alf5071h, et al
I reinforce the point that it extremely disappointing that the FAA is not considering rulemaking, yet are party to JAR comment procedures. The FAA’s position does little to reduce the problems of differing standards and alternate terminology in use around the world.
Some FAA history on the subject - contaminated runway.
At the Aeronautical Information Services and Aeronautical Charts Division Meeting 1966, specification for Snowplan; definition and pro forma for SNOWTAM was on the agenda. Statement by the delegation of the USA:
“The Delegation of the United States of America wishes to record a reservation to Recommendation 2/1 – Amendment to Annex 15, (Snow Plans), Recommendation 2/2 – Snowtam Reports, and Recommendation 2/3 – Amendments to Annex 15 (Snowtam proforma). This reservation is based on the fact that without having looked at the substance of EUM V Recommendation 4/9, 4/10 and 4/11, the Air Navigation Commission referred these recommendation to AIS/MAP Meeting only insofar as the reporting and dissemination procedures are concerned. This was done less than 14 days before this Meeting convened. Consequently, the Delegation of the United States and perhaps many other delegations were not prepared to consider all the various aspects of the problems raised by these recommendations from the Fith EUM Meeting. In formulating its recommendations, this Meeting clearly exceeded the terms reference given it by the Air Navigation Commission. Nevertheless, it is hoped that action by this Meeting will not be considered to have prejudged the importance and continuing work of the ICAO Study Group on Snow, Slush, Ice and Water on Aerodromes, which may in due course produce more mature and considered recommendations for world-wide standards, practices and procedures.”
With reference to the 1966 meeting, the Snow Plan and SNOWTAM-format was part of Amendment 10 of ICAO Annex 15 (Adopted/Effective/Applicable – 13 Jun 67/8 Oct 67/8 Feb 68)
There exists a draft FAA AC 91-6B – Performance information for operation with water, slush, snow, or ice on the runway”. It is dated JUN 18 1986.
ALPA commented the AC in a letter OCT 7 1986:
“We are pleased the FAA is issuing an AC on this subject. For many years the U.S. military services and many foreign regulatory agencies and carriers have had procedures and correction charts for dealing with decreased friction on runways. We have long advocated more precise air carrier procedures for dealing with contaminated runways.”
8 comments
“Again, we want to congratulate the FAA for taking the initiative in developing such a comprehensive document. The use of this AC should go a long way toward improving safety while operating on contaminated runways”
There exist another updated version of the draft AC dated 8-16-89.
JAA - JAR 25. In Change 13, 18 Oct 1988 - Performance Information for Operations with Contaminated Runway Surface Conditions – became part of JAR 25. The rule and associated advisory material addressed the development of performance information on both wet and contaminated runways. In this you will find definitions for contaminated runway in principle as used in the draft FAA AC 91-6B.
EASA NPA 14/2004 – Operation on Contaminated Runways:
“FAR 25 does not address performance on contaminated runways so harmonisation is not currently a consideration”. …. “However, harmonisation of this will be addressed in the future.”
Don Stimson. FAA, Transport Standards Staff.
From the Proceedings of the 3rd International Meeting on Aircraft Performance on Contaminated Runways, IMAPCR 2004, Montreal November 2004.
“Abstract:
Currently, the FAA’s certification and operating rules do not contain specific requirements for operating on runways contaminated by snow,slush, standing water, or ice. Guidance for contaminated runway operations is provided in FAA Advisory Circular (AC) 91-6A, “Water, Slush, and Snow on the Runway,” dated May 24, 1978. FAA Order 8400.10, “Air Transportation Inspector’s Handbook,” provides guidance to FAA inspectors for contaminated runway operations.
In 2002, the Aviation Rulemaking Advisory Committee (ARAC)recommended that the FAA revise the operating rules to take intoaccount the effects of contaminated runways on takeoff performance anddevelop harmonized airplane certification requirements for contaminatedrunway performance. Because of concerns about economic impact, the ARAC did not reach a consensus on whether consideration for an engine failure (as in the current dry and wet runway takeoff requirements)should be included.
Due to resource constraints and higher priority safety and security issues,the FAA has not yet taken action on the ARAC’s recommendations. Even without specific Federal Aviation Regulations requirements, however,many U.S. operators account for contaminated runways for dispatch.”
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Well, as harmonization will take place in the future (some time) it is a good thing that FAA comments on the EASA regulations. At least there is a "dialogue". But like you I am disappointed with respect to the progress to
"...in due course produce more mature and considered recommendations for world-wide standards, practices and procedures.”
as the US delegation expressed themselves in 1966.