New FAA AC 90-70B

 

The FAA has published the newest version of their Oceanic and Remote operations, AC 91-70B. I think this is a superior product over previous editions of this advisory circular. Previous editions were very 121 and commercial operator centric. This issue is broader based and has a better developed perspective for 91 operators. Below here is my summary of AC 91-70B, issued 4OCT16. Here is a link to the download: http://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1030086

Introduction

I think this is important to read, it sets the tone for this document. The FAA is really trying to make international flight operations procedures and planning information logical and easier to find. Look here for the interaction between this document and the regional resource guides and NOTAMS

Chapter 1, General

As usual previous editions are obsolete, pilots and operators are expected to use this new document as a their informational guide. This section goes on to explain where and how to find the latest updates to the information found here. The FAA spells out that “We are also targeting GA pilots who do not fly regularly in oceanic and remote continental airspace and need a refresher on what to consider before, during, and after such a flight. Most commercial operators have company procedures for operations in oceanic and remote continental airspace.” I think this is a big step forward.

This chapter ends with a comprehensive listing of resource documents and the FAR’s that are important to international operations. This would make a great study aide for a recurrent review or an initial qualification pre-study guide.

Chapter 2

This chapter is “Foundations” chapter. Background Information on The International Civil Aviation Organization, ICAO is placed here. This chapter makes an excellent connection from the FAR’s to ICAO standards and recommended practices. Annexes 1-19, the “SARPS” and documents are explained w/o great detail. I think there should be more definition of differences between ICAO “Articles” and the “Annexes” in this paragraph. I think that paragraph 2.3.2 should place more important on a country’s AIP.

In paragraph 2.4 there is a comprehensive list of ICAO documents that are to be considered when operating internationally. Document #4444, #8168, GOLD, and #7030 are specifically important ones. Look for a new issue of the GOLD latter this year. NAT Document #007 is listed here also and a note will explain that the old “NAT IGA” has been incorporated into #007.

Paragraph 2.5 needs to be combined with Appendix B. This presents an excellent description of the when and where special authorization to operate is required. The common name for this in in 91 operations is Letter of Authorization, LOA. In commercial operations this is know as Operations Specifications, OpsSpec.

For your reference I have listed several of the more useful LOA/OpsSpec’s here:

A056: Datalink/CPDLC (if applicable)
A153: ADS-B Out (if applicable)
B034: P-RNAV
B036: RNP4/RNP10
B039: NAT HLA
B046: RVSM
C052: LPV (if applicable)
C063: Terminal RNP-1/RNAV 1
C073: VNAV IAP using MDA as a DA
 

Chapter 3

This is the “Training” chapter. As if to punctuate the need for specific pilot and operator training, this chapter starts out with a quote from Annex 6. Compare Paragraph 3.1 to ICAO Annex 6, Part 1, Paragraph 3.1 and Part 2, Paragraph 2.1.1. This list of relevant subject matter found here needs to used in conjunction with the regulations and resources found in Appendix G

Chapter 4

This chapter covers the Communications, Navigation, and Surveillance Systems found in Oceanic and Remote Continental Airspace. You will find familiar terms like “RNP” and what criteria are used to determine RNP values. What may be not so familiar is the “RCP” and “RSP” terms found here. Required Communication Performance, RCP and Required Surveillance Performance, RSP are explained and defining levels continuity is explained here. I think these elements will be a bigger factor in oceanic operations going forward. For example “P-Code” designation in block #10 on flight plans will identify what RCP level an aircraft is capable of will begin introduction early next year.

There seems to be a lingering question of when or if an HF radio is required for Oceanic/Remote operations. Paragraph 4.3 answers this definitively. Areas of US Oceanic and Remote operations are described well in Paragraph 4.6.3

Chapter 5

This is the “Flight Planning and Permitting” chapter. An excellent itinerary-planning checklist is found in paragraph 5.2. This is in the form of open-ended questions that are calculated to provoke thoughtful responses and risk mitigation in your planning. A very good discussion of crew fatigue, risk mitigation and self-care strategies is found in paragraph 5.3.

Paragraph 5.4 provides a comprehensive list of required documentation for crew, passengers and aircraft operating internationally. I think a reference to ICAO Annex 9 and use of the General Declaration form, as Journey Log Book should be included here. (Annex 6, Part 1, Para. 4.5.5 and Part 2 para. 3.4.5.4) Specific reference to the ICAO “6mos retention” is found in Appendix A, Paragraph A.2.39. No mention of a 90-day requirement is found but paragraph 5.4.1.2 directs pilots/operators to the individual countries’ AIP for guidance.

A brief discussion of “ETOPS” and Polar operations is included near the end of this chapter. An interesting LOA for enroute IFR operation in Class G airspace is described here also.

Chapter 6

This is the “Risk and Error Mitigation” chapter. There is an excellent discussion of error cause, mitigation strategies and operational procedures discussions found here. Significant details are provided on how to NOT to wander off your cleared route, altitude and speed. This of this as an expanded checklist for the Sample Oceanic Checklist found in Appendix D. The material presented here has been pulled from several relevant sources. It is worth the extra time to absorb this material.

Chapter 7

This is the “Contingency” chapter. The chapter is fairly short and is a general discussion of the thought process when things do no go as planned. Specific reference to ICAO Annex 2, Document #4444 and the AIP is made here. I think that this is another case of extra time and deep dive into the references is needed here.

Bottomline
  1. This is a big step up from the previous guidance material
  2. References and documentation is well detailed
  3. Proven risk and error mitigation procedures are spelled out
  4. Spend some time here and you will be pleasantly surprised