In an alarming disclosure, the FAA last month released figures showing that only about two-thirds of all U.S.-registered business jets have received approval to fly in RVSM airspace despite the planned nationwide implementation of the new operating rules less than two months from now.
The figures almost certainly mean that thousands of business airplanes will be locked out of the airspace between FL290 and FL410 starting on January 20, the implementation date for U.S. domestic RVSM (DRVSM). Because there is little hope for a delay of DRVSM beyond that date, the situation is prompting concerns about possible flight delays and overcrowding in the lower flight levels as non-compliant jets are forced to fly below FL290.
“There is the very real potential for bottlenecks at those lower altitudes for airplanes that have not obtained an FAA letter of authorization (LOA) to operate in domestic RVSM airspace,” said Ross Burton, RVSM program manager for CSSI, a technical and engineering consulting firm based in Washington that has worked closely with the FAA to implement the new requirements. “This hasn’t turned out the way many of us thought it would.”
Word that RVSM compliance today stands at about 62 percent of the total U.S. business jet fleet is especially disconcerting considering that at this time last year the pace of RVSM certification work actually appeared to be ahead of where the FAA expected it to be. According to figures the FAA provided last January, operators of about 3,700 business jets had obtained LOAs from the FAA clearing them for RVSM operations. But as of last month, the number of airplanes approved for RVSM was around 6,100, meaning that in the last year or so the FAA has approved fewer than 2,400 additional airplanes for RVSM out of a total bizjet fleet that numbers about 9,800.
An unknown number of airplanes are in the RVSM approval pipeline, but even relying on the most optimistic estimates there will still be more than 1,000 non-compliant airplanes in the fleet after the start of RVSM in North America. Pessimistic figures, meanwhile, put the total closer to 3,700.
Also somewhat troubling is the fact that of all the airplanes that have so far been approved to fly in RVSM airspace, from an operational standpoint only a small portion (less than 13 percent) are business jets. Chief pilots and aviation department managers have complained that because business aviation is such a small component of the overall airspace picture compared with the airlines their concerns have fallen on deaf ears. Many have also charged that approval standards vary widely from one FSDO to another, with some operators experiencing long delays in obtaining LOAs.
But while representing just a sliver of the whole, bizav is an important slice as it puts the total U.S. aircraft fleet over the 85-percent operational compliance threshold that the FAA needed to justify implementing domestic RVSM on schedule. As a result, there apparently have been no discussions inside the FAA that would lead to a delay of DRVSM beyond next month.
“From everything I have heard, it has been green-lighted all the way up the chain of command,” Burton said. “All the signs say DRVSM is a go.”
Living below FL290
For the past few years, aircraft manufacturers and avionics installers have been warning operators to start RVSM-related upgrades sooner rather than later. While many listened, apparently not everyone heeded the admonitions from OEMs. In fact, according to the FAA’s own figures, the level of compliance for certain models is startlingly low. As examples, RVSM LOAs have been obtained by only about 20 percent of Learjet 35 operators; 35 percent of Beechjet 400A operators; and 60 percent of Gulfstream II operators.
The situation has deteriorated to the point that Cessna is reporting that more than 900 Citation operators in the U.S. have yet to take the necessary steps to comply with RVSM, this despite the fact that the manufacturer has spent the time and money to develop STC packages for all of its models except certain Citation 500s.
Cessna has warned that prices for the RVSM kits will increase after the first of the year. This is an interesting side note to the RVSM story because many operators apparently presumed prices for RVSM upgrades would fall after U.S. implementation, and now, at least in this one case, the opposite is occurring.
Still, it is tough to fault the chief pilot who decided to forego RVSM approval work far in advance of the compliance date considering the FAA’s track record for completing lofty modernization projects on schedule.
According to operator surveys, more than 1,000 U.S.-registered business jets definitely will not be approved for RVSM on time. Reasons vary, but a recurring answer from respondents to surveys has been that they plan to wait until after RVSM takes effect to complete the necessary avionics upgrades if they find living with the new rules is too restrictive. This way, presumably, flight department managers would not be forced into the position of having to justify to their bosses the capital outlay for equipment upgrades that turned out to be unnecessary.
A Frost & Sullivan survey released early last year and paid for by avionics manufacturer Innovative Solutions & Support found that while several thousand business jets had yet to comply with the requirements of RVSM, only 2,400 more were expected to be upgraded on time. That leaves at least 1,600 airplanes in non-compliance after the deadline, a situation that even the FAA has admitted could cause problems for ATC, especially in busy sectors affected by bad weather.
RVSM reduces the vertical separation between airplanes from the typical 2,000 feet to 1,000 feet, effectively squeezing more aircraft into the same block of airspace. The penalties for non-compliance with RVSM center on reduced range and higher fuel burns resulting from being forced to fly below the restricted airspace (presuming that ATC will not always allow airplanes to transition through the RVSM flight levels to cruise on top). According to some, the consequence for not complying with RVSM could also include delays and ground holds if the nightmare scenarios– where an influx of turboprops, regional jets and non-RVSM business jets mix at the same flight levels–indeed play out.
“The performance penalties are bad enough, and now the CEO has to deal with thunderstorms and a bumpy ride, or even a ground hold, when last spring it was smooth sailing?” asked David Windham, vice president for Conklin and de Decker.
Conklin and de Decker worked up performance figures on behalf of AIN to give readers an idea of the fuel penalties for a variety of popular business jet models flying at FL270, FL350, FL390 and FL410 (see chart). Using a mid-weight figure for each of six models, the numbers show the fuel burn for the airplanes’ most efficient altitudes compared with FL270 (the highest available flight level below the floor of RVSM airspace), which in these examples were anywhere from about 50 to 200 gallons per hour higher.
The Learjet 35, as an example, burns 181 gallons of fuel per hour at FL410 and 287 gallons at FL270, for a difference of 106 gallons an hour. Calculating that a gallon of jet-A these days sells for an average retail price of about $2.75, that’s almost $300 more per hour. It gets worse for a Gulfstream II, which was calculated as burning 542 gallons an hour at FL390 and 746 an hour at FL270, for a difference of 204 gallons (or about $561) an hour.
CSSI’s Burton admitted the RVSM compliance rate has been far lower than original estimates, but he said there are many airplanes that typically are not flown on long trips, meaning those operators have done the math and calculated they can live with flying below FL290.
Certain airplanes cannot wait for DRVSM to take effect to make necessary modifications because these airplanes are so inefficient below FL290. These aircraft include the Learjet 24, 25, 31, 31A, Beechjet 400A and Falcon 20, 50 and 900. And, as noted earlier, it doesn’t always just come down to dollars and cents. A loaded Learjet 31A has less than a 1,200-nm IFR operational range at FL430. At FL290, the range of that same airplane is significantly reduced, meaning not only paying more for additional fuel, but having to make extra stops along the way.
As a consultant to the FAA on RVSM, CSSI was involved with the cost/benefit analysis that the agency used to justify the new airspace rule. According to the figures that the FAA relied on to go ahead with implementation of RVSM, the total savings to airlines and general aviation operators between now and 2016 would be about $5.3 billion, with some $4.8 billion attributed to fuel savings and another $460 million to delay reductions.
But on the “costs” side of the ledger the FAA estimated fuel penalties in that same timeframe of $103.7 million, which would be accrued by non-compliant airplanes. It is not clear how the agency arrived at this figure, but based on the low rate of compliance shown in the FAA’s own figures, $103 million certainly could be an underestimate. And we may never know the true costs for operators of non-compliant airplanes because the FAA is unlikely to pay for a
new analysis now.