HGS is not a guarantee for Cat III approaches
In the past several years there have been many magazine articles touting the promise of the Head-up Guidance System (HGS). It is a system that has great potential for Part 91 operators, but currently IBM is the only Part 91 operator certified and current to use an HGS for Category II/III approaches. Several large corporations have given up trying to put their systems into service.
Apparently there is a misconception that if an HGS is bolted in your aircraft, you can use it immediately to fly an approach to lower than Cat I minimums. To do that, you need an operations manual certified by the FAA, and to have a manual you need to develop your own Cat II/III program, including maintenance, operational and training procedures.
My interest in HGS developed when I first saw one installed in Dassault’s flight-test Falcon 2000. In spring 1996 I had the opportunity to get my type rating in S/N 001, at the Dassault test facility in France, before a simulator was built in the U.S.
Our two new Falcon 2000s were ordered with HGS installed. Everyone was excited about its potential. Our management believed at the time that eventually we would be able to fly to lower than Cat I minimums on a Cat I runway. It was the primary reason they decided to spend $500,000 on one piece of avionics. I am hoping it will happen one day for Part 91. However, the current FAA documentation (FAA Order 8400.13, paragraph 5) applies only to Part 121/135 operators, and if you have a Falcon 2000 below S/N 78, you will have to make major avionics changes to be legal for lower than Cat I on a Cat I runway.
I do not know what the procedure would be to have an airport added to the 8400.13 order. Bob Blouin, senior v-p of operations at NBAA, is currently working on bringing together the “low visibility” office and the general aviation office of the FAA to have Part 91 operators included in 8400.13 or perhaps have the order addressed in a general aviation document. I imagine it is not a simple process.
In summer 1996, when we received our two new Falcons, I knew only that a manual of some sort would be required for us to fly Cat II/III approaches with the HGS. It didn’t sound too difficult at the time, so I started with the aircraft flight manual supplement pertaining to HGS, and began to write. Our chief pilot had given it a try, but quickly assigned the project to me.
There are two documents that are crucial in developing an HGS operations manual. The first is Advisory Circular 120-28D, and the second is Flight Standards Handbook Bulletin for General Aviation 99-16. Neither of these documents existed in 1996; they were not published by the FAA until July 13, 1999, and Aug. 31, 1999, respectively. The handbook addresses operations manuals and states that a manual must be developed by the operator/certificate holder. It does not actually use the word “must,” but it was interpreted that way when we asked for help with a manual at various operator conferences. The mantra we heard from the manufacturers was “the FAA does not want ‘cookie-cutter’ manuals.”
One recent article in AIN was titled, “Following bizav’s lead, many airlines see the virtues of HUD” (August, page 70). The idea that “bizav” is leading the airlines could not be further from the truth. Alaska Airlines was the leader in HGS use and has been using them since 1988. As previously stated, Part 91 did not even have the regulatory means for certification until 1999. Airlines have the resources of large operational, maintenance and training departments to support a low-visibility program. We had one person–a regular line pilot, typing on his days off.
IBM had one pilot working on the program. He and I traded information back and forth, but in keeping with the anti-cookie-cutter philosophy, our two manuals looked completely different.
Hundreds of Hours Later
In fall 1999, after hundreds of hours and three complete format changes, I thought I had a pretty good manual put together. I had all of the required letters written and all of the forms filled out. The application for Cat III operations filled a three-inch ring binder. I handed it in to the Farmingdale FSDO in October 1999, and then the real work began. Many changes were made. The wording had to be changed on the application and maintenance procedures had to be changed. Maintenance documentation also had to be invented. We (the operators) had to get Dassault to change its maintenance manual.
Every paragraph of 120-28D had to be addressed. I would go over at night and work with the maintenance inspector when he was on night duty, waiting for an airline emergency. Finally, on Dec. 23, 1999, everyone at our FSDO was satisfied and our application was sent off to Washington for approval.
The “low-visibility approach” office at the FAA is called AFS-410. They liked the manual. We received our approval from them in March last year. The initial authorization provides for Cat II minimums only (100-ft DH/1,200-ft RVR). Six months after our approval, we flew a checkride with our FSDO and received approval to operate to Cat III minimums (50-ft DH/700-ft RVR). In October last year we had completed the process, four years after taking delivery of our two Falcon 2000s.
We (Citigroup) became the first Part 91 operator to become certified for Cat III operations. We received about a paragraph of recognition in some aviation magazines. IBM is the only other corporate operator currently certified for Cat III operations. That company’s manual was approved shortly after ours.
There were some heroes. Mike Spielberger from FlightSafety Teterboro provided a lot of information and guidance, Dick Smith from Flight Dynamics provided tons of technical information, and Steve Ludwig from Dassault engineering got things done when we asked him to change things. The biggest surprise to me was the competence, knowledge and “let’s get the job done” attitude of the FAA staffers. They didn’t make it easy, but they worked and worked until we came up with a solution to every problem. The FAA never told us to go figure it out on our own.
Although we were the first Part 91 operator certified by the FAA for Cat III operations, at the present time we are not operational. It was a decision our management made because they felt it was not a program we could maintain on our own.
Training has been a difficult issue. I acquired an HGS-specific interactive training CD-ROM from an airline training department. We have asked at the last two operator conferences if a training CD-ROM could be provided for us. It was an action item in the minutes from the meeting last November. Jeff Lee, director of IBM’s flight operations, posted a request for a training CD-ROM on Flight Dynamics’ Web site on April 26, 2000. There has not been a Part 91-specific operator conference since last January 30, and not even a status report on the CD-ROM.
Dassault Falcon Jet has one person at its help desk, who is just now learning about HGS. Dassault owns the paperwork for the installation of the Flight Dynamics HGS installation in Falcons, and it is ultimately responsible for the success of the HGS. One new person at a help desk does not translate into an important program. Dassault has two new airplanes coming along, and a totally new avionics suite called EASy. Perhaps HGS is no longer that important. Another important question: why doesn’t Dassault Falcon Jet have Cat III approval for its own flight department?
Alvin Toffler wrote a book 30 years ago called Future Shock. In the book he analyzed in detail how society/humanity is changing at an ever accelerating pace. One of his predictions was that “things” would become less and less valuable. It may be at this point that HGS has lost its value for Part 91 operators to the ever accelerating pace of avionics development.
Tom Morrison is a Falcon 2000 and 900EX captain for Citigroup.