AC 91-85A

U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum (RVSM) Airspace Date: 7/21/16 AC No: 91-85A Initiated by: AFS-400 Change:

This advisory circular (AC) applies to all Operators conducting Reduced Vertical Separation Minimum (RVSM) operations. The AC can be used to obtain an initial operational authorization, or amend an existing, operational authorization. The AC appendices include supportive information relating to RVSM airworthiness certifications, training programs, operating practices and procedures, RVSM operations in oceanic and remote continental airspace, and review of height-keeping parameters.

This AC describes acceptable means, but not the only means, for an Operator to obtain authorization to conduct flight in airspace or on routes where RVSM is applied. The advisory material contained in this AC has been substantially modified since the AC was issued in its original form in 2009.

ORIGINAL SIGNED by /s/ John Barbagallo Deputy Director, Flight Standards Service

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CONTENTS Paragraph Page

Chapter 1. Introduction1-1

1.1 What is the Purpose of This Advisory Circular (AC)?1-1

1.2 Who Does This AC Apply To?1-1

1.3 What Does This AC Cancel?1-1

1.4 What Regulations Apply to RVSM Operations?1-1

1.5 What Other Reading Material is Helpful to an Applicant?1-1

1.6 What Do Some of the Capitalized Terms Used in This AC Mean?1-2

Chapter 2. Authorization Overview2-1

2.1 Why are RVSM Authorizations Required, and How has the Authorization Process Changed Since RVSM Authorizations were Initially Implemented

on a World-Wide Basis?2-1

2.2 What are the Basic Technical Requirements Associated with Obtaining an

Appropriate RVSM Authorization?2-2

2.3 What are the RVSM Authorization Elements?2-2

2.4 What is the RVSM Authorization Matrix?2-2

2.5 What is a Summary of the Process Needed to Obtain a New RVSM

Authorization?2-4

Chapter 3. RVSM Authorization Elements3-1

3.1 What is the Background Behind Using the RVSM Authorization Elements to

Apply for an RVSM Authorization?3-1

3.2 What Do I Need to Know About RVSM-Compliant Aircraft?3-1

3.3 What Do I Need to Know About RVSM-Knowledgeable Pilots?3-2

3.4 Who is the Proper Party to be the Applicant for, and the Operator Under, an

RVSM Authorization?3-3

3.5 Who is a “Responsible Person,” and What Duties Does This Person Fulfill, Under

an RVSM Authorization?3-4

3.6 What Other Issues Should be Addressed by Applicants with Respect to Requests

for RVSM Authorizations?3-5

Chapter 4. Submitting an Application for RVSM Authorization4-1

4.1 What is the First Step an Applicant May Consider Taking When Applying for an

RVSM Authorization?4-1

4.2 What are the Applicable Steps and Information Required to Seek an RVSM

Authorization?4-1

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Chapter 5. FAA Review and Evaluation of RVSM Applications5-1

5.1 What is the General Process the FAA will Follow Upon Submission of the

Request for an RVSM Authorization or Amended Authorization?5-1

5.2 What are the Applicable Forms of the RVSM Authorization Documents?5-1

5.3 What are the Conditions That Would Require the Removal of an RVSM

Authorization?5-2

5.4 What Happens if I Change RVSM Equipment After Operational Authorization

has been Granted?5-3

Appendix A. RVSM Airworthiness CertificationA-1

Appendix B. Training Programs and Operating Practices and ProceduresB-1

Appendix C. Operations in Oceanic and Remote Continental AirspaceC-1

Appendix D. Review of ICAO Document 9574D-1

Appendix E. RVSM Authorization OverviewE-1

List of Figures

Figure 4-1. RVSM Decision Matrix4-3

Figure A.6-1. Example of Air Data System/Autopilot ConfigurationA-13

Figure A.6-2. Single Air Data Computer Configuration for Autopilot InputA-14

Figure A.8-1. Altimetry System Error and Its ComponentsA-18

Figure A.8-4. Static Source Error/Static Source Error Correction Relationships for Altimetry System Error Where Static Line, Pressure Measurement, and

Conversion Errors are ZeroA-22

Figure A.9-1. Process for Showing Initial and Continued Compliance of Airframe Static

Pressure SystemA-27

Figure A.9-2. Compliance Demonstration Ground-To-Flight Test Correlation Process

ExampleA-27

Figure A.9-3. Process for Showing Initial and Continued Compliance of Airframe Static

Pressure Systems for In-Service and New Model AircraftA-28

Figure C.1-1. Scenario 1C-2

Figure C.1-2. Scenario 2C-3

Figure C.1-3. Expanded Scenario 1C-4

Figure C.1-4. Expanded Scenario 2C-5

Figure C.1-5. Expanded Scenario 3C-5

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Figure C.1-6. Expanded Scenario 4C-6

Figure C.1-7. Expanded Scenario 5C-6

List of Tables

Table A.2-1. Full RVSM Envelope BoundariesA-5

Table A.8-2. Static Source ErrorA-20

Table A.8-3. Residual Static Source Error (Aircraft with Avionic Static Source Error

Correction)A-21

1-1 CHAPTER 1. INTRODUCTION

1.1 What is the Purpose of This Advisory Circular (AC)? This AC is not mandatory and does not constitute a regulation. This AC describes an acceptable means, but not the only means, for an Operator to obtain an initial operational authorization, or amend an existing operational authorization to conduct flight in airspace or on routes where Reduced Vertical Separation Minimum (RVSM) is applied. Additionally, this AC provides information on RVSM performance specifications, obtaining and maintaining RVSM airworthiness certification for aircraft, specific elements of an RVSM authorization, and policy and procedures for RVSM operations. RVSM airspace is any airspace or route between flight level (FL) 290 and FL 410 inclusive where aircraft are separated vertically by 1,000 ft (300 m).

1.2 Who Does This AC Apply To? This AC applies to operators who want to apply for authorization to conduct operations in RVSM airspace.

1.3 What Does This AC Cancel? This AC cancels AC 91-85, Authorization of Aircraft and Operators for Flight in Reduced Vertical Separation Minimum Airspace, dated August 21, 2009, which provided guidance on aircraft and Operator approval for operating in RVSM airspace.

1.4 What Regulations Apply to RVSM Operations? Title 14 of the Code of Federal Regulations (14 CFR):

• Part 43;

• Part 91, §§ 91.180, 91.411, 91.413, 91.705, 91.706, and Appendix G;

• Part 121;

• Part 125;

• Part 129;

• Part 135; and

• Part 145.

1.5 What Other Reading Material is Helpful to an Applicant?

• Federal Aviation Administration (FAA) Aeronautical Information Manual (AIM).

• FAA Order 8900.1, Flight Standards Information Management System (FSIMS) (http://fsims.faa.gov).

• FAA Documentation Web site:

http://www.faa.gov/air_traffic/separation_standards/rvsm/documentation/.

• International Civil Aviation Organization (ICAO) Document 4444, Procedures for Air Navigation Services, Air Traffic Management.

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• ICAO Annex 6, Operation of Aircraft, Part I—International Commercial Air Transport—Aeroplanes and Part II—International General Aviation—Aeroplanes.

• ICAO Document 7030, Regional Supplementary Procedures.

• ICAO Document 9574, Manual on Implementation of a 300 m (1000 ft) Vertical Separation Minimum Between FL 290 and FL 410 Inclusive.

1.6 What Do Some of the Capitalized Terms Used in This AC Mean? For the purposes of efficiency and consistency, when the various capitalized terms below are used in this AC, then they have the following meanings. Or you can find their meanings in the paragraphs specifically mentioned in the definition.

• Operator. The person who should be the RVSM authorization applicant and holder.

See paragraph 3.4 for a detailed discussion on who is and is not the correct person to be designated as an Operator for the purposes of holding an RVSM authorization.

• RVSM-Authorization Element(s). Individually or together, RVSM-Compliant Aircraft or RVSM-Knowledgeable Pilots. (See paragraph 2.3.)

• RVSM-Compliant Aircraft. An aircraft the FAA has found to comply with the requirements of part 91 appendix G, section 2, for the purposes of conducting RVSM operations. (See paragraph 3.2.)

• RVSM-Knowledgeable Pilots. Pilots who have been trained according to RVSM operating policies and/or procedures for pilots (and, if applicable, dispatchers) the FAA has found are sufficient to ensure each pilot has adequate knowledge of RVSM requirements, policies, and procedures. (See paragraph 3.3.)

• RVSM-Point of Contact (POC). A person an Operator can designate in addition to the RVSM-Responsible Person to act as a contact person who has actual day-to-day knowledge of the RVSM-Compliant Aircraft operations and RVSM airworthiness status the FAA may contact to gather such information when such a need arises.

(See paragraph 3.5.)

• RVSM-Responsible Person. A person(s) designated by the Operator who has the legal authority to sign the RVSM authorization on behalf of the Operator and who has adequate knowledge of RVSM requirements, policies, and procedures. (See paragraph 3.5.)

2-1 CHAPTER 2. AUTHORIZATION OVERVIEW

2.1 Why are RVSM Authorizations Required, and How has the Authorization Process Changed Since RVSM Authorizations were Initially Implemented on a World-Wide Basis?

2.1.1 Special Navigation Area of Operation. RVSM airspace is designated a special navigation area of operation. Both the individual Operator and the specific aircraft type or types the Operator intends to use must be authorized by the appropriate FAA offices before the Operator conducts flight operations in RVSM airspace.

2.1.2 RVSM Implementation. The FAA implemented RVSM in all of the airspace in the lower 48 states, Alaska, the San Juan flight information region (FIR), Gulf of Mexico, and Atlantic High Offshore Airspace on January 20, 2005. To safely operate in RVSM airspace, all aircraft needed to be configured and inspected to ensure the applicable RVSM performance requirements were complied with.

2.1.3 Reason for Change. Because the RVSM requirements were new to most Operators when they were first put into place, those aircraft and Operators had to be reviewed by the FAA as a first instance in order to ensure the basic requirements were being met. Since domestic RVSM implementation occurred in 2005, most existing aircraft have since been configured for compliance or have been newly manufactured in compliance with these requirements and have been reviewed at least once by the FAA. Also, most Operators have now developed pilot knowledge and/or training programs previously reviewed at least once by the FAA. Therefore, the initial “one-size-fits-all” authorization approach initially adopted in 2005, which assumed all Operators, aircraft, and pilot training programs had never been reviewed before, is no longer warranted with respect to the processing of new or amended RVSM authorizations.

2.1.4 FAA Order 8900.1 Guidance. In recognition of these changes, the FAA amended those portions of Order 8900.1, Flight Standards Information Management System (FSIMS), addressing the issuance of RVSM authorizations on January 24, 2014, in order to create guidelines improving efficiency in the authorization process. Based on the changes highlighted above, there is recognition of two key elements for a RVSM authorization.

The two key elements are an RVSM-Compliant Aircraft and properly trained pilots who have met applicable RVSM-Knowledgeable Pilots requirements. The guidance was created along with a “decision matrix” (see paragraph 2.4) to allow the FAA to more efficiently direct attention to only the RVSM Authorization Elements requiring initial review. The guidance allows the reviewing safety inspector to accept previously reviewed RVSM Authorization Elements without further examination, so long as the appropriate information has been provided to the FAA as part of the application process.

2.1.5 AC Not Regulatory. The material contained in this AC is not regulatory. It provides several methods for an Operator to successfully apply to the FAA for an RVSM authorization with the goal of expediting the review and approval process.

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2.2 What are the Basic Technical Requirements Associated with Obtaining an Appropriate RVSM Authorization?

2.2.1 Altimetry System Error (ASE). RVSM compliance proceeds on the basis of FAA certification of the altimetry system design and implementation, which is typically conveyed through type certification (TC) or Supplemental Type Certification (STC). It is generally acknowledged that one aspect of the design is an instrumentation system error budget allowing for a difference between the static pressure sensed and the actual altitude flown. This difference is not seen on the displayed altitude in the flight deck and it is not in the Mode C or Mode S reply from the aircraft transponder. Therefore, it is invisible to the pilot, to air traffic control (ATC), and to the Traffic Alert and Collision Avoidance System (TCAS).

2.2.2 Height Monitoring. Aircraft instructions for continued airworthiness (ICA) are designed to keep the altimetry system error (ASE) to within the limits of the error budget throughout the flight envelope. These limits vary between aircraft types and within a type, from airframe to airframe. Regardless, even with attention to continuing airworthiness, there are factors that can affect the ASE significantly and can go undetected in routine operations. Thus, through continuous sampling, the FAA independently monitors altimetry system performance of airframes in the population of aircraft participating in RVSM operations. This sampling is accomplished through operational monitoring flights using either special equipment brought on board the aircraft or through separate ground-based height monitoring systems. See paragraph 3.6.4.

2.2.3 RVSM Performance. Appendix A gives details regarding the ASE performance demands for safely operating in RVSM airspace.

2.3 What are the RVSM Authorization Elements? The definition and use of the two RVSM Authorization Elements—RVSM-Compliant Aircraft and RVSM-Knowledgeable Pilots—arose from recognizing these are the two basic building blocks needed to meet the technical requirements in order to safely conduct operations in RVSM airspace. These elements provide the basis for developing the RVSM Matrix (see paragraph 2.4). Once the FAA has found an aircraft to be RVSM-compliant, if it is properly maintained and monitoring shows that its performance has not degraded over time, the aircraft remains RVSM-compliant. Under these conditions, it is inefficient for the FAA to have to review the status of that aircraft again (as if it had never been compliant) when a subsequent Operator requires his/her/its own authorization to operate that aircraft in RVSM airspace.

By specifically defining these two elements and putting certain safeguards into place (such as compliance statements by subsequent Operators), the FAA could then create the RVSM Authorization Matrix in order to streamline the process of reviewing and issuing new RVSM.

2.4 What is the RVSM Authorization Matrix? The RVSM Authorization Matrix (or simply the “Matrix”) is a tool created to assist Operators and the FAA in determining the typical documentation needed for application and which RVSM Authorization Elements

2-3 approval action the applicant is seeking. The full Matrix is provided in Chapter 4, but the following is a summary of how the Matrix works.

2.4.1 When Does Authorization Group I Apply? Authorization Group I applies to applicants seeking an administrative change only to an existing authorization. The following changes are considered to be administrative in nature only when all other existing elements are not changed:

1. Change in the primary business address of an RVSM-Compliant Aircraft and/or RVSM authorization holder.

2. Change in an existing RVSM Operator’s designated Responsible Person (or RVSM-Authorized Representative or RVSM-POC).

3. Change in the registration markings of an RVSM-Compliant Aircraft being operated by an existing RVSM authorization holder.

4. Removal of an RVSM-Compliant Aircraft from an existing RVSM authorization having multiple RVSM-Compliant Aircraft listed.

2.4.2 When Does Authorization Group II Apply? Authorization Group II applies to applicants seeking new RVSM authorizations based on one or more existing approved RVSM Elements. This group will normally apply to a new or proposed RVSM Operator seeking the issuance of an RVSM authorization for an aircraft already an RVSM-Compliant Aircraft or where the new RVSM Operator will be utilizing previously accepted RVSM- Knowledgeable Pilots requirements with respect to its operations of that specific aircraft.

Examples given in the Matrix include:

1. There is a change in the legal status or identity of the business entity that is the approved RVSM Operator, but the Responsible Person, RVSM Authorized Representative, and/or RVSM Contact Person and each of the approved RVSM Authorization Elements are remaining the same.

2. A new proposed RVSM Operator will be using an existing RVSM-Compliant Aircraft or previously accepted RVSM-Knowledgeable Pilots.

3. An existing or new proposed approved RVSM Operator seeks an RVSM authorization and will be utilizing one or more existing approved RVSM Authorization Elements.

2.4.3 When Does Authorization Group III Apply? Authorization Group III applies to applicants for new RVSM authorizations not based on any existing RVSM Authorization Elements. If neither Authorization Group I nor II apply, the applicant should submit sufficient evidence to show its ability to comply with each of the RVSM Authorization Elements.

2.4.4 What Additional Issues Should an Applicant be Aware of When Using the Matrix? The FAA has created inspector guidance in order to allow for the most efficient processing of an RVSM authorization without sacrificing operational safety. While a safety inspector may rely on that guidance in issuing new or amended RVSM authorizations, applicants

2-4 should understand each Flight Standards District Office (FSDO), certificate-holding district office (CHDO), International Field Office (IFO), principal operations inspector (POI), principal avionics inspector (PAI), principal maintenance inspector (PMI), and/or aviation safety inspector (ASI) retains the authority to conduct as much review and research with respect to any proposed RVSM-Compliant Aircraft or RVSM- Knowledgeable Pilots requirements as is warranted. This authority is to ensure safety and regulatory compliance requirements have been met. Applicants should also understand it is the Operator's responsibility to ensure documentation reflects the requirements for authorization. A positive statement by the Operator detailing any changes made to previously approved programs can assist the inspector in determining the level of review necessary.

2.5 What is a Summary of the Process Needed to Obtain a New RVSM Authorization?

Chapters 3, 4, and 5 of this AC describe the RVSM authorization process in detail, but a summary of this process is as follows:

1. The applicant identifies the appropriate FAA office to apply to. (See paragraph 4.1.2.)

2. The applicant determines if a new RVSM authorization is required, or if only an amendment to an existing RVSM authorization is required. (See paragraph 4.2.1.)

3. If only an amendment to an existing RVSM authorization is required, then the applicant will follow the procedures described in paragraph 4.2.1 with respect to Authorization Group I in the Matrix.

4. If the applicant determines a new RVSM authorization is required, then the applicant should first determine who the correct Operator will be with respect to applying for and holding the RVSM authorization. (See paragraph 3.4.)

5. Once the appropriate Operator is determined, the applicant will determine if it will be utilizing any existing RVSM Authorization Elements, and if so, will then follow the process described in paragraph 4.2.2 with respect to Authorization Group II in the Matrix.

6. If the applicant determines they are unable to use any existing RVSM Authorization Elements, then the applicant will follow the process described in paragraph 4.2.4 with respect to Authorization Group III in the Matrix.

3-1 CHAPTER 3. RVSM AUTHORIZATION ELEMENTS

3.1 What is the Background Behind Using the RVSM Authorization Elements to Apply for an RVSM Authorization? The RVSM authorization process recognizes two key elements of any RVSM authorization—an RVSM-Compliant Aircraft and properly trained pilots who have met applicable RVSM-Knowledgeable Pilots requirements. An Operator must demonstrate to the FAA both of these elements exist to be authorized to operate in RVSM airspace. All of these RVSM Authorization Elements are described in this chapter.

3.2 What Do I Need to Know About RVSM-Compliant Aircraft?

3.2.1 What is an RVSM-Compliant Aircraft? An aircraft is an “RVSM-Compliant Aircraft” when (1) the FAA has determined the aircraft design satisfies RVSM performance requirements and (2) the aircraft has been properly maintained on an on-going basis to conduct such operations. An aircraft will satisfy RVSM performance requirements if it complies with part 91 appendix G, section 2. (See paragraph 3.2.2 below for more detail concerning meeting these performance requirements.) Aircraft may be produced RVSM-compliant or brought into compliance through the application of appropriate Service Bulletins (SB), Service Letters (SL), Engineering Change Orders (ECO), or STCs.

3.2.1.1 If the aircraft was manufactured RVSM-compliant, the date of the Airworthiness Certificate is usually the compliancy date. (For additional information see the Airplane Flight Manual (AFM), AFM Supplement (AFMS), and/or Type Certificate Data Sheet (TCDS).

3.2.1.2 If the aircraft was made RVSM-compliant through a SB, STC, or SL, or other appropriate methods, the RVSM-compliant date will be listed in the airframe maintenance log. Include copies of the maintenance record return to service entry.

3.2.2 How Does an Aircraft Achieve the Designation of Being an RVSM-Compliant Aircraft?

Each aircraft type an Operator intends to use in RVSM airspace should have received FAA RVSM airworthiness approval in accordance with part 91 appendix G, section 2, before the operational authorization will be granted. Obtaining RVSM airworthiness approval is a two-step process. First, the manufacturer or design organization develops a data package through which to seek RVSM airworthiness approval and submits the package to the appropriate FAA Aircraft Certification Office (ACO) for approval. Once the ACO approves the data package, the Operator applies the procedures defined in the package to obtain approval from the FSDO/CHDO/certificate management office (CMO)/IFO (as appropriate) to use its aircraft to conduct flight in RVSM airspace. The initial airworthiness review process must consider continued airworthiness requirements, as described in Appendix A of this document. For more detail on RVSM aircraft airworthiness approvals see Appendix A.

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3.2.3 How Does an Aircraft Retain the Designation of Being an RVSM-Complaint Aircraft?

An aircraft once designated RVSM-compliant should retain that designation as long as properly configured and the maintenance procedures listed in the ICA are complied with.

Subsequent modifications to the aircraft must be evaluated and determined to have no negative impact on RVSM design or performance.

3.3 What Do I Need to Know About RVSM-Knowledgeable Pilots?

3.3.1 Who are RVSM-Knowledgeable Pilots? To obtain authorization from the Administrator to conduct operations in RVSM airspace, the Administrator must find the Operator to have adopted RVSM operating policies and/or procedures for pilots (and, if applicable, dispatchers) and ensure each pilot has adequate knowledge of RVSM requirements, policies, and procedures, with those pilots (and, if applicable, dispatchers) being referred to in this AC as “RVSM-Knowledgeable Pilots.”

3.3.1.1 For an applicant operating only under part 91 or part 125 (including A125 Letter of Deviation Authority (LODA) holders), demonstrating it has RVSM-Knowledgeable Pilots will consist of providing sufficient evidence each pilot has an adequate knowledge of RVSM requirements, policies, and procedures as required in part 91 appendix G, section 3(c)(2).

• The following are acceptable means for the Operator to show the FAA its pilots have adequate knowledge of the RVSM operating practices and procedures: 14 CFR part 142 training center certificates without further evaluation; certificates documenting completion of a course of instruction on RVSM policy and procedures; and/or an Operator’s in-house training program.

Note: The FAA, at its discretion, may evaluate a training course prior to accepting a training certificate.

3.3.1.2 For an applicant who operates under part 91 subpart K (part 91K), 121, or 135, in addition to meeting the adequate knowledge requirements for part 91 operators, that applicant will need to provide sufficient evidence of initial and recurring pilot training and/or testing requirements as well as policies and procedures allowing the operator to conduct RVSM operations safely as required in part 91 appendix G, section 3(b)(2) and (3) in order to demonstrate they are using RVSM-Knowledgeable Pilots. Therefore, part 91K, 121, and 135 Operators should submit training syllabi and other appropriate material to the FAA showing operating practices and procedures and training items related to RVSM operations are incorporated in initial and, where warranted, recurrent training programs. (Training for dispatchers should be included, where appropriate.)