July 31, 2024
An FAA proposal to revamp certain terminologies, procedures and authorizations for operations in oceanic and remote continental airspace ahead of the Aug. 16 deadline for public comments was the topic of a recent NBAA News Hour webinar.
“Revamping the Skies – Redefining International Airspace Lingo, Protocols and Authorizations” focused on changes proposed in draft Advisory Circular (AC) 91-70D, specifically the adoption of two new terms: Remote Continental (RemCon) and Remote Oceanic (RemOce). Review the draft 91-70D.
These address special authorizations, operational specification (OpSpec) and letters of authorization (LOA) for flying in areas where where certificated operators (Part 91K, 121, 125 or 135) are unable to obtain a “reliable fix” from a ground-based navigational aid at least once each hour.
RemCon applies to flights within 50 nautical miles of shore, while RemOce covers ops greater than that distance. A third term, Dom/Con, applies to flights where operators can secure reliable fixes more than once per hour.
Kevin Kelley, FAA aviation safety inspector and the agency’s primary author on AC 91-70D, noted the changes are intended to streamline and clarify definitions for several related terms. “The coexistence of the ‘oceanic remote continental’ generic term, the ‘Class 2’ term and the ‘reliable fix’ terms has created lots of confusion about exactly when an oceanic and or remote continental authorization is required,” he said.
The FAA notes B036 authorization is currently required for oceanic RNP operations. For certified operators, the new draft AC describes new B036 RemOce and RemCon authorization for flights at or above flight level 180, and a new B030 RemCon for flights under 18,000. Part 91 operators continue to need a B036 to indicate RNP at all flight levels in oceanic operations, while B030 is optional for RemCon at all flight levels.
While only the terms have changed – the underlying definitions remain the same – operators must be familiar with the new terminology as they will be used by FAA inspectors issuing LOAs.
Paul Scurio, CAM, vice-chair of the NBAA International Operations Committee and chief pilot at OC Sunbird Aviation, emphasized the importance of harmonizing terms in all aviation documentation to avoid confusion and enable operator compliance.
“One of the things that creates confusion from an operator standpoint is that sometimes we read different FAA documents that seem to contradict each other, because terms may be different,” he added.
Kelley acknowledged the proposed changes primarily represent an administrative change for most business aviation operators. “If your operations manual uses the title of the authorization, that title of the authorization has changed [but] the underlying framework didn’t change,” he added.
Panel moderator Brian Koester, CAM, NBAA director of flight operations and regulations, encouraged business aviation operators to thoroughly review the proposed AC 91-70D and comment ahead of the Aug. 16 deadline.
“It’s important to tell the FAA if you identify language that can be interpreted differently from what’s been described today,” he added. “This AC will be read by a lot of aviation safety inspectors and making sure the language is clear and concise can be very helpful.”
International Business Aviation Council Ltd.