-running MMEL vs MEL debacle. However, it may not be the one we were expecting!

Last year, ramp checks on some US aircraft in France highlighted an important issue – EASA and the FAA have different interpretations of the ICAO standards regarding deferring aircraft discrepancies.

In the US, with FAA authorization operators can use a master minimum equipment list (MMEL) to defer repairing certain equipment. But in Europe, MMEL cannot be used in lieu of an MEL specific to each aircraft or fleet.

The European Aviation Safety Agency (EASA) began requiring all aircraft transiting European airspace to have an approved Minimum Equipment List (MEL) for each, individual aircraft. An MEL that references the MMEL was not acceptable.

This was a pain for US operators, as to get an individual MEL approved under the Letter of Authorisation (LOA) from the FAA takes time – but by not doing so, they ran the risk of failing a ramp check in a European country.

At the start of 2018, we understood that the FAA had reached an agreement with EASA: the FAA would start requiring international operators to obtain new D195 LOA’s, and in return EASA would halt any findings for a period of 12 months to allow for these new LOA’s to be issued.

But now we understand the FAA have decided that making operators get new D195 LOA’s will be far too much work for everyone involved!

Instead, they intend to just continue to issue the D095 approvals – but they will more vigorously validate the required components (such as the Preamble and M&O procedures).

This certainly appears to present a reversal of the previous commitment to EASA, who may very well not accept these LOA’s. If that happens, then the approval won’t be valid over in Europe – meaning ramp checks of N-reg aircraft in European countries will once again throw up the old MMEL finding, just like before.

We expect the FAA to officially issue this updated guidance to inspectors in the very near future, to be followed by a FAA InFo Letter to Part 91 Operators. The NBAA have said they will issue a bulletin to share the guidance as soon as it is released.

How to prepare for a ramp check in Europe?

We wrote a 2017 article all about how to make a ramp check painless.

We have also updated the FSB SAFA Ramp Checklist. Download it here.

Keep a copy with you and run through it before you head towards the EU.

Further reading

EU SAFA ramp checks NOT on the rise – but are you ready for one?
SAFA Ramp Checks – Guidance Material
How are ramp checks performed?
Special thanks go to Mitch Launius at 30westip.com for help with this post.

Process simplified for Border Overflight Exemptions

1 August, 2018 / David Mumford / 0 Comments

Recent changes mean that Border Overflight Exemptions are now more straight-forward in two key ways:

Everything has been centralized! Before, operators had to apply for their BOE’s from CBP offices at individual airports – some would approve requests, and others wouldn’t, and there seemed to be a bit of a lack of consistency in some cases. CBP has now streamlined the process, and will be issuing all new BOE authorizations from their headquarters instead.
Authorizations have been simplified! Before, some BOE authorizations contained the aircraft operator, approved aircraft, and approved crew; and some others contained only the aircraft operator and approved crew. Now, all new authorizations will only contain the aircraft operator. What this means is that for operators who get this new approval, they will now be able to fly any of their authorized aircraft with any authorized crew when conducting an Overflight arrival.

Important to note: CBP will issue new BOE’s to operators as requested, but until that happens, operators must comply with the terms and conditions of the authorizations they already hold.

CBP have told AOPA the following – “Because this change in procedure is occurring on a case-by-case, operator-by-operator basis, CBP officers are having to process operators who have been authorized under three sets of terms and conditions. Until the transition is complete, please be patient with our officers.”

So, bottom line – if you’ve got any BOE required flights coming up soon and you want to benefit from the new format, better submit a request for an updated BOE authorization as soon as possible! Send CBP an email at GAsupport@cbp.dhs.gov

What is a Border Overflight Exemption, and when do I need one?

When flying to the US from the south, you need to land at the first designated airport of entry that is nearest to the point of crossing the U.S. border or coastline (see the chart below for the list of these airports). If you want to land elsewhere, you need to get a Border Overflight Exemption.

In this case, ‘the south’ means everywhere from south of 30 degrees in the eastern U.S. and south of 33 degrees in the western U.S. This covers all flights from the Caribbean, Mexico, Central and South America, and some parts of French Polynesia.

Here is the list of designated southern airports of entry:

Further reading:

Africa: Hajj 2018 routes in operation

23 July, 2018 / David Mumford / 0 Comments

From 19JUL, the Hajj routes for 2018 will take effect.

What are Hajj routes?
Every year, millions of pilgrims travel to Mecca and other sites in Saudi Arabia – and this changes the predominant traffic flow over the African continent. ATC in the FIR’s most affected put in place standard routings to help flow that traffic.

Normally, traffic is very much north-south predominant, with Europe-Africa flights being the main flow. When Hajj operations start up, a good amount of traffic starts operating east-west (ie. Africa-Saudi Arabia and vice versa), and this is something to be aware of when cruising along at FL330 with spotty HF comms.

So, in addition to the normal IFBP belt and braces on 126.9, keep an eye out for a much higher amount of crossing traffic during the coming months.

The FIR’s affected are: Algiers, Accra, Brazzaville, Dakar, Jeddah, Kano, Khartoum, N’Djamena, Niamey, Roberts, and Tripoli.

The Hajj routings are contained in this ASECNA AIP Supplement.

Further reading:

Read IFALPA’s updated information on safety of operations within the Mogadishu FIR (HCSM) here.
New 19-state Upper FIR planned for Africa.

Aircraft security search now a requirement departing France

20 July, 2018 / David Mumford / 1 Comment

Update July 20th: Looks like this is not only happening in France, but some other EU countries too: we’ve had reports of the same procedure being required at some airports in Italy, Greece, and the Netherlands. If you have any further knowledge or recent experience to share, please let us know!

According to various reports we’ve had from Business Aviation aircrew and handlers, as of July 16, all aircraft departing specific French airports are now required to have completed a security search before departure, and to complete a form to be left with the handler. This applies to all aircraft unless the previous departure point was one of the following:

28 countries of the European Union + Norway / Iceland / Switzerland / Lichtenstein
USA
Canada
Isle of Man
Montenegro
Faeroe Islands
Guernsey and Jersey

This new rule applies to all aircraft, no matter the country of registration or status (private, commercial or charter).

The security search is basically to check that no “prohibited articles” are on board (the usual things – guns, explosives, etc.). It’s common practice amongst airlines, but seems until now not to have been enforced as a rule for business aviation or private operations.

Once completed, this form must then be given to the ground handler, who will store it, in case the French authorities want to see it at some point.

It seems this new procedure is governed by an EU directive that was published in 2015, namely: the European decision (UE) C (2015) 8005 (Appendix 3-A) and the regulation (UE n°2015/1998 (Appendix 3-B32). Who would have thought that a new rule with such a tantalising name as this could go unnoticed until now ?

So it seems that all EU countries should be implementing this new procedure, but so far only certain French airports have done so – the ones we know about so far are:

LFMN/Nice
LFMD/Cannes
LFPB/Paris-le-Bourget

(Quite possibly the reason that it’s only French airports which have implemented the new procedure is that it was something that was cited in a French national audit conducted in Nov 2017!)

Can the handler provide the crew with a “security search” form?
Answer – Probably not. As the security search is done by the crew, it’s down to the operator to provide the form – the only responsibility of the handler is to receive it signed from the Captain and store it, that’s it.

What about flights that have arrived from the United Kingdom ?
Answer – You won’t need to do the search, as the UK is still part of the EU… for now! We will wait and see what their status will be once the “Brexit” happens, but until then, no worries 🙂

If a flight is operating PART 135 Air Ambulance, would they be subject to this search as well ?
Answer – Yes, if they arrived in from somewhere other than those countries mentioned above. The procedure is linked to where the aircraft came from, not to the aircraft reg or its status (be it commercial, private, charter, cargo, air ambulance, quick-turn, night-stop, fuel stop, transit flight, etc).

What kind of info should be in the form?
Answer – This kind of info:
Flight Information: Flight number / Date / Aircraft Number / Airport of Origin / Airport of Destination
Aircraft Interior: Flight Deck / Storage Area in the Galleys / Lavatories / Catering Trolley and Containers / Seat Pockets / Area Under the Seats / Area Between Seats / Area Between Seats and Bulkheads/ Jump Seats / Trash Bins / Overhead compartments / Pax and Crew Storage Compartment.
Between 5 and 10% of the life vest bags are to be checked as well.
Aircraft Exterior: Aircraft Holds / Service Panels / Bays / Wheel Wells / Fuselage / Engines / AOG Spare in Hold
Search Information : The search must be performed by a member of the cockpit crew. The name of the Captain must appear on the form as well as the date and a place for him/her to sign the document.

You probably have a standard form in your OEM for something like this. But if not, then fear not! The good folks at Signature have provided us with a standard template. Click the image below to download!

If you have any further knowledge or recent experience to share, please let us know!

Further reading:

EU SAFA ramp checks not on the rise – but are you ready for one?

Italy ATC strike CANCELLED

17 July, 2018 / David Mumford / 0 Comments

Update 17 July: The 24hr ATC strike planned for July 21 has now been CANCELLED.

Controllers at all the ACC sectors were planning to take part, and additional strikes were planned at the local level at at the following airports: LIRA/Rome Ciampino, LIRF/Rome Fiumicino, LIEE/Cagliari, LICC/Catania, LICA/Lamezia, LICJ/Palermo, LIBP/Pescara, LIPZ/Venice

But now the strike has been cancelled. Normal ops now expected at all ACC’s and airports across the country.

Further reading:

All the latest official information about Italy ATC strikes can be found here. Just make sure you have your Google Translate tool enabled on your browser!

No fuel at LFMN/Nice

9 July, 2018 / David Mumford / 0 Comments

Update July 9th: Following last week’s issues with a break in the fuel pipeline coming into the airport, local handlers are now saying there are no more issues with fuel supply and availability. However, some third-party fuel providers are warning they still cannot arrange fuel for BA/GA operators, and are advising them to tanker inbound. Do you know different? Let us know!

July 5th: Due a break in the pipeline into the airport, for most operators there is no fuel available at LFMN/Nice.

Check with your handler before operating if your uplift at Nice is essential, as many are now advising all ad-hoc operators to tanker-in.

Information is still coming in, but it appears this may affect operations for a few days. No word of other airports affected, and nothing has been published in the Notams yet.

Customs now closed overnight at KBGR/Bangor

5 July, 2018 / David Mumford / 0 Comments

Bad news for trans-Atlantic operators! The Customs office at KBGR/Bangor Airport will now be closing each night from 22-06 local time (02-10z).

They used to be open H24, which made Bangor a great option for trans-Atlantic operators wanting to clear U.S. Customs somewhere nice and straightforward overnight. Now with the new changes, you can still request overtime, but Customs needs 24hrs notice to arrange and will only assess on a case-by-case basis.

Now it seems that the nearest airport in the region still with Customs available H24 is KBOS/Boston International Airport, and given it’s size, it’s not the most BA/GA friendly at the best of times.

Where else to go? Here are some options:

KALB/Albany
Open 08-22 local time, 7 days a week
Available out-of-hours but minimum 2hrs notice required.

KPSM/Portsmouth
Open 08-17 weekdays only
Available out-of-hours but minimum 24hrs notice required.

KPWM/Portland
Open 07-21 local time, 7 days a week
Available out-of-hours but minimum 24hrs notice required.

Know of anywhere else in the region which provides Customs H24? If we missed somewhere obvious, let us know!

HLLL Tripoli FIR 2018 Operational Changes – Libya

3 July, 2018 / David Mumford / 1 Comment

UPDATE Friday 7 Sep 2018: HLLM/Mitiga Airport reopened on Sep 7, following a UN-mediated ceasefire between local militia. It had been closed since Aug 31 – the latest in a long string of closures due to heavy fighting in the area. We continue to advise against all ops to Libya, including overflights.

A number of countries already have blanket warnings in place against operating to Libya, and they all say pretty much the same thing: avoid the entire country – don’t overfly the Tripoli FIR, and don’t land at any Libyan airports.

Even the Libyan authorities have issued some guidance of their own, showing those areas that they believe to be active Conflict Zones – this type of notification from a ‘Conflict Zone state’ is rare.

HLLL/LIBYA A0067/18 
THE FOLLOWING AREAS ARE CONSIDERED TO BE CONFLICT ZONES WITHIN HLLL FIR:
AREA 1: 3116N01610E 3108N01707E 3030N01700E 3042N01605E
AREA 2: 3251N02240E 3243N02246E 3239N02218E 3247N02216E.
GND - FL195, 12 MAY 09:40 2018 UNTIL 12 AUG 12:00 2018 ESTIMATED.
CREATED: 12 MAY 09:48 2018

One of these areas is around the city of Sirte, including HLGT/Sirte Airport; and the other covers the city of Derna to the east of HLLQ/Labraq Airport:

Other than those two small areas, Libya is happily advertising the country as being open for business! In their updated Notam published in May 2018, they say their airspace is “available H24 for international traffic transiting the HLLL FIR”, and they outline their mandatory routing scheme. They also claim that HLLB/Benina, HLLM/Mitiga, HLLQ/Labraq, HLMS/Misrata and HLTQ/Tobruk airports are “available H24 for international flights and diversions”.

Don’t be fooled. Libya is still a desperately unstable country. There are still regular outages in the provision of ATC services – especially at the main airports due to security or technical failure issues. The main ACC in Tripoli is also subject to severe limitations with no radar service and limited provision of CNS/ATM services in most of the HLLL FIR airspace.

The situation at the country’s main airports is no better. Both airports in Tripoli are focal points for fighting. Given their strategic value, they periodically serve as headquarters for various local militias.

HLLT/Tripoli Airport has been more or less completely closed since mid-2014, when at least 90% of the airport’s facilities were destroyed in fighting between local militias. Since then, international flights to and from Tripoli have been using HLLM/Mitiga instead. Technically, HLLT/Tripoli is now only available for VIP, emergency and ambulance flights; but in reality, it should be avoided at all costs.

HLLM/Mitiga Airport is the old military airfield, which is now being used for civilian traffic, since the closure of HLLT/Tripoli. However, the airport has been plagued by violence over the past few years, and has been forced to close on a number of occasions.

Here’s a rough timeline of notable incidents at Libya’s main airports over the past few months:

April 2018: militants fired rockets at Mitiga, causing damage to the airport building, parts of the apron tarmac, and a parked Libya Airlines A320 aircraft (see picture to the right).

April 2018: HLMS/Misrata Airport briefly suspended operations and redirected flights to Mitiga, when an armed group entered the airport, demanding the release of two members of a local militia.

Feb 2018: another closure at Mitiga related to ongoing clashes between local militia. This time, a mortar shell fell near the airport, and the ATC tower was evacuated, forcing flights to divert to Misrata.

Jan 2018: heavy clashes across Tripoli left at least twenty people dead and forced Mitiga to close for five days, from Jan 15-20. Gunfire at the airport damaged multiple aircraft, including a few A319s and at least one A330:

Oct 2017: a Libyan Airlines A330 at Mitiga airport was hit by gunfire during an exchange of fire between local militia in the district directly south of the airport:

Given the current security concerns, it may be prudent to ignore whatever the Libyan authorities decide to publish on the HLLL FIR Notams about the country’s airspace and main international airports being “available H24”. We continue to list the entire country as “Level 1 – Avoid” at safeairspace.net.