InFO Stresses That Pilots Need Clearance To Enter Reduced
Vertical Separation Minimum Airspace
The FAA has relased an Information for Operators (InFO) document
emphasizing RVSM flight planning guidance. The document states
“If either the operator or the aircraft or both have not
received RVSM authorization (non-RVSM aircraft) the pilot will
neither request nor accept a clearance into RVSM
Air traffic controllers have reported numerous instances of
pilots requesting RVSM flight levels or cruising in RVSM airspace
without required authorization and/or not using proper phraseology
and flight plan filing practices as guided in the Aeronautical
Information Manual (AIM). In the first 15 days of November 2011, 35
Instrument Flight Rules (IFR) operations were filed incorrectly.
These events indicate that not only are “non-RVSM”
aircraft being filed as RVSM authorized, but also, authorized
aircraft unable to conduct RVSM due to equipment malfunctions
(operations in accordance with an MEL item) are being incorrectly
filed as RVSM authorized.
Flight plans are also being filed with an RVSM
equipment/capability qualifier while simultaneously annotating a
contradictory entry (e.g. NON-RVSM) in the “Remarks”
RSVM requirements are covered under Title 14 of the Code of
Federal Regulations (14 CFR) Part 91, § 91.180 and Appendix G.
The cited rules lay out RVSM requirements and designate
exclusionary domestic RVSM airspace (FL 290-410). With limited
exceptions, all operators and individual aircraft must have RVSM
authorization and RVSM authorized aircraft must have all RVSM
equipment operable to operate at RVSM altitudes.
An operator annotates the equipment block of the FAA or
International Civil Aviation Organization (ICAO) flight plan with
an equipment/capability qualifier indicating RVSM capability only
after it has been determined that both the operator and its
aircraft are RVSM-compliant and issued RVSM authorization. An
aircraft or operator not authorized for RVSM operation or an
operator/aircraft without operable RVSM equipment is referred to as
RVSM guidance is also included in FAA Advisory Circular (AC)
91-85, Authorization of Aircraft and Operators for Flight in RVSM
Airspace, and in AIM, Section 4-6, Policy/Procedures for RVSM in
the Domestic U.S., Alaska, Offshore Airspace and the San Juan FIR.
Pay special attention to AIM Sections 4- 6-4, Flight Planning into
RVSM Airspace; 4-6-5, Pilot RVSM Operating Practices and
Procedures; and 4-6-10, Procedures for Accommodation of Non-RVSM
Aircraft. Basic Pilot RVSM Operating Practices and Procedures
stipulate if either the operator and/or aircraft has not received
RVSM authorization or an operator/aircraft does not have operable
RVSM equipment, the pilot will neither request nor accept a
clearance into RVSM airspace except when using procedures found in
AIM, Section 4-6-10.
Non-RVSM aircraft must not file a flight plan with an RVSM
equipment/capability qualifier (i.e. W for ICAO flight plan or /Q,
/W, /L, or /K for an FAA flight plan). When an erroneous RVSM
equipment/capability qualifier is included, ATC automation will not
alert the controller to provide required 2000’ vertical
separation for the Non-RVSM aircraft.
Program Managers, Directors of Operations, Directors of Safety,
Pilots, dispatchers, flight planning services and flight followers
should review the AIM guidance regarding RVSM airspace. The FAA
recommends that they:
- Be knowledgeable of flight planning requirements and do not
file an RVSM equipment/capability qualifier unless authorized and
capable of operations into RVSM airspace.
- Understand and comply with the MEL guidance for inoperative
items that disqualify an aircraft from RVSM airspace
- Do not request accommodation for non-RVSM operations in RVSM
airspace unless meeting one of the permitted exceptions documented
in AIM Section 4-6-10. If accommodated, use proper phraseology and
never indicate RVSM capability in the equipment and capabilities
- Remember that regardless of who files the flight plan; the PIC
is responsible for operating within § 91.180 including correct
flight plan filing.