Story ID: 
Coming DRVSM crunch could extend LOA delays
By: Stephen Pope
Caption: The road to RVSM approval can be as smooth as a ribbon of freshly laid desert highway or as rough as a rock-strewn forest switchback.
Word Count: 2299
The road to RVSM approval can be as smooth as a ribbon of freshly laid desert highway or as rough as a rock-strewn forest switchback. From those unfortunate enough to find themselves stuck on the rocky path, there has been a chorus of complaints recently about lengthy approval delays and other problems, with some business aircraft operators saying the difficulties they face are just as likely to be related to genuine issues with the airplane and RVSM paperwork as to bureaucratic fumbling by local FSDO inspectors. 
From online pilot forums to FBO lounges and aircraft hangars, RVSM talk these days is most likely to focus on the requirements for obtaining a letter of authorization (LOA) from the FAA to operate in the soon-to-be-restricted airspace. Spanning FL290 to FL410 across the continental U.S., domestic RVSM (DRVSM) is intended to ease ATC delays and save fuel by allowing more airplanes to operate in the same airspace at the same time. But for some the cost of new avionics, coupled with long delays, has conspired to create one gigantic headache. 
The most common complaints from operators center on the long waits that can ensue once the requisite paperwork has been submitted to the FAA, as well as criticisms that there can sometimes be big variations in the way different FSDOs handle the approval process. 
Industry insiders who deal with RVSM daily counter the critics by saying that many of the delays can actually be traced back to the operators themselves, who either have not submitted the right paperwork, have not complied with all of the requirements or who might have unrealistic expectations where RVSM and the FAA are concerned.
According to Eli Cotti, NBAA’s director of technical operations, the FSDO situation is not as clear cut as some would make it. The RVSM process, he said, needs to be thought of as a “three-legged stool,” with only one of the legs representing the RVSM equipment package installed on the airplane. The second leg of the stool can be identified as the pilot-training requirements that are unique to RVSM airspace.The third leg deals with the rules handed down long ago by the International Civil Aviation Organization (aviation’s equivalent to the U.N.) that require operators to obtain approval from the civil aviation administrator in the country where RVSM approval is being sought.
“It is true there have been delays, but the reasons for the delays vary,” Cotti said. “There is no single cause or factor. There has been a learning curve for everybody involved, whether it is the FAA, the local FSDO or the operator.”
Operators have been complaining about RVSM for years, but critics of the approval process seem to have grown palpably louder recently. As an illustration of the horror stories that have been circulating, one Cessna Citation operator said that after his company took the time to compile the required RVSM manual, submitted the airplane for inspection and passed the monitoring check flight, it had to wait more than eight months for an LOA as the paperwork languished at the FAA. Conversely, other operators have reported that they breezed through the process and received their LOAs in as few as two or three days. 
“Clearly there is a disparity,” said Cotti, “but the reasons are not always so obvious.”

Pilots Point Finger at FSDOs
The RVSM LOA is the golden ticket to RVSM airspace, which already covers many parts of the world and is coming to the U.S. early next year. The major factor that will determine how hard or easy it is to obtain an RVSM LOA, say some frustrated pilots and flight department managers, centers on the individual FSDO, with inspectors at certain locations said to have a better handle on the process than others. 
“The problem is that FAA managers on the national level are simply not providing the proper guidance to the FSDOs on how to complete the tasks for the RVSM LOA,” said a Citation Ultra captain who flies for a company based in the Southwest. “All too often we heard ‘I don’t know’ or ‘this is new to us’ as answers to why our LOA was delayed. I certainly don’t envy the position these inspectors are in.”
A common complaint is that the FAA has not given local inspectors the guidance they need to be able to apply uniform standards for all business aircraft operators in all parts of the country. As a supposedly real-world example cited by another business jet operator, during the RVSM approval process the FSDO inspector needed to make sure that the altimeters were certified and working properly. Would this mean the inspector actually needed to see the raw data from the airplane’s last Part 91 altimeter check, the operator asked, or could he simply assume that the IA who signed off on the RVSM Service Bulletin had already certified it as functioning properly? 
Apparently, the answer depends on the inspector. If the FSDO inspector needs to pore over the raw altimetry data, obviously issuance of the LOA will be slower. These seemingly minor issues can add up, say critics, adding that they are a major reason some operators receive their LOAs in less than a week while others wait six months or longer.

Issues for New Buyers
RVSM approval delays have led to calls from some corporate operators for the FAA to abandon the LOA process altogether and allow airplanes to fly in RVSM airspace as soon as they have undergone the needed upgrades and completed a flight check. Especially for new airplanes rolling out of the factory, some operators say they would like to see these aircraft stamped as RVSM-approved as soon as they are delivered.But under current rules the operator must obtain an RVSM LOA even for a new aircraft that is “RVSM ready.” It is a process that cannot be completed until the airplane has been delivered, and as a result after next January 20–the date DRVSM takes effect–operators of new airplanes will have to fly below FL290 until they get their LOA.
“Are new airplane buyers expected to accept having to fly around below FL290 for months while the FAA LOA system processes paperwork that is totally useless anyway?” asked one business jet pilot.
Gerald Naekel, president of GLN Compliance Group, an independent RVSM consultant based in Englewood, Colo., said the potential for delays facing new airplane buyers ranks near the top of the most pressing RVSM-related issues. 
“There needs to be some way for the FAA to allow buyers of new airplanes to fly away with RVSM approval, even if it’s just a 60-day exemption until the paperwork can be approved,” he said. “Otherwise this is going to be a really problematic issue for airframe manufacturers.”
Naekel’s company so far has helped operators of more than 400 business jets obtain LOAs, but this is just a small portion of the total number of aircraft that have to be approved.
According to the FAA’s own estimates, some 4,000 business aircraft have not been granted an LOA, out of a total of about 9,100 U.S.-registered business airplanes.Naekel said avionics installers are currently as many as four months behind in performing installation work, adding that a significant bottleneck at the end of the year is likely–just when many FAA employees are taking vacation.
“I would say that about 85 percent of all the FSDOs are doing a very good job with RVSM,” said Naekel. “Some offices are acting very slowly, and in some cases there may actually be an issue with an individual inspector. But the real test is still ahead of us. December is typically not the time you want to try to get things done with the FAA.”

Two Sides to Every Story
Some people consider Roy Grimes one of the founding fathers of RVSM. He was the FAA’s RVSM program manager when the rules went into effect over the North Atlantic in 1997, and he has assisted the agency every step along the way since, most recently in his current role as a consultant with CSSI, a technical and engineering services company based in Washington, D.C.
In an interview, Grimes said there have been instances when FSDOs and local FSDO inspectors have needed assistance in certain areas to get up to speed with RVSM, and CSSI has tried to provide that help. In other cases, the problems have had more to do with the operators themselves, usually in cases when the correct data was not submitted. 
“Some of the complaints about the FSDOs are legitimate, and our approach is to try to mitigate the problems, however possible,” Grimes said. “Oftentimes you get a complaint from an operator and you look into it and there is actually a problem with what the operator has done. And so the FSDO’s response is, ‘We told him we needed this and we don’t have it,’ and then suddenly they are at an impasse.” 
Grimes pointed out that there are generally two sides to every story, and that sometimes the problem is on the FSDO side and other times it is the fault of the operator, or it could be a combination of factors. The FAA and CSSI, he said, have tried to ease the pain for all the parties involved, most visibly through a series of RVSM seminars hosted throughout the country in the last two years that help operators get started on the path to approval. The next (and possibly final) RVSM seminar will be held before the NBAA Convention in Las Vegas on October 11.
“We have established what I think is a pretty good network to aid FSDOs and inspectors when it is needed,” said Grimes. “We have points of contact with each of the FSDOs, and if operators or inspectors have questions the best place to find the answers is the FAA’s DRVSM Web site” at www.faa.gov/ ats/ato/rvsm1.htm. 
In interviews for this article, pilots, aircraft operators and consultants mentioned the FSDOs in Baton Rouge, La.; Fort Lauderdale, Fla.; Miami; Riverside, Calif.; and San Antonio as being among the most difficult to deal with on RVSM issues. Grimes said FSDOs that have performed international RVSM approvals in the past might be able to do a better job than an office that has done few or no approvals, but he could not comment on the performance of specific FSDOs or inspectors. 
NBAA, meanwhile, has developed an RVSM template for Part 91 operators to help them put together a manual that they can submit to their FSDO, said Cotti. The effort has helped standardize RVSM approval criteria and streamlined the process for operators and inspectors. Asked whether he thinks RVSM approval delays will ease as operators and FSDOs become more familiar with the process, Cotti said the opposite will probably be true.
“The closer we get to January, the more applications are going to come in, and I think we will probably suffer some type of a bottleneck,” Cotti said. “For those FSDOs that are still a little behind the power curve, the delays that operators experience could continue to be quite lengthy.”    

DRVSM Training Fit for a King
King Schools, famous for its folksy, easy-to-understand pilot-training video courses, has developed an online, one-hour training program to satisfy the DRVSM training requirement. “The FAA requires a certificate of training from a creditable organization,” said company co-founder John King, “and we certainly qualify.”
San Diego-based King Schools has been providing training videos since 1984. In the past decade, King Schools has sold more than 2.5 million video courses, ranging from private pilot to ATP.
The $199 (volume discounts available) RVSM program is King Schools’ first exclusively online course. The pilot signs on and views a series of bite-size information pages on RVSM, its requirements and approved procedures. For example, if onboard altimeters do not agree, there is an approved checklist for pilot/crew action. The King program provides the needed information and then follows up with a series of question-and-answer sessions for the candidate to complete. Incorrect answers are reviewed and clarified. There are no video segments, only text, graphs and illustrations.
At the end of the session, which King said should take about an hour, the candidate fills out an online certificate and prints it for submission to the FAA. He said, “Our specialty has been to convert complex bureaucratic language into simple terms. We try to keep it simple. We know our job is done when the program is easy and fun to complete. Could a flight department develop its own program? Sure, but its syllabus might need to be approved by the FAA since it does not come from ‘a creditable training organization.’”
The King Schools program focuses on North American domestic RVSM and does not address RNPs, MNPS, North Atlantic tracks and other issues related to international operations. “There are some international elements, such as what to do if you are beyond voice-communication range and are uncertain of your altitude,” said King.But, he said, the course is kept simple by not tying itself into elements that are fundamental to existing RVSM training programs, such as North Atlantic Track procedures.
King Schools introduced the DRVSM training course in May at Aviation Industry Week in Las Vegas.