RVSM: myths, money and reality check
Admittedly, there are a few serious concerns regarding the implementation of RVSM on January 20. However, when you talk to a lot of operators and MROs about it, you begin to recognize that most people aren’t as upset by it as conventional wisdom would have you believe. What you do discover is a lot of misunderstanding and a certain amount of hyperbole.
The late Sen. Everett Dirksen (R-Ill.) was believed to have once said, “A billion here, a billion there, and pretty soon you’re talking about real money,” so it’s important to realize that it’s a bit too easy to talk about spending someone else’s money. The operator’s costs involved with preparing for RVSM are not inconsequential, but then flying any turbine aircraft is hardly an inexpensive venture. Take, for example, the owner of a Learjet 23 who talked to AIN.
He kept peppering the conversation with, “It’ll cost me more to set this aircraft up for RVSM than it’s worth,” “I’ll be out of business either way because if I don’t do it I can’t fly the airplane,” and “What was the FAA thinking when it came up with this ridiculous idea?”
The truth of the matter isn’t quite as dramatic as the claim. To set the record straight, the FAA didn’t come up with the RVSM idea–ICAO did, and the FAA is actually lagging most of the world in implementing it. Europe, the Atlantic and the Pacific already require RVSM operation. The Americas go online January 20, nearly seven years after RVSM began over the Atlantic Ocean.
Butting heads once more with the FAA’s official reluctance to let employees talk freely to the press, AIN talked to an anonymous FAA source who has significant knowledge of the RVSM program. “First of all, anyone can operate at or below FL280. We didn’t launch into the RVSM program without a lot of thought up front regarding the economics of it,” he told AIN. “We have no desire to put anyone out of business. In fact, the FAA did an analysis of the cost of operating at FL280 compared with FL350.”
He said the FAA used NBAA’s estimated average domestic flight time of 1.4 to 1.7 hours for business jets in its computations. The agency discovered that aircraft operating at FL280 with long-range cruise power would actually, in some cases, save fuel in that time/distance frame over normal cruise at FL350. “And here’s the kicker, when you run the numbers you’re only looking at about an extra 15 minutes of flight time,” he emphasized.
The FAA source went on to say that, in his experience, today’s average top figure for an RVSM solution is about $150,000. “You keep hearing $250,000+ talked about, and that was true a couple of years ago because air data computers were running $100,000 each, but now you can do them both for about $150,000, assuming you’re operating an aircraft that doesn’t have one to begin with,” he said. “It’s true that older analog aircraft are going to be more expensive to modify, but the value of a good-condition Lear 23/24 these days is in the $500,000 to $600,000 range, so it’s pretty clear the airplane is worth more than the solution. Nevertheless, it can still be operated cost-effectively without RVSM approval.”
He also said aircraft already equipped with RVSM-compatible equipment can be approved for as little as $15,000. “Another little-known fact is that there is a provision to allow non-RVSM-equipped aircraft operating in U.S. airspace to climb through RVSM airspace to above FL410, where they can also operate,” he said. The catch is that ATC has to determine that traffic flow at the departure and destination points will allow it, so a pilot cannot bank on being able to climb through.
The length of time to get approval is yet another thorny issue. Bruce Buchanan, vice president of operations for Owensboro, Ky.-based MidAmerica Jet, said he requested the initial pre-application meeting with the Louisville FSDO this past January 20, 12 months in advance of the DRVSM deadline.
“We got no response for 60 days,” he said. “Finally, after several telephone calls, we were advised by the FSDO it would be next to impossible to get the three required inspectors together in a meeting at one time,” Buchanan said. “They asked us how comfortable we were with what it takes to put the package together and submit it. We said we felt pretty good about the process, so we were advised to just go ahead and do it. We submitted the application on March 18, and as of July 6 the FSDO had still not opened the application for review! The problem is our FSDO has such a heavy workload that the inspectors simply can’t get to it, but when I talked to them on July 6 they told me our application was ‘on the front burner.’ I don’t blame the FSDO, but I do think the FAA has taken a very hard stance about January 20 and it’s not being flexible.” One of Buchanan’s aircraft, a Mitsubishi Diamond (S/N 10) isn’t projected to have an RVSM solution available until August.
Scheduling a monitoring flight is also one of the problems. The FAA source said, “The system is such that once the aircraft is certified with an STC, Service Bulletin or a flight manual entry from the factory, most of the process is done. You show your paperwork to the FSDO, show them your RVSM maintenance program, which can be only a few pages long, and your training program and you can be approved. What people don’t seem to understand is that you can start flying your airplane because you don’t have to do a monitoring flight for up to six months after the January 20 implementation date if you’re going to fly only domestic RVSM. Even if you fly international, you have a six-month grace period starting the day you received authorization.”
RVSM Application Quagmire
The other issue that keeps coming up is who should shepherd the RVSM application. “It’s not rocket science,” the FAA source stressed. “You can go to the FAA’s Web site [www.faa.gov/ats/ato/rvsm1.htm] and everything you need to know is there. The thing is, you’re going to spend some time wading through all the material. If you’re United Airlines and you have two or three full-time staff members dedicated to RVSM, that’s fine. More likely, if you’re going to do it yourself you’re going to do it in between flying the airplane, doing other paperwork, training and a host of other things. Does that make sense?”
John Leder, manager of aircraft maintenance at Richmond, Va.-based Dominion Resources, takes care of a Gulfstream IV-SP and three Hawker 800XPs. He said, “I kind of stuck my feet in the water by renewing the LOA for the Gulfstream; it has to be done every two years. It went pretty smoothly so we decided we’d take the GIV-SP manual and adapt it to the Hawker. Well, that worked OK, too, and then the second Hawker went really easily. The Richmond FSDO was very helpful. Overall, I’d say it’s been a pretty good experience, and I’m not complaining at all, but make no mistake, there’s a learning curve.”
Danny Wright, president of D&D Aviation in Marietta, Ga., said, “I think there are quite a few operators that have the ability to do this on their own, but we’ve gone through this process all over the world and the reality is that no two approvals are ever quite the same. It’s a very time-consuming process and the guidance material is complicated at best.”
Wright also stressed that there’s the human element involved: “I can tell you with certainty that the process in Tampa will be different from the one in Milwaukee, which will be different from the one in Van Nuys, California. Expertise is a large part of the successful equation. You might eventually get the job done on your own, but at what cost? Using someone who does this every day will save you time and money in the long run.” D&D has facilitated more than 1,900 RVSM approvals since the program began in 1997, including the very first RVSM approval, which was for a Falcon 900.
Marcelo Casenove, supervisor of avionics/electrical support for Cessna Aircraft, said two years ago his company developed a group to support its customers’ RVSM needs. “We’ve done more than 750 data packages and more than 800 GMU (ground monitoring unit) flights to gather the required statistical data. I have to think we should have a handle on the process,” he said. “We’ve dealt with just about every FSDO, with a great deal of success in getting approvals. That track record and the resources we have at our disposal because we’re the OEM are a definite benefit to the operator, and the feedback we’ve received from FAA supports that opinion. If you go it alone you’re starting from scratch. What’s the point? There’s a learning curve in the process, and we’ve been doing it for quite a while now.”
Al Cipo, RVSM services administrator for Cessna’s Citation fleet, said, “We should be able to save a client at least a month’s time by doing the work for them. One FAA inspector wrote us saying, ‘The document package was the most complete and workable one I’ve received.’ It really doesn’t make a lot of sense to go it alone. We’re able to get an LOA in only a few business days in an environment where it’s not uncommon for the process to take months.”
By far, the majority of comments AIN heard reflected the thought that it’s a significant expense but it’s a justifiable one. Also, people said the FSDO personnel have been very cooperative and helpful, though often heavily overworked and not always in agreement with one another on exactly how things should be done.
Ironically, and perhaps intentionally, the deadline for domestic RVSM is January 20 at 0901 UTC. Perfect timing–all of the FAA’s top personnel will be out of the office the day RVSM goes in effect since they’ll be attending the Presidential inauguration.