RVSM with AC 91-85A

Reduced Vertical Separation Minimum, RVSM was initially implemented in North Atlantic Minimum Navigation Performance Specifications, MNPS Airspace in March 1997. Since then, RVSM operations have been implemented almost worldwide. FAA Advisory Circular 91-85A was issued 21JUL16. This AC applies to all USA operators who want to apply for authorization to conduct operations in RVSM airspace. Aircraft approved for RVSM can be used worldwide. This includes RVSM operation in Oceanic/Remote and continental areas such as Europe, Asia and the United States. Aircraft equipage and altitude-keeping performance requirements were developed using the highest density traffic counts in the world so aircraft could receive one-time approval for worldwide operations. Below here is a summary of the findings in this document.

Operators Seeking Approval For Aircraft

The FAA must find that the operator has adopted RVSM operating policies and/or procedures for pilots and dispatchers. Each Flight Standards District Office, FSDO, Certificate-Holding District Office, CHDO, International Field Office, IFO, Principal Operations Inspector, POI, Principal Avionics Inspector, PAI, Principal Maintenance Inspector, PMI, or Aviation Safety Inspector, ASI retains the authority to conduct as much review and research with respect to any proposed RVSM-Compliant Aircraft or RVSM-Knowledgeable Pilots requirements as is warranted. Details of this process will be found in Chapter 5 and Appendix E.

Operators applying for RVSM authorization will need to provide a configuration list for the applicable aircraft, which details components and equipment relevant to RVSM operations. Operators conducting operations under an MEL adopted from the Master Minimum Equipment List should include items pertinent to operating in RVSM airspace. Any evidence of previous operating history should be included in the application. Specifically explain any events or incidents related to poor height-keeping performance indicating weaknesses in training, procedures, maintenance, or the aircraft group intended to be used.

Operators issued OpSpecs are not required to obtain an LOA for those operations conducted under part 91 provided that:

  • 1. The aircraft is operated under the Operator name listed on the OpSpecs.
  • 2. The flight is conducted in an area of operations listed in the OpSpecs.
  • 3. The aircraft is operated under the conditions under which the OpSpecs were granted

Each part 91 operation, not associated with a certificated operator, will need a LOA to operate in RVSM airspace.

FAA’s Operational Approval, The “Matrix”

Operators will find the process more streamlined and less cumbersome. FAA estimates that each RVSM approval requires 12hrs to complete the “Paperwork” and between 2,500 to 3,000 approvals per year are administered. FAA thinks with this new process will save it’s budget $5,000/approval.

It is important to be aware of a new decision “Matrix” for FAA RVSM approvals. Review figure 4-1 in AC 91-85A for details. Here are some of the important points to remember.

In the case of RVSM authorization changes that are administrative in nature only, “Authorization Group I”. This group only applies in circumstances where a previously authorized RVSM Operator is seeking an administrative change only AND all of the previously accepted RVSM Authorization Elements are remaining the same.

“Authorization Group II” applies to applicants seeking new RVSM authorizations based on one or more existing approved RVSM Elements. This group will normally apply to an operator seeking the issuance of an RVSM authorization for an aircraft already an RVSM-compliant aircraft or where the new RVSM operator will be utilizing previously accepted RVSM-Knowledgeable Pilots requirements with respect to its operations of that specific aircraft.

“Authorization Group III” applies to applicants for new RVSM authorizations not based on any existing RVSM Authorization Elements. The RVSM applicant should submit sufficient evidence to show its ability to comply with each of the RVSM Authorization Elements, and the FSDO, CHDO, or IFO should process the request as a new and unique request by reviewing all of the materials provided by the applicant to ensure each of the RVSM Authorization Elements have been met.

Performance Monitoring Required

RVSM is a “performance-based” operation requiring ongoing, independent monitoring to ensure that the RVSM airspace airplane population adheres to stringent altimetry system requirements. All Operators wishing to conduct operations in RVSM-designated airspace are required to participate in RVSM height monitoring. U.S.-registered Operators are required to conduct initial height monitoring within 6 months of the authorization date of issue and must conduct height monitoring every 2 years or within intervals of 1,000 flight hours.

“Operational Control” and “Responsible Person”

It is important to submit a request for RVSM authorization in the name of the person having operational control of the aircraft. It is not the responsibility of the FSDO or a specific ASI to make such a determination.

For non-commercial operations (14CFR Part 91 and Part 125) the legal operator should normally be the registered owner of the aircraft operating the aircraft incidental to its own non-air transportation business or personal activity. The legal operator will generally not be an owner trustee, a management company that has not accepted a transfer of operational control or a holding company/bank that holds title to the aircraft solely for the purpose of leasing or transferring operational control of the aircraft to other persons.

It is not un-common to have multiple operators for part 91, 91K, 125 or 135 aircraft. Multiple dry leases for the use of any one aircraft is an example of this situation. In such instances, each individual operator is required to have an appropriate RVSM authorization issued in its own name in order for that Operator to have access to RVSM airspace.

For commercial and fractional ownership program operations conducted under 14CFR Parts 91K, 121, 125, and 135, the authorization applicant and holder should be the operating certificate holder, air carrier certificate holder, or fractional ownership program manager.

The operator will need to designate a person who has the legal authority to sign the RVSM authorization on behalf of the Operator and who has adequate knowledge of RVSM requirements, policies, and procedures. That person may be the individual person who will be the operator, or an officer or employee of the legal entity operating the aircraft. The operator may also choose a separate person who has been contracted with in order to act on behalf of the individual person or legal entity with respect to the RVSM authorization. It is generally not appropriate to designate an “Agent for Service” with respect to RVSM authorizations being issued to 14CFR Part 91 operators. The responsible person for crew operations must be a U.S. citizen or who holds a U.S. pilot certificate and accepts responsibility for complying with the stated regulations by signing this document.

The Operator should also designate a person to act as a contact person who has actual day-to-day knowledge of the RVSM-Compliant Aircraft operations and RVSM airworthiness status the FAA may contact to gather such information when such a need arises. The operator may use one individual to fulfill both positions. The Responsible Person and/or the RVSM-POC should be a person having on-going knowledge of the operations of the aircraft under the RVSM authorization.

Key Element For Approval, “RVSM-Compliant Aircraft”

An aircraft is an “RVSM-Compliant Aircraft” when the FAA has determined the aircraft design satisfies RVSM performance requirements. This will be indicated type certification (TC) or Supplemental Type Certification (STC) and the aircraft has been properly maintained on an on-going basis to conduct such operations. 14CFR 91.405 and 91.407 require operators to have their aircraft inspected and approved for return to service by authorized persons and otherwise maintained in accordance with part 14CFR Part 43. This means that each person performing maintenance and preventive maintenance is required to do so using the methods, techniques, and practices prescribed in the manufacturer's maintenance manual, Instructions for Continued Airworthiness, ICA or other means acceptable to the Administrator. The primary effect of this final rule is to remove the requirement for an applicant to submit an RVSM-specific maintenance program to the FAA as part of its application for an RVSM authorization.

Key Element For Approval, “Properly Trained Pilots.”

Also, pilots and dispatchers should be knowledgeable on contingency and other procedures unique to an operator’s specific areas of operation.

For an applicant operating only under part 91 or part 125 to demonstrate that it has RVSM-knowledgeable pilots will consist of providing sufficient evidence that each pilot has an adequate knowledge of RVSM requirements, policies, and procedures as required in part 91 Appendix G, section 3(c)(2). The FAA, at its discretion, may evaluate a training course prior to accepting a training certificate. Training is commonly obtained thru 14 CFR part 142 training center certificates, completion of a course of instruction on RVSM policy and procedures; and/or an Operator’s in-house training program.

For an applicant who operates under 14CFR Part 91K, 121, or 135, in addition to meeting the adequate knowledge requirements for part 91 operators, that applicant will need to provide sufficient evidence of initial and recurring pilot and dispatcher training and/or testing requirements as well as policies and procedures allowing the operator to conduct RVSM operations safely. Special emphasis items for flightcrew training remain largely unchanged.

USA RVSM “Exceptions”

An aircraft or operator not authorized for RVSM operations or an operator/aircraft without operable RVSM equipment is referred to as non-RVSM. If either the operator or the aircraft or both have not received RVSM authorization, the operator or dispatcher must not file the RVSM equipment code in the flight plan. The pilot of non-RVSM aircraft must inform the controller of the lack of RVSM approval in accordance with the direction provided in the FAA Aeronautical Information Manual, paragraph 4-6-8. An aircraft or operator not authorized for RVSM or an operator/aircraft without operable RVSM equipment is referred to as non-RVSM. If either the operator or the aircraft or both have not received RVSM authorization the operator or dispatcher will not file the RVSM equipment code in the flight plan.

If any of the required equipment fails prior to the aircraft entering RVSM airspace, the pilot should request a new clearance so as to avoid flight in this airspace. The following equipment should be operating normally at entry into RVSM airspace:

  • 1. Two primary altitude measurement systems.
  • 2. One automatic altitude-control system.
  • 3. One altitude-alerting device
  • 4. Ascertain the requirement for an operational transponder in each RVSM area where operations are intended

After realizing that they no longer can comply with RVSM requirements (aircraft system failure, weather, lost com, etc.) pilots must request a new clearance from the controller/radio operator as soon as the situation allows. If a new clearance is not available or the nature of the emergency requires rapid action the pilot should notify ATC of their action and contingency procedures. Operators should refer to the RVSM section of the AIM when experiencing abnormal situations and implementing contingency procedures. It is also the responsibility of the crew to notify ATC when the implementation of the contingency procedures is no longer required.

In Domestic U.S., Alaska Offshore Airspace and the San Juan Flight Information Region, Non-RVSM aircraft may be accommodated on a workload-permitted basis. See the U.S. Aeronautical Information Publication, Enroute, Section 7 for details. Here are the highights:

  • 1. The vertical separation standard applied between aircraft not approved for RVSM and all other aircraft must be 2,000ft
  • 2. Department of Defense aircraft
  • 3. Flights conducted for aircraft certification and development purposes
  • 4. Active air ambulance flights utilizing a “MEDEVAC” call sign
  • 5. Aircraft climbing/descending through RVSM flight levels to/from FLs above RVSM airspace and without intermediate level off
  • 6. Foreign State aircraft

In addition, when in U.S.-controlled oceanic airspace, the following aircraft can be accommodated on a workload-permitted basis:

  • 1. Aircraft being initially delivered to the State of Registry or Operator
  • 2. Aircraft that was formerly RVSM-approved but has experienced an equipment failure and is being flown to a maintenance facility for repair in order to meet RVSM requirements and/or obtain approval
  • 4. Aircraft being utilized for mercy or humanitarian purposes

USA RVSM Authorization Removals

The operator should make an effective, timely response to each height-keeping error. The operator should also report the event to the FAA within 72 hours with initial analysis of causal factors and measures to prevent further events. The FAA should determine the requirement for follow-up reports. Height-keeping errors fall into two broad categories:

  • 1. Errors caused by malfunction of aircraft equipment, “Parts”
  • 2. Operational errors. “People”

If the Administrator determines that the operator is not complying, or is unable to comply, with this appendix or subpart H of this part. Examples of reasons for amendment, revocation, or restriction include, but are not limited to, an operator's:

  • 1. Committing one or more altitude-keeping errors in RVSM airspace
  • 2. Failing to make an effective and timely response to identify and correct an altitude-keeping error
  • 3. Failing to report an altitude-keeping error.

Errors that should be reported and investigated are:

  • 1. Total Vertical Error (TVE) equal to or greater than ±300ft
  • 2. Altimetry system error (ASE) equal to or greater than ±245ft
  • 3. Assigned altitude deviation (AAD) equal to or greater than ±300ft

Operational Pilots Will Find Little That Has Changed

Previous operational policies and procedures remain unchanged for flight planning, preflight, action during flight and postflight maintenance issues description. The RVSM minimum equipment fit should be:

  • 1. Two independent altitude measurement systems
  • 2. One secondary surveillance radar altitude reporting transponder
  • 3. An altitude alert system
  • 4. An automatic altitude control system

The automatic altitude control system is generally comprised of an autopilot with altitude hold mode. The automatic altitude control system should be capable of operation from either of the two required independent altitude measurement systems

RVSM Contingencies

 In Appendix C of AC 91-85A there are several scenario based descriptions of expected pilot and ATC action in contingency situations. I this it is largely under served that the pilot and ATC are expected use good judgment and determine the action most appropriate to any given situation. No one set of actions or procedures are the best solution to all RVSM failures. The guidance material recognizes for certain equipment failures, the safest course of action may be for the aircraft to maintain the assigned flight level and route while the pilot and controller take precautionary action to protect separation. For extreme cases of equipment failure, however, the guidance recognizes the safest course of action may be for the aircraft to depart from the cleared FL or route by obtaining a revised ATC clearance; or if unable to obtain prior ATC clearance, executing the established ICAO Doc. 4444 and Doc. 7030 contingency maneuvers for the area of operation.

Operators and pilots conducting oceanic and remote airspace operations should ensure their familiarity with and the actions expected of pilots in such contingency situations. The basic concepts for contingencies in oceanic airspace are contained in ICAO Document #4444, Chapter 15.2. Operators are responsible for knowing the RVSM procedures in the areas of intended operation. Operators starting RVSM operation in an RVSM area of operation new to them should ensure their RVSM programs incorporate RVSM policy and procedures unique to the new area of operations. ICAO Document #7030 provides differences for individual regions of the world.


  • 1. Operational procedures remain largely unchanged
  • 2. USA operators still need to obtain RVSM approval from FAA
  • 3. The new process is major improvement from past practice and was years in the making
  • 4. A standalone RVSM aircraft maintenance program is no longer required
  • 5. Aircraft qualification and on-going maintenance are key
  • 6. Pilot and dispatcher training are key
  • 7. Regular RVSM performance monitoring is required