Summary of AC 91-70B with Change 1

 

The FAA has published the newest version of their Oceanic and Remote operations, AC 91-70B with Change 1 dated  1FEB19. The previous edition issued on 4OCT16 is still current (with this change) AC 91-70, 91-70A and the NAT IGA are all cancelled with the publication of AC 91-70B, Change 1. Here is a link to the download.

There are not many large procedural or philosophical differences from AC 91-70B inside Change 1. You will find better-defined references and updated sources of Oceanic/Remote along with CNS information for the International General/Bizav operator. Of course there are editorial changes across this new document. Below here is my detailed summary of AC 91-70B, Change 1.

INTRODUCTION

Better links to the regional resource guides. 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.

CHAPTER 1, GENERAL

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. Read this, then jump to the new Appendix G for more details on how the FAA wants to achieve these goals. This would make a great study aide for a recurrent review or an initial qualification pre-study guide.

CHAPTER 2, Background Information

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 listed w/o great detail in paragraph 2.2. Paragraph 2.3 does a nice job of showing the importance of Annex 2 and 6 and a country’s AIP.

In paragraph 2.4 there is an updated comprehensive list of ICAO documents that are to be considered when operating internationally. Document #7030, #4444, #8168, GOLD, PBCS and SATCOM Voice Guidance Material are all specifically listed here. 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 and 2.6 succinctly describes where special authorizations are required and briefly explains the process for operational approval. These paragraphs need to be combined with Appendix B to get the fuller picture of what is required to operate. The common name for this in in 91 operations is Letter of Authorization, LOA. In commercial operations this is know as Operations Specifications, OpsSpecs. For your reference I have listed several of the more useful LOA/OpsSpec’s here:

A056: Datalink/CPDLC (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, Pilot Qualification and Training

No changes here. 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, CNS/ATM Guidance

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. Performance Based Communication System, PBCS and the terms “RCP” and “RSP” terms found here. Required Communication Performance, RCP and Required Surveillance Performance, RSP are explained and defining levels continuity is explained here. PBCS reference documents are well defined here and linked for your easy reference.

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. This is also the paragraph that defines how SATCOM Voice interacts with the HF Radio requirement. 

ATC separation standards based upon the CNS available are explained with a link to FAA JO 7110.65 and the International/Domestic “NTAP” NOTAM document is paragraph 4.6.4.4.

CHAPTER 5,Flight Planning Guidance

Minor changes. 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. 

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, Flight Execution Guidance

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. Re-Route, Conditional Clearances and common errors with means to trap the errors are explained here. Think 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.

Paragraphs 6.4.8 and 6.4.8.5 is of particular interest to those that want to use an “Electronic Plotting” option.

CHAPTER 7, In-Flight Contingency Guidance

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. Primary guidance is referenced to ICAO Annex 2, Document #7030 and #4444 are made here. I think that this is another case of extra time and deep dive into the references is needed here. Ready reference to Appendix F should be made here.

Appendix A

Abbreviations and Definitions added for PBCS operations.

Appendix B

Comprehensive listing of useful OpsSpecs and LOA for Oceanic/Remote and International operations.

Appendix C

Volcanic Ash and Space Weather information resources are detailed here.

Appendix D

An expanded Oceanic Checklist is presented here. This is basically the “Why” and “How” to work a risk reduction in your operation.

Appendix E

Traveling to Central Africa? Here’s how to make your ICAO Traffic Information Broadcast, TIBA. This same procedure is labeled as “IATA In-Flight Broadcast Procedure” here.

Appendix F

Few changes. Basically this is expanded discussion and description of  the General oceanic/remote contingency and Weather deviation contingency. This should be referenced when reading Chapter 7.

Appendix G

Completely new Appendix. Basically this is what your training program should cover and the manual your crews should  be very familiar with. Couple this with the Chapter 1 declared goals, and you can see the importance of covering this material in your overall international operations.

Bottomline

1. References and documentation are updated and well detailed

2. Proven risk and error mitigation procedures are spelled out

3. New training and documentation guidance is presented

4. Spend some time here and you will be pleasantly surprised with the results