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| NATA Says “No” to FAA’s Landing Distance Margins for GA Operators | Sep '06 |
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| By Karen Di Piazza |
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The Federal Aviation Administration's new requirement for landing distance safety margins draws sharp criticism from the National Air Transportation Association, as well as general aviation operators under Part 135, 91 and 91K that fly turbojet aircraft.
The aviation industry is steaming over the FAA's "policy for landing performance assessments after departure for all turbojet operators," published recently in the Federal Register, and its related Operations Specification C082 and Management Specification M082.
Eric Byer, VP of NATA, said NATA is demanding that FAA Administrator Marion Blakey immediately postpone the agency's implementation of the notice, to take effect Oct. 1.
"The new landing distance requirement would unfairly penalize Part 135, 91 and 91K operators, where they wouldn't be allowed to land without 15 percent more runway available for the actual landing," Byer said. "This FAA 'policy' is solely based on last year's Southwest Airline accident; this is another case of the FAA's rulemaking by policy—a new requirement operators are expected to comply with without having gone through the 'formal rulemaking process.'"
He said a separate landing assessment with a new mandatory 15 percent margin isn't required by regulation. In NATA's postponement request, it asked the FAA to postpone distribution of the OpSpec/MSpec and related guidance for a minimum of 60 days, allowing for a fair, joint industry/FAA-working group to discuss the notice.
"We're having none of it; this is unacceptable!" he said. "If we don't get a reasonable response to our request to postpone this, soon, we'll take this to the Office of Management and Budget; we'll also look into whether or not this is legal. The FAA seems to think it can impose a detailed, new process on operators without following the mandates of the Administrative Procedures Act."
The FAA bypassed formal rule making procedures, adopting a new 15-percent landing margin imposed for all turbojet aircraft, after a Dec. 8, 2005 Chicago Midway accident. Southwest's 737-700 skidded off a wet runway and onto a highway and beyond, hitting a car, and killing a 6-year-old boy.
Subsequently, the FAA discovered nearly half of the commercial operators they polled reported they had no policies for assessing sufficient landing-distance margins in various weather conditions. The FAA reported that because commercial aircraft landing distances used were calculated from manufacturers' data, based on dry and smooth conditions, a new 15-percent landing distance was needed for inclement conditions.
"NATA has a problem with that study," Byer said. "Aircraft operated under Part 121 is being applied to Part 125, 135 and 91K; this blanket approach imposed onto these operations isn't acceptable."
He says not only does NATA oppose the FAA's policy, but also the language used in its guidelines to follow the 15 percent landing margin "appears to be a regulatory trap for the pilots and operators." He said NATA fears that the FAA's unclear definition of time of arrival could lead to second-guessing by the feds, thus resulting in enforcement actions against Part 135, 91 and 91K operators.
"If the meteorological conditions change when the aircraft is 500 feet above ground level, what's the pilot to do, mathematically recalculate landing distance at this critical phase of flight?" Byer quipped. "This policy isn't doable for on-demand operations; it would unnecessarily limit the number of available destination airports that operators would be allowed to use." He added that currently, the FAA allows for a "generic minimum runway length," taking into account the worst meteorological conditions, based on operators' total fleet or fleet type.
NATA President James K. Coyne said that although the FAA's goal of increased aviation safety through a standardized landing margin is laudable, the Part 121 driven and oriented notice could actually diminish aviation safety for Part 135, 125 and 91(K) operators.
"The FAA appears to have developed a case of 'tunnel vision' and can only see the perceived benefits of this new policy, and appears to have not considered the possible unintended safety consequences of their actions," he said. "Ultimately, the flying public could be the ones who suffer."
Coyne further added that the FAA's new policy is a blatant disregard for the unique characteristics of 135 and 91(K) operations. Citing several FAA oversights in developing the policy, he points to unreliable or unavailable braking action reports, and lack of friction measuring equipment at many airports frequented by on-demand charter and fractional operators.
"The FAA's policy notice doesn't provide clear guidance to operators and flight crews as to how to determine braking action under these circumstances and whether a landing is permissible given these facts," he said.
Meanwhile, unless the FAA postpones its new landing margin implementation, it expects operators to be ready for new operation specification procedures by Sept. 1, providing only a 30-day window for implementation.
For more information on the 15-percent landing margin and additional rules, visit www.nata.aero.
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