More Work Needed on Ground Vehicles AC

 

ACI-NA Raises Concerns on FAA Ground Vehicle Operations Draft Circular

Introduction

As you may have seen, earlier this month the FAA issued a draft of revised Advisory Circular (AC) 150/5210-20A, Ground Vehicle Operations and Mechanic Taxiing or Towing an Aircraft on Airports. As noted by the FAA in its Letter to Industry, "the AC provides guidance for ground vehicle operation plans promote the safety of airport users by helping identify authorized areas of vehicle operation, outlining vehicle identification systems, addressing vehicle and operator requirements, and coordinating construction, maintenance, and emergency activities."

One of the most significant proposed changes included in the draft AC is the extension of the AC's applicability aircraft being taxied or towed by persons other than certificated pilots (e.g., aircraft mechanics, ground service equipment operators). New provisions of the AC pertaining to what the FAA terms "mechanic taxiing or towing of aircraft" include:

  • Establishment of "adequate procedures for the safe and orderly operation of vehicles and aircraft that are taxied or towed by mechanics on the airside of the airport" including requirements that those taxiing or towing aircraft are able to read, write, and speak English, and that their vehicles/aircraft meet certain minimum equipment standards. 
  • Making the airport operator responsible for enforcement of new requirements relating to mechanic taxiing and towing operations via tenant lease or use agreements or other undefined means. These enforcement requirements include the establishment of "periodic checks to ensure that only properly authorized mechanics taxi or tow aircraft on the airside".  As defined in the draft AC, the airside includes both movement and non-movement areas.

Our Concerns

Although we understand the FAA's interest in assuring that mechanic taxiing and towing operations are performed safely, we are concerned that the draft AC shifts the responsibility for safety assurance from airlines and firms employing aircraft mechanics to airport operators. As or more importantly, we are concerned that the AC will create new legal and monetary liabilities for airport operators who have not previously been required by the FAA to regulate mechanic taxiing and towing operations.

We strongly believe that these issues need to be given more significant consideration before the FAA issues its final AC. We also believe that there needs to be much more significant consideration of how the safety oversight and compliance roles of FAA's Flight Standards Division--which is currently responsible for the safe operation of aircraft--including aircraft operated by mechanics--and FAA's Office of Airports will be distributed.

What ACI-NA is Doing

ACI-NA is preparing comments regarding the draft AC for submittal to the FAA prior to the FAA's April 18, 2014 deadline for comments. We encourage airport members to review the draft AC and submit your own comments either directly to FAA or through ACI-NA.

The FAA has requested that commenters submit their comments in this tabular form for ease of FAA review. Comments submitted directly to FAA should be sent electronically to Freddie James (freddie.james@faa.gov) at FAA Headquarters.

Comment that you would like to have included in ACI-NA's consolidated response should be sent to Paul Eubanks no later than April 16, 2014.

Points of Contact

Please contact Chris Oswald  or Paul Eubanks if you have questions, comments, or need additional information regarding this topic.


This message has been distributed to the members of the Operations & Technical Affairs, Public Safety & Security, Legal Affairs, Risk Management, and Small Airports committees.