FAA ALASKA AVIATION
SAFETY INITIATIVE
FY21 FINAL REPORT
Aviation in Alaska is a way of life and an absolute necessity for much of the state. The
FAA has teamed with the ying community to develop a document to improve aviation
safety in Alaska. A plan for managing current, planned and new approaches is discussed.
FAASI FY21 Final Report
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Table of Contents
Executive Summary .................................................................................................................................... 2
Introduction ................................................................................................................................................. 3
1.0 Stakeholder Comments ........................................................................................................................ 4
1.1 Environment ...................................................................................................................................... 4
1.2 Fleet .................................................................................................................................................... 6
1.3 Infrastructure: Communications, Navigation, Surveillance (CNS) ............................................. 7
1.4 Operations Safety Management ...................................................................................................... 7
2.0 Individual FAA Lines of Business Summaries ................................................................................... 8
2.1 Aviation Safety (AVS) Summary ..................................................................................................... 8
2.2 Air Traffic (ATO) Summary .......................................................................................................... 11
2.3 Office of Airports (ARP) Summary .............................................................................................. 23
3.0 Conclusions and Recommendations to the FAA Administrator ..................................................... 25
4.0 Next Steps ............................................................................................................................................ 28
List of Appendices ..................................................................................................................................... 30
Appendix 1: Prioritized List of Initial Efforts .................................................................................... 31
Appendix 2: Glossary of Terms ........................................................................................................... 39
Appendix 3: Table of Stakeholder Comments ................................................................................... 40
Appendix 4: Links to Reference Documents and Reports ................................................................ 84
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Executive Summary
The Federal Aviation Administration Alaska Aviation Safety Initiative (FAASI) has its origins in
the September 2019 National Transportation Safety Board (NTSB) Part 135 Roundtable
discussion held at the University of Alaska Anchorage (UAA). During that discussion, the
participants focused on the relatively high accident rate in the Federal Aviation Regulation
(FAR) Part 135 aviation community. Subsequently, the NTSB recommended the FAA should
move towards a less “stove-piped” and more interdisciplinary approach to safety in Alaska to
foster coordination between the various FAA Lines of Business (LOBs). In addition, the NTSB
recommended the FAA consider input from external parties in developing its safety strategy in
Alaska.
Thereafter the Administrator directed the Alaskan Region Regional Administrator (RA) to lead a
panel of experts drawn across FAA LOBs to focus on safety issues specific to Alaska. The RA
and this panel, the FAASI team, were instructed to analyze how the FAA is deploying resources,
the effectiveness of those resources, and how the FAA can improve delivery of services and
prioritize its available resources. To fully execute on the additional directive and to consider
external Stakeholders’ concerns and knowledge, the FAASI team produced an Interim Report
including an analysis of the multiple safety challenges and the current and planned programs to
address those challenges. The agency then used the Interim Report as the foundation for
discussions with external Stakeholders.
The FAASI team presented the Interim Report to external Stakeholders through a webinar held
May 6, 2021 and in advance of the webinar via web link. Approximately 100 individual and
organizational Stakeholders participated in the webinar.
The FAASI team created a calendar for 18 Stakeholder sessions to offer individuals and
organizations an opportunity to provide feedback in individualized settings and to ensure the
team garnered the most robust and diverse portfolio of views and inputs The respective LOBs
provided subject matter experts to attend these sessions to accurately understand, capture and
document the feedback. After receipt of requests for participation, the FAASI team hosted 12
individualized virtual sessions with airmen, industry, airport sponsors, aviation interest
organizations, and also held some sessions with multiple external Stakeholders who shared
related interests.
The FAASI team then integrated the information gathered through the Stakeholder events to
develop both immediate refinements of current programs and strategic conclusions and
recommendations for future planning.
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Introduction
Alaska’s population density is the lowest in the United States, with 82 percent of the
communities in Alaska accessible only by air. Alaska spans nearly 600,000 square miles, has 14
mountain ranges, and is more than twice the size of Texas. The mountainous terrain and high
latitude weather patterns create significant logistical environmental challenges for safe air travel.
With most of the communities accessible only by air, annual enplanements in Alaska are 7.1
times the state population compared to 2.8 times the population in the Contiguous United States
(CONUS). This results in a dependence on aviation which significantly exceeds the rest of the
United States.
As of December 2020, Alaska has 396 public use airports (284 land based, 4 heliports, and 108
seaplane bases). The nature of public airports varies considerably, from sophisticated,
contemporary airports near major population centers, to small village airports with gravel
operational areas and few to no weather stations or instrument approaches. Even urban airports
have their own operational challenges because of terrain and the environment, some with no
practical ability to use radar and others burdened by extreme weather conditions during
the Arctic winter seasons.
Alaskan aviation stakeholders repeatedly conveyed that the mountainous terrain and high latitude
weather in Alaska underscore the need for reliable weather reporting/forecasts and improved
route structure. Additionally, they underscored the importance of the associated communications
infrastructure which supports both Instrument Flight Rules (IFR) in low altitude airspace and
Visual Flight Rules (VFR) operations.
The discussions with Stakeholders crossed a wide-range of issues, some of which were not
identified in the Interim Report published in May 2021. To ensure transparency, all Stakeholder
input was catalogued and documented in Appendix 3 of this report. Stakeholder input was
categorized by subject area and, to the extent possible, expressed verbatim to provide both
transparency, future reference, and relative emphasis as reflected by repetition amongst
Stakeholders. The FAASI team then further categorized and discussed the most prevalent issues
in the body of the report to include the following subject matter areas:
a. Environment
b. Fleet
c. Infrastructure: Communications, Navigation, Surveillance (CNS)
d. Operations Safety Management
After the Stakeholder engagement sessions, three LOBs with operational safety management,
infrastructure deployment, and support responsibilities (Office of Aviation Safety (AVS), Air
Traffic Organization (ATO), and Office of Airports (ARP)) compiled individual summaries of
their programs in response to Stakeholder comments. The summaries are found in Section 2.0 of
this document and identify the most salient issues, planning, and priorities related to the
Stakeholder comments.
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AVS, ATO, and ARP then conducted a series of discussions to create an integrated series of
findings and conclusions regarding the most pressing and prevalent safety issues with associated
recommendations for moving forward to address those issues. This Final Report transmits these
conclusions and recommendations to the Administrator.
The RA, in consultation with the FAASI team members and leadership in the Office of Policy,
Environment and International Affairs (APL), also created a plan for next steps within the
FAASI process. After the transmission of the Final Report, the FAASI Team will facilitate
continued interface with external Stakeholders and develop a roadmap for execution of the
recommendations contained in the Final Report.
1.0 Stakeholder Comments
Following the release of the FAASI Interim Report in May, 2021, the FAASI team conducted 12
separate Stakeholder feedback sessions by video conference which were often supplemented by
written input from other Stakeholders. Although not identified by name or company, the
Stakeholder input is diverse and informative of challenges, efforts, and investment by
Stakeholders. Please see Appendix 3 for a complete list of feedback from Stakeholders. Most
segments of the aviation community were represented, including Part 91 pilots and operators,
Part 135 operators, along with industry associations, the University of Alaska, and the Alaska
Department of Transportation and Public Facilities. Given the focus of the FAASI study, Part
121 carriers did not participate.
1.1 Environment
With only a small fraction of the State served by roads, aviation is considered a primary
transportation mode. Since weather plays such a significant role in aviation it was not surprising
that much of the Stakeholder feedback focused on weather-related issues. For Alaskan aviators,
“environment” usually boils down to two elements: weather and terrain, the latter static and the
former ever-changing. The lack of available weather reports was a running theme through most
of the interview sessions with generally strong user support for new and existing systems.
Alaska has fewer weather observation systems than the contiguous 48 states (CONUS) and those
which do exist are situated at greater distances from each other. This presents a myriad of
challenges for both Part 135 and other general aviation operators. As noted by the FAASI team
and again by almost all Stakeholders who participated in the process, most rural airports do not
have weather observation systems. Without certified weather reporting, or an approved
alternative with adequate fidelity, by regulation, Part 135 operators cannot conduct IFR
operations into these airports.
The relative sparsity of weather reporting stations also inhibits forecasting models as more
locations and a greater quantity of weather reports lead to more robust and reliable forecasts.
Across the entire range of VFR operations, increased en route weather reporting and forecasting
allows for better pre-flight planning and encourages pilots and operators to make smart “go/no-
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go” decisions using safety risk management tools before initiation of flight rather than making
such decisions en route by individual pilots.
One program which received extensive positive recognition was the Weather Camera Program.
Stakeholders all agreed the cameras and the ease of access to the information have become a
vital part of flight planning across the state. One Stakeholder, with a broad history of Part 91,
Part 135, and corporate operations across Alaska, noted, “One of the best things FAA has done.
Similar comments regarding the Weather Camera Program were repeated across the Stakeholder
sessions. While the Weather Camera Program has received widely favorable recognition, there
are still many limitations identified by industry. Future improvement requests include adding
more sites, expanding information offerings, and increasing access to information by airmen
while in flight.
Stakeholders also acknowledge how valuable and necessary the Automated Weather Observing
System (AWOS) is to flight planning. Many comments were made requesting more AWOS
coverage across the state. For instance, an air carrier serving the Alaska Peninsula stated, “The
Perryville airport is one of the most dangerous for our company. They have to fly using Visual
Flight Rules (VFR) because of the lack of infrastructure. There is an approach at Perryville, but
the operators can’t use it due to the lack of weather.” AWOS comments also included outage
concerns and inquiries regarding telecommunications upgrades to existing systems. The air
carrier community was very uniform in their on-going concern about how the FAA identifies and
manages outages. One carrier emphasized, “Telecommunication issues aren’t reported by the
FAA as a broken AWOS. From an operator standpoint, if an AWOS has a partial outage or a
telco issue then the operators can’t fly because they don’t have the information needed.” Real
world examples such as this assist in building a business case for future projects. As reported in
other areas of this document, an initiative is underway to increase the number of AWOS units
across the state.
In addition to AWOS services, Stakeholders were very interested in the Visual Weather
Observation System (VWOS) currently being developed and tested at four key sites. More
information on this system was requested.
Stakeholders indicated a very focused desire to move forward with alternatives to AWOS
systems where cost or design make it unlikely the AWOS system would be installed at a given
airport. One very active member of the general aviation community underlined his feelings and
that of others: “The current Alaska weather systems aren’t approved as replacements for
Automated Weather Observing System/Automated Surface Observing Systems (AWOS /ASOS).
A pilot can’t fly if there isn’t legal weather data prior to the start of flight. The lack of legal
weather data is an issue.” Stakeholders are encouraged by the products and systems available but
stated that the FAA needs to energize and move forward with approving alternative weather
sources in accordance with Section 322 of the FAA Reauthorization Act of 2018 for Part 135
operators and to similarly increase safety for general aviation.
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1.2 Fleet
The FAASI Interim Report described a number of factors considered by aircraft owners and
operators when selecting aircraft for their fleet. Responses noted some agreement with the
Interim Report observations and challenged other statements.
Several responses dispute the assertation of a reluctance of operators to install IFR equipment.
Specifically, Part 135 Stakeholders challenged the Interim Report depiction, “The fleet is most
often comprised of single and small multi-engine general aviation aircraft. Many of these aircraft
are not equipped for IFR flight and are not equipped with aircraft deicing equipment.” Part 135
operators and an industry association felt that the FAA did not fully capture the carriers’
investments in upgrading avionics in order to expand IFR capabilities. One carrier noted, Our
company has 14 planes that are IFR only and 7 that are not yet IFR. To date, we have spent $2.5
million to upgrade our fleet for Wide Area Augmentation System (WAAS) approaches.The
FAASI team recognizes this statement is significant and emblematic of many carriers’
commitment to an IFR-capable fleet.
Many responders also indicate a willingness to commit their own resources to equip carrier
aircraft with ADS-B equipment even though many do not operate in airspace where the
equipment is required by rule. As an example, one commenter with both private and state
governmental aviation experience captured the general observations of a large number of
participants by stating, “If the weather coverage, communications, and ADS-B coverage
improved statewide, then CFIT and mid-air collisions would decrease. Notably, the majority of
comments supporting ADS-B came from carriers who operate scheduled, commuter operations,
the subgroup of Part 135 operations which transports the largest percentage of passengers within
Alaska to remote locations.
Nonetheless, several participants mentioned the financial limitations smaller operators may have
equipping their aircraft with new capabilities and corresponding safety enhancements. One
Stakeholder opined that the demise of government-sponsored avionics programs has had notable
negative impacts on parts of the Part 135 industry, “Under Capstone, the Chelton radio
equipment was popular. The equipment is costly and most of the smaller operators can’t afford
it. This is really good equipment for mountain passes and preventing CFIT. It would drive
fidelity to a narrower band. It is better than the Garmin package a lot of smaller operators are
using.”
The discontinued Capstone Program received praise from other Stakeholders, a number of whom
requested to see it continued or reinstituted. This program was initially a research and
development project with phased FAA-financed equipage of program aircraft with ADS-B based
avionics. The FAA communicated to Stakeholders the agency has no plans to reintroduce that
program.
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1.3 Infrastructure: Communications, Navigation, Surveillance (CNS)
Comments from Stakeholders addressed the same issue identified in the FAASI Interim Report
regarding outdated infrastructure when it was stated, “Infrastructure in Alaska is decades behind
the rest of the country.” As an example of frustration, one individual Stakeholder noted the
difference in surveillance capabilities by Air Traffic compared to the Continental United States,
“The best way to improve safety in Alaska is to improve infrastructure. Specifically, radar and
preventing blackout areas.”
As stated in the Interim Report, “Adding ADS-B Ground Based Transmitters (GBT) and
associated Remote Communications Air to Ground (RCAG) would enable increased PBN IFR
operations in the remote areas of Alaska increasing safety for VFR operations.” It was
acknowledged, however, this would be “… difficult due to the high cost of installing,
maintaining, and sustaining the ground based infrastructure in remote areas.” One carrier
mirrored the Interim Report conclusion affirming from its perspective that “ADS-B has been
installed on their aircraft, but there isn’t reliable coverage throughout Alaska.”
Stakeholders stated significant support for developing more effective Area Navigation (RNAV)
Terminal Transition Routes (T-routes). Because of the limitations/sparsity of ground based
navigation in remote areas, Global Positioning System-Wide Area Augmentation System (GPS-
WAAS) is viewed as a necessary alternative to allow lower flight altitudes for IFR operations
suitable for smaller, less complex aircraft. However, the Stakeholders identified the very same
limitation and challenge as the FAA has identified – communication and surveillance gaps where
navigation is feasible but other necessary elements for safe operations are not.
At least one Stakeholder voiced support for other forms of CNS capabilities but to also pair it
with increased regulatory requirements for all aircraft operators. “Alaska’s airspace is mostly
Class G. ADS-B and radio equipment are optional at most airports. There are planes that fly
without any form of communication, not even a radio. ADS-B needs to be fully implemented in
Alaska and a requirement no matter the age of the aircraft. At a minimum, radios should be
required.” The FAASI team captured this input in the report but advised all participating
Stakeholders the study and report process did not include initiation of rule-making.
1.4 Operations Safety Management
The FAA emphasizes safety culture, training, operational planning and management oversight
processes as foundational to reducing accident rates in Alaska. Stakeholder responses to the
FAASI Interim Report indicate a number of concerns. These include the experience level and
training of pilots, the ability to accurately assess weather, less than optimal IFR Flight
Procedures, and the need to improve and expand charting information, including VFR mountain
routes.
Many of the participants noted a trend of newer, less-experienced pilots in the airspace.
Stakeholders noted that unlike pilots in the Part 121 environment, Part 91 and 135 pilots often
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have much less experience and corresponding diminished exposure to comprehensive training
programs.
Some Stakeholders expressed concern with the intermittent and inconsistent availability of Pilot
Reports (PIREPS) and their accuracy. They suggested the FAA make these valuable real-time
weather observations more formal. PIREPS, particularly outside of the airport areas, are
considered very important in assessing the safety of VFR flight and also detecting adverse,
unsafe conditions for any flight whether IFR or VFR. Their accuracy and availability depends on
pilot participation, accuracy of reported information, and effective capture and dissemination of
the information by the FAA.
Part 135 Stakeholders commended the value of charts and the information provided by FAA
process, but questioned the location and altitudes of flight procedure fixes and routes. General
Aviation participants stated “R” Routes and mountain pass charting continue to be critical needs.
One Stakeholder also asserted the FAA needs to reinstate publications which target certain areas
of operation with special airspace or procedures, such as a former publication directed at
operations in southeast Alaska.
Some Stakeholders raised concerns about airport design criteria contained in FAA Advisory
Circular 150/5300-13A, Change 1, as well as runway length requirements for airport design
under Advisory Circular 15-/5325-4B, with particular reference to critical aircraft determination
and associated runway length standards.
The participants stated that continued communications between the industry and the FAA are
necessary to implement proactive, rather than reactive, fixes after an accident. Respondents
considered previous Safety Initiatives such as Aviation Safety Action Program (ASAP) /
Medallion Program / Compliance Program as still having value.
2.0 Individual FAA Lines of Business Summaries
2.1 Aviation Safety (AVS) Summary
The FAA Alaskan Region is responsible for providing safety oversight, infrastructure support
and air traffic services over an area that is roughly one-fifth the size of the lower 48 states
combined. There are many communities in Alaska where commercial aircraft provide the only
means of delivery for essential goods and services. Most of the communities are served by air
carriers who conduct operations under CFR 14 Part 135 and typically fly small, single engine
piston type aircraft in the low altitude environment. Many of the aircraft used for 14 CFR Part
135 operations in Alaska are only equipped for VFR flight. Often the operators serve
destinations which are not supported by terminal instrument procedures, such as seaplane bases,
off airport destinations, and more rural airports which either lack an established terminal
approach or weather reporting to support use of an established terminal approach. However,
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though smaller in number of actual aircraft, the companies that perform the majority of the
operations and flight hours are those that are equipped to operate IFR.
Often, 14 CFR Part 135 operators that are equipped to fly IFR will opt to fly VFR. There are a
variety of barriers which, if eliminated or reduced, would likely encourage these operators to
operate in the IFR environment. These barriers include unavailability of weather reporting and
forecasts, restrictive en route structure, unavailability of terminal instrument approach
procedures, and unclear authorization and eligibility requirements for IFR operations and
equipment.
During the FAASI stakeholder engagement process, external stakeholders continually verbalized
one primary obstacle to safer operations; the absence of adequate weather reporting
infrastructure at most rural Alaska airports and the associated inadequacy of weather forecasts in
current forms for so many areas.
External stakeholders were relatively uniform in their desire for a more expansive ability to
operate to remote locations IFR, with the attendant need for the FAA to provide not only
required weather reporting capability, but more useable low altitude route structures appropriate
to smaller aircraft which do not operate at higher altitudes. There was a corresponding request
that the FAA add additional instrument approaches and consider modifications where
appropriate to allow for lower landing minima at some airports.
Weather Reporting and IFR Capabilities
The lack of certified weather reporting and forecasts is a significant impediment to aviation
operations in Alaska. Currently, there are 133 automated weather reporting stations compared to
roughly 1,800 for the lower 48 states. Analysis indicates approximately 157 airports are without
a Terminal Aerodrome Forecast (TAF). Several airports have instrument approach procedures,
but do not have a weather source at the airport as required by regulation for IFR commercial
operations, preventing IFR operations to that airport.
Section 322 of the FAA Reauthorization Act of 2018 (“Section 322”) was intended to allow
certificate holders to fly IFR to destinations with approved approach procedures but which lack
AWOS/ASOS facilities or certified weather observers and have enough fuel to fly to an alternate
fully-IFR capable airport. The FAA interpretation of this statutory provision is that operators still
require adequate, reliable destination weather reporting to conduct instrument approaches at a
given airport and that the Section does not create a deviation to current Part 135 rules. While the
FAA desires flexibility in approving alternative weather sources, this legislative direction has
been extremely difficult to implement, as the rural nature of the communities served precludes
reliable, trained weather observers or special weather equipment.
Weather cameras are a potential tool to achieve the requirement of adequate weather
observations. They are used extensively to assist both IFR and VFR go/no-go decisions
throughout Alaska due to the absence of a road system and additional data. This infrastructure is
critical, but was not initially installed with the goal of satisfying Section 322. The regulatory
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structure related to Section 322 would allow the use of weather cameras when destination
weather is not available, but this requires vertical and horizontal landmarks appropriate to the
approach minimums being used. Many areas in Alaska are flat and have no such landmarks
precluding the use of weather cameras alone as a reliable mechanism to gauge ceilings and
visibility with acceptable fidelity.
The FAA Weather Camera Program is currently conducting development of its new VWOS.
VWOS is an emerging technology which may address shortcomings of the traditional weather
observation systems, including sensor redundancy and lower cost. The ATO Summary discusses
the program in detail. The final analysis phase of its development is expected to be complete in
March 2022.
Route Structure and Management
Published routes are designed and approved using multiple factors, including terrain and obstacle
clearance, ATC surveillance capabilities and communication coverage. The topography in
Alaska may require the minimum en route altitudes to exceed the performance capability of the
smaller aircraft typically used in Alaska and the higher altitudes may also put the operators at
more risk of icing conditions. Some existing routes have communication gaps, often Air Traffic
Control (ATC) is aware of this issue but it is unknown to the pilots since they are not charted.
There are 112 airports in Alaska which do not have instrument approach procedures; many of
these airports are serving communities that receive daily commercial service for basic needs.
Flight Standards approves and authorizes special instrument procedures which are developed by
the FAA or can be developed by non-FAA service providers. Non-FAA service provider
services, however, can be costly.
IFR equipment regulations and associated Operations Specifications are often difficult to
understand and from an industry standpoint lack clarity. Gaining greater clarity and direction for
operators who wish to maximize their ability to operate IFR using both land and space-based
systems will assist in their strategic planning for fleet equipage and encourage the corresponding
investment by those operators.
Operational Safety Management
The FAA continues to move forward to transition and expand programs previously provided by
the Medallion Foundation. Flight Standards continues a process to expand the ASAP and to
create a paradigm that works effectively for small operators so prevalent in the Alaska aviation
industry. Flight Standards is committed to effective safety mitigation development through
robust communications with carriers/operators and the concurrent sharing of information
between certificated entities.
Similarly, and for all users, Flight Standards shares the desire expressed by Stakeholders to
improve and increase waypoint charting for mountain passes and improve education and
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community outreach through on-line methodology and more traditional education methods
employed by the FAA Safety Team (FAAST). Flight Standards believes better charting and
education all serve the same purpose, to improve the situational awareness and knowledge of
pilots as they operate in given area, be it a mountainous area or an airport area with its own
topography, operational procedures, or locally-established voluntary procedures.
Some Stakeholders expressed concerns about several regulatory prohibitions, such as instrument
flight planning requirements (prohibition on filing to a point in space) and concerns about FAA
internal guidance change and use by principal inspectors assigned to oversee carriers/operators.
While not devaluing those concerns, they are outside the initial scope of the FAASI directive
and/or would involve regulatory change. These concerns are documented in the report and will
be communicated to the appropriate policy offices or possibly addressed through follow-on
phases of FAASI.
2.2 Air Traffic (ATO) Summary
Following the release of the Interim report, the FAA held numerous Stakeholder feedback
sessions to hear the questions and concerns of the Alaska flying community. These sessions were
an invaluable way to ensure the FAA understands the needs of the aviation community it serves.
During these sessions Stakeholders reported a number of concerns including a need for
additional approved weather data sources, expanded use and availability of ADS-B,
improvements to the Notice(s) to Airmen (NOTAMs) system, more frequent and complete pilot
weather reporting, and a more robust and better maintained National Airspace System (NAS)
infrastructure. The following paragraphs summarize the actions the FAA is currently taking to
address many of these concerns. They are organized into six categories: Weather Reporting,
Navigation, Communication, Surveillance, and Safety Management.
Weather Reporting
The most common concern brought forth during Stakeholder meetings was the lack of available
weather reporting data to support both VFR and IFR operations. Without current weather data,
pilots cannot make an informed and safe decision whether to “go, or no-go”. Additionally,
Stakeholders indicated that, “Many rural airports have instrument approaches approved but are
unusable because there is no weather reporting at those airports.” Approaches without local
weather reporting are a greater risk for all operators. The lack of a usable approach inhibits
flying under IFR. The approaches are technically usable for aircraft flying under Part 91, but an
approach without available weather reporting is a greater risk for all operators. This concern is
valid and efforts to rectify this situation remain a very high priority for the FAA. For example,
the FAA has engaged in the following initiatives to improve the availability of weather reporting
data. An additional important consideration is that surface communications with the weather
reporting station are critical since the station cannot be used for preflight planning or for
forecasting if its surface communication link is not operating.
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Automated Weather Observing Systems
From 2015 through 2017, the FAA implemented technical refresh upgrades at all 89 FAA
AWOS sites in Alaska to improve performance and extend the system service life. All
Automated Weather Sensor System(s) (AWSS) were replaced by AWOS. The improvements
included both new computer hardware and meteorological sensors. The FAA has already begun
planning for the next AWOS technical refresh effort which will start in 2025 and extend system
service life beyond 2030.
Prior to 2018, airport sponsors were hesitant to purchase new AWOS units utilizing Airport
Improvement Program (AIP) funding. This was partly due to the requirement for a cost/benefit
analysis and the high maintenance costs the airport operator would incur. These concerns were
eliminated by the FAA Reauthorization Act of 2018 which removed the requirement for a
benefit/cost analysis in low population density states, including Alaska, and required the FAA to
assume operation and ownership of AWOS units that meet FAA specifications.
In collaboration with the Alaska Air Carriers Association (AACA), airport sponsors, and other
external Stakeholders, the FAA has identified 35 potential locations for new AWOS installations.
The initial installation and commissioning of eight units is currently underway and is scheduled
to be complete by September 2022. These AWOS units will be installed at Akiachak, Crooked
Creek, Nulato, Tok, Coldfoot, Kotlik, Perryville, and Tununak.
Weather Camera Program
The FAA has also worked to address the high cost and technical challenges of traditional AWOS
installations. One such example is the FAA Weather Camera Program. This program’s extensive
network provides added benefits in aviation access, safety, and efficiency in the NAS. The aim is
to improve pilot situational awareness and flight decision-making, resulting in the reduction of
weather-related aviation accidents and flight interruptions. The program manages more than 230
camera sites in Alaska, Hawaii, and the CONUS, and it plans to expand the number of systems in
the coming years. The weather camera system is a low cost, innovative technical design that
produces high value aviation data products which are delivered to pilots and aviation users via its
public website: https://weathercams.faa.gov. The program serves a wide variety of users
including pilots, dispatchers, helicopter operators, military, emergency response, and the
National Weather Service (NWS), which uses the weather camera images and weather data to
improve its weather forecasts and graphical weather models. The weather cameras have solar and
wind solutions that can provide alternate power sources.
Visual Weather Observation System
The FAA Weather Camera Program is conducting analysis of its new VWOS. The VWOS is an
advanced low-cost, advisory weather station that combines 360-degree camera images with
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quality weather sensors to provide pilots and users with both visual and textual weather
observations. This system provides winds, temperatures, ceiling, visibility, pressure, cloud and
other important weather information necessary to support aviation operations in the NAS. The
design includes automated, self-validating processes to ensure accuracy and dependability of
sensor operations and data outputs. The FAA is seeking to install VWOS at Alaska airports
where AWOS/ASOS and Meteorological Terminal Air Reports (METARs) are not available.
The system is currently under final test and analysis at four Alaska airports: Palmer, Tatitlek,
Healy River, and Eek. The final analysis phase of its development is expected to be complete in
March 2022.
This planned expansion of additional weather systems and infrastructure will increase safety,
efficiency, and access to numerous locations where certified METARs do not exist. The VWOS
has a strong potential to support future advanced aviation technologies such as drone operations.
Additionally, the observations collected by the VWOS will be shared with the NWS to
significantly benefit Area Forecasts and automated forecast products such as the Alaska Aviation
Guidance (AAG) and Local Aviation Model Output Statistics (LAMP).
Runway Visual Range System
The Runway Visual Range (RVR) system provides pilots and air traffic controllers with a
measurement of the visibility at key points along a runway. That data is used to decide whether it
is safe to take off or land during limited visibility conditions and to continue operations under
reduced visibility Category I/ II/III conditions. Fourteen PC-based Runway Visual Range (PC-
RVR) systems will replace the obsolete equipment of the New Generation (NG) RVR systems
improving precision approach service reliability by 2026. The FAA has a funded program,
Alaska RVR Refresh, to replace all Alaska RVR systems with newer PC-based RVRs in 2026.
AWOS Maintenance and Notices to Airmen System
During the Stakeholder meetings, the FAA also heard concerns related to the maintenance of
AWOS units, the frequency of outages, long restoral times, and a desire for improvement in the
NOTAM system used to disseminate the operational status of the equipment to users. These
concerns also include surface communications outages which prevent the use of AWOS for
preflight planning and for weather forecasting.
FAA Technical Operations (Tech Ops) is responsible for status monitoring, NOTAM issuances,
maintenance, and restoration of all AWOS systems in Alaska. The NWS is similarly responsible
for all ASOS systems in Alaska, although Tech Ops supports the modem and
telecommunications lines that connect these units to the FAA weather database, making the
information available to pilots, air carriers, weather forecasters, and other users of the data via
the internet. This connectivity to the FAA weather database is called Service-A. Analysis of the
performance of these systems shows some degradation in overall system reliability, especially a
trend toward more frequent and longer interruptions of Service-A reporting.
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Analysis of the Service-A failures points to several issues all related to aging technology. The
data transport used is serial data over traditional dedicated voice grade telephone lines. The
modems used to encode/decode this data are obsolete and well beyond service life. The voice
grade analog telephone lines used are also very old and obsolete. The communications
companies that own them struggle to keep them operational and have little incentive to add
resources to support technology which has almost no market. This means there is no investment
in new infrastructure or technician training to maintain the existing failing architecture.
The COVID-19 pandemic created the perfect storm of issues for supporting AWOS/ASOS data
products. Many of the mandates implemented for employee safety created further challenges to
both the FAA and the telecommunications providers. It became very difficult to travel to any
remote site and even more difficult to execute joint trips with telecommunications providers that
are needed to resolve Service-A issues. Automated weather report outages increased in duration
and in numbers as repair efforts were delayed or deferred.
The FAA is aware of, and is working to correct, the obsolescence issues with AWOS/ASOS
Service-A and many other services that are regularly transported via serial/analog circuits. The
FAA engineering teams are working multiple initiatives to address what is a national concern.
There is a team dedicated to developing technology to bridge the gap between the outdated
Time-division multiplexing (TDM) communications protocols used by FAA systems to the
modern Internet Protocol (IP) technology broadly used by telecommunications service providers.
These TDM to IP conversion devices will be designed to provide interim solutions until a
broader, system-wide solution is implemented with FAA Enterprise Network Services (FENS)
(Replacement for FAA Telecommunications Infrastructure (FTI)). These solutions are still in
development and most have a common issue of data security. All of the services mentioned
interface with the live NAS network and data security and integrity must be guaranteed.
One solution the Technical Operations Anchorage District is considering to address the Service-
A issue in Alaska involves the use of cellular LTE technology for data transport. The Program
Management Organization, Network Deployment Services Team is working with a Tech Ops
engineering team to explore the option of implementing this LTE technology in Alaska on a trial
basis. Not every AWOS/ASOS location in Alaska has a cellular carrier in range, but most sites
will have coverage. If this initiative can be implemented as a pilot program, there is great
promise for much-improved Service-A performance.
Analysis of AWOS system reliability does indicate a trend of decreasing reliability of individual
sensors and overall system performance. As this system ages and nears end-of-life, these changes
in reliability are expected as even solid state equipment degrades in time. Spare parts and
components are also becoming increasingly difficult to maintain. As will all equipment systems,
the FAA continues to manage lifecycle performance through technical refresh programs and
individual projects to replace systems, as required.
Another issue discovered during a review of the Stakeholder concerns is a gap in how the FAA
reports AWOS/ASOS Service-A status to the users. The FAA provides data from these weather
stations to the users via three methods: Service-A (Automated to Internet), Dial-up (user initiated
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to a site), and VHF (radio receiver must be in range of the station). National NOTAM policy
requires NOTAMs for failed weather sensors, a full failure of the weather station, or a failure of
the VHF radio transmission capability. However, NOTAM policy does not permit a NOTAM to
advertise a failure of only the Service-A communications or the dial-up service. Users can only
determine the operability of Service-A by assumption when the data is not available via the
internet.
Navigation
Stakeholders expressed concern related to a perceived lack of a back-up navigation system to
address GPS outages, including when Department of Defense GPS Testing exercises are
ongoing. The FAA acknowledges and has addressed this concern by intentionally excluding
Alaska from current efforts to reduce the overall footprint of the Very High Frequency Omni-
directional Range (VOR) network within the CONUS to a Minimum Operating Network
(MON), known as the VOR MON program. Additionally, the FAA works very closely with the
Department of Defense to assess potential impacts related to GPS testing exercises, disseminate
the information within the affected areas, and monitor operations to ensure there are no
unacceptable impacts to the Air Traffic Control system. If anomalies are detected that impact air
traffic operations, mitigations are immediately taken.
However, the FAA does acknowledge that when navigational aids experience unexpected
failures or outages, it sometimes takes longer than desired to return that equipment to service for
various reasons. One example is the Galena VOR.
The Galena VOR was damaged beyond repair due to a river ice jam and subsequent flooding in
2013. This catastrophic natural disaster presented a funding challenge which was not budgeted,
or resolved through disaster funding. The FAA budgetary process usually requires many years to
develop, prioritize, and fund such a large project while accomplishing the other essential projects
to sustain the NAS. Rebuilding the VOR site has been an FAA collaborative effort among the
various FAA programs, to fund and oversee the numerous components of the project. The
challenges included safely clearing the site, establishing communications and electrical power
over 4.5 miles through remote and inhospitable terrain, designing and constructing the site to
meet the unique challenges of permafrost, and Alaska’s limited construction seasons. The
estimated total project cost is approximately $5 million and the target project
completion/commissioning is September 2022.
Based partially on the lessons learned from the Galena VOR experience and difficulty in
developing the proper channels to fund a key re-establishment of a major, very costly
navigational aid, the FAA established the DME, VOR, and TACAN (DVT) Program. This
program provides funds to sustain these navigational aids and enters into contracts with Industry
to provide navigation services.
The FAA has also made it a priority to sustain the VOR infrastructure in Alaska. Three recent
examples are the efforts to sustain the VORs at Annette (ANN), Level Island (LVD), and Fort
Yukon (FYU). All three of these projects are scheduled to be completed before calendar year
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2022. Additionally, major renovations were planned for the Kenai (ENA) VOR in FY21, but a
contract award protest resulted in construction delays to FY22.
T-Routes and Instrument Approaches
Stakeholders also commented on the need for continued development of T-routes for
GPS/WAAS-equipped aircraft and alternative procedures where communication capabilities are
unavailable in some parts of a route. Other comments were related to a perceived need for
development of more instrument approaches at rural airports that do not currently have them.
The FAA’s efforts related to T-route development demonstrate our commitment to increasing
and modernizing the NAS route structure in Alaska to better serve system users.
Current NAS Low Frequency/Medium Frequency (LF/MF) airways that utilize ground-based
Non-Directional Beacon (NDB) navigational aids are no longer sustainable in Alaska. However,
these airways have provided air taxi and general aviation operators the routes needed to support
over 80% of the communities throughout Alaska for several decades. The low minimum en route
altitudes (MEAs) established on such airways are critical to ensure the safest and most efficient
way of delivering personnel and cargo throughout Alaska. With NDBs being decommissioned
throughout Alaska and CONUS, a new and safe airway structure is needed to support Alaska
aviation. The T-route structure is a long-term solution to this challenge.
Since such routes are not limited by ground-based equipment, T-routes are being developed to
suit Alaska’s current needs for a safe, low altitude airway structure along the most desirable
routing corridors. Currently, 56 such T-routes have been developed. Though flight inspection is
not yet completed, the expectation is that these routes will have the same or more advantageous
MEAs than the previous structure without the reliance on obsolete equipment. Also, these routes
would avoid the high costs and logistical challenges of maintaining a ground-based system. The
T-route development process is also collaborative, where system users work closely with the
FAA to ensure the designs meet user needs.
The Stakeholders recognize that satellite-based navigation, while powerful and continuing to
rapidly evolve across both the safety and efficiency spectra, is not publishing the needed number
of instrument approaches at rural airports. Consequently, the FAA is engaging in the following
initiatives to increase and/or improve the development of more instrument approaches at rural
airports:
1) Published a total of 143 WAAS-based Localizer Performance (LP), and LP with
Vertical Guidance (LPV) approaches in Alaska as of December 2020, including
point-in-space procedures for seaplanes.
2) Collaborating with stakeholders and the State of Alaska Department of Transportation
and Public Facilities to identify and prioritize rural airports that qualify for WAAS
LPV/LP approaches.
3) Developing and applying new WAAS RNP 0.3 criteria to increase safety and
facilitate more LPV/LP approaches at airports with challenging obstacles.
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4) Improving satellite-based navigation and facilitating better service in Alaska by
increasing coverage by geosynchronous orbit (GEO) satellites.
5) Transitioning WAAS ground stations from terrestrial to satellite communications for
improved reliability.
6) Improving WAAS aircraft antenna placement for lower GEO elevations angles.
7) Increasing the number of GPS and WAAS safety assessments.
8) Planning to publish WAAS LPV/LP approaches to every qualified runway end in the
NAS, including Alaska, for fixed-wing and helicopter point-in-space approaches, and
special Required Navigation Performance (RNP) approaches.
9) Modifying the design criteria for LPV approaches to allow more runways to qualify.
10) Transitioning WAAS to dual-frequency operation, which should improve instrument
approach availability in Alaska.
Stakeholders also commented on the need for continued development of R-route concepts and T-
routes for GPS/WAAS-equipped aircraft and alternative procedures where communication
capabilities are unavailable in some parts of a route.
The Capstone-era R-routes are outdated, have not been reviewed in years, and are essentially
obsolete because only outdated Electronic Flight Instrument System (EFIS) equipment can fly
them. Many avid users of the R-routes started their company 15+ years ago using IFR and the
Capstone R-routes as key components of their business plan. These R-routes allow them to
safely operate IFR in Southeast Alaska at much lower altitudes, keeping their aircraft below
icing conditions much of the time. The FAA has initiated outreach to this select group of
operators to evaluate any changes to improving utility and, further, to gauge their contemporary
use and dependence by those operators.
Stakeholders also questioned how the FAA prioritizes the development of instrument
approaches, specifically the approval and authorization of special instrument procedures which
are a valuable tool in Alaska. Special instrument procedures can be developed where standard
criteria may be difficult or impossible to apply, or a special procedure may be developed for
private-use airports. Special procedures are often developed and funded by the FAA, however,
they may also be developed by non-FAA service providers as proprietary.
Visual Guidance Navigational Aids
The FAA is improving ground-based navigation in Alaska. For example, the FAA will continue
to improve NAVAIDs that give visual guidance to pilots during the approach and landing phases
of flight. All NAVAID sustainment/establishment efforts include the installation of new
equipment.
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Stakeholders have recommended the FAA continue to develop and integrate LED-lighted
NAVAIDs into the Alaska infrastructure to increase safety, reliability, and visibility while
reducing life cycle and maintenance costs.
Planned Visual Guidance Lighting Systems (VGLS) improvements include the following:
(1) The FAA is planning projects to replace 23 existing unsupportable Visual
Approach Slope Indicators (VASI) systems with LED Precision Approach Path
Indicators (PAPI). LED lighting technology has demonstrated brighter and more easily
distinguishable visual guidance to pilots during the approach and landing phases of flight
over the legacy incandescent lighting systems. This provides an International Civil
Aviation Organization (ICAO)-compliant visual NAVAID, which is more
distinguishable, more reliable, and has an energy savings of 62% over the incandescent
VASI system.
(2) The FAA is upgrading Medium Intensity Approach Lighting Systems with
Runway Alignment Indicator Lights (MALSRs) to include LED technology through the
replacement of the existing incandescent lamps. This effort is slated to begin in FY23.
From October 2017 to January 2018, the Juneau International Airport (JNU) was one of
the first sites to operationally evaluate the LED MALSR lamp technology. The
evaluation determined the LEDs MALSR was brighter and easier to see in Instrument
Meteorological Conditions (IMC).
(3) The FAA is also replacing Runway End Identifier Lights (REIL) with the latest
modifications will standardize the configuration and address moisture intrusion issues
which will reduce maintenance.
Communication
The FAA’s Program Management Organization (PMO), Air/Ground Voice Communications
Office has three programs addressing Communications in Alaska. The Self-Sustaining Outlet
(SSO) Replacement Program, the Next Generation Air/Ground Communications (NEXCOM)
Program and the Communication Facility Sustainment (CFS) Program. All three programs
address improving safety in Alaska through air/ground voice communications (controller to pilot
communications).
1) SSO Program This program replaced and established 14 remote facilities with
modern facilities operating with solar panels and batteries in areas that have no
infrastructure. These facilities provide critical voice communications to pilots in some of
the most remote locations. The fourteenth remaining SSO at Finger Mountain, Alaska
was completed on July 7, 2021 and is currently in service, completing the technical
refresh effort.
2) NEXCOM Program – This program is replacing all the air/ground voice
communication radios in all the RCAGs, Backup Emergency Communications Systems
(BUECs), Remote Transmitter Receivers (RTRs) and Remote Communications Outlets
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(RCOs) throughout Alaska. This program is providing the latest radio equipment in the
NAS to Alaska that is fully supported at a national level with training and logistics.
3) CFS Program – This program is providing new air/ground voice communication
frequencies and facilities to Alaska. This program improves safety in Alaska by filling
required voice communications gaps in coverage, providing seamless voice coverage in
the airspace.
Additionally, the FAA completed the Alaskan Satellite Telecommunications Infrastructure
(ASTI) Modernization in September 2019. Forty-one Alaskan NAS Interfacility
Communications System (ANICS) sites were modernized to ASTI. ASTI has improved system
availability, information system security, and life cycle support. In 2021, the FAA started a
project to replace the ASTI antenna and antenna controllers, with an estimated project
completion of 2023.
Surveillance
Another area of significant interest expressed by our aviation Stakeholders was a desire for the
FAA to expand ADS-B coverage. Also, some users commented that the FAA should put more
emphasis on ADS-B and weather in the cockpit.
The FAA plans to expand ADS-B services in the state of Alaska. As part of the FAA’s continued
planning for the Surveillance and Broadcast Services (SBS) Future Segment in FY20-FY25, the
FAA analyzed the potential to expand ADS-B infrastructure to include the remaining five Alaska
Service Volumes not covered by the SBS Capstone Statewide Plan which defined ADS-B
ground infrastructure deployments and aircraft equipage plans throughout the state.
As a brief background, in August of 2007, the FAA, in concert with Alaska aviation industry
Stakeholders, developed and jointly approved the “Surveillance and Broadcast Services
Capstone Statewide Plan”. This plan identified 14 Service Volumes (SV) along with the aircraft
equipage rates necessary to provide a benefit-to-cost ratio with positive net benefits to the FAA
and industry. Nine of these SVs were implemented as part of the baseline SBS Program and five
were not implemented because they did not attain the necessary aircraft equipage levels for a
positive net benefit at that time. In 2017, the Aircraft Owners and Pilots Association (AOPA)
requested an expansion of ADS-B radio station coverage, with Alaska being one of the main
points of focus. The FAA then began coordinating with the Alaska aviation industry and other
Stakeholders on deploying ADS-B services for the five non-implemented SVs listed in the
original SBS Capstone Plan in a manner which provided coverage of current major air routes in
Alaska. The FAA, working with industry and Alaska Stakeholders, has developed a priority set
of locations for ADS-B deployments and is working diligently towards the approval of funding
for this effort while simultaneously encouraging the continued increase in aircraft ADS-B
equipage in Alaska to leverage the new infrastructure.
Emphasis on the delivery of valuable flight information to the cockpit via Flight Information
System Broadcast (FIS-B) is also a high priority and was a driving factor in the FAA’s decision
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to increase the look-ahead range of all available FIS-B products in the state. This allows
appropriately equipped aircraft to access critical data such as regional Next Generation Weather
Radar (NEXRAD), METARs, Terminal Area Forecast (TAFs), and PIREPs at a distance of 500
NM (nautical miles), effectively doubling the previous distance of availability.
Safety Management
Stakeholders voiced some concerns that could be categorized as Safety Management issues.
These issues are related to the systems FAA has in place to ensure safety is maintained, risks are
identified, information is disseminated, and/or mitigations are in place.
One example is the concern that the FAA must address and improve the effectiveness of the
NOTAM System. The concerns were related to the following two areas:
(1) NOTAM cancellation - Under the FAA NOTAM Modernization initiative, efforts are
underway to transition FAA Order 7930.2, National Policy for NOTAM over to the
ICAO Standard. Targeted for full implementation in the fourth quarter FY2024, the
new ICAO Order ushers in significant improvements governing the current US
NOTAM operations supporting the NAS. This also harmonizes current US NOTAM
Policy with the ICAO Standards and Recommended Practices (SARPS).
Additionally, a modern and efficient automation platform replaces the current legacy
system, USNS (US NOTAM System), to improve the timely processing and global
distribution of US NOTAMs.
(2) Verification limitations for conversion of PIREPS to NOTAMS where a Flight
Service Station or other suitable FAA facility is not co-located on the airport.
Federal Flight Service Stations (Alaska only)
FAA Flight Service strives to increase safety in all of its programs, with particular interest in
Alaska, due to its extreme terrain and weather that disproportionally impacts accident and fatality
rates. Flight Service in Alaska is focused on modernizing facility infrastructure that will meet
current industry standards. These efforts include modernization of the automation and voice
switch capability to improve safety sustainability and accessibility for the aviation community.
Along with the Weather Camera Program (already discussed), Flight Service is focusing on the
Enhanced Special Reporting Service (eSRS).
Enhanced Special Reporting Service (eSRS)
Over the last several years, the FAA has fine-tuned the eSRS that provides situational awareness
and helps to expedite search and rescue (SAR) operations in Alaska. Pilots must establish a
master flight plan with Flight Service and set up their satellite/GPS tracking device to participate
in the program. The FAA begins search and rescue action upon receipt of a distress message
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from one of these satellite/GPS tracking devices. The tracking device augments the normal
VFR/IFR flight plan search and rescue process, allows a quicker response, and reduces the total
search time by providing a known track or location from the distress message.
An eSRS internal baseline release is anticipated for 2022, which will enhance the service with
two-way text communications between Flight Service Specialists and pilots. The enhancement
will also enable pilots who have registered with Flight Service through the master flight plan
program to communicate via two-way texting enabling flight movement messaging and other
communications needs in otherwise underserved voice communication areas outside of
the eSRS program.
Bethel Work Group
The Bethel, Alaska, Aviation Work Group was established in 2018 to mitigate and reduce the
safety events in the airspace surrounding the Bethel Airport. Safety events and instances of Near
Mid-Air Collisions (NMACs) have been significantly reduced by the enhanced use of beacon
codes and ADS-B for position determination by controllers and pilots. Events have been
reduced as follows:
2018 - 66 events, of which 12 were NMACs
2019 - 90 events, of which 4 were NMACs
2020 - 40 events, of which 2 were NMACs
2021 – 28 events with no reported NMACs
In December 2018, the Bethel (BET) Air Traffic Control Tower (ATCT) and the Anchorage Air
Route Traffic Control Center (ARTCC) established a Beacon Code Letter of Agreement (LOA)
which authorized BET ATCT to use beacon codes to enhance situational awareness in
determining aircraft position. In October 2019, the FAA and Stakeholders established the BET
Airport Frequent Flyer Program which uses pre-assigned codes for each aircraft of signatory
users. These procedures increased safety by providing air traffic controllers and pilots the same
information as a basis for determining the position of aircraft. The workgroup continues with the
focus transitioning to surface safety of the Airport Operations Area.
The Bethel Aviation Work Group meets quarterly and now includes runway safety topics,
elevating the airport users awareness of surface safety related issues and concerns when
operating in the movement area.
Runway Safety Action Team
The Runway Safety Action Team (RSAT) convenes to discuss surface movement issues and
concerns at a particular airport and formulate a Runway Safety Action Plan (RSAP) to address
those concerns. Regional and local RSATs include personnel from the ATCT and airport
operator and may include personnel from various FAA LOBs (including Runway Safety) and
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interested users of the airport. Composition of special focus teams vary. All attendees at the
RSAT meeting are considered to be part of the RSAT. A Regional RSAT is led by Runway
Safety and local RSAT is led by the ATCT manager.
Outreach to General Aviation Pilots
FAA Runway Safety provides videos (specifically, From the Flight Deck and Runway Safety
Pilot Simulator videos) to improve pilot awareness for taking off, landing, and operating in the
airport movement area.
The From the Flight Deck video series provides pilots with actual runway approach and airport
taxiway footage captured with cockpit-mounted cameras, combined with diagrams and visual
graphics to clearly identify hot spots and other safety-sensitive items.
FAA’s Runway Safety Pilot Simulator video series is a self-guided resource to assist flight
instructors with teaching student pilots surface safety best practices before the students enter the
cockpit. It allows student pilots to navigate on airport surfaces while communicating with ATC
and following instructions provided. The scenarios are interactive and allow viewers to make
decisions based on ATC instructions.
Pilot/Controller Forums are venues that provide two-way communications regarding aviation
safety issues. The goal of the meeting is to elevate pilots and controllers awareness of safety
issues and concerns on and around airports.
Mountain Pass Working Group
The ATO continues to improve Alaska VFR sectional charts with over 50 mountain passes either
added, verified, or locationally corrected, with standardizing names and the addition of Alaskan
mountain pass elevations. By verifying charted information and adding elevations to mountain
passes, chart users have more complete information when navigating through mountainous
terrain.
Alaska Chart Supplement
The ATO is establishing a Stakeholder workgroup to examine the current Alaska Chart
Supplement content, currency, and accuracy and make recommendations to improve the
publication’s Notice and Supplementary information. The workgroup will define the roles of the
FAA Western Service Area and the Aeronautical Information Services offices with maintaining
and updating content in the chart supplement product. The workgroup’s effort will result in
identifying and prioritizing Stakeholder recommendations which the FAA will use to modernize
the Alaska Chart Supplement. The end result of this collaborative effort will be to define
Stakeholder content need and establish processes for Alaska Chart Supplement’s continuous
review and update.
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The above programs provide a summary of ATO initiatives in Alaska for the past and coming
years. Appendix 1 also provides a full listing of programs. However, more effort is needed to
further reduce the accident rate in Alaska, and outlines of these efforts will be provided in later
sections of this report.
2.3 Office of Airports (ARP) Summary
In the FAASI Interim Report, the Office of Airports (ARP) – specifically, the Alaskan Region
Airports Division (Airports Region Office) – anticipated Alaska-specific airport Stakeholder
focal points to include:
(1) the extensive financial investments ARP enables via federal funding provided to
airport sponsors through the AIP and related supplemental funding as well as specific,
timely airport revenue replacement and capital infrastructure improvement funding
legislation related to the COVID pandemic;
(2) the importance of the 14 CFR Part 139 airport certification and safety program;
(3) new provisions contained in Section 147 of the FAA Reauthorization Act of 2018
related to the transfer of airport sponsor-owned AWOS units to the FAA, and
(4) collaboration with internal and external Stakeholders to promulgate value-added
airport infrastructure improvements and development opportunities.
Indeed, throughout the FAASI Stakeholder collaborative process, these four principles were the
collective subjects of a significant amount of discussion.
Equally as important, Stakeholders also raised the following related points:
(1) VWOS research and development, the status of FAA certification, and airport sponsor
acquisition and installation;
(2) airport sponsor-issued NOTAM specifically concerning airfield condition reporting
and associated issuance delays and hindrances;
(3) FAA airport design and runway length and width criteria at airports in Alaska,
specifically shortening runway lengths to meet FAA design standards, and
(4) an interest in elimination of 14 CFR Part 139.1(c)(3) which directs Part 139
applicability in Alaska to airports during periods of scheduled air carrier service using
aircraft configured with 31 or more passenger seats as compared to Part 139’s
applicability to aircraft configured with 10 or more passenger seats as is the case in the
rest of the United States.
Federal funding
In FY21, the Airports Region Office anticipates award of a total of $346M of combined federal
funding in Alaska. The funding is provided via the Airport Improvement Program (AIP),
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Coronavirus Response and Relief Supplemental Act 2021, and the American Rescue Plan Act of
2021. These funds are awarded directly to airport owners and operators (FAA-recognized
“airport sponsors”) to effect airport infrastructure improvements and development projects which
constitute a number of airports-related recommendations within this Final Report.
14 CFR Part 139
Any change to apply certification standards for scheduled operations conducted in aircraft
configured for ten or more passenger seats or supplemental operations conducted in aircraft
configured for 31 passenger seats or more would require congressional action to amend 49 USC
44104(b)(3) and thereafter require the FAA to conduct rule-making to amend 14 CFR 139.1 and
14 CFR 121.590. The FAA has not recommended to Congress any modification to the existing
regulatory structure.
AWOS and VWOS Deployment
Section 147 of the FAA Reauthorization Act of 2018 establishes the provision for the transfer of
eligible air traffic systems or equipment (specifically AWOS units, among other systems) to the
FAA. The Airports Region Office administers the Section 147-responsive AWOS procurement
and airport sponsor installation initiatives in Alaska by working with Airport sponsors and the
FAA Technical Operations (Tech Ops) for integration into the National Airspace System (NAS).
Tech Ops is the division of FAA responsible for effecting unit transfers to FAA ownership and
maintenance.
The deployment of AIP-funded AWOS units is a multi-phased process. Individual airport
sponsors make their own policy and financial determination whether to apply for AIP funding for
construction of an AWOS at an individual airport. Thereafter, the Airports Region Office
reviews the application and, if funded, the airport sponsor is responsible for oversight of the
construction and installation. If a sponsor determines other priorities dictate against application
for AWOS-related funds, then the FAA does not simply fund an AWOS unit out of its
operational funds. Thus, the deployment is somewhat dependent on airport sponsor
prioritizations.
If funded and constructed, the sponsor will then work with Tech Ops for any transfer to the FAA
and the corresponding assumption of maintenance and quality assurance for the units.
Regarding Stakeholder interest in VWOS units, as of the date of this Final Report, VWOS unit
procurement and installation funding is not eligible under the Airport Improvement Program.
Congressional approval is a necessary element for the use of AIP funds. Should such approval be
enacted, the Office of Airports would then develop policy guidance for award of AIP funds to
sponsors. Because VWOS is in a developmental stage, other LOBs (ATO and AVS) are
currently evaluating its fidelity, feasibility and potential for use by air carriers.
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Airfield condition NOTAMs
The Airports Region Office has added airport sponsor-issued airfield condition NOTAMs to its
focal point discussions with sponsors to not only impress NOTAM importance, but also to
identify and offer corrective solutions to reporting delays and hindrances.
Airport design/runway length criteria
The FAASI Stakeholder collaboration process prompted a discussion of airport design criteria
contained in FAA Advisory Circular 150/5300-13A, Change 1, as well as runway length
requirements for airport design under Advisory Circular 15-/5325-4B with particular reference to
critical aircraft determination and associated runway length standards. The Airports Region
Office is responsible for communications and oversight of implementation of both advisory
circulars by airport sponsors related to airport and airfield design. Collaboration continues to be
the focal method for airport design integrating the Airports Region Office, airport sponsors,
engineers and the needs of the aviation industry and operators.
The Airports Region Office values its multiple roles in facilitating the improvement of public-
use airport infrastructure in the FAA Alaskan Region. The Region Office fully supports the
FAASI initiative and is vested in the favorable outcomes of numerous communications,
meetings, and collaborations with airport sponsors and other Stakeholders.
3.0 Conclusions and Recommendations to the FAA Administrator
Considering the content of both this Final Report and the previously-issued Interim Report, with
particular reference to Stakeholder input and LOB summaries, the FAASI presents the following
11 recommendations to the FAA Administrator:
1. Weather Reporting Enhancements (AWOS/VWOS)
One of the primary focal points of FAASI is the requirement for additional and enhanced
weather reporting capability via ground-based systems such as AWOS and VWOS.
Recommendation 1.1: Continue FAA focus on new-installation AWOS units at airports
for which the airport sponsor requests unit acquisition, installation, and FAA certification
with funding under the Airport Improvement Program. Consistent with Section 147 of the
FAA Reauthorization Act of 2018, complete each of the initial eight AWOS unit transfers
at Alaskan airports (Kotlik, Tok Junction, Coldfoot, Nulato, Perryville, Crooked Creek,
Tununak, and Akiachak) to the FAA by October 2022. Optimize the process to transfer
AWOS units from airport sponsor ownership to the FAA, enabling seamless completion
of the same in a more timely manner.
Stakeholder feedback also expressed concern about the FAA’s timely acknowledgment
and repair of existing FAA-owned AWOS/ASOS units which experience frequent service
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outages, including associated surface communication outages. FAA should conduct a
study to examine the root cause of “Service A” outages and associated impacts and
identify alternative mitigations which could include infrastructure improvement
recommendations, alternate notification procedures, and/or the issuance of NOTAMs
advising of outages. FAA should consider any necessary changes to FAA Joint Order
7900.5 Surface Weather Observing and FAA Order 7930.2 Notices to Airmen
(NOTAM).
Recommendation 1.2: Continue testing and evaluating VWOS systems at four Alaskan
airports (Palmer, Healy River, Tatitlek, and Eek) with the goal of completion by August
2022. FAA has developed standards for air carrier use during testing and validation of
the VWOS units and will develop standards for non-sensor visual-based weather
information to support gridded weather analysis information currently available from the
National Weather Service.
Upon successful completion of the evaluation, the FAA seek funding for VWOS unit
acquisition and installation at airports throughout the state of Alaska where AWOS
and/or ASOS units do not exist. Aircraft operators intending to utilize VWOS
technology to support IFR operations are required to submit a program for acceptance to
their FAA Principal Operations Inspector to grant modification of FAA-issued
Operations Specifications.
2. Navigation Strategy Development
Collaboration with Stakeholders prompted a significant amount of discussion related to
development of an Alaska airspace navigation strategy, associated policy for lower-altitude
operations, and plans for GPS resiliency. Specific points of reference centered on equipment
requirements when using GPS for navigation and optimizing/enabling lower-altitude direct flight
paths.
Recommendation 2.1: The FAA evaluate and clarify aircraft operator authorization and
eligibility requirements for commercial aircraft operations under Instrument Flight Rules.
Specifically, FAA should update the policy and guidance related to equipment
requirements for commercial operators when using GPS for navigation.
Recommendation 2.2: The FAA evaluate a potential policy change permitting
communication gaps on routes where communication capability is the determining factor
for the minimum enroute altitude. This would allow flexibility for aircraft operators with
performance limitations or icing concerns while still maintaining acceptable terrain and
obstacle clearance.
FAASI FY21 Final Report
27
Recommendation 2.3: The FAA develop strategies to address GPS backup resiliency in
Alaska. These strategies may include plans for retention and long-term support for
conventional navigation aids.
Recommendation 2.4: The FAA continue the development of T-routes as a replacement
for Low Frequency/Medium Frequency (LF/MF) and other conventional airways by
2025.
3. Aeronautical Charting
The importance of accurate and relevant aeronautical charting, given the extent of topographical
and geographical challenges in Alaska, was discussed intently during the FAASI process.
Recommendation 3.1: The FAA continue the Mountain Pass Working Group initiative
and partnership with the Aircraft Owners and Pilots Association aimed at verifying
existing mountain pass information and adding additional mountain passes to the Alaska
VFR sectional charts as coordinated through the Service Center and as information
becomes available.
Recommendation 3.2: Aeronautical Charting Meetings (ACM) are held bi-annually to
identify issues concerning safety and usefulness of aeronautical charts and flight
information products/services. To ensure adequate focus is placed on this initiative, FAA
should ensure time is reserved at every future meeting to specifically address Alaska-
specific charting needs that may be different than the continental United States.
4. Surveillance
Stakeholder discussions and FAASI internal conversations often revolved around the need for
additional air traffic surveillance capability, particularly given the number of recent aircraft
incidents, accidents, and near mid-air collisions in Alaska. ADS-B equipage and coverage was a
frequent topic.
Recommendation 4.1: The FAA continue education and outreach with Stakeholders
related to the requirement for equipage of ADS-B Out within certain airspace in Alaska,
with a focus on the safety-enhancing benefits of aircraft position notification/display for
users within all airspace. Indeed, a large number of Alaska operators have independently
equipped with ADS-B Out and In or were participants in the FAA Capstone upgrade
program which replaced first-generation equipment on approximately 400 aircraft with
rule-compliant equipment. And, the extensive usage of it demonstrates the positive safety
impact not only in airspace for which ADS-B is required, but also where the system is not
required.
FAASI FY21 Final Report
28
Recommendation 4.2: The FAA continue its efforts to deploy ADS-B services for the
five non-implemented service volumes in a manner that will provide coverage along
major air routes in Alaska.
5. Safety Outreach
The FAASI team and Stakeholders both repeatedly recognized the value of safety programs and,
importantly, the opportunity to conduct them jointly while realizing the resultant synergistic
value.
Recommendation 5.1: The FAA continue the various safety programs already
underway and seek to maximize adjacent opportunities for program integration. For
example, FAA sponsors and/or participates in numerous programs such as Runway
Safety Action Team meetings, the Aviation Safety Action Program, and Alaska-specific
working groups including the Bethel Work Group and the AOPA-sponsored Mountain
Pass Working Group. There are opportunities for FAA LOBs to conduct safety outreach
efforts jointly among each other and via these program initiatives to address an entire
realm of operational and environmental safety requirements and best practices. One such
opportunity may exist at the Bethel Airport (BET). The FAA should explore combining
efforts between AVS, ATO, and ARP utilizing the BET as a pilot program that addresses
runway safety, local air traffic and traffic pattern safety, Class D airspace requirements,
and accident/incident analysis and discussion utilizing a shared set of safety data. FAA-
derived data and subject matter expert presentation material would become even more
meaningful and would be more apt to be cohesively delivered in prospective multi-
meeting settings.
4.0 Next Steps
Reducing fatal and serious injury accidents and increasing system efficiency remains the focus of
FAASI. During FY22, the FAASI team will be expanded to include additional FAA LOBs.
Specifically, the Office of Hazardous Materials Safety (ASH) will join the FAASI effort. This
expanded team will develop a roadmap for near- and mid-term implementation of FAASI
recommendations. The roadmap will focus on initiatives with the greatest benefit to safety and
will emphasize achievable, cost-effective implementation.
The FAA will continue Stakeholder engagement concentrated on the needs of the national
airspace system and specifically the Alaskan aviation community. The FAA will share the draft
roadmap and implementation plans and solicit information from appropriate external
Stakeholders. External engagement will remain essential and continuous. This will not change
or replace the normal collaboration related to day-to-day agency operations.
Milestones for this effort will include:
1. The FAA shall establish a cross-organization “tiger team” to develop the roadmap
based on the recommendations in the FAASI Final Report with a prioritized emphasis
FAASI FY21 Final Report
29
on those recommendations that may be quickly integrated in the national airspace
system. Team composition and designation shall occur on or before January 15, 2022.
2. The tiger team shall develop an initial draft of the roadmap by February 15, 2022.
3. The roadmap shall be presented to the external Stakeholders and associated
engagement with those Stakeholders will be completed by May 30, 2022.
4. The FAA will commence implementation of roadmap initiatives.
5. The tiger team, supplemented by other FAASI elements of the agency, will
incorporate Stakeholder feedback into a FAASI progress report released to the
Stakeholders no later than September 30, 2022.
In addition to the broader research and reporting standards outlined above, two specific goals
will be incorporated into FAASI efforts in FY22:
1. Support increased testing and potential deployment of VWOS in underserved
locations.
2. Commission the eight newly-deployed AWOS in Alaska by September 30, 2022.
Measureable progress will remain an integral part of FAASI both in terms of achieving
meaningful improvement to the safety of the NAS in Alaska and public confidence that the
FAASI process was intended to achieve meaningful results.
FAASI FY21 Final Report
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List of Appendices
Appendix 1: Prioritized List of Initial Efforts
Appendix 2: Glossary of Terms
Appendix 3: Table of Stakeholder Comments
Appendix 4: Links to Reference Documents
FAASI FY21 Final Report
31
Appendix 1: Prioritized List of Initial Efforts
AIR TRAFFIC ORGANIZATION
ATO Efforts
Description
Category
Weather
AWOS, SWS, and
SAWS Upgrades
Will upgrade weather systems to extend service life.
Ongoing
Weather Camera
Expansion – VWOS
The Weather Camera Program is conducting a business
case analysis to fund up to 160 new camera facilities at
locations throughout the state of Alaska where services
are determined to be beneficial to aviation operations.
The analysis will be completed in early FY23 and
installations will follow. The installed systems will be
a combination of WCAMs and VWOS systems
depending upon the locations and needs of the intended
location, increasing aviation safety and efficiency
throughout Alaska.
Ongoing
NEXRAD Pedestal
Refurbishment
These projects are efforts to sustain the weather
sensing RADAR sites across Alaska. These sites are
typically in remote, harsh areas with punishing weather
that takes a toll on this equipment. Sustainment efforts
on these important systems were completed at all 7
Alaska sites.
Ongoing
PIREPs
FAA Flight Service is collaborating with stakeholders
to increase the quality and quantity
of PIREPs throughout the NAS, including in Alaska.
These efforts will assess an electronic feedback
mechanism on the FAA weather camera website and
the Leidos web portal and evaluate for effective
communication regarding PIREPs. Efforts to improve
and modernize the PIREP system include exploring
how voice-to-text technology and machine learning
might be used to alleviate issues with PIREP
submission and retrieval. Options to incentive PIREP
use are being discussed.
Ongoing
Alaska RVR Refresh
The FAA has a funded program to replace all Alaska
RVR systems with newer PC based RVRs by 2026.
Ongoing
Navigation
Galena VOR
Replacement Project
The Galena VOR was damaged beyond repair due to
an ice jam and flooding in 2013. Construction is
underway and is estimated to complete by Winter
2021-2022.
Ongoing
FAASI FY21 Final Report
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ATO Efforts
Description
Category
Sustainment of DME,
VOR,
and TACAN (DVT)
Program
Program is being established to sustain these
navigational aids and enter into contracts or
partnerships with industry to provide navigation
services.
Ongoing
Publish WAAS LPV/LP
Approaches to Every
Qualified Runway End
Developing and applying new WAAS RNP 0.3 criteria
to increase safety and incentivize WAAS equipage.
Ongoing
WAAS Procedures
Collaborating on Certificate of Authorization with
specific focus on airspace planning, route structure,
and transitioning airspace to and from approved and
unimproved landing zones, airports and austere
locations.
Ongoing
PAPI Installations
Installation of PAPIs at 19 additional locations is
planned by 2026.
Medium
Communications
Self-Sustaining Outlet
Replacement Program
The fourteenth remaining SSO at Finger Mountain,
Alaska was replaced in July 2021, completing the
technical refresh effort.
Ongoing
Anchorage Fiber Optic
Telecommunications
System
Anchorage replacement/establishment project has been
an ongoing effort for the last five years. The entire
FOTS will be established along with the new ATCT
project; estimated completion 2029.
Ongoing
Replace all VHF/UHF
Radios at
RTR & RCO Facilities
Planned radio replacement at all 118 RCOs in Alaska
by December 2026.
Medium
Establish
RCO/RTR Facilities/
Frequency
The FAA has funded projects to establish/replace
RCOs at three locations (Golovin, Chignik, Swentna),
the Fairbanks RTR, Lake Clarke SSO. Additionally,
the following projects are seed funded and awaiting
full project development and funding: Klawock
RCAG, McCarthy RCO, Galbraith Lake RCO.
High
Surveillance
Frequent Flyer Program
Assigns discrete transponder codes to individual
general/commercial aviation aircraft at several
locations throughout Alaska. Improves situational
awareness for pilots and controllers.
Ongoing
ADS-B Radio Station
Service Volumes
FAA anticipates an imminent funding decision for new
ADS-B service volumes which would supply
additional coverage within five areas.
High
FAASI FY21 Final Report
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ATO Efforts
Description
Category
ASSC
The implementation of Airport Surface Surveillance
Capability (ASSC) has increased safety at Anchorage
ATCT by providing controllers a real-time picture of
traffic on and in the immediate vicinity of the runways
and taxiways. Installed in July of 2021, it has added
situational awareness over Airport Surface Detection
Equipment (ASDE) / Airport Movement Area and
Display (AMASS) aircraft and vehicles are tagged
with call signs and conflict detection and alerts are
provided aurally and visually to controllers. The ability
to display closed portions of taxiways will prevent
unwanted aircraft movement on closed or unsafe
surfaces during construction. Additionally, these new
capabilities will be invaluable during inclement
weather and snow removal operations. Finally, ASSC
Taxiway Arrival Prediction (ATAP) is slated to be
installed in the near future and will provide an even
greater level of safety by detecting aircraft aligned with
a taxiway. Wrong surface landings are a current ATO
focus item as they are often difficult to detect only
through manual scan in a timely fashion.
High
Safety Management
Alaska Chart Supplement
A workgroup has been established to decide ownership
of Alaska Chart Supplement data and to analyze
currency and accuracy of the information as well as
establish processes for its continuous review and
update.
Ongoing
Aeronautical Charting
Meetings
Aeronautical Charting Meetings (ACM) are held bi-
annually to identify issues concerning safety and
usefulness of aeronautical charts and flight information
products/services.
Ongoing
Mountain Pass Working
Group
This group is working on standardizing the names and
locations of the Alaskan mountain passes for VFR
sectional charts.
Ongoing
Bethel Tower Work
Group
The efforts of this work group are ongoing, and aimed
at improving pilot and air traffic controller situational
awareness.
Ongoing
FAASI FY21 Final Report
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ATO Efforts
Description
Category
Airport Construction
Advisory Council
The Airport Construction Advisory Council (ACAC) is
dedicated to ensuring the safety of all stakeholders
operating in the NAS during all runway and taxiway
construction projects. The ACAC is tasked with
developing strategies and risk mitigations, for Air
Traffic Managers (ATMs) to employ, that will enhance
surface safety and ensure that communication is
complete and consistent.
Ongoing
Air Traffic Services
Public Outreach
Programs
Includes the Alaska Civil Military Aviation Council,
Aviation Industry Council, Alaska Aviation
Coordination Council, pilot/air traffic controller
forums, RSAT meetings, numerous working groups,
and collaboration with AOPA and the AACA.
Ongoing
Flight Service Station
Pilot Outreach Safety
Meetings
Pilot Safety meetings are held at airports collocated
with an active Flight Service Station.
Ongoing
FAAST
Disseminates aviation notices and information (such as
Temporary Flight Restrictions, etc.) to general aviation
pilots in Alaska.
Ongoing
RSAT Meetings
RSAT convenes to discuss surface movement issues
and concerns at a particular airport and formulate a
Runway Safety Action Plan (RSAP) to address those
concerns.
Ongoing
Runway Safety Outreach
to GA Pilots
From the Flight Deck Videos and Pilot Simulator.
Utilizing online resources and social media, Runway
Safety provides videos and interactive pilot simulations
to improve pilot awareness for taking off, landing, and
operating in the airport movement area.
Ongoing
Review of Alaskan
Offshore Airspace
An effort is underway to examine compliance with
FAA orders and directives related to offshore
airspace including limiting domestic airspace outside
of 12 nautical miles from the shore.
Ongoing
Clear Air Force
Station Airspace Proposal
The USAF is proposing to establish/modify restricted
area airspace over Clear Air Force Station to provide
the protective airspace required for a new Long Range
Discrimination Radar.
Ongoing
Anchorage Terminal
Area Airspace and
Procedures Study
(ATAAPS)
The goal of the ATAAPS is to consider all aspects of
aviation in the Anchorage area and align air traffic
flows and associated delegated airspace to produce a
more efficient, safe and predictable operation for all
users. This effort will produce detailed standard
operating procedures and agreements between affected
facilities.
FAASI FY21 Final Report
35
ATO Efforts
Description
Category
Anchorage ATCT
Replacement Project
The FAA is in the design phase to replace the ATCT at
the Ted Steven International Airport. This replacement
will improve air traffic controller visual line of sight at
both Ted Stevens and the Lake Hood Seaplane Base.
High
Alaska Flight Service
Student Academy
The FAA established the Alaska Flight Service
Training Academy (AFSTA) in Kenai, Alaska in 2011
to train the federal workforce unique to Alaska. The
FAA recently refurbished and expanded AFSTA and
continues to hire and train new Flight Service
specialists. The new facilities enhance simulation lab
instruction and allow for further expansion of class size
and student throughput. In addition, five new
instructors were hired to ensure the continued success
and exceptional training remain the standard for future
Flight Service controllers in the years to come.
Technical Training (AJI) is working with AFSTA to
create a new, revised training course. The course runs
over four months and is the longest initial qualification
course in Air Traffic. The revision effort is underway
with a completion date expected in 2023. There is a
current “local hire” effort underway to recruit Alaskans
who are interested in aviation and demonstrate the
necessary aptitude for this type of work.
Ongoing
Automation
eSRS
This enhancement will provide registered pilots with a
means to communicate with Flight Service via two-
way texting and enable them to activate, close, or
amend their flight plans and other communications
needs in otherwise underserved voice communication
areas outside of the eSRS program. An eSRS internal
baseline release is anticipated for 2022.
Ongoing
ASTI Sustainment
An antenna and antenna controller replacement project
will commence in 2021 and is scheduled to complete in
2023.
Medium
ERAM
This system, if approved, would be implemented in
2025-2026 and will replace the aging MEARTS and
FDPS at Anchorage.
Medium
Advanced Technologies
Oceanic Procedures
Expansion
Currently have a group working on contingency
procedures that will allow Oakland, CA and
Anchorage the ability to assume either facility’s
airspace.
Ongoing
FAASI FY21 Final Report
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ATO Efforts
Description
Category
Standard Terminal
Automation Replacement
System Standardization
Planned upgrade of STARS standardized components
at five ATCT to the latest hardware baseline.
Ongoing
OFFICE OF AIRPORTS
ARP Efforts
Description
Category
Internal Collaboration
Collaborating with all FAA LOBs to enhance
understandings of coordinating processes, procedures,
and priorities.
Ongoing
External Collaboration
Collaborating with airport sponsors; airport
stakeholders; aviation advocacy organizations; aviation
interest groups; other federal, state, and local regulatory
entities, and the general public engaging in strategic
discussions/meetings regarding airport/airfield strategic
development, airport system planning, airport planning
and capacity initiatives, and best practices related to
airport fiscal planning.
Ongoing
Airport Improvement
Program (AIP)
Leading and implementing the regional AIP with a
particular focus on funding capital development and
infrastructure improvements meeting the unique needs
of Alaskan airports, seaplane bases, and heliports.
Ongoing
Airports Capital
Improvement Program
Identifying and prioritizing eligible development
projects and initiatives within the constraints of
available federal funding and project eligibility and
justification criterion.
Ongoing
Airports Environmental
Management Program
Consistent with the National Environmental Policy Act
and other federal environmental laws and regulations,
working with airport sponsors and other interested
parties to make environmental determinations which
serve as a foundation for execution of capital
development projects.
Ongoing
Airports Compliance
Program
Oversight of airport sponsor adherence with federal
AIP grant assurances requiring sponsors to maintain
and operate their facilities safely and efficiently and in
accordance with specified conditions.
Ongoing
Alaskan Region Airport
Safety Program
Oversight of general aviation airport safety, runway
safety, and airports certificated under Part 139
regulations
Ongoing
AWOS AIP Grants
Collaboration with airport sponsors to procure AWOS
utilizing AIP funding.
Ongoing
FAASI FY21 Final Report
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AVIATION SAFETY
AVS Efforts
Description
Category
ASAP Part 135 outreach
Expand the ASAP Initiative to attain 100% outreach
with Part 135 Operators.
Ongoing
Weight and Balance
Program Revisions
The FAA has amended the templates for
OpSpecs/MSpecs/LOAs to ensure operators use
updated information in maintaining FAA approval
of their WBPs.
Ongoing
CFIT Accident Prevention
Initiative
Outreach and education to reduce CFIT accidents.
Ongoing
FAAST Outreach
FAAST safety seminars, WINGS safety program,
IA Seminars, and outreach activities.
Ongoing
HR 302 Section 322
approval process
improvements
Continue to approve the stipulation in HR 302
Section 322 that allows operators to operate into
airports without weather reporting systems.
Ongoing
Aircraft safety enhancing
equipment and
modifications outreach
Promoting the certification of several safety
enhancing equipment and modifications.
Ongoing
DeHavilland Operators
International Working
Group
Lead for the DeHavilland Operators International
Group
Ongoing
Operational safety oversight
of aircraft fleet
Monitor Alaska’s aviation fleet to promote
continued operational safety of aircraft
Ongoing
ADS-B certification and
approval process
Streamline the ADS-B certification and approval
process.
Ongoing
VFR/GPS routes in Alaska
mountain passes
Implementing VFR/GPS routes for Alaska mountain
passes for high risk on demand carrier including
Flight Risk Profiles/Dispatch Procedures.
Ongoing
Special procedures to
remote Alaskan airports
Approve and manage special procedures to provide
IFR access to remote airports in Alaska.
Ongoing
SMGCS approvals
Surface Movement Guidance Control Systems
(SMGCS) approval at Anchorage and Fairbanks
Ongoing
Alaska Mountain Pass
Waypoint Charting
initiative
Leading an effort for the resolution on the Alaska
Mountain Pass Waypoint Charting initiative.
Ongoing
Voluntary Safety Reporting
Program expansion
Expansion of Voluntary Safety Reporting
Programs to incorporate Safety Management System
principles.
Ongoing
Navigation equipment and
surveillance requirements
clarification study
Identify opportunities to increase IFR operations to
identified barriers for Part 135 operators.
Ongoing
FAASI FY21 Final Report
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AVS Efforts
Description
Category
Communication gaps and
minimum IFR altitudes
study
Identify regulatory, infrastructure, and equipage
barriers to low altitude IFR operations for Part 135
operators.
Ongoing
Non-Part 95 Capstone
Routes and Minimum En
Route Altitudes
Normalize the Non-95 Capstone Routes through the
waiver process or increased Minimum En
route Altitudes
Ongoing
ASAP Initiative Expansion
Expand the ASAP initiative to include operators
under all FAR parts.
Ongoing
ASAP Part 135 outreach
Expand the ASAP Initiative to attain 100% outreach
with Part 135 Operators.
Ongoing
FAASI FY21 Final Report
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Appendix 2: Glossary of Terms
AACA - Alaska Air Carriers Association
ADS-B Automatic Dependent Surveillance Broadcast
ARP FAA Airports
ASAP Aviation Safety Action Program
ASTI Alaska Satellite Telecommunications Infrastructure
ATC Air Traffic Control
ATO FAA Air Traffic Organization
AVS FAA Aviation Safety
ASOS – Automated Surface Observing Systems
AWOS Automated Weather Observing Systems
CFITControlled Flight into Terrain
CNS – Communications, Navigation, Surveillance
CONUS – Contiguous United States
CTAF – Common Frequency Advisory Frequency
eSRS Enhanced Special Reporting Services
EFIS Electronic Flight Instrument System
FAA Federal Aviation Administration
FAASI FAA Alaska Aviation Safety Initiative
FAAST FAA Safety Team
FCN – Field Condition NOTAM
FIS-B - Flight Information System Broadcast
GA – General Aviation
GPS Global Positioning System
ICAO - International Civil Aviation Organization
IFR Instrument Flight Rules
IMC – Instrument Meteorological Conditions
LF/MF - Low Frequency/Medium Frequency
LOB Lines of Business
LP Localizer Performance
LPV LP with Vertical Guidance
NAS National Airspace System
NAVAIDs Navigational Aids
NTSB – National Transportation Safety Board
PIREP – Pilot Report
RA Alaskan Region Regional Administrator
RCO – Remote Communications Outlet
RTR Remote Transmitter/Receiver
RVR - Runway Visual Range
SBS - Surveillance and Broadcast Services
T-routes – RNAV Terminal Transition Routs
UAS Unmanned Aircraft System
VFR Visual Flight Rules
VOR VHF Omni-directional Radio Range
VWOS Visual Weather Observation Systems
WAAS Wide Area Augmentation System
FAASI FY21 Final Report
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Appendix 3: Table of Stakeholder Comments
FAA Topic
Stakeholder Comments
Alaska Supplement
The Southeast Alaska publication document for low level routes hasn’t
been updated since 2002 or 2003. It is very out of date. We (industry
member) have visiting pilots from out of state a lot in this area in the
summer and the FAA can’t push out up to date information. Online
information would be better.
Is the Alaska Chart Supplement changing?
Will there be the ability to print off the chart supplements? The paper
copies have a lot of useful information in them. They are also useful
when assisting with emergency response requests. Participant agreed
there is some repetitive information that can be removed.
Recommend the FAA fast track the chart supplement update and make
this a priority.
VFR is sticking around in Alaska. We need to maximize our support,
including supporting the chart supplement.
The confined terrain and coastal weather conditions in South East
Alaska tend to concentrate low-level VFR traffic along specific routes.
Part 135 operators have worked out routes and procedures in this region
of the state, yet Part 91 pilots--either new to the area or transient--are not
aware of these routes or protocols. The FAA used to publish a pamphlet
titled “Alaska Aviation Information” jointly authored by Juneau Flight
Standards, Air Traffic Control, and Flight Service. This publication was
last updated in 2002 and is no longer in print. Updated information of
this nature, whether published in hard-copy, online or both, is another
tool that could help improve situational awareness across the aviation
community and improve safety. Requests by industry to update this
publication have so far yielded no action, and again there is no
mechanism for obtaining feedback or an update on the status of these
requests by the FAA.
eSRS
The Interim Report discusses the eSRS for expedited search and rescue.
What is the timeline for implementing this system? Is there anything 70
North can do to take advantage of this? The Interim Report mentions an
option for two way text communication between pilots and Flight
Services
FAASI FY21 Final Report
41
Frequent Flyer
Program
Report page 17, last paragraph – The Frequent Flyer Program has no
teeth to it. Industry member is ADS-B equipped, but other Bethel based
operations aren’t. A major issue in the Bethel area are “ghost aircraft”.
Industry member had an issue yesterday where an incident was averted
due to an observant pilot. Industry member had been given clearance for
take-off, but luckily the pilot saw a ghost aircraft landing and held off
the take-off until the ghost plane was out of the way.
PIREPs
If the PIREP system was more accurate, it could help with the ADS-B
issue. PIREPs are a snapshot of the weather at a given time and location.
Not all pilots will submit a PIREP.
If the FAA paid pilots for the PIREPs (recommend between $20 - $30
per report) they would get more reports. This would be a salvation to the
weather data in Alaska and make a significant improvement to safety. A
survey of some pilots in the Fairbanks area by participant shows more
PIREPs would be filed if the pilots were getting paid.
A commenter recommends moving the PIREPs away from Flight
Services and having a commercial vendor manage these. Per this
commenter, Flight Services isn’t interested in the PIREPs and Flight
Services is “useless”. The value of the PIREP data is better than the
information Flight Services is providing. The PIREPs aren’t the job of
Flight Services and they don’t want to do it.
On a recent flight to Anchorage, one commenter flew through bad
weather that was reported by another pilot and should have been a
PIREP, but Flight Services didn’t issue the PIREP. Had this shown up
when it was reported, the commenter might have been able to avoid the
bad weather.
Page 12 of the Interim Report in the last paragraph where “the FAA
conducted focus group discussions with stakeholders to obtain feedback
on the PIREPS”. Strategy #1 (Encourage pilots to file more PIREPs) a
commenter sees this as an example of a research focus group that isn’t
defined. The FAA doesn’t describe what the focus group was, what
information was gathered, or what evaluations came out of the focus
group. Are we gathering the same information because we are
researching the same ways with the same requests? What operational
research is happening to ensure new results are provided about issues
and challenges?
-Strategy #3 (Improve knowledge of PIREP processes, tools, and system
impacts through ATC training and education) – What operations
research is the FAA doing? Is the research being done appropriate for
Alaska? We had the Medallion Foundation in the past, but that didn’t
move the needle. The ADS-B program started in Alaska, but still needs a
FAASI FY21 Final Report
42
lot of work. What research is the FAA drawing from when determining
the initiatives it acts on? How can UAA help with that research?
Internally, the industry needs to encourage each other to file PIREPs.
This is something that should be pushed by AACA and the other pilot
organizations. This isn’t something the FAA can fix.
Suggested the FAA develop programs to encourage PIREPs, especially
at small airports.
Publish WAAS LPV/LP
Approaches to Every
Qualified Runway End
One operator has a CASA and a twin Otter that they fly. They are
currently working on a low level waiver to fly the CASA below 12,000
feet due to icing conditions. The typical flights are only 5 to 12 miles in
distance. There aren’t approaches at all locations the operator flies to. It
would save fuel costs and would help with deicing if there was.
Airport Improvement
Program (AIP)
Surface Improvements
The AIP Handbook allows runway markings to be painted only once
every three years. Alaska airports have heavy snow that must be plowed
routinely to ensure safe braking action for jet traffic. The runway
markings are degraded annually and should be repainted annually. AIP
Handbook prohibits funding the annual painting of runway markings.
Snow Removal Equipment Building (SREB) and Airport Rescue
and Fire Fighting (ARFF), and Training and Living Space
The logistics of rural and remote airports that have limitations based on
staffing and location. Rural and remote airports are required to have
SREBs to house necessary maintenance equipment, and larger rural
airports with a Part 139 certificate also have ARFFs; these two buildings
can be combined into one structure (FAA, 2019, pp. O-5 – O-6).
Training and living space, including restrooms, near the airport can be
difficult to find or non-existent at rural and remote airports, lengthening
staff emergency response time.
The AIP Handbook has the following limitations for SREBs (FAA,
2019, p. C-12):
1. Personnel Quarters
2. Training Space
3. Restrooms
4. Offices
These four limitations can critically impact maintenance personnel at
rural and remote airports. Smaller airports can be miles away from the
nearest community. This means emergencies cannot be responded to
quickly and critical infrastructure can’t be maintained in a timely manner
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because staff must travel to the airport to respond to an emergency or
access snow removal equipment after a storm. Encouraging staff to stay
at the airport with training and office space keeps staff available for
maintenance situations.
For storm events or maintenance work that requires hours to resolve at
non-Part 139 airports, staff must travel back into town to use restrooms.
Restrooms are defined in the AIP Handbook as “a dedicated room for
toilet and wash basin facilities. Restrooms do not include bathing
facilities such as a shower or tub” (FAA, 2019, p. A-13). This adds time
to the work and puts an unnecessary burden on the sponsor to pay wages
for the employee to drive into town to use a toilet.
ARFF facilities are only sized to be the “…minimum structure to house
and protect the grant funded ARFF vehicle…” (FAA, 2019, p. O-1). The
AIP Handbook does not currently allow dorm rooms or day rooms for
ARFF facilities that do not require 24/7 access; FAA claims these
facilities are not appropriate (FAA, 2019, p. 3-7). However, smaller
communities that have airports located away from the community may
not be able to respond within three minutes (Title 14, CFR Part 139,
§139.319) to a crash due to the time for personnel to travel to the airport,
change into gear, and drive to the crash site. Allowing staff to remain
on-site when an unanticipated plane meeting Part 139 requirements is
expected benefits the airport, air carriers, and passengers because ARFF
staff is immediately available in the case of an emergency.
Proposed Solution
FAA should allow minimal training (e.g. office space) and living (e.g.
day rooms and dorm rooms) facilities in rural and remote airports that
have a clearly defined need due to distance between the airport and the
community. Training and living space can be combined into one room to
decrease the space requirement. This allows staff to stay on airport to
facilitate staff response time during emergencies, storm events, and
maintenance that requires more than several hours. Allowing restroom
facilities in SREBs decreases storm event clearing time and general
maintenance time as well as decreases sponsor payroll by keeping staff
close by the airport.
Driveways off Airport Access Roads
Rural and remote airports are frequently surrounded by parcels that may
not be accessed by other, if any, roads. Restricting the use of driveways
on an airport access road limits the local population’s willingness for
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airport improvements. Lot use by private landowners varies, which
defines the amount of use for a given driveway.
FAA’s Reauthorization Act of 2018 (FAA, 2018, §162(3)) provides a
short-term solution for Alaska and Hawaii for development of airport
access roads that meet the following criteria:
1. Is not located in a contiguous state
2. Is less than five miles long
3. Connects to public roadways of a maximum of two closest
places, as defined by the census
4. May provide incidental use for public or private land adjacent
to the road that does not have any other access.
This use is temporary, however, and will expire in 2023. A permanent
solution should be developed that allows for not only these four criteria,
but for all National Plan of Integrated Airport Systems (NPIAS) airports
and an extension for census areas that are defined as rural by the Federal
Highway Administration (FHWA). The FHWA definition should be
used instead of the FAA’s definition as it restricts the number of eligible
airports: “According to definitions in 23 U.S.C. 101(a)(33), areas of
population greater than 5,000 qualify as urban for transportation
purposes in contrast to the Census Bureau's threshold of 2,500” (FHWA,
2013, ¶10).
Land Considerations
Land available for airports and airport expansion is becoming
increasingly difficult to find. Expanding or relocating an airport can lead
to cutting off sections of land that are still economically viable and are
therefore not eligible to be bought with AIP funds, but no longer have
road access to the smaller parcel. Other parcels could be landlocked until
an airport access road is developed, providing access to previously
inaccessible land for private owners and native allotment owners.
Proposed Solution
Denying legal access to these landowners sets up conflict between the
airport sponsor who is trying to meet their grant assurances and the
landowner. It also decreases the chances of adjacent landowners to
support airport improvements during the National Environmental Policy
Act (NEPA) process. The FAA should pursue a permanent solution that
incorporates the FAA’s Reauthorization Act of 2018 allowances for all
NPIAS airports and FHWA’s definition of rural communities to allow
airport sponsors to meet their federal obligations and be a good neighbor
for adjacent landowners.
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Rolling Stock, Including Graders and Front-end Loaders
Alaskan bush communities typically have small populations and few
resources. Furthermore, 82% of Alaska communities are not connected
to the road system. As a result, the airport’s grader and front-end
loaders are the only large rolling stock equipment in the villages. The
AIP Handbook does not allow a local tribe or village to rent the rolling
stock, or even move it off airport property.
Airports Compliance
Program
The FAA made improvements to the Nenana airport. These
improvements resulted in the runway being shorter.
Alaska Airports
Part 139 is a large contributor to safety in Alaska. This doesn’t apply to
Alaska like the rest of the US since Alaska has an exemption. Alaska is
missing out because this doesn’t apply to many of our airports.
With Grant Assurance 19, there is a significant gap in Alaska. Airports
aren’t maintained in the winter or they aren’t maintained very well in the
summer. Better maintenance would lead to better safety. Better staffing
at the airports would help too.
Understands the role of AK DOT at the airport operator. Hoping this can
be a forum to lobby for some improvements to be made on the DOT side
such as better maintenance and snow removal.
The Grant Assurance is an FAA issue on the Part 139 airport side.
AK DOT doesn’t have the resources to go beyond the bare minimum.
This does create some compliance challenges. AK DOT manages 200+
airports in Alaska.
Runways get closed because of ice on the runway, but airports can’t get
the temperatures above 40 degrees. This is a requirement that leads to
runway closures. Some airports can treat the runway with sand or take
other measures that would allow the runway to be open for small
aircraft. Unfortunately, opening the runway to small aircraft in this
situation isn’t allowed by regulations. This leads to some small aircraft
operating on closed runways and taking extra risk.
Small airports operate like large commercial airports, even though the
FAA doesn’t classify them as commercial airports. These locations lack
weather and NOTAMs.
Airports comments:
There have been some runway reductions, specifically at Galena. We
have Part 121 operators flying to Galena but now they have to fly lighter
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cargo and more frequent flights due to the shorter runway. NAVAIDs
have been taken out also which increases safety risk (ex: PAPIs).
The airport design criteria isn’t working for Alaska. The aircraft being
used in the state can’t be fully utilized at airports with the new designs.
There are a lot of heavy aircraft in the Anchorage area that are mixing
with small planes. This is causing wake turbulence issues.
AWOS/ASOS
We need more AWOS and we need more funding for aviation.
Report page 4, first paragraph – The FAA claims to have a strategic
focus to work with airport sponsors to install more AWOS using AIP
funding. The air carriers are being told the new AWOS have been
deferred for a new communication system that is in the development
stages. We won’t see any change here for at least two years. AWOS is
very important in Alaska. Why can’t we get the AWOS installed while
the new communication system is being tested? The Perryville airport is
one of the most dangerous for one operator. They have to fly VFR
because of the lack of infrastructure. There is an approach at Perryville,
but the operators can’t use it due to the lack of weather.
AWOS needs to be moved to a high priority for the FAA.
There have been a lot of AWOS outages in the YK Delta. Operators are
being told by the FAA that parts supply is an issue that leads to the
outages being extended. Would like to see AWOS outages and reliability
added to the report.
The FAA needs to change their approach to AWOS outages. If it is
broke, it’s broke. The FAA doesn’t consider an AWOS broke if it is a
partial outage. Telecommunication issues aren’t reported by the FAA as
a broken AWOS. From an operator standpoint, if an AWOS has a partial
outage or a telco issue then the operators can’t fly because they don’t
have the information needed. With the FAA not considering a partial
outage or telco issue as a broke AWOS, their data is being skewed so the
issue isn’t being addressed.
Fully agrees with the AWOS if it’s broke, it’s broke statement. If the
telco issue means the pilots can’t get the data, then the AWOS is broke
because the pilots can’t fly without the data.
The AWOS aren’t necessarily being installed in the most useful places
for the operators. How is it determined where an AWOS will be
installed?
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When AWOS Service A is not operating per the National Weather
Service due to outages, it is considered a telco issue. Is there a way to
improve the telco issues with the next AWOS tech refresh?
We are using outdated technology. If the Telco isn’t working then the
AWOS isn’t working and it needs to be recorded as an outage. This
should be a high priority in the report.
Fort Yukon has an ASOS, but the villages around it don’t. Pilots are
required to fly to Fort Yukon using the ASOS and then have to drop
down in elevation to fly to the surrounding villages in the area.
One carrier operates on the North Slope. They fly VFR and IFR cargo
and IFR passenger flights. AWOS project is very important to them.
They are encouraged by the effort. Minimal terrain issues, but a lot of
weather issues on the North Slope. It is a day/night operation.
Requested additional information regarding the AWOS take-overs and
specifics on the North Slope and Deadhorse areas.
Is the North Slope Borough aware of the process for obtaining an
AWOS?
AWOS comments: There is an upcoming tech refresh on the AWOS
Service A. Service A is the largest safety issue in Alaska.
Part 135 operators fly to the small airports for the same reason that
Alaska Air and Delta fly to the large airports; medical appointments,
passengers visiting friends/family, and grocery shopping. The small
airports need reliable weather programs and we don’t have it.
Service A is not reliable. This is needed for pilots to fly. It isn’t optional
to fly without Service A. Weather is also needed and so are NOTAMs.
The lack of Service A is causing safety issues.
Commenter would like to see improvements with the Service a tech
refresh.
In Alaska, Tech Ops is allowed to determine the AWOS availability and
reliability.
Operators have contracts with USPS and are required to provide x
number of flights or they lose the contract. If they can’t fly due to
AWOS outages then they can still lose their contract.
Recommends the FAA prioritize AWOS and ground based radio
transmitters.
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CFIT Accident
Prevention Initiative
CFIT is a big safety issue in Alaska.
Incorporate CFIT accident prevention initiative into all aviation
meetings.
There was a glancing blow regarding the ADS-B moving display. This
ties directly into CFIT. Basic thing is approximately $85 million has
already been spent to develop the digital model that is an upgrade from
the 1920s paper topographic maps. The digital map updates aren’t being
used by the FAA in the moving maps and is it causing CFIT accidents.
The 2016 crash of a Ravn flight outside of Togaik is an example where
the updated information could have saved three lives.
The excuse from the FAA for not using the updated digital maps is that
the FAA can’t update the system until they have updated 100% of the
locations. Currently, the FAA says they are only at 95% completion.
Operational safety
oversight of aircraft
fleet
Transport operations should all be transferred to Part 135 operations.
The seasonal lodges don’t fall under Part 135 regulations, but they
should since they fly passengers.
Voluntary Safety
Reporting Program
expansion
The voluntary safety reporting program for Part 121 sounds nice, but we
have had these come and go in the past. Is there a way to broaden this
and include non-certificated carriers?
A commenter expressed interest in the voluntary program. Sees a benefit
for the whole industry.
Navigation and
surveillance
Communication gaps
and minimum IFR
altitudes study *
Some T-Route restrictions are forcing aircraft into known icing
conditions which makes it unsafe. This is especially true for the 1000
foot VFR ceiling requirement.
High frequency, satellite based LAN communications are not reliable.
There is no backup for this.
There are gaps in ground to ground communication that need to be
addressed.
A commenter stated he worked hard to get a T-route approved from
Fairbanks to Kaltag four years ago. That T-route is worthless because
ATC won’t let you fly low enough. The T-route MEA (Minimum
Enroute Altitude) has a height of 3200 to 4200, but ATC in Anchorage
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Center won’t let pilots fly lower than 6000 due to lack of comms and
weather data. Flying this high will put a pilot in icing conditions.
With regard to the low level T-route on the North Slope, are there any
plans to update the surveillance in the North Slope area? Or the
communications?
In Section 3.2.1 of the report, it talks about the FAA considering
whether to allow communication gaps on some routes. For this non-
135/121 operator, there is an internal training program and an internal
waiver pilots have to obtain to fly the routes with communications gaps.
Non-Part 95 Capstone
Routes and Minimum
En Route Altitudes
Low level IFR routing through Anaktuvuk Pass would be helpful for this
carrier from an IFR flight plan standpoint.
Under Capstone, the Shelton radio equipment was popular. It would
allow pilots to get down to 1 mile safety area. The equipment is costly
and most smaller operators can’t afford it. This is really good equipment
for mountain passes and preventing CFIT. A commenter recommends
the FAA embrace the technology. It would drive fidelity to a narrower
band. It is better than the Garmin package a lot of smaller operators are
using.
It would be good if the FAA could embrace the R-Route option (like the
one in Juneau) and let the market drive improvements.
Having more R-routes would be useful so the pilots could add them to
their Garmins.
Capstone was a useful initiative, but is was never finished.
The Capstone era R routes are in a no man’s land right now. They’re
outdated, haven’t been reviewed in years, and essentially orphaned
because only the Chelton Flight Systems EFIS equipment can fly them.
As you may know we started our company 14 years ago using IFR as the
backbone of our business plan and a key component of our business plan
is or was the Capstone R routes. These R routes allow us to safely
operate IFR in Southeast Alaska at much lower altitudes keeping our
aircraft below icing conditions much of the time.
Chelton gave us notice about 1.5 years ago that they will no longer
support or repair the Chelton EFIS systems that many of the operators
currently have installed in their aircraft. Chelton stated the equipment
has reached the end of their service life. We have tried to gather as many
of these units on the used market as we can but with the maintenance
issues these units frequently have after 20+ years in service it’s just not
cost effective or reliable enough to continue using this equipment in our
operation. The new version of Chelton is four times as expensive as a
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full Garmin G600/ GTN750 suite so basically Chelton has priced
themselves out of the commercial market and clearly are concentrated on
helicopters and military aircraft.
For the past year we have been upgrading our fleet to all Garmin
avionics suites (G600Xi, GTN 750Xi, GTN650Xi, GFC600 digital
autopilots) and they have been fantastic to maintain and for pilots to
operate. Chelton was and is the ONLY system approved for Capstone
Phase II in Alaska but due to the challenges stated we have been forced
to switch to equipment that can no longer operate on the R routes. The
Chelton system is setup to scale to RNP 1.0 in the enroute phase of
flight. The Garmin units default to RNP 2.0 but can very easily be scaled
down to RNP .3 by the pilot. Once scaled down the scaling remains
scaled down, never requiring it to be scaled down again even after the
units are powered down so it’s really a onetime process that only
requires pilots to verify the scaling is set as a checklist item. When
scaled down to RNP .3 the Garmin suite with the digital autopilot is truly
a game changer, extremely precise and stable in a phases of flight.
Commenter’s suggestion to the FAA would be allow users with GPS
units capable of auto or manual scaling (with an approved training
program similar to what Island Air Express has developed for our
tailored procedures) to add the R routes to their tailored NavDB. Having
this ability would allow operators to stop being held hostage to end of
service life avionics equipment, continue providing the safety of not
having to fly aircraft at altitudes that produce icing conditions much
more frequently than the R routes do, and preserve the valued R routes
the FAA developed years ago.
Thank you for reaching out to us and asking about this important
subject, I hope this info helps shed light onto the Capstone/ R route
issues.
These routes need to be approved for other equipment than the
extremely outdated Chelton Flight Systems EFIS.
ASAP Initiative
Expansion
Web-Based Application Tool (WBAT) Safety is looking at ways to pick
up some of the pieces from the old Medallion initiative and to get
operators back on board with Aviation Safety Action Program (ASAP).
WBAT is a contractor who can run he ASAP program from the
individual operators.
The Interim Report mentions there is money available for some projects.
Would like to see some of that money put towards implementing ASAP
across the whole state.
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Not all of the operators can afford ASAP or a safety program. Medallion
was the solution to that hurdle in the past, but that isn’t an option
anymore.
Currently, WBAT runs approximately half of the Alaska Memorandums
of Understanding (MOUs) for ASAP. WBAT has the ability to provide
additional support.
The operators commenter has spoken with don’t have the funding or the
personnel to implement ASAP. They are waiting to see how the FAA
replaces Medallion before they take any action.
WBAT requested this meeting to help make sure they are talking with
the right group of people to help get the word out about ASAP.
One option for the single pilot operations is to combine them into one
ASAP instead of separate ASAPs.
Clarified that for this purpose, buy-in was trust and not funding. Both
would be needed.
The single operators lack the time, system knowledge, and funding to
make ASAP happen for them.
WBAT only has comments on the ASAP program.
Added Topic Categories
FAA Staffing in Alaska
Expressed concern over the continual disassembling of the FAA within
Alaska and moving those positions out of state. Fewer local employees
means there is less understanding within the FAA on the Alaska specific
challenges.
The FAA used to have an online employee directory the stakeholders
could use. That has gone away. It is hard for industry to know who to
contact in the FAA and how (phone number or correct e-mail address).
Would like to see this directory come back. There have been times when
FAA employees reach out to the stakeholders to ask the stakeholders
who the FAA can contact within the FAA for something.
There are some concerns regarding the Flight Standards staffing in
Alaska. Is the staffing adequate? One operator recently received a letter
telling them about a new inspector being assigned when they never even
met the old inspector.
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There is the appearance that the current moral within the FAA is the
lowest ever seen. This is a concern being expressed within the industry
along with the increase in retirements.
The decrease in moral is leading to the FAA saying no more and not
thinking out of the box.
In general when it comes to safety culture, there has been a disconnect
over time. After Ted Steven’s death the FAA moved employees out of
Alaska and reorganized things to the WSA. There is less of a DC
connection now and aviation safety is suffering.
Alaska DOT has had to go directly to the Alaskan Congressional
delegation to change the FAA regulations to add Alaska specific
language. It was necessary for the AK DOT to go around the FAA to get
FAA regulations change because AK DOT couldn’t get help from the
FAA. There is a disconnect with DC FAA not understanding the local
FAA needs. There is a “feeling of no love” from the WSA since they are
all outside of Alaska and they don’t prioritize Alaska needs.
The current points of contact, roles, positions, and responsibilities within
the FAA are not transparent. In the past, the FAA published an online
employee directory, a much-used tool that helped industry locate staff
contact information, and where they fit in the organization. If it is not
possible to restore this tool, the FAA Regional Administrators office
should at a minimum develop and maintain an organization chart for the
different lines of business that operate in Alaska and include key staff
members for the different lines of business, along with their contact
information.
We understand from anecdotal comments by different operators that
turnover among Principal Operations Inspectors (POIs) is an issue,
resulting in a lack of continuity, limited communications, and potential
gaps in regulatory oversight between operators and Flight Standards.
One operator went so far as to observe that they received a letter
announcing a new inspector yet had never met the currently assigned
POI for their operation. The FAA should do an analysis of their POI
turnover. This staffing issue may have also carried over to the FAA staff
responsible for interacting with the public, as pilots have reported
difficulty in accessing flight standards representatives for questions.
Instances are reported of messages left, calls not returned, and no
process for verifying where the disconnect occurs.
An assessment of the FAA’s staffing issues should be applied to define
the staffing problem, identify the causes of the problem, develop and test
interventions, implement the interventions, and evaluate the
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interventions. Each of these steps can be documented, a matrix can be
developed and made available for use in other regions as well as Alaska,
and attempts at improvement can be quantified. This method of analysis
is transparent and can be used to document efforts, justify funding, and
demonstrate good faith attempts to provide operators and pilots with
regulatory oversight and guidance.
Aviation Dependence
In approximately eight or nine years, 80% of the areas this Part 91
operator will be operating in will have no road access. Aviation is
essential to the continued operation of the oil fields in Alaska and will
become even more important in the near future.
Pilots will push the limits of weather and approaches for emergencies
since the only way to get to some villages is by plane.
Weather Reporting
There have been issues in the past where Part 135 operators couldn’t
travel to some locations due to the lack of weather reporting.
En route weather reporting is an issue. Is the FAA still installing weather
stations and turning them over to DOT for maintenance?
The weather reporting in the villages improves in the summer when
there is nothing but daylight. In the winter, a weather report from a
village might be nothing but a report of “dark” because there is no
daylight and no technology.
Instrument approach procedures are being held up due to lack of
weather. This shouldn’t be happening.
Pilots aren’t able to get weather reports for the villages. Some villages
have forecasts, but not actual weather reports. The NWS (National
Weather Service) forecasts aren’t always accurate. The NWS forecasts
are supplemental weather information and not approved for flight
determinations.
The weather issues related to NextGen are not working. The current
Alaska weather systems aren’t approved as replacements for
AWOS/ASOS. A pilot can’t fly if there isn’t legal weather data prior to
the start of flight. The lack of legal weather data is an issue.
The FAA likes to use the word “soon” to push projects off. Pilots keep
being promised that the Galena VOR will be replaced “soon”. The FAA
keeps promising a weather approach through Anaktuvuk Pass “soon”.
Fort Yukon, Beaver, and other areas don’t have any weather data. Pilots
are flying “scud runs” to those locations and are being told by the FAA
that they will have improvements “soon”.
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At one location the on-site weather reporter died six years ago and hasn’t
been replaced. When will a new on-site weather reporter be hired? There
used to be 12 or 13 places where there was a person on-site to provide
weather reports. That went away with Capstone and wasn’t replaced
with anything.
For Nenana, uncontrolled approaches can’t be used at night due to no
weather. The entire month of December is “night” since there isn’t any
daylight. That means pilots can’t fly uncontrolled approaches to Nenana
in December and they are limited all winter.
Alaska needs a central broadcasting system for weather updates in flight.
Pilots use iPads during flight to get weather updates. Sometimes the
PIREPs show up in the system and sometimes they don’t. There isn’t
consistency.
The ultimate goal is to fly from Fairbanks to Juneau and know what
weather he will encounter on the way. This pilot often comes across
unidentified weather such as thunderstorms. He notifies Flight Standards
of the weather, but the response is “it isn’t on the model from the NWS
so it isn’t there”.
Weather is the main challenge for flying in Alaska. For this 135 carrier,
weather is more important than ADS-B. Would like to see weather
improvements as a higher priority.
When flying to a location with no weather that is close enough for you to
see and you can see the weather is clear, it is frustrating that you can’t
land at that location because it doesn’t have any official weather data. It
would be nice to have a common sense approach for a solution to this.
Understands this wouldn’t work when flying to a location you can’t see
prior to take-off.
Terminal forecasts are not at all locations, just areas forecasts. There are
some issues with that.
More weather data is needed by pilots. The pilots can’t start a flight
unless weather is above minimums at the expected time of arrival. There
isn’t enough weather data for pilots to make this decision at a lot of
locations.
There is some difficulty in forecasting weather so the National Weather
Service will include that there is a chance of incremental weather. This
blanket statement prevents flights from taking off.
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This pilot has been flying in Alaska since 1982 and currently works for a
135 carrier. The carrier flies twin-turbo prop, IFR capable aircraft for
cargo service. The lack of weather forecasts means flights can’t take off
since the weather “might” not be above minimums. The regulations
prevent the pilot from starting the flight and turning back if the weather
doesn’t meet the minimums at the destination.
In the YK Delta, there was a former initiative to setup weather stations
that hasn’t made any traction. Weather in the area is frequently marginal,
but there is no weather data for pilots.
Continue to support development of a standard for a low-cost weather
station to use for VFR flight operations. Lowering the cost to acquire,
install and maintain aviation weather reporting stations is essential to
increase the density of reporting stations in Alaska. While the results of
this effort will have impacts for the rest of the country, conducting the
needed demonstration and evaluation in Alaska is appropriate based on
the lack of certified weather stations.
Navaids and GPS
A big issue in Alaska is the lack of Navigational Aids (NAVAIDs) and
the lack of power for the NAVAIDs.
GPS jamming from the military can be an issue. Sometimes a pilot’s
GPS will suddenly jump and show they are flying over Hawaii when
they are actually in Alaska.
Will there be a backup to GPS and WAAS? NDBs are going out of
fashion and are being decommissioned. The NDBs are reliable and
should be kept.
A big issue in Alaska is the lack of NAVAIDs and the lack of power for
the NAVAIDs.
Medallion
The Medallion program was a great opportunity, especially for the
smaller operations when it comes to an SMS program. The smaller
operations can’t afford to send pilots to training on their own. Having a
local product was much more cost effective.
Would like to see industry collaborate together to bring back Medallion
and fund it.
The operators need external support. Something like the Medallion
Foundation or Capstone that had a technical focus to help everyone
improve.
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Recommends the FAA Safety Team (FAASTeam) revives the Medallion
initiatives.
Are there any plans to address the functions of Medallion and pick that
up somehow?
Wasn’t expecting Medallion to be reincarnated. Would like to see some
of the programs come back and keep pushing the safety aspect.
Understand the funding issue.
Pilot Experience
The aviation industry is seeing more inexperienced pilots in Alaska since
the more experienced pilots have retired during COVID.
There needs to be a way to mitigate the lack of experience. Alaska has
some unique terrain and the lack of experience can be deadly.
Aviation in Alaska is literally life and death for the oil fields and for a
lot of villages. If there is an accident at an oil field or village the only
way to get the injured person to medical help is by plane. If a village is
in critical need of food, water, or medication the help arrives by plane.
Knowing that aviation is life and death leads pilots to take more risks in
marginal weather and to push the approach limits. With more and more
inexperienced pilots flying in Alaska and making life and death flights
the system is being setup for a catastrophic event to happen.
This operator is standing up an internal pilot training and mentoring
program to bring the less experienced pilots up to the higher standards.
This is very important with the critical nature of aviation in the oil fields.
Encourages the other operators in the state to implement a similar
program and to implement some pilot mentoring.
There is an increasing number of new, inexperienced pilots moving to
regional airlines. The increase in new pilots is an issue.
How can UAA assist with research for new/incoming pilots to help
things change?
Alaska Aviation
Infrastructure
The 2005 Capstone project is a model for how to address infrastructure
related issues. Capstone was a concentrated effort in the FAA to bring
everyone together to the address the needs. Unfortunately, Capstone
didn’t finish and was left unfunded. The commenter would like to see
this project completed.
There have been many recommendations to improve safety in Alaska
throughout the years that haven’t been implemented. These include the
23 recommendations from the RTCA report and numerous NTSB
recommendations.
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The commenter would like to see the FAA develop a plan to implement
change. That plan will need to come with funding.
Progress has been made since the 2005 Capstone project, but more needs
to be done. AIP money needs to be allocated to improve runways,
NOTAMs need to be improved to include weather conditions, and the
requirements to operate airports needs to be improved.
Appendix 1 – The FAA priority list shows the FAA only considers
something a high priority if it has already received approval to
implement and is already funded. The FAA needs to identify projects to
move up to a high priority and work to get those projects funded. An
example of something to move to a high priority are infrastructure
projects, especially IFR related.
For reference, one carrier provides service to 160 destinations. From the
Bethel area, only 30 of those destinations have IFR. Another carrier
noted it provides service to 70 – 74 service areas. He reports the same
proportionate lack of IFR capabilities at airports his carrier services.
Infrastructure in Alaska is decades behind the rest of the country.
The lack of roads in Alaska means we rely more on aviation for travel.
This leads to more accidents.
We need more ATCTs. Understands there is an expense and logistics
aspect to this. There are lots of busy airports in Alaska that don’t have
ATCT. If those airports were in the lower 48, they would already have
an ATCT. Virtual and remote ATCTs is a good option for some
locations. We are fortunate to have Flight Services at some locations (ex.
Deadhorse) that can take the place of the ATCT.
The best way to improve safety in Alaska is to improve infrastructure.
Specifically, radar and preventing blackout areas.
Alaska relies on aviation and cargo flights. The FAA formula for
airport/runway design doesn’t really apply to Alaska with the aircraft
that are being flown in the state. It would be nice to have some longer
runways.
If the weather coverage, communications, and ADS-B coverage
improved statewide, then CFIT and mid-air collisions would decrease.
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Most pilots with Aircraft Owners and Pilots Association (AOPA) and
Alaska Airmen don’t fly IFR, but Alaska does need an IFR
infrastructure.
More T-routes are needed at lower altitudes due to icing on aircraft at
the higher altitudes. This will reduce crashes and increase safety.
If the infrastructure improvements are available and the equipment costs
are low, then the combined safety impact will been seen. Pilots will
install the equipment when this happens. (If you build it, they will come
approach.)
Rural Alaska is dependent on aviation. They don’t have the
infrastructure equal to the lower 48.
The medivac operations in Alaska are very different than the lower 48.
In Alaska, we land on gravel or ice covered airstrips. One size fits all
requirements don’t apply to the Alaska conditions.
The FAA uses the excuse that a lot of improvement projects don’t have
the needed ROI (return on investment) to be implemented. The ROI
determination doesn’t account for the lack of road access and the lack of
communications for IFR structure.
The terrain in Alaska impedes IFR coverage. Funding for improvements
impedes coverage.
General aviation relies on VFR more than IFR.
There is a resistance of aviators to invest in IFR and avionics due to the
low ROI at some airports.
If the airports have spotty or no coverage then the pilots will revert back
to VFR.
There is a circle that the aviators need to invest in equipment, but they
don’t want to pay the expense when the FAA doesn’t invest in the
infrastructure. The FAA doesn’t want to invest in the infrastructure until
the aviators equip their aircraft. Need to find a solution to the circle so
both the FAA and aviators can move forward.
Suggested the FAA look at demographics to make its decisions instead
of looking at ROI by airport.
The FAA should explore a partnership with the FCC (Federal
Communications Commission) and satellite companies to expand
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internet and wifi hotspots in Alaska. Pilots use iPads for
communications and the lack of wifi is a problem in rural areas.
Recommends the FAA partner with native corporations. It is the natives
who are being affected and their projects and their people. A partnership
with the native corporations would help identify some options for
infrastructure.
Comments of FAASI
Interim Report
There is some frustration on the part of the aviation industry. We have
been here before and haven’t seen change.
What is the purpose of FAASI? That isn’t clear in the report.
Is this a strategic plan for the FAA? The FAA needs a tactical plan and
needs to implement it now.
What are we doing now to improve safety? What can be done today, not
years from now? The report doesn’t talk about today and how to change
things right now. It focuses on what the FAA might do years from now.
Report page 9, last paragraph – Takes exception to this entire paragraph,
especially the statement about operators not installing IFR equipment.
The industry has spent millions of dollars to equip their fleet and now
the FAA isn’t installing the infrastructure to support the new fleet
equipment.
The operators and POIs weren’t included in the report or asked for their
input. This is an FAA only report.
Report section 3.2.2, first paragraph – There is only 1 GEO approved.
Appreciates knowing this is part of the process and that the stakeholders
input will be included in the Final Report.
Strongly agrees with another commenter about being frustrated. “We
have been here before and nothing has changed. “
Report page 2, second paragraph – “The Administrator directed the
Alaskan Region Regional Administrator (RA) to lead a cross-agency
group of FAA experts to focus on safety issues specific to Alaska and to
determine how the FAA is deploying resources, their effectiveness, and
how the FAA can improve in delivering services and how to prioritize
the delivery of the resources.” Is this the purpose of the report? Didn’t
see much in the report on the effectiveness of the FAA programs or how
to improve.
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Report page 3 – “The fleet is most often comprised of single and small
multi-engine general aviation aircraft. Many of these aircraft are not
equipped for IFR flight and are not equipped with aircraft deicing
equipment.” Did the FAA look at all the Part 135 operators in the state
or the number of flights? The larger air carriers who conduct a large
number of flights have already upgraded their fleet. One carrier has 14
planes that are IFR only and seven that are not yet IFR. To date, the
carrier has spent $2.5 million to upgrade their fleet for WAAS
approaches. This is an opinionated statement by the FAA and needs
some factual data behind it if this remains in the report.
Report page 9, second to last paragraph – “The majority of these aircraft
are equipped only for VFR flight…” This is too broad of a statement.
Did the FAA include the seasonal only operations in “the majority” of
the fleet? This doesn’t account for the year round operations conducting
the majority of the flights.
Report page 9, last paragraph – Very strongly recommends removing
this entire paragraph, especially the last sentence which reads “a
substantial segment of Part 135 operations in Alaska will remain VFR
centric regardless of FAA efforts to enhance the use of IFR routes and
suitably equipped aircraft”. This is an opinion statement by the FAA that
the operators won’t equip their fleet. This isn’t true. One carrier has
spent millions of dollars to upgrade their fleet. Why would the FAA
consider funding improvements in aviation safety when their own report
claims, falsely, that the aviation operators won’t do their part?
Most of the report is covered fairly well. Recognized the work that went
into the report.
The way the report is written is very opinionated by the FAA and paints
a 1975 – 1980 image of Alaska. This doesn’t reflect current flying
conditions in the state. The FAA needs to remove their opinions and
stick to fact based information.
Report page 9, last paragraph – This is an FAA opinion that if the FAA
installs the infrastructure then operators won’t use it. This is simply not
true and is not a fact based statement. Operators in Alaska are upgrading
their equipment and investing in their fleet. Like previous commenters
have already said, X Company has also invested in their fleet to upgrade
the equipment and keep their pilots safe. Alaska isn’t the wild west of
aviation that the FAA is portraying in the report. Operators are
upgrading and want to keep their pilots safe.
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The report has a heavy emphasis on General Aviation and not the rest of
the operators. The report needs to differentiate between General
Aviation and the smaller operators in the summaries.
The whole fleet section of the report is very opinionated by the FAA.
This entire section needs to switch to presenting fact based information
only.
Overall, this is a decent report, but the priorities need to be realigned.
This should be a tactile planning report and not a strategic report.
Need to cover what can be done NOW and not wait for technology
improvements before trying to improve aviation safety.
Appreciate the ability to share candid thoughts and feedback.
The more feedback that is incorporated into the report from the industry
the better.
This discussion has been helpful for the stakeholders to understand this
is a process and the report isn’t the final point.
Would like to see more support from the top down within the FAA.
The comments can be summed up with section 3.2.2 of the report and
what needs to change.
The report appears to be the same research and the same
programs/initiatives conducted and reported in the past. There isn’t any
new information being researched or reported. Why is the FAA looking
at the same thing again?
The UAA is great at research and can assist the FAA on these strategies.
A deep dive into the data on what is causing the accidents and how they
can be overcome should be completed.
What can UAA do to help out with this? Is anyone looking to see what
isn’t being said by the data?
Didn’t see much in the Interim Report on aircraft maintenance. There is
a lot of discussion on airport maintenance, but not aircraft. Is this a low
priority in Alaska, specifically for the GA and Part 135?
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UAA is asking where the FAA focus is derived from and how this will
be implemented from an educational standpoint.
Have we reached critical mass where UAA is matching what is going on
in the field?
Looking at the report to see where UAA might need to adjust their
program for what is coming from the FAA.
UAA has approximately 100 flying and maintenance students at one
time.
Alaska flying isn’t the same as the lower 48. We need approaches and
data from people in Alaska who know flying in Alaska.
Thank you for the effort that went into the report. It is encouraging to
see what the FAA is working on.
The infrastructure programs in the Interim Report all look impressive.
How long has the FAASI been around? Is this a 2 year program?
The Interim Report didn’t cover how the process would change or be
updated. Is there a mechanism for improvement?
Transparency keeps being brought up in conversations. Summer is a
hard time for operators to provide feedback. It is frustrating to some
operators who feel their voice won’t be heard.
It is good to see the FAA stepping up to address some of the NTSB
recommendations.
One question to ask ourselves is if the FAA is trying this hard to update
the rules, do we really need to do this? If it is something everyone wants
and would make a difference, why is it so hard?
There are some statements in the report about improving charting and
Common Traffic Advisory Frequency (CTAF) on sectional charts.
Those statements aren’t accurate.
VFR GPS routes and Mountain Pass Waypoint should be combined
since they are the same thing.
Need to add the continued development of low cost weather for VFR.
Communication improvements need to be moved to a high priority.
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The FAA needs to collaborate with a 3rd party to improve safety.
Expressed thanks for all of the FAASI efforts. What is in the report is
there because FAASI is pushing it.
There are some questions about phraseology and grammar. Commenters
will submit these questions in writing.
The stakeholders today are on-demand freight and passenger airlines.
One also flies medivacs.
This is the start of the discussion to make the safety changes we all know
are needed, especially in rural Alaska.
Report page 5, paragraph 1 states the “annual enplanements in Alaska
are 7.1 times the state population compared to 2.8 times the population
in the CONUS”. Is this based on commercial or Part 121?
Report page 6, paragraph 1 states: “The February 2020 NTSB Report
ASR-20-02, notes that during the period from 2008 to 2017, the total
accident rate in Alaska was 2.35 times higher than the rest of the United
States with the fatal accident rate in Alaska being 1.34 times higher.” Is
this based on all accidents or Part 121?
One size doesn’t fit all for Alaska. The lower 48 rules don’t apply here.
The report purpose is to discuss the problems being brought up.
The report doesn’t identify the needs and the needs categories.
Recommend adding that and aligning it with Appendix 1.
Recommends adding to the report a comprehensive list of aviation
organizations in Alaska and indicate if the FAA is a member.
Understands the document isn’t going to fix all problems.
A great overall document will come from this process. Not convinced it
will address the real issues. Understands there are some constraints.
The Interim Report does identify that VFR flight will continue into the
future.
The FAA should integrate the terrain updates into the moving map
display (Digital Elevation Model).
The report title is specific to Alaska. The accident rate in the report is
specific to Alaska. The FAA gets tired of hearing how special Alaska is.
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Are there amendments that can be made to the AIP handbook to address
the specific needs of Alaska?
Acknowledge the challenge of breaking down the stovepipes and
addressing the stakeholder feedback.
Hopes the feedback is implemented.
Aviation is a team sport.
One of the recommendations that NTSB made based on the 2019
Roundtable was to create a “focal point” within the FAA to work with
the different lines of business inside the agency and industry
stakeholders to ensure that safety programs were implemented. While
the interim report outlines activities of a number of FAA lines of
business and includes a list of projects, we do not see any mechanism or
process described or proposed to improve coordination internally and
externally.
Evaluation of Safety Programs Emphasis needs to be placed on
determining which efforts and initiatives have been successful. An
approach that incorporates the problem definition, causes of the
problem, intervention implementation, and evaluation of the
interventions should be adopted. This final step in evaluation of
programs or products is required to make improvements where
necessary and ensure efficient use of funds. Improvements can be made
to the interventions and ideally the cycle is repeated to routinely evaluate
and improve programs.
The FAA needs to evaluate the effectiveness of safety programs and
procedures after implementation by developing metrics for
measurement, goals for success, and assessments for changes to existing
programs and procedures. For example, evaluation of use and changes to
T-routes, use of weather cameras, and legacy infrastructure should be
conducted to optimize efforts and funding spent on these systems and
programs. Engaging the assistance of MITRE, CAMI, or other
organizations to conduct studies or surveys for assistance with
evaluation should be utilized to determine the results of activities, use of
resources, and inform needs for further change or discontinuation of
ineffective programs. Consultation with stakeholders and publication of
the measures used for evaluation and the assessment findings will help
ensure transparency and the adherence to the measurement metrics.
P2: If “The goal is to deliver a fully-integrated report to the
Administrator regarding safety program needs and priorities throughout
Alaska” why is the Civil Aerospace Medical Institute (CAMI) not
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included as one of the lines of business? As the research, education, and
occupational health wing of the FAA, their expertise could give
credence to analyses and recommendations on the needs of pilots in
Alaska.
P2: “As a reference, the teams used information contained in multiple
studies by the FAA and external entities related to aviation safety in
Alaska.” Please include a list of the referenced studies and any available
internet links to those documents.
P3: Human factors, human error, and human performance should be
included in the areas of emphasis developed by the FAA
interdisciplinary team. Research on pilot behavior is needed to address
several key themes in crashes in Alaska, such as why pilots are not using
all of the available resources to avoid VFR into Instrument
Meteorological Conditions (IMC) and crashes due to CFIT.
P4: “The FAA is also evaluating the deployment of the Visual Weather
Observation Systems (VWOS), a new technology to provide non-certified
weather reports and allow its use by Part 135 operators for both IFR
and VFR flight planning.” Use by Part 91 operators is also important and
should be included in guidance for using this new system.
P4: “Alaska-based Part 135 operators continue to evolve away from
dated aircraft designs, and as more capable, complex aircraft
predominate, airport operational needs change in order to make safe
and efficient services available for rural communities.” A complex
aircraft as defined by the FAA is an airplane that has a retractable
landing gear, flaps, and a controllable pitch propeller. Do you mean
technologically advanced aircraft?
P5: “Alaska has approximately 763 recorded landing areas in addition
to the public use airports.” According to the FAA 5010 Airport Master
Record database, Alaska has 761 registered airports, of those 393 are
public use. There appears to be a disparity between these numbers and
the claim that these are “in addition to the public use airports.”
P5: “These are commonly used for intrastate transportation of goods
and passengers within Alaska by both commercial operators and
prevalent Part 91 operations.” Please define prevalent Part 91
operations.
P6: “The RA is to work with Alaskan stakeholders to gain insight into
the effectiveness of such programs.” Does this mean the effectiveness of
the FAA programs will be evaluated by subjective Alaskan
stakeholders? Suggest the FAA develop an objective, science-based,
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fact-driven methodology for evaluation of program effectiveness and
share with the stakeholders prior to implementation.
P8: “Alaska has almost twice as many landing areas as public use
airports” According to the Airport Master Record database, just over
half the registered airports in Alaska are public use. Are there additional
“landing areas” not included in this database? And if so, where are these
documented?
P8: “Figure 2 reflects the remoteness and varying topography that limits
the usability of ground- based navigation aids in the low altitude
environment used for intrastate air commerce.” Intrastate commerce
also uses the high-altitude environment, and not all users of the low
altitude environment are commercial. General aviation, Part 91
operations are also conducted in the low altitude environment and should
be included.
P8: “Satellite based navigation, while powerful and continuing to
rapidly evolve across both the safety and efficiency spectra, is only
available to aircraft equipped with modern avionics.” This is not true.
Handheld GPS technology was widespread in the early 1990s. Perhaps
edit language to specify satellite-based navigation using panel-mounted
avionics meeting FAA certification requirements.
P9: “Aircraft operator fleet selections determine the critical aircraft at
each airport, and the subsequent AIP designations determine federal
funding eligibility.” Please define or explain what critical aircraft are.
P9: “However, of all Alaskan flight operations, there is still a significant
number of IFR flights conducted. As a result, operators often elect not to
install IFR equipment since it would provide minimal benefit at great
cost due to limited availability of more accessible instrument procedures
and the inability to fly into known icing conditions.” These sentences
contradict each other. Please edit for clarity.
P11: We anecdotally understand that Part 135 operators are plagued by a
revolving door of Flight Standards Principal Operations Inspectors
(POI), making it difficult for these operators to maintain continuity
regarding oversight of their operations. One operator indicated that they
received a letter introducing a new POI, yet had not met the inspector
currently assigned. Individual pilots also report difficulty in accessing
Flight Standards staff for questions and guidance. The FAA should
conduct a review of Flight Standards staffing turn over and related issues
that may be contributing to this situation.
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P12: “Additionally, the FAA Alaska PIREP Improvement Workgroup is
holding routine meetings to continue this discussion in an effort to
develop a strong network of members to establish goals and milestones.”
Please include these goals and milestones in the report.
P14: “The FAA and Part 121 operators are cooperating to obtain
authorizations for special terminal operations procedures. To date, these
procedure authorizations have been obtained for three Part 121
operators.” Please include the list of Part 121 operators who hold these
authorizations.
P14: “This initiative has also led to improved charting and accuracy of
flight frequencies on VFR sectional charts.” This statement does not
appear to be accurate. The ‘CTAF Areas’ now defined for some specific
areas in Alaska are not charted on VFR sectional maps as defined areas.
In one location they are depicted in an inset on the Anchorage Terminal
Area Chart, however this case is not extensible to other areas in the state
that have defined CTAF Areas.
P14: “Alaska currently has 33 requirements related to expanding
communication coverage, two of which have received funding.” Please
list the two requirements that have received funding.
P15: Many of the route segments in the proposed T-routes project have
Minimum Enroute Altitudes (MEA) that are higher than required based
on terrain, due to lack of communications. Unless either (a) additional
RCAG stations are installed to allow lower MEA’s or (b) waivers for
COM gaps are established, the resulting MEA’s will place the very
aircraft mentioned in this report as most in need of protection, outside of
an altitude range they can use, either due to icing or performance issues.
Addressing this issue is of critical importance to encourage increased
IFR operations and the resulting safety associated with them.
P15: “The Special Use Airspace Information Service (SUAIS) consists of
frequencies used by GA pilots while transiting special use airspace
under VFR.” Commercial pilots also use this service. Or is this statement
intended to mean non-military? Please clarify.
P16: “The Alaska Mountain Pass Waypoint Charting initiative supports
pilot situational awareness when flying in remote and mountainous
areas and decreases CFIT incidences. The Mountain Pass Working
Group consists of FAA, regulatory, and stakeholder representatives. The
goals of the initiative are to identify mountain passes that should be
charted, establish VFR waypoints to identify mountain pass entry and
exit points, and remove unsafe or unused mountain passes from VFR
sectionals. The group is recommending that altitude and terrain
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elevation data be incorporated into aviation charts to enhance pilot
awareness.”
In currently charted mountain passes (where an FAA pass symbol is
depicted) the working group has asked that the elevation of the pass be
added to the charts, as is currently the practice for charted mountain
passes in the CONUS. The group is not making any request to define or
include altitude data for aircraft flying these passes, which would vary
depending on the type of aircraft, prevailing weather, and experience of
the pilot.
P16: “The goals of the initiative are to identify mountain passes that
should be charted, establish VFR waypoints to identify mountain pass
entry and exit points, and remove unsafe or unused mountain passes
from VFR sectionals.” This initiative is broader than charting mountain
passes and the establishment of entry and exit points. It includes adding
elements to improve pilot situational awareness along mountain routes
for VFR navigation and communication.
P 19: “The FAA is considering whether to allow communication gaps on
some published routes. Allowing communication gaps on some routes
would significantly lower the minimum IFR altitudes, while still
providing obstacle clearance. This would provide flexibility for pilots
that may have performance limitation or flight into known icing
conditions restrictions. Additionally, the FAA is evaluating the feasibility
of advanced communication equipment for aeronautical
communications.”
This section either needs to be moved to section 2.2.2 or cross-
referenced there so that the reader has a complete picture of the
situation.
P19: This section discusses improvements to navigation infrastructure
based on WAAS. The section needs to include information on how Part
91 operators may use and benefit from proposed changes mentioned in
this section.
General Note: Please add the organization names associated with the
internal FAA codes to the document so that readers will better be able to
understand what part of the FAA is being referenced. For example,
summary sections that start with 4.2 AVS should mention the line of
business by name associated with the letter code.
P20: These options listed are all considerations, not actual plans or
initiatives.
P22: “AIR leads many user groups, such as the deHavilland
Beaver/Otter group, to increase communication on airworthiness
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concerns, as well as conducting an extensive outreach program.” This is
the summary section, please list user groups and detail the outreach
program in the appropriate section.
Comments on the Prioritized List of Initial Efforts (Appendix 1):
In the interests of improving involvement across lines of business, the
projects listed should include a field that indicates which FAA
organizations (or industry partners, where appropriate) are involved in
each project, including what group or entity is the lead. Analyzing the
degree of involvement across the lines of business and with industry
may also help identify opportunities for stakeholder engagement and
overall safety improvement.
-A prioritized list implies efforts have been ranked in some degree of
importance, urgency, or precedence. This table appears to be are more of
a list of ongoing efforts. A field should be added to indicate where the
effort falls in a ranked system, such as high medium or low, or 1, 2, or 3
with an explanation provided of what these designations mean. If the
category field is an attempt to do so, it should be revised to be clear.
Many of the efforts have no ranking and are confused with the state of
the activity, or contain a ranking and an activity level or only one term.
Please revise for clarity.
-This list includes activities like the Mountain Pass Working Group,
which clearly are safety projects in development. Also included are
standard FAA programs or functions, such as the FAAST Team
disseminating notices, or the Runway Safety Team holding routine
meetings, and ongoing infrastructure refurbishment (replacing a
NEXRAD pedestal or sustaining VORs, etc.). These three types of
activities should at least be separated into different lists, to allow the
reader to clearly see what new, developing efforts are under
development, separate from routine ongoing activities and maintenance
programs.
-The list includes an item labeled “Internal Collaboration.” Elaborating
on how the FAA is planning to enhance this should be a significant part
of this report. While each of the lines of business have provided a list of
their activities, closer examination of how these activities will be
integrated, communicated, and coordinated within the lines of business
would be helpful in demonstrating sincere efforts to improve aviation
safety in Alaska. Endeavors to involve other lines of business within the
FAA, such as CAMI, should also be addressed.
-The AVS section of this appendix list includes an entry “VFR/GPS
routes in Alaska mountain passes” and another “Alaska Mountain Pass
Waypoint Charting initiative.” If these are not two separate items, they
should be combined. If they are separate efforts, more detail is needed to
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describe and differentiate them. A third reference to this working group
exists in the ATO section of the appendix.
We appreciate the goal of this Alaska safety initiative process, and the
work done to date toward that objective.
VWOS
When it comes to the AWOS and VWOS and the non-certified weather
and cameras, why can’t we get the non-certified weather certified? Why
can’t it be used for aviation? Why can’t we get approval for this? Alaska
needs better weather reporting and we should be using all of our options.
The FAA needs to invest in more VWOS. These provide more
information than AWOS, especially when paired with cameras.
The FAA still needs to move forward with AWOS, but VWOS should
be the highest priority and pairing these with cameras. This needs to be
moved up on the FAA priority list.
Agree that the AWOS/VWOS needs to be moved to a high priority and
needs to be funded. We need more systems in Alaska.
The upgrade to the system is amazing and if we can get more funded for
the upgrade it would make a big difference.
160 VWOS stations are needed in Alaska to support General Aviation,
tour operations, smaller operations, and everyone else.
For the VWOS test case, the commenter has heard nothing but positive
comments from his pilots.
Alaska needs reliable weather data for the pilots.
Are ASOS/AWOS the best option? Would VWOS paired with a weather
camera be better in some areas? The FAA regulations have adapted to
changes in technology so we can’t utilize other options that are out there.
The report mentions VWOS projects. How are the VWOS different from
the AWOS?
The Interim Report briefly discusses AWOS. The Barter Island AWOS
isn’t always reported as inoperable when it isn’t fully functioning. Is
someone with the FAA tracking the AWOS outage reporting?
Please continue to support the VWOS program. It is an amazing
advancement.
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Safety Management
System (SMS)
SMS is a great program, but if we don’t have the infrastructure it isn’t
helpful.
SMS – This will help provide some improvements. There are dozens and
dozens of pages for the operators to go through, which is unrealistic for
small operations. Can this be pared down for the Part 135 operations
instead of having each individual operator have to do it themselves?
Alaska Aviation Safety
There has been a lot of work done to improve safety in Alaska, but we
have a long way to go still.
In 2019, 35 people died in aviation crashes in Alaska. The important
information isn’t getting to the pilots.
Flying in Alaska is way different than the lower 48.
The need to improve safety in Alaska isn’t the hard part. The need is
there. The hard part is funding and developing an implementation plan.
Recommends the FAA develop programs to raise awareness in rural
communities to promote aviation safety. This could be similar to the
education campaign in rural villages to address the destruction of
runway lights.
Alaska has a significantly smaller population than the Pacific. If a plane
crashes in Alaska, there is a significantly larger impact to the
community. Especially when an entire family is lost.
Recommends the FAA examine other areas in the country with
significant uncontrolled airspace (example: North Dakota or Montana)
and see what they are doing to improve safety.
Multiple Government
Agency Requirements
Government to government communications isn’t addressed. Different
agencies are putting more stringent rules in place that make it harder on
operators when you combine all the rules. Examples are more FAA
regulations, increasing TSA requirements, stricter Postal Service
requirements.
NOTAMS
When it comes to runway conditions, DOT maintains the reports, but
they aren’t always educated enough to provide proper NOTAMs.
There is a possible delay in issuance from Flight Service due to a
contract in place. There seems to be a lack of education on issuance of
NOTAMS throughout management, or no connectivity for education to
management of NOTAMS which creates a lag time from the system to
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the users. Can the FAA help with the lag or provide the education
needed?
It’s a statewide delay with the system, more information can be
researched and provided. (Good suggestion) Can we provide additional
training to airport operators?
The main issue with the NOTAMs is an issue with Field Condition
NOTAM (FCN) cancelling after 24 hours.
If there is no FCN then the runway is supposed to be clear, dry, and
uncontaminated. The reality is it usually means the airport runway hasn’t
been inspected and could be contaminated.
Page 30 of the report (Appendix 1, AVS Efforts) identifies an effort for
“communication gaps and minimum IFR altitudes study”. Regarding
this, pilots need a better NOTAM system with timely NOTAMs. This is
especially true for runway closures. Pilots sometimes find out about
runway closures when they are going to land their plane.
The airport was closed due to snow removal not being completed, but
the NOTAM didn’t mention the runway closed. The pilot flew to the
airport and saw the issue prior to attempting the landing. Flight Services
in Kenai was notified and they didn’t know the runway was closed.
There have been issues at other airports where the runway closure won’t
be posted in the NOTAM for days. Then, when the runway is open, the
NOTAM isn’t updated to remove the closure. This means that once the
runway is finally useable, the pilots can’t legally use it because the
NOTAM says the runway is closed when it isn’t.
Instrument Approach
Procedures
Is it possible to cluster some of the approaches? If so, it would be
beneficial to have operator input and involvement for this process.
The FAA is building approaches that aren’t useful. They are too high for
the aircraft to utilize them and are based off NDBs. There is a private
contractor that can develop an approach to get pilots down to 300 feet
for Coldfoot, but the FAA approach will only allow a 2,000 foot
approach.
The FAA needs to take a look from the top down and overhaul the data
they are using to make decisions. The data isn’t reflecting actual
conditions for pilots.
Adding instrument approaches should be a high priority in the report.
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What is the process for determining where new approaches go?
There currently aren’t any approved approaches for Nenana, but the
airport is used anyway. This is an important runway in the Fairbanks
area. This is the alternate landing location for Fairbanks and is used if
someone can’t get into Fairbanks International and doesn’t have enough
fuel to divert to Anchorage. An official approach here will prevent
accidents since pilots will go to the approved alternate.
The decision height for the Fairbanks International airport isn’t
appropriate for pilot decisions, especially if the area is socked in with
smoke. The last time this happened, Fairbanks wasn’t clear but Nenana
was.
When pilots fly somewhere in Alaska that doesn’t have weather
reporting, it would be nice to have established let down areas. That way
a pilot who encountered unexpected bad weather had a safe option to
land.
Page 29 of the report (Appendix 1, AVS Efforts) identifies an effort for
“VFR/GPS routes in Alaska mountain passes”. Pilots are flying VFR
routes to Fort Glenn and they use satellite phones for communications. A
GPS approach in this location would be safer. Is there a better way to get
approaches approved and flight tested? It currently takes too long to
complete this process.
Requested clarification if the approaches were different than the special
approaches the oil fields are getting.
There is a lodge operator who tried to get an AWOS installed, but he
gave up after four years because he couldn’t get a special approach
approved.
The approaches need to evaluate the impact to the community. The
communities need the airports for medivacs, but the low population
means a high cost for few people. The current guidelines being used for
evaluation don’t take into account that these are roadless communities
and it would cost far more for DOT to build a road than it would for the
FAA to put in an approach. The safety impact for the individual
community should be a deciding factor and not just the cost per person.
ADS-B
ADS-B has been installed on their aircraft, but there isn’t reliable
coverage throughout Alaska.
When flying from Fairbanks to Anaktuvuk Pass there isn’t coverage.
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How does the FAA determine where new ADS-B infrastructure is
installed?
The FAA is working on a plan to install additional infrastructure in
service areas being used with no coverage. The project will have a final
funding decision made next month. If approved, the plan is to start the
installation in the 2022 construction season. The Alaska construction
season will impact when these can be installed. Per Contributor – This
should be moved to a high priority in the report.
ADS-B coverage is a big issue for pilots. Pilots like the ADS-B and they
want to see improvements in the coverage.
The ADS-B needs more coverage so it can used by the pilots.
We only need ADS-B in Anchorage, not the rest of the state. How do we
get word out to pilots outside of Anchorage? ADS-B is not in the airman
certification standards and we are not testing pilots on this.
Some planes have ADS-B In installed, some have ADS-B Out, and some
have both In and Out. Because of the difference, not all planes are
showing up on the technology for pilots. A pilot can be flying right next
to another plane and the second plane could be invisible because they
don’t have the same equipment installed.
Asking as both airport management as well as a newly licensed private
pilot; as a private pilot, I’ve noticed there is a lot of air traffic and the
traffic is growing over time, there is not a mandate for ADS-B and it’s
important to get coverage to avoid aircraft collisions due to the
abundance of traffic.
Alaska’s airspace is mostly Class G. ADS-B and radio equipment are
optional at most airports. There are planes that fly without any form of
communication, not even a radio. ADS-B needs to be fully implemented
in Alaska and a requirement no matter the age of the aircraft. At a
minimum, radios should be required.
When it comes to IFR, if you don’t have ADS-B Out for IFR then you
don’t have anything.
Suggested the FAA start with reinvigorating the ADS-B retrofit funding
from Capstone.
The FAA needs to deploy an ADS-B infrastructure in Alaska. Are
satellite communications taking over ADS-B?
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The FAA claims the benefit/cost ration doesn’t work for ADS-B to be
installed in urban areas. This isn’t true. It feels like Alaska is getting the
short end because the infrastructure isn’t there. The “other side” of the
FAA is unplugging NDBs and leaving Alaska with nothing because we
still rely on the legacy NDBs due to the lack of ADS-B.
Alaska
Communications
Requirements Meeting
Report page 14, second to last paragraph (section 2.2.1) – The report
references an “annual Alaska Communications Requirements Meeting
where stakeholders have the opportunity to present new requests and
give feedback.” Alaska Air Carriers Association (AACA) hasn’t heard
of this annual meeting before. Can someone provide additional
information on this?
Requested clarification on the FAA’s plan to improve communications
in Alaska.
We believe that significant challenges have been encountered that are
attributable to a lack of clear communications between the FAA’s lines
of business at the regional level. This adds extra time and steps to
development of interventions, safety improvements, and changes to
systems. Included in these challenges are the lack of visibility in points
of contact in the FAA, within the lines of business, and in managing
regional issues. Highlighting and publicizing relationships between lines
of business and points of contact would encourage feedback and
participation in safety interventions from the public and operators.
Workgroups
The Interim Report section 2.3 Operations Safety Management
references various committees and workgroups (Bethel Tower
Workgroup, RSAT, FAAST, ASAP, and the CFIT Accident Prevention
Initiative). What is being done differently this time from what has been
done in the past?
How is the FAA encouraging GA participation in those committees and
workgroups? What does the FAA have in place to evaluate the
effectiveness of those committees and workgroups?
The existing communication tools of the FAA Industry Council and
Alaska Coordination Council are good for information sharing, but not
all FAA LOBs participate in these monthly meetings.
Recommends the FAA become involved in the quarterly air carrier
meetings.
Participated in many workgroups for Alaska. There is a history of a long
lag time from when changes are made to when they actually show up in
the official documents.
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Alaska has an FAA Industry Council, which we believe is an effective
forum to exchange information both across lines of business and with
industry. Yet participation by the different FAA lines of business is not
consistent. Increasing regular participation in this forum by the lines of
business would help keep internal and external stakeholders involved
and provide a venue for industry to be informed regarding FAA
programs and activities.
Collaborate with CAMI researchers in the evaluation of Alaska’s
existing aviation initiatives. Understanding why pilots continue to fly
VFR into IMC and evaluating weather cameras and other weather
resources from a human factors, human error, and human performance
perspective can lead to improvements or modifications to increase their
usage and improve pilot decision-making abilities.
FAA Outreach
How is the FAA utilizing social media for outreach and
communications? UAA conducted a test by putting out a message via e-
mail only and a separate time putting out a message via Instagram only.
The e-mail only message didn’t reach many students since they just
don’t use e-mail. The Instagram only message had a significantly higher
response rate. Today’s students (new pilots and mechanics) are using the
various social media platforms such as Twitter and Instagram for
communications and not e-mail. How is the FAA adjusting our
communications for the new generation?
The report includes a significant amount of equipment and future
projects (ADS-B, T-routes, etc.), but there is nothing that addresses
training, teaching, or outreach to GA pilots.
Recommends the FAA increase its social media presence.
Create a public dashboard with a description of the different Alaska
aviation safety initiatives, their status, schedule for implementation, and
points of contact for each project or program. This will help improve
transparency externally as well as internally across the FAA lines of
business.
FAR Part 147
Here in Alaska, maintenance is approached different due to Part 147.
Congress ordered the FAA to issue a final rule on Part 147, but the FAA
is still sitting on the updates. The FAA inaction is holding back the
industry on maintenance updates. It is time for a change and we need the
rule updated to make the change.
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Weather Cameras
Weather cameras aren’t as good as ground-based systems. There is no
in-flight Wi-Fi for the pilots which means the pilot can’t use the weather
cameras for updates during flight.
Alaska didn’t get enough ADS-B and ASOS installed. Instead, weather
cameras were substituted for the infrastructure. Weather cameras are
commonly referenced during preflight, however they aren’t helpful
while in-flight.
The weather camera program is excellent. It is one of the best things the
FAA has ever done. It is a good alternative to an actual person on the
ground.
Alaska could use more weather cameras and more VWOS. A commenter
agrees that the places that need them don’t have the infrastructure for the
power. It would be great to have these, but a solution to the power issue
needs to be found.
Weather cameras would be helpful if they included a windsock in the
video. It would also be nice to have a camera on the ramp area. This
would be a helpful feature if a pilot forgets to close IFR. This way it can
be verified that they flight did land safely. Understands there are some
privacy issues with putting a camera on the ramp area.
Flight Service
A recent memo was sent to pilots directing them to “brief themselves”
before a flight and “not bother Flight Services”. This is an example of
the lack of interest pilots are getting from Flight Services.
Kudos to Flight Services in the Deadhorse area. They are easy to work
with and the 70 North pilots have no issues with them.
One commenter operates 2 Part 91 airplanes. He recently had to fly to
Spokane for some maintenance repairs. While trying to find information
for filing his flight plan, commenter had a very hard time finding the
information for his Ketchikan fuel stop and the Part 93 rules. Ketchikan
Flight Services required a written letter through the USPS and then they
would mail back, via USPS, the flight procedures. This is 2021. Why
can’t pilots get this information electronically? Why isn’t the
information published? The requirement to use the USPS and then sit by
your mailbox and wait for a reply prohibits pilots from getting the
needed information. The average pilot won’t bother with this process.
FAR Part 139
On the whole it is important for FAA rule making for the nine seats or
more to have required inspections and rescue personnel on stand-by,
currently it is for 30 seats or more when the smaller aircraft hold the
same valued loved ones. (Re: Part 139 exemption)
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The exemption is a “mis-advertisement” only operating part 139 airport
not at all times-is that level of service only necessary for a 737? It should
be just as important for the smaller aircraft as well.
From the student pilot perspective: There is an issue with airports that
don’t report frequent conditions. If they are obligated airports they could
issue a NOTAM to inform pilots of same day conditions.
Airports (Deadhorse) justify traffic for funding a tower? We could start
counting the amount of traffic in areas to provide justification for the
need of a dedicated tower to areas that need one.
SMS
Wanted to express support for SMS for airports and wants to see it
continue as it is very important.
Commenter sees the increase in SMS and the utilization of the flight
assessment tool. In the FAAST Talk (2015 – 2016) there was talk of
developing a flight risk assessment tool. Using a tool from United
Airlines doesn’t apply to the small operations. It would be better to have
a tool developed for the small operations that can be universally used in
Alaska.
One commenter stated that Alaskan carriers are working to collect data
and information on this. It would be helpful for the operators to have a
tool to use. We need a starting place. A lot of programs are already in
place. The SMS is over 1000 pages and not appropriate, or practical, for
the small operators to implement.
A flight assessment tool from Dallas, Texas has very different needs
than a flight assessment tool for Bethel, Alaska. The weight and balance
program applies differently in Alaska with the different aircraft being
flown in the state.
Military Operations
Areas
Military Operations areas of restrictions across mainly the northern areas
of Alaska in particular are growing with the multitude of exercises.
One solution might be to plan cooperation with public and private flying
stakeholders during restricted times and areas.
Enhance communications in the areas that will be effected during
scheduled exercises.
Fairbanks commercial air carriers are effected as they have windows for
arrival and departures during the exercise times or they will be grounded
to wait until they are clear of the time or will be diverted around the area
of military operation.
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A commenter was curious about the “share the airspace” solution in AK.
And, is there a “master plan” for airspace in AK?
CTAF
There used to be a working group for CTAF usage and mid-air collision
avoidance. This coordination/collaboration went away in 2017. Requests
since then, such as the one at Kenai, have gone unanswered.
In Fairbanks, a chart notice appeared one day telling pilots to use a
CTAF frequency that isn’t used in the Fairbanks area. This caused a lot
of confusion for pilots. It would have been helpful to have a forum to
address changes like this and avoid the confusion.
The Mat-Su CTAF change is still causing tension with pilots regarding
that decision that was made.
There was a fatal mid-air collision in the Kenai Peninsula in July 2020,
hopefully the investigation doesn’t find that CTAF was a contributing
factor.
One commenter stated his operations are based out of Fairbanks. The
Fairbanks CTAF change is confusing pilots since it isn’t the frequency
used in that area. The pilot’s understanding is the change was made at
the request of the military.
Most of Alaska lacks sufficient ATC radar coverage to provide Flight
Following services. The FAA and industry worked collaboratively to
evaluate and revise the use of Common Traffic Advisory Frequencies in
specific regions of the state as one strategy to mitigate mid-air collisions.
A request was made by an industry group in the Kenai Peninsula
regarding changes to CTAF frequencies in their local area on January
25, 2017. Employees in several key positions have been made aware of
the risks of mid-air collisions in this area due to overlapping frequencies
and pilots and industry have asked for assistance in remedying the
discrepancies. To our knowledge the FAA hasn’t addressed this issue
and has not provided feedback on the status of this request.
In a different location, in Interior Alaska, a chart notice of an “area
CTAF” frequency was placed on the Fairbanks sectional advising pilots
to use a CTAF frequency that is assigned for a different area, causing a
potential reduction in pilots actually using a common frequency when
making traffic reports in this area.
No notification of the change was publicized to the local pilot
community, nor was there an FAA point of contact provided for
questions or feedback on this confusing notice.
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The lack of communication and coordination across the FAA lines of
business, and lack of a specific point of contact for these issues appear to
contribute to these and potentially other situations regarding the use of
CTAFs.
VFR Routes
There is a lot of time being spent on instrument improvement/weather
and VFR.
There is significant VFR traffic in Alaska. There is currently no formal
process to identify VFR routes in the state. This would help to identify
weather camera locations and help with flight restrictions. VFR isn’t
considered when flight restrictions are issued.
ADS-B coverage, specifically satellite ADS-B, would help define these
routes.
VFR routes aren’t published on a chart, but they are how a pilot
normally flies from A to B with GPS direct. The terrain doesn’t always
allow a straight line flight to occur.
The voluntary 1090 out has helped to identify the preferred routes that
pilots are flying.
The purpose of the information is where to install weather cameras and
identify possible choke points, not to add everything back to the charts.
The information might be helpful for identifying infrastructure needs
and not adding more routes.
We aren’t looking to tell people how to go from A to B, we are looking
at how they are already getting there to identify the needs along the most
used routes.
While significant attention is being devoted to the improvement of
instrument flight rules infrastructure, we anticipate that the lack of
deicing capabilities for smaller general aviation aircraft will result in the
majority of flight operations in Alaska continuing to be conducted under
visual flight rules. These aircraft types are used both in Part 135 and Part
91 operations. Pilots flying under VFR also have needs for
infrastructure, such as Remote Communication Outlets to communicate
with Flight Service, a broader network of weather reporting stations to
make informed operational decisions, and additional weather cameras to
aid pilot decision making for VFR flights.
To plan and continue a build out of infrastructure to support VFR
operations in an efficient manner, the FAA needs to define the major
VFR routes across the state for planning purposes. Knowledge of
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major VFR routes would assist with organization and scheduling of
infrastructure development and optimize the use of resources. This
would provide the basis for justifying where additional weather
cameras are needed, as well as lower cost weather reporting stations
that are being prototyped presently, to fill gaps in the observational
network. The FAA should work with industry to identify and
understand the major VFR routes in Alaska to help site infrastructure
specific to the needs of the VFR operators. Better understanding of
VFR routes would also inform the design of airspace when considering
military training areas, restricted areas, and temporary flight
restrictions, etc.
Deicing
Larger companies have to file carbon footprint and deicing reports with
other federal agencies. Any measures the FAA could implement to help
operators reduce their carbon footprint and reduce the amount of deicer
they use the better.
Even when larger companies operating more sophisticated aircraft can
fund de-icing at remote airports, it isn’t always feasible to establish the
deicing options due to regulations regarding chemical usage in
environmentally sensitive areas.
The current Presidential Administration has increased the reporting on
carbon emissions and chemical usage. Reduction of these is a big item
for the Administration.
NEXRAD
NEXRAD is lacking in Alaska.
RCAG and RCO
RCAG (Remote Communication Air/Ground): The infrastructure has
been out of service for a long time (inoperable). Need new fiber optics
but it hasn’t been funded.
Give high priority to continued development and testing of innovative
technology to increase the number of RCO and RCAGs and improve
communications with Flight Service and Air Traffic Control. This
should provide more access to IFR infrastructure, in the form of lower
MEAs on T-Routes, as well as giving VFR pilots more opportunities to
use FSS and ATC services.
Aviation Accidents
It is important to note that not all accidents in Alaska are being reported.
Especially in remote locations.
Federal Aviation
Regulations
The FAA takes too long to change regulations so the FAA writes a
handbook on how to interpret the regulations instead.
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The local Flight Standards District Office (FSDO) has interpreted
regulations wrong in the past. It is all up to interpretation.
An update was released for 49 USC last week. How long has that been
in the works?
The Alaska exemption in the regulations hasn’t been widely known or
the operators would have been using it. This highlights the issue that it
takes the FAA too long to make a rule and update the regulations. By the
time the guidance gets to the operators, it is too late to make a
difference.
The 89 guidance was written by Part 139 operators who didn’t know
how this really applies in Alaska.
We have a lot of legacy aircraft here. There are flight manuals from the
1970s still being used. Operators are being told by FAA inspectors that
the manuals don’t cover the required items because they are too old. The
aircraft are older, but they are very reliable for the needs in Alaska. The
FAA has an obligation to operate for all system users, not just the lower
48 larger operations.
The DC rule makers don’t understand that 82% of Alaskan communities
are off the road system and rely on aviation.
NTSB
Recommendations
Recommends the FAA track the NTSB findings and provides regular
updates on the progress of meeting this recommendations.
There is the appearance that the NTSB recommendations aren’t being
fully embraced by the FAA.
Some of the issues being raised are systemic and enduring. Rich found
and NTSB study from 1995 regarding aviation safety in Alaska. That
study had the same chronic issues we are talking about today.
There needs to be a systematic way to address the issues.
Understands the NTSB has an advisory role and is not an enforcement
agency.
UAS
The FAA should explore ways to leverage UAF (University of Alaska
Fairbanks) and partner with ACUASI (Alaska Center for Unmanned
Aircraft System Integration). There are 3 UAS (unmanned aircraft
systems) programs ongoing and UAF is the only group with a seat at the
table for all 3 groups.
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UAS is working to map airports to identify obstructions. A better
partnership with the FAA and UAS would improve safety. Alaska DOT
has an airport mapping challenge at Nenana on August 25th. Contractors
will be flying UAS over the airport and showing off what the technology
can do. Encouraged the FAA to participate in the event.
Recommends the FAA encourage and support UAS in rural Alaska. This
would save in AIP funding.
Recommends the FAA keep UAS in mind when they are developing
airport infrastructure for rural Alaska. Cargo deliveries are in the R&D
stage with plans to install hubs at rural locations.
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Appendix 4: Links to Reference Documents and Reports
NTSB Report and Safety Recommendations
NTSB Report ASR-20-02 can be found at the following website:
https://www.ntsb.gov/investigations/AccidentReports/Reports/ASR2002.pdf NTSB
Safety
Recommendation can be found at the following website:
https://www.ntsb.gov/_layouts/ntsb.recsearch/Recommendation.aspx?Rec=A-20-011
14 Code of Federal Regulations: Parts 91, 119, 121, 135 and 139
14 CFR – Part 91 GENERAL OPERATING AND FLIGHT RULES
https://www.ecfr.gov/cgi-
bin/textidx?c=ecfr&sid=3efaad1b0a259d4e48f1150a34d1aa77&rgn=div5&view=text&n
ode=14:2.0.1.3. 10&idno=14
14 CFR – Part 119 CERTIFICATION: AIR CARRIERS AND COMMERCIAL
OPERATORS https://www.ecfr.gov/cgi-
bin/textidx?c=ecfr&sid=4d87705808eddb6d1f536f86f59ff284&tpl=/ecfrbrowse/Title14/
14cfr119_main _02.tpl
14 CFR – Part 121 DOMESTIC, FLAG, AND SUPPLEMENTAL OPERATIONS
https://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title14/14cfr121_main_02.tpl
14 CFR – Part 135 AIR CARRIER AND OPERATOR CERTIFICATION
https://www.faa.gov/licenses_certificates/airline_certification/135_certification/
14 CFR – Part 139 CERTIFICATION OF AIRPORTS
https://www.ecfr.gov/cgi-
bin/textidx?c=ecfr&SID=8313bccee050ec81d7e8fb3377331177&rgn=div5&view=text&
node=14:3.0.1.1.14&idno =14
Flight Standards under Sections 322 and 516 and in accordance with AC 135-45.
https://www.faa.gov/documentLibrary/media/Notice/N_8900.563_FAA_Web.pdf
Interim FAASI Report
https://www.faa.gov/sites/faa.gov/files/2021-09/FAASI_Interim_Report.pdf
HR302 Section 322 (FAA Reauthorization Act), Page 86
https://www.congress.gov/115/plaws/publ254/PLAW-115publ254.pdf