March 2019 Issue

New FAA Guidance On Turbine Climb Gradients

Parsing the difference between engine-out and all-engine climb transport airplane performance.

The FAA on November 19, 2018, issued new operating guidance to pilots and operators of Part 25-certificated turbine-powered airplanes intended to help determine compliance with climb gradient requirements published in standard instrument departures (SIDs), obstacle departure procedures (ODPs), diverse vector areas (DVAs) and missed approach procedures. The guidance is found in an Information for Operators bulletin, InFO 18014.

The agency offered a two-part rationale for the new policy statement. First, according to the InFO, “It has come to the attention” of the FAA that some confusion exists regarding “compliance with climb gradients on IFR departure procedures and/or missed approach procedures. In some instances, this confusion has led to...excessive weight penalties to the departure performance capabilities of the aircraft.” More important, according to the InFO, “some operators may not be accounting for all obstacles in the planned departure path” when flying departure procedures and/or missed approach procedures.

According to the new guidance, “IFR departure procedures or a DVA may include a higher-than-standard climb gradient originating at the departure end of the runway.” Similarly, “a higher-than-standard missed approach climb gradient may be published from the missed approach point.” The reason for this, according to the FAA, is that an exception exists in obstacle-avoidance criteria when there are “low, close-in obstacles” near the departure end of the runway. These obstacles are identified in the applicable Terminal Procedures Publication. The agency notes these “low, close-in obstacles” must be cleared by a means other than the published climb gradient.

All pilots, no matter the airplane, are required to remain above the published climb gradient, expressed as a minimum rate of climb per nautical mile. An example might be to climb at a minimum rate of 500 fpm until reaching 4000 feet msl. As the FAA notes, compliance with FAR Parts 91 and 97, requires that “pilots must not accept a clearance that includes an IFR departure or an instrument approach unless the airplane can remain above the plane generated by the climb gradient.”

The “confusion” identified by the FAA and addressed in the InFO involves this required climb gradient, which presumes all engines are operating (AEO), and the additional, similar climb performance requirements for one-engine inoperative (OEI) operations. It’s compounded because Part 25 airplane manufacturers “may not have provided AEO climb performance data that show the ability to comply with TERPS climb gradient criteria,” according to the FAA, nor are they required to do so. Instead, operators may use supplemental data, including computer software or additional information from the airplane manufacturer to determine AEO performance.

To put it more succinctly, the FAA notes that the “various operating rules (91, 91K, 125, 121, and 135) have different requirements on aircraft departure and approach performance” and, “If AEO climb performance data is not provided by the manufacturer or otherwise furnished by the operator, pilots and operators must exercise sufficient care in determining expected takeoff/departure performance.” Ensuring adequate climb performance exists to meet a SID, ODP, or DVA climb gradient under OEI conditions “does not adequately ensure compliance with the applicable OEI takeoff obstacle clearance operating rules” and the “FAA imposes no requirement, nor is it recommending, that operators use this FAA-approved AFM OEI performance data...on a SID, ODP, DVA, or missed approach procedure.”

The FAA notes that pilots must determine that the aircraft can comply with a SID, ODP or DVA climb gradient. To do so, “pilots may use manufacturer or operator prepared AEO data to determine compliance, or they may determine the rate of climb required by the climb gradient for the anticipated ground speed during the climb. Pilots must ensure that they perform the climb-out, including managing configuration, airspeed, and thrust changes such that the airplane remains above the plane generated by the climb gradient beginning from the departure end of runway.” Using FAA rules designed to ensure OEI obstacle clearance by limiting weight “does not necessarily guarantee that the airplane can meet the climb requirements on an instrument procedure.”

FAA Publishes AD on Aspen Avionics EFIS Units

As we highlighted in our January 2019 issue, an FAA special airworthiness bulletin (SAIB SW-18-31) was published in November to address spontaneous resetting of Aspen Avionics EFD1000 PFD, EFD1000 MFD, EFD1000 EBD and EFD500 MFD units. “The condition is apparently caused by unexpected/malformed data being transmitted from some FIS-B ground stations that is not rejected by the EFD1000/500 system,” the company said at the time. “Since it is caused by the data content of the specific ground station you are near, not all aircraft are affected equally.” Now, the FAA has published an airworthiness directive (AD 2019-01-02) in response. It’s set to go into effect February 7, 2019.

The new AD was published as a final rule accompanied by a request for any public comments to be filed with the agency by March 11, 2019. In justifying the AD, the FAA said, “Since we issued SAIB SW-18-31, additional analysis of the reports of uncommanded resets and the nature of the possible unsafe condition were evaluated, and we have determined that a more urgent safety need requiring AD action is necessary.” The AD requires “disabling the ADS-B In function and revising the AFMS to reflect that the ADS-B In has been disabled on the unit.”

The AD applies to the listed EFIS units when 1) software version 2.9 (SW 2.9) is installed; 2) the Flight Information Service-Broadcast (FIS-B) weather interface option is enabled and 3) independent airspeed, attitude and altitude back-up instruments are not installed. The FAA said it considers the AD an interim action, and that Aspen is developing a “modification that will address the unsafe condition identified in this AD. Once this modification is developed, approved, and available, we might consider additional rulemaking.”


A New Record In FBO Fees?

When major events like a Super Bowl attract thousands of participants, managing the increased demand for ATC and airport services often results in some kind of reservation system. The FAA pioneered ATC reservations with its High-Density Traffic Airport rules and the general aviation reservation (GAR) program put into place after the 1981 controller strike. The practice has expanded to include IFR arrivals at air shows and major sporting events, to name a few types.

The FBOs at airports serving the event may make their own preparations, which often involve establishing a reservation system of their own in consideration of the greater demand for their services. They may even institute special fees, jack up the price of normal ones or turn away customers. But in our view, Hill Aircraft at Atlanta’s Fulton County Airport-Brown Field may have set the record for special-event fees.

As detailed in the table above, a screenshot from the FBO’s web site—Hill Aviation instituted a “non-refundable, non-transferable” flat-rate reservation fee during Super Bowl LII of $1700 per aircraft. The fee structure offered a 50-percent discount for the first 10 piston-aircraft reservations, but full fare for all other aircraft up to business jets converted from airline transports. They got to pay $3400.