Fellow APA Pilots,
As explained when we announced the formation of the Maintenance and Technical Analysis Ad Hoc Committee (MTA), APA has begun tracking maintenance-related flights (FCF, Ferry, and Exhibition Flights) in order to provide pilots as much information as possible about this type of flying and, when we can, about the particular situation they are assigned. As you may understand, this information is important and detailed. Although the world is now used to information being distributed in the “280-character tweet” format, these issues require more space. We urge you to read through these MTA messages so you have all the information needed to determine acceptable risk.
In this message, we will go over some basic definitions from FM Part 1 (FM 1), the General Procedures Manual (GPM), and some FAR references regarding the special operation of aircraft, including Functional Check Flights (FCF), the different types of ferry flying, and exhibition flying.
Special operation of aircraft
You may remember that FM 1 Chapter 14.1.2, “Safety During FCF, Ferry and Exhibition Flights,” states the following:
“More than one quarter of turbine aircraft accidents happen during FCF, Ferry and exhibition flights. There are different causes and factors for these accidents, but the common thread for many is the crew’s failure to adhere to established procedures or failure to operate the aircraft within its performance limitations.”
Because of the inherent risk associated with this type of flying, the APA MTA was formed to provide an additional resource for pilots assigned to perform this type of flying, as well as any maintenance-related issue APA pilots might encounter on the line. APA will seek to develop this resource to provide information and guidance; however, to be clear, APA cannot and will not direct crew actions. As always:
THE CAPTAIN IS THE FINAL AUTHORITY ON WHETHER A FLIGHT STARTS, CONTINUES, OR ENDS AND IS RESPONSIBLE TO END ANY SUCH FLIGHT AT A TIME THE CAPTAIN FINDS SAFETY IS COMPROMISED.
Typical scenario: You have been called out by Crew Scheduling to fly an aircraft, perhaps with damage or a system that may be out of maintenance manual limits. APA pilots should understand that there are a number of regulations and (OpSpecs) Operations Specifications that govern these flights, some of which you have likely NEVER seen, including: 14 CFR 21.197, 14 CFR 91.213, AA Ops Spec D084, AA Ops Spec D085, AA General Procedures Manual (GPM), and several foreign countries’ aviation regulations. These circumstances may subject crews to additional risks outside their normal purview. This review is being made available so you can conduct these flights in the safest manner, avoid many pitfalls, and stay within all regulations. First, let us define some terms:
Airworthy, Non-airworthy and Safe for Flight
From Flight Manual Part 1, Chapter 14.1.9, Airworthy is defined as:
“Airworthiness for the purposes of this section is defined as (If these conditions cannot be met the aircraft is considered non-airworthy):
- The aircraft must conform to its type design. Conformity to type design is considered obtained when the aircraft configuration and components installed are consistent with the drawings, specifications, and other data that are part of the Type Certificate (TC), which includes any Supplemental Type Certificate (STC) or other approved alterations.
- The aircraft must be in a condition for safe operation.
- The status of the aircraft must be known and have a current aircraft airworthiness release.”
Safe for Flight is defined in FM Part 1 Chapter 14.1.10:
“Safe for Flight for the purposes of this section refers to the condition of the aircraft relative to wear and deterioration, for example skin corrosion, window delamination or crazing, fluid leaks, tire wear, damage that does not preclude safe operation, etc. The aircraft may not meet the technical standard of airworthiness. Aircraft that are on a Special Flight Permit are safe for flight but may not be airworthy. After takeoff flight crew may perform incidental checks (speed changes, configuration changes, turns, etc.) to confirm the aircraft is safe for continued flight.”
Functional Check Flight
FM Part 1 talks about FCFs at length in Chapter 14.2.1. An FCF is conducted to:
- Confirm the airworthiness of an aircraft, aircraft engine or aircraft component after maintenance was performed.
- Check aircraft conformance to specific standards as established by the manufacturer and AA after undergoing maintenance, repair or alternation that can have appreciably changed its flight characteristics.
- Verify whenever flight characteristics develop that cannot readily be detected on the ground or if doubt exists to the effectiveness of the corrective action.
FM Part 1 Chapter 14.2.1.C specifically points out that “The FCF aircraft must be airworthy (no Special Flight Permit).”
Positioning Ferry Flights
FM Part 1 Chapter 14.3 describes Positioning Ferry Flights:
“Positioning Ferry Flights are operated to move airworthy aircraft to another location for a particular purpose (i.e., meeting flight schedules, extra sections, charters, new aircraft delivery) or to move airworthy aircraft to a location necessary for scheduled maintenance. On such flights the aircraft is currently airworthy and may be operated by line crews. Position Ferry Flights may be combined with Functional Check Flights.”
Chapter 14.3.4 also notes that, “No special authorization is required,” meaning positioning ferry flights do not require a spotting message unless it is combined with an FCF.
SPECIAL FLIGHT PERMIT
FM Part 1 Chapter 14.4 describes Special Flight Permit flights in detail. You need to be familiar with the entire section, as it is very detailed. In particular, 14.4.1 states:
“A special flight permit may be issued for an aircraft that may not currently meet applicable airworthiness requirement but is capable of safe flight, for the following purposes:
- Flying the aircraft to a base where repairs, alterations, or maintenance are to be performed, or to a point of storage.
- Delivering or exporting the aircraft.
- Production flight testing new production aircraft.
- Evacuating aircraft from areas of impending danger.
- Conducting customer demonstration flights in new production aircraft that have satisfactorily completed production flight tests.”
The American Airlines (GPM) General Procedures Manual Section 10.1.1.B.1 further defines these Special Flight Permit flights specifically as:
“…Non-airworthy aircraft movements from station to station. They cannot be combined with any other check (except an incidental check to determine if the aircraft is safe to complete the flight).”
American Airlines is only authorized to conduct flights for the purpose of moving an aircraft to a station for maintenance/repairs. Flights for any of the other aforementioned reasons require the Special Flight Permit to be issued by the FAA.
From a regulatory point of view, either an aircraft meets its type design criteria or it does not. Our FAA-approved MEL/CDL allows for certain systems to be inoperative or missing. In addition, our TMS (Technical Manual System) — i.e. AMM, SRM, MCM, etc. — allows for damage and/or anomalies meeting certain criteria to exist, but there are limits. If those limits are exceeded, the aircraft may not meet its type design. In cases where these limits are exceeded, some form of Approved Data is required (usually in the form of an E.A. “Engineering Authorization”). When these Manual limits have been exceeded, the E.A. will either restore the airworthiness of the aircraft, or provide data in the evaluation/determination of the aircraft to be in a safe condition for flight under an SFP.
The GPM further elaborates in Section 10.1.3.B.2.b noting, “FCFs are not authorized on SPF/Maintenance Ferry flights.” FM Part 1 restates this limitation in Chapter 14.4.1.
Flight Crew Requirements
You are REQUIRED by FM Part 1 Chapter 14.4.7.H to contact, be briefed by, and reach agreement with MOD-MOC and Dispatch prior to accepting and using the Special Flight Permit.
DOCUMENTATION IS KEY! APA recommends printing and retaining for your records all applicable logbook pages, records of aircraft damage, Engineering Authorizations, Flight paperwork and copies of MX documents, including spotting messages, etc. Images of actual damage/aircraft condition is optimum.
Basic Special Flight Permit action items you may consider before accepting one of these aircraft:
- Review FM Part 1 Chapter 14, “Ferry, Charter and Exhibition Flights,” in its entirety.
- Review the AML Logbook per FM Part 1. Pay particular attention from its out-of-service date to the Special Flight Permit issuance in detail.
- Review with MX any history on all systems affected.
- Ask questions especially covering noted aircraft damage that has been temporarily repaired or inspected IAW a procedure or an E.A. (Engineering Authorization). Detailed damage dimensions and locations should be documented in the AML. Ask about the E.A. (Engineering Authorization) in particular; if a determination has been made that the aircraft is safe for flight by an E.A., per the GPM and FM Part 1, a copy of that E.A. should be provided to the PIC.
- Make sure you have a Spotting Message if on a Special Flight Permit or FCF.
- Spotting Messages labeled SFP/FCF are not authorized.
Did you get a copy of the completed Pre-Ferry Bill of Work (BOW) and any applicable Engineering Authorizations?
Check that the maintenance actions taken in making the determination of safe condition for ferry flight is entered into the AML.
Some of these ferry flight destinations are into airports that we typically do not use. In case of unfamiliar operations, we recommend a review of FM Part 1, Chapter 6.1.12-13 Operations without an Operating Control Tower; how to get IFR/VFR clearances at these airports; a review of full airport diagrams, etc.
These flights may be conducted under 14 CFR Part 91. However, the aircraft MEL still applies under Part 91.
These documents make extensive use of acronyms, abbreviations, and jargon. Review everything, and if you are unfamiliar with any of the terms used in the MX documents, you may have them explained to you during your pre-briefing.
If you still have questions or concerns, contact the APA Maintenance and Technical Analysis (MTA) ad hoc Committee through the link “MTA” on the front page of the APA website; by email at APAMTA@alliedpilots.org; or leave a voice message for call-back at 817-302-2302.
Coming soon: an explanation of the use of a Spotting Message and what it means to the assigned crew.
Remember former AA instructor Tom Pasqual’s idiom, “Your hearing will get better at your hearing.”
The devil is always in the details. In future messages, we will discuss further details of pitfalls and mitigating risk during these operations and how to determine what type of ferry you are flying.