"First Days of RVSM" 

January 20, 2005, we departed LAX headed for the Pacific Northwest.  It was a day like any other, apart from one operational aspect.  This was “Day One” for comprehensive RVSM operations in our hemisphere.

The initial differences were hardly extraordinary; after all, we’ve been using RVSM altitudes for enough years to equal the corporate careers of several friends and acquaintances.  OK, so I can count either number without getting to my toes.  Neither fact represents anything new.

“Nine Alpha Lima, cleared to climb to FL400,” uttered the controller, with more ease than familiarity.

“Roger, Niner Alpha Lima climbing flight level four hundred”.

It was only after we had been in the upper level structure for an hour that we finally questioned Oakland.  It had been so quiet we expressed our shared intuition that too much silence is not a good thing.

“Oakland, Nine Alpha Lima, mike check”.

Oakland responded saying that it was indeed quiet, especially since a raft of supervisors had stopped peering over everyone’s shoulders.  That set me to thinking about how strange our FAA’s approach to RVSM has been.

Much of my career experience has been with foreign flags, where the ratio of regulators to fleet hulls is quite a bit different—adequate to abundant are words that spring to mind.  On the other hand, our GA fleet is relatively huge with each regulator responsible for many more Operators than in other countries.

My work frequently involves operations with new or nearly new Group 1 aircraft (those aircraft that are manufactured as RVSM compliant rather than old or retrofitted hulls).  Those aircraft are more easily (quickly) approved in most flags—sometimes taking as much as a week to ten days for operational authority / approval to be issued.

For comparison, during a control period (2001-present) we operated:

·        Twenty six “N” registered GA aircraft (21 were Group One)

·        Twenty had / have no RVSM LOA due to change of operator; or, it involved the delivery of a newly built aircraft

·        More than ten different FSDO offices were / are involved (geographically distributed in most regions of the US)

·        Turn-around times (then and now) run anywhere from two weeks to three months.  More often, it is the 30-90 day range.

·        Fourteen foreign hulls, representing six nations

·        Average time for approval (of Group 1 Aircraft), less than 7 days.

Most new aircraft maintenance programs are highly standardized.  Operators have little “wiggle room” and fewer still are inclined to exercise it these days.  Underwriters and safety initiatives (like IBAC’s International Standards – Business Aircraft Operations) continue to foster and maintain sets of best practices, and semi-annual or annual training (including RVSM) is now the norm.  IS-BAO is the brainchild of NBAA and others who have consistently sought to “raise the bar” for business aviation.

In the middle of 2003, many FSDO safety officers came back from training courses that had them convinced that the operator was to be accountable for routine maintenance and upkeep of testing equipment used by any maintenance facility.  I could understand that if I intended my own maintenance staff to purchase or lease the required equipment.  In this case, the view did not distinguish between “organic assets” and OEM or FAA Approved Maintenance facilities whose equipment (at least in my view) should be covered by that separate approval process.

All of this leads me to ponder the unfathomable (and I am fully aware that asking such questions carries the risk of relegating myself to a “rubber room”). Why does it take so long for LOA approval--especially for Group 1 Aircraft?  It’s not rocket science.

Is there any way to help the FAA to become more streamlined and standardized?  I am not attempting to criticize the approval process for older aircraft which, depending upon age and type could drive a considerable number of relevant operational issues and questions.  

What I am saying is that we (the US) are the world’s largest producer of business aviation aircraft.  To the best of my knowledge, there is not a single OEM producing non-RVSM aircraft capable of flying above FL270.  RVSM approval process certainly has taken longer now but shows little sign of amelioration following the current “rush hour”.  Purchasing a new aircraft (even a previously owned one) will trigger the whole approval process with widely varying timelines—some of you may have built relationships with local authorities that may prevent truly egregious turn-around times.

Fundamentally we all acknowledge that the FAA has a primary role of safety management.  I suggest that we channel our resources to better make use of their limited resources.  Perhaps operators of Group 1 aircraft, flown by departments whose best practices have been certified (ala IS-BAO) can fast track approvals; thus, making better use of our ever limited resources—regulatory, human and the precious fuel we consume.

If you think these problems will magically disappear when the DRVSM dust settles, consider that your FSDO will likely have to issue LOA’s for forthcoming initiatives like P-RNAV and perhaps a host of other issues as we move towards this next century’s airspace.