AC 91-70D

Advisory circular · Oceanic and Remote Continental Airspace Operations

Approved
April 3, 2025
Last reviewed
April 9, 2025
Cancels
AC91-70C
Family
AC 91-70 · 6 versions
Revision
D
14 CFR parts
91, 119, 121, 125, 135

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 37–48

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• Improper execution of contingency procedures.

• Turbulence encounters.

6.1.2.1.2 Data indicates that a majority of crew-related errors involve misinterpretation or misapplication of “conditional clearances.” Conditional clearances improve the efficient utilization of airspace, allowing ATC to assign altitudes that enable lower fuel burn. Event reports from ATC and flightcrews indicate that pilots misapply terms in the clearance such as “BY” or “AT,” terms which have completely different meanings. See Table 6-1 below for examples of incorrectly applied conditional clearances.

Table 6-1. Examples of Incorrectly Applied Conditional Clearances

CLEARANCE CREW ACTION CORRECT ACTION Via CPDLC at 1714, crew conditionally cleared, “maintain F340, at 1725 climb to and maintain F360, climb to reach F360 by 1735, report level F360, due to traffic.”

Crew initiated climb early, reported (ADS-C) passing F354 at 1721.

Crew should have delayed commencing climb until 1725 and planned to reach F360 before 1735.

Via CPDLC, crew at F380, cleared to cross 66N040W at F390, report level F390.

Crew commenced climb to F390 at 40W (Mode C).

Crew should have initiated climb prior to 40W in order to cross 40W at F390.

Via CPDLC at 1945, crew cleared maintain F330, at 1952 climb to and maintain F350, climb to reach F350 by 1957, report level F350.

Reported (ADS-C) level at F350 at 1948.

Crew should have delayed commencing climb until 1952 and planned to reach F350 before 1957.

Crew cleared 68/40 64/50 IRBIM F360 M083 via HF voice, crew recleared to descend after passing 65N to be level F340 before 64N.

Crew commenced descent at 6529N/4650W.

Crew should have initiated descent after passing 65N and levelled at F340 prior to 64N.

Crew cleared 66/30 65/40 63/50 IRBIM LOMTA F400 M081. Via CPDLC, crew cleared climb F410 to cross 65/40 level.

Crew failed to climb as cleared and crossed 65/40 at F400 (ADS-C).

Crew should have initiated climb prior to 65N in order to cross 65N at F410.

6.1.2.1.3 Your training program should provide your flightcrew with procedures that ensure all ATC clearances are complied with correctly, particularly clearances with en route restrictions, such as changing flight levels (FL) based on a coordinated time or a specific geographic position.

6-3 Note: Per ICAO NAT Doc 007, North Atlantic Operations and Airspace Manual, when flying in North Atlantic High Level Airspace (NAT HLA), if your aircraft is not using Controller-Pilot Data Link Communications (CPDLC)/Automatic Dependent Surveillance-Contract (ADS-C), you must immediately report to ATC both when leaving and reaching a new FL. Doing so can enable the controller to identify and intervene when you have misunderstood or misapplied your conditional clearance.

6.1.2.2 Gross Navigation Error (GNE). The FAA defines GNEs as lateral deviations from course of 10 nautical miles (NM) or greater.

6.1.2.2.1 The majority of today’s GNEs arise from pilots flying a very precise track to the wrong position because they failed to properly update their navigation system to reflect their currently effective route clearance. This can also result from a clearance or revised clearance that was incorrectly entered, misread, or misunderstood. Procedures to follow in the event of a revised clearance are included in paragraph 6.4.1.6. Examples of scenarios that have led to GNEs are:

1. Poor management of the Master Document, resulting in crews not knowing the currently effective route clearance.

2. Incorrect waypoint entry procedures, particularly if the waypoints are not named and flightcrews must enter the full latitude and longitude.

Note 1: We use the term “currently effective route clearance” to describe what ICAO Annex 2, Rules of the Air, refers to as the “current flight plan,” or the most recently issued ATC clearance.

Note 2: Waypoints entered via full latitude and longitude can produce misleading display names, with truncated or rounded minutes of latitude/longitude or longitude. For example, the two points listed in Table 6-2 below could have identical avionics display names:

Table 6-2. Selected Waypoint Entry Methods and Avionics Display ATC Flight Plan Entry Geographic Coordinates Avionics Display24 5530N02000W (11 characters, degrees & minutes) N55°30'/W020° N55W020 55N020W (7 characters, degrees only) N55°/W020° N55W020

24 Avionics displays vary by manufacturer. Some produce a generic name (e.g., “LL01”). Using the ARINC 424 rules (see Figure 6-2, ARINC 424—Oceanic Waypoints, below), the half-degree of latitude and whole-degree points in Table 6-2 would be H5520 and 5520N, respectively.

6-4 Note 3: Pilots should therefore always confirm the expanded coordinates of undesignated significant points (i.e., unnamed waypoints defined by geographic coordinates).

6.1.2.2.2 GNEs also result when the aircraft navigation mode is actually different from that assumed by the crew. This scenario typically occurs when the crew fails to return the flight guidance system to an Area Navigation (RNAV) mode

(e.g., “LNAV”) after using heading mode (e.g., “HDG”) to maneuver the aircraft.

6.1.2.2.3 Although there are a number of causes of GNEs, pilot inattention has been the root cause of many navigational errors. ICAO NAT Doc 007 guidance on guarding against common errors provides excellent lessons learned from evaluation of GNE incidents.

6.1.2.3 Longitudinal Errors. Longitudinal errors, in the form of failure to provide updated estimated times of arrival (ETA), are another common navigation error and one that is easily preventable.

6.1.2.3.1 Deviations around weather can affect ETAs. ICAO Annex 2 requires you to provide ATC with an updated ETA when weather deviations cause the originally notified ETA to be inaccurate.

6.1.2.3.2 Per ICAO Annex 2, you must adhere to any assigned Mach number or airspeed. If you use Long Range Cruise (LRC) or Economy (ECON) modes, you are operating in a constantly changing speed mode. Flying in these modes may not be compatible with maintaining a fixed ATC speed assignment.

6.1.2.3.3 When position reports are made by voice, ICAO Annex 2 requires you to report to the Air Traffic Service (ATS) any change to your ETA in excess of 2 minutes, both for your initial oceanic entry point as well as all required reporting points along your route of flight. (In the NAT region, the allowance for revised estimates is “3 minutes or more.”)

6.1.2.3.4 Discrepant wind data can result in inaccurate ETA computations. This can be particularly problematic if you are not flying at the flight-planned altitude or have outdated winds loaded in your navigation system. You must diligently monitor your ETA and maintain your assigned Mach number in order to minimize these errors.

6.1.2.3.5 Navigation system-computed ETAs, particularly for more distant waypoints, may be erroneous due to down track wind conditions, which the navigation system is not presently using to compute the ETA. You should compare navigation system estimates with the ETA calculated using the operational flight plan prior to reporting the ETA to ATC.

6.1.2.3.6 Automatic position reports delivered via ADS-C have greatly reduced the occurrence of longitudinal errors caused by inaccurate ETAs. ATC establishes

6-5 an ADS-C periodic report interval appropriate for the longitudinal and lateral separation criteria being used. More frequent reports compensate for wind discrepancies and provide ATC with accurate ETAs.

6.2 Flight Plan.

6.2.1 ATC Flight Plan.

6.2.1.1 ICAO Annex 2 requires you to file a flight plan for any flight that crosses international borders. Instrument flight rules (IFR) operations in oceanic airspace generally start at 6,000 feet. Visual flight rules (VFR) operations at or below 5,500 feet must comply with all applicable regulations and foreign airspace requirements.

6.2.1.1.1 Even though you may legally conduct flights in oceanic and remote continental airspace under VFR, you will likely encounter instrument meteorological conditions (IMC) at some point in your flight.

6.2.1.1.2 We therefore recommend that you file and fly under IFR on all oceanic flights.

6.2.1.2 Proper completion of an ATC flight plan relies on detailed knowledge of the airspace you intend to transit, the airspace equipment requirements, and the required FAA operational authorizations. You also need to be thoroughly familiar with the equipment your aircraft has on board as listed in your filed flight plan. When you file, your flight plan is transmitted to ATS facilities along the route of flight. If you do not file correctly, you could possibly experience delays before takeoff for an issue with an ATS authority along your route of flight.

6.2.1.2.1 The Aeronautical Information Manual (AIM) and the U.S. Aeronautical Information Publication (AIP) have step-by-step descriptions detailing how to complete FAA Form 7233-4, Pre-Flight Pilot Checklist and International Flight Plan.

6.2.1.3 As Performance-based Navigation (PBN) and Performance-based Communication and Surveillance (PBCS) become more prevalent worldwide, ATS authorities will increasingly set aside certain airspace for compliant aircraft. You list your aircraft and crew capabilities using descriptors in items 10A, 10B, and 18 of the flight plan.

Note: Without the proper codes or remarks identifying the operational approvals of your crew and aircraft, controllers may deny you en route climbs to your most fuel-efficient FLs or access to the optimum routings, or, in some cases, may reject your flight plan entirely.

6.2.1.4 Title 14 CFR part 121 dispatch services have staff knowledgeable in all filing requirements for both domestic and international operations. These services

6-6 can support flight plan reroutes that may arise due to weather or congestion along the route of flight. Regardless of whether you are operating with a dispatch service, you must comply with 14 CFR § 91.103, which requires pilots to “become familiar with all available information” concerning a flight.

Pilots should have the knowledge and necessary tools available to react to unplanned reroutes, equipment failures, or emergencies that may affect a flight while en route. Operators using commercial vendor flight planning services remain responsible for all aspects of the flight.

6.2.2 Equipment Capability Codes—Flight Plan.

6.2.2.1 PBN and PBCS are changing the way ATS Providers (ATSP) apply separation criteria between aircraft. Without notifying the crew of either aircraft involved, ATSPs in “mixed mandate” airspace can reduce separation between aircraft based on your stated capability. In order to take advantage of opportunities for more efficient routings, your flight plan should reflect the lowest (i.e., the best) Required Navigation Performance (RNP), Required Communication Performance (RCP), and Required Surveillance Performance (RSP) values for which you are capable and authorized. You must only use codes for equipment that is installed and operable. Similarly, you must only use capability codes that reflect your actual authorizations, when authorization is required. You must have a B036 authorization to indicate RNP 2 (oceanic/remote), RNP 4, or RNP 10 capability on your flight plan.25 Conversely, 14 CFR part 91 operators do not require an authorization to indicate RNAV 1 or 2 capability.

25 Regulatory reference is 14 CFR § 91.169, which refers to 14 CFR § 91.153. This requires the flight plan to include “any other information the pilot in command or ATC believes is necessary for ATC purposes.” The U.S. Aero nautical Information Publication (AIP) states that pilots must “advise ATC” if equipment failures render the filed capability indicators inaccurate.

6.2.2.2 The abse nce of equipment or capability codes in your flight plan (e.g., for RNP, RSP, RCP, ADS-C, Automatic Dependent Surveillance-Broadcast (ADS-B), CPDLC, Reduced Vertical Separation Minimum (RVSM), etc.)

informs ATC that your aircraft is either not equipped with or authorized to use such capabilities. The presence or absence of equipment and capability codes affects route and altitude assignments, as well as separation differences with other aircraft. You should ensure your flight plan reflects all the codes, as per flight plan guidance in the AIM, applicable to your aircraft equipment and authorizations.

6.2.2.3 The RNAV/RNP, RCP, or RSP capability indicated on your flight plan must not be better than that for which you have been approved via an operational authorization, as applicable. For example, if you have only been approved for RNAV/RNP 10 (code A1), you must not indicate RNP 4 capability (code L1).

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6.3 Aircraft Preflight Guidance.

6.3.1 Preflight—Necessary Documents. Effective oceanic and remote continental airspace flight planning and execution requires a number of important pieces of information. You should ensure you have easy access to the following documents/information in the cockpit, as well as others that may be pertinent to your flight:

6.3.1.1 Master flight plan (“Master Document”).

Note: Use strict procedures to manage the Master Document. Maintain only one operational flight plan labeled “master” in the cockpit.

6.3.1.2 Notices to Airmen (NOTAM) for departure, destination, alternate(s), Extended Operations (ETOPS) alternates (as applicable), and applicable flight information regions (FIR).

6.3.1.3 Global Positioning System (GPS) NOTAMs. Select “GPS NOTAMs” in “Predefined Queries” under “Location” (as applicable).

6.3.1.4 Weather for departure, destination, alternate airports along the route of flight, and ETOPS alternates (as applicable).

6.3.1.5 Significant Weather (SIGWX) chart.

6.3.1.6 Wind charts for planned altitudes and altitudes after driftdown/emergency descent.

Note: Compute Equal Time Points (ETP) for contingencies, such as medical divert, engine loss, rapid decompression (RD), and a simultaneous RD and engine loss. Note the location of the ETPs on your plotting/orientation chart.

6.3.1.7 Space weather: solar flare information (refer to the National Oceanic and Atmospheric Administration’s (NOAA) website at https://www.swpc.noaa.go v/forecasts).

6.3.1.8 Volcanic ash information (as applicable).

6.3.1.9 Pilot Weather Reports (PIREP).

6.3.1.10 Receiver autonomous integrity monitoring (RAIM) and fault detection and exclusion (FDE) prediction tools (for Global Navigation Satellite System (GNSS) and RNP operations), available at https://sapt.faa.gov/default.php.

6.3.1.11 Current track message (for any operations in airspace with a flexible organized track system (OTS)).

6-8 Note: If you have a track message or other separate route document associated with the flight, verify that the effective time of the message corresponds to your flight and that the designated route agrees with both your filed routing and the waypoint routing on your Master Document.

6.3.1.12 Plotting/orientation chart.

6.3.1.12.1 You should use an oceanic plotting/orientation chart, of appropriate scale, and with latitude and longitude depicted, to provide a visual presentation of your intended route, regardless of your type(s) of long-range navigation system (LRNS) and method of cross-checking aircraft position. Plotting your route on a chart helps with situational awareness, and (together with the operational flight plan) also helps with navigation contingencies such as dead reckoning, in the event of navigation system degradation/failure.

6.3.1.12.2 Your chart should include, at a minimum:

1. The route of your filed flight plan. If your cleared route differs from what you filed, your currently effective route clearance.

2. Clearly depicted waypoints using standardized symbology.

3. All ETPs, plotted on the chart (with relation to the route).

4. Alternate airports.

5. Other adjacent/nearby tracks.

6.3.1.12.3 Figure 6-1 shows a sample plotting chart for an eastbound flight on a random route in the NAT at FL 410. Note that the westbound tracks are plotted north of the route of flight, for situational awareness.

6-9 Figure 6-1. Sample Plotting Chart Note : For certificated operators, if you hold the A061 authorization authorizing use of an EFB, the principal inspector (PI) can authorize “interactive plotting for oceanic and remote continental navigation,” ensuring the EFB application fulfills plotting/orientation chart requirements listed in paragraph 6.3.1.12. With this authorization, you can use your EFB application in place of a paper plotting/orientation chart. AC 120-76, Authorization for Use of Electronic Flight Bags, provides guidance for operators to develop associated EFB procedures.

Title 14 CFR part 91 operators may use an EFB, provided they observe the criteria and considerations of AC 91-78, Use of Class 1 or Class 2 Electronic Flight Bag (EFB).

6.3.2 Cockpit Preparations.

Note: These procedures assume at least two pilots are on duty. Some aircraft are certified for single-pilot operations. If your intended flight in oceanic or remote airspace can safely accommodate single-pilot operations, you should develop some methodology to check your clearance, waypoint entries, equipment setup, etc. It may be possible to involve non-flying crew in some checks, either prior to flight, or in flight, via appropriate voice and/or data communications.

Where such support is not available, single-pilot procedures should be carefully designed to detect and fix errors promptly, thereby minimizing or altogether preventing deviations.

6.3.2.1 Check your maintenance log to ensure all your required communications, navigation, and surveillance and altimetry equipment is operational.

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1. Consult your minimum equipment list (MEL) to be fully familiar with operational procedures associated with any inoperative equipment before you depart.

2. Inoperative equipment could affect the capabilities filed in the ATC flight plan. It is important to update the codes, as needed, to ensure ATC routes you in accordance with your capabilities.

3. A departure delay to accommodate repairs may be warranted.

Alternatively, a reroute to avoid oceanic airspace may be necessary.

6.3.2.2 Identify a single master clock in the cockpit.

1. Verify that your onboard primary time source, or master clock, is set to Coordinated Universal Time (UTC). In most cases, this time source is the FMS, which for some systems is automatically synced with GPS time.

Note: As clock errors can be symptoms of GPS spoofing, it is recommended to have a backup clock set to UTC that is not dependent on GPS.

2. Use master clock times for all ETAs and actual times of arrival (ATA).

6.3.2.3 Align your inertial navigation system (INS)/inertial reference system (IRS).

1. Proper INS/IRS loading and operating procedures are another important aspect to help you avoid navigation errors. Ensure you select navigation (NAV) mode at the appropriate time and properly manage your navigation computer during intermediate stops.

2. Carefully follow your inertial system flight manual procedures to ensure proper navigation reliability.

6.3.2.4 Have a second pilot independently verify the aircraft present position coordinates you have loaded in your navigation system.

1. Both pilots should verify the present position in the LRNS. Aircraft maintenance or towing can cause the present position suggested on initialization to be incorrect.

2. If you conduct another present position check on taxi out and it shows a gross difference from your gate coordinates, it could indicate a problem with the LRNS.

6.3.2.5 Two pilots should independently coordinate the loading and verification of all flight plan entries. One pilot should load the entire route into the LRNS, to include all waypoints, using the Master Document as source. That pilot should then verify the routing has been loaded correctly. Below are recommended steps for performing this loading and verification. The second pilot’s

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subsequent confirmation procedures are explained beginning in paragraph 6.3.2.6.

6.3.2.5.1 Prior to loading the flight plan, carefully cross-check the waypoint routing on your Master Document against your filed flight plan to verify both documents show the same routing.

6.3.2.5.2 Ensure your navigation database and FMS software version are current and correct.

6.3.2.5.3 For systems with pilot-defined waypoint designators or numbers, we recommend you use a consistent procedure. Enter this designator on the Master Document and use it to store waypoints in the navigation computer.

Figure 6-2 depicts sample waypoint designators using rules published in ARINC 424 Specification, Paragraph 7.2.5, Reporting Positions Defined by Coordinates.

Figure 6-2. ARINC 424Oceanic Waypoints North Latitude and West Longitude North Latitude and East Longitude 50N 160W 50N 060W 50N 060E 50N 160E 50N60 5060N 5060E 50E60 50 30N 160W 50 30N 060W 50 30N 060E 50 30N 160E 5N060 * H5060 E5060 5E060 Hxxyy introduced in A424-23, published July 8, 2022 0° South Latitude and West Longitude South Latitude and East Longitude 50S 160W 50S 060W 50S 060E 50S 160E 50W60 5060W 5060S 50S60 50 30S 160W 50 30S 060W 50 30S 060E 50 30S 160E 5W060 W5060 S5060 55060 0° Whole Degree Latitude Waypoints ½ - Degree Latitude Waypoints Note: ARINC 424 names can be used for "undesignated waypoints" where ATC has not established five-letter name codes (e.g., HOIST). For undesignated points, 6-11

6-12 t he proper latitude/longitude format for ATC flight plans and communications with ATC is shown in Table 6-2 above.

6.3.2.5.4 Verify all navigational information contained in the Master Document against the navigation data information in the navigation system.

6.3.2.5.5 Your procedures should provide for a means of verification of the data you loaded. You should check the expanded coordinates and course/distance between waypoints against the same information on your Master Document.

You may also check the route presentation on your navigation display. Most long-range aircraft have a navigation system that is capable of uplinking flight plans sent from ATC and/or from a dispatch service, either prior to departure or while airborne. These uplinks can normally be added to the active route via a “push-to-load” function, but there are occasional glitches in the associated “functional integration” that can require you to make changes to complete the route load. Regardless of how you load your flight plan into your navigation system, you should have procedures to verify your flight plan route against your navigation system entries.

6.3.2.6 After the first pilot has loaded and verified the navigation system entries against the flight plan, a second pilot should recall and confirm the waypoint data against source information.

6.3.2.6.1 It is not sufficient for one crewmember simply to observe another crewmember entering the data. You should use an independent cross-check method between pilots so no navigation system entry goes unverified. An attitude of “healthy suspicion” can facilitate good cross-checks.

6.3.2.6.2 Cross-checks should include comparing the expanded coordinates of the waypoints loaded in the navigation system to the filed flight plan, track message (if applicable), and the Master Document.

6.3.2.6.3 Verify the total route distance in your navigation system against your Master Document to help find gross errors. More importantly, cross-check course/headings and distances between each waypoint to ensure the navigation system routing matches your Master Document. Referencing your plotting or orientation chart here can also be beneficial.

6.3.2.6.4 A 1-degree course deviation causes the aircraft to be off planned routing by approximately 1 mile every 60 miles of travel. A course deviation on an oceanic crossing closer to the Equator, where leg lengths are typically longer, can result in cumulatively larger displacements from course. However, although leg lengths are typically shorter at higher latitudes, and similar deviations result in cumulatively smaller displacements from course, the density of traffic and closer spacing of parallel tracks at high northern latitudes actually constitute an environment less tolerant of course deviations.

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6.3.2.6.5 The second pilot should work from the navigation system back to the Master Document (i.e., by reading what is in the navigation system, and comparing that with what is in the Master Document). Reading from the Master Document to the navigation system can result in “seeing what we expect to see” (expectation bias). A simple way to consider this is that the first pilot works from “paper to glass” while the second pilot works from “glass to paper.”

6.3.2.7 Adopt appropriate annotations to indicate the status of each waypoint listed on the Master Document. For example:

1. The first pilot could put a circle next to the waypoint, waypoint number, or symbol on the Master Document to signify that they have independently cross-checked the entry of the coordinates in the navigation computer.

2. The second pilot could then tick or diagonally slash the circle next to the waypoint, waypoint number, or symbol to signify having performed the cross-check described above, to include confirming the course and distance information within a specified tolerance (e.g., plus or minus 2 degrees and 2 NM).

6.3.2.7.1 We discuss additional Master Document symbology in the en route section, in paragraph 6.4.

6.3.2.8 Set the appropriate mode select secondary radar with data link (Mode S) flight identification (FLT ID), which should correspond verbatim to the Aircraft Identification (ACID) (call sign) entered in item 7 of the ATC flight plan.

6.3.2.8.1 ATC systems worldwide are becoming more reliant upon information transmitted by Mode S transponders to manage air traffic. ATC systems use transmitted FLT IDs to uniquely identify each aircraft within a given airspace and correlate them to a filed flight plan for the provision of surveillance and separation services.

6.3.2.8.2 An FLT ID is composed of a maximum of seven alphanumeric characters

(e.g., N235RA, AAL3342, BONGO33) and must agree, verbatim, with the ACID entered in item 7 of the ATC flight plan.

6.3.2.8.3 You typically enter your FLT ID through either an FMS interface or your transponder control panel. For ATC systems to function correctly, you must ensure the FLT ID you enter in the FMS exactly matches the ACID in item 7 of the ATC flight plan.

6.3.2.9 Check your groundspeed in the blocks and on taxi out.

1. If you are still in the blocks and your groundspeed reads other than zero, you may have a developing error in your LRNS.