Rules and Regulations: Not knowing is not an excuse

Not knowing is not an excuse

By Jim Sparks

Good, bad, or otherwise, nothing goes on forever. This of course applies to the rules and regulations that govern aviation. As new technology becomes a part of our industry and those in rule-making capacities learn the benefit, in many cases rules change.

Just look at all the advancements in only 100 years. Back in the days of Orville and Wilbur Wright there was no need for devices like cockpit voice recorders and issues such as airspace congestion just could not exist. Too many aircraft in the skies, who would ever have thought that aircraft would routinely fly in the area of 30,000 to 40,000 feet above the ground, much less having to decrease the vertical spacing between them to accommodate yet more traffic?

Other issues including Emergency Locator Transmitters (ELT), terrain awareness, traffic collision avoidance, and Mode-S transponders are all issues that we, the ones entrusted to keep the flying public flying safely, are required to know in order to make sure the machines in our trust and care meet current industry standards or government stipulations. Although the issue of keeping aircraft compliant is supposed to fall on the shoulders of the operator, it is still the responsibility of those of us in the maintenance profession to maintain surveillance and apply proper procedures and techniques as applicable with the evolving equipment and accompanying rules and regulations.

One of the first issues is the implementation of the new rules governing U.S. Federal Aviation Administration certified Repair Stations. Although these changes were made and published in August 2001 they are to go into effect in April of this year. The changes impact FAR Part 91, 121, 135, and 145 operations and those persons involved should be sure to review the applicable regulations to be aware of what's new. In addition, new rules for reporting service difficulties that were scheduled to go into effect January of this year have been postponed until January 2004. This will allow the FAA to issue a Notice of Proposed Rule Making (NPRM) that is planned to take into account issues brought up by the aviation community on the subject.

Reduced Vertical Separation Minimums
Reduced Vertical Separation Minimums (RVSM) and now Domestic RVSM (DRVSM) across the United States are issues that will impact all of us that work with aircraft that occupy airspace between 29,000 to 41,000 feet. The requirement is now set to be in place by January 2005 not only across the continental United States but southern Canada as well.

An RVSM flight envelope includes the range of Mach number, weight divided by atmospheric pressure ratio, and altitudes over which an aircraft is approved to be operated in cruising flight within RVSM airspace.

RVSM flight envelopes are defined as follows:

The full RVSM flight envelope is bounded as follows:

(1) The altitude flight envelope extends from FL 290 upward to the lowest altitude of the following:

(i) FL 410 (the RVSM altitude limit);
(ii) The maximum certificated altitude for the aircraft; or
(iii) The altitude limited by cruise thrust, buffet, or other flight limitations.

(2) The airspeed flight envelope extends:

(i) From the airspeed of the slats/flaps-up maximum endurance (holding) airspeed, or the maneuvering airspeed, whichever is lower;
(ii) To the maximum operating airspeed (Vmo/Mmo), or airspeed limited by cruise thrust buffet, or other flight limitations, whichever is lower.

To date FAR 91 has been changed by adding Part 91-706 to address RVSM operation. In fact an entire new appendix has been written to cover applicability.

Appendix G to Part 91 - Operations in Reduced Vertical Separation Minimum (RVSM) airspace