91-73B Parts 91 and 135 Single Pilot, Flight School Procedures During Taxi Operations
1. PURPOSE.
This advisory circular (AC) provides guidelines for the development and implementation of standard operating procedures (SOP) for conducting safe aircraft operations during taxiing to avoid causing a runway incursion. In accordance with the current edition of Federal Aviation Administration (FAA) Order 7050.1, Runway Safety Program, the definition of a runway incursion is any occurrence at an aerodrome involving the incorrect presence of an aircraft, vehicle, or person on the protected area of a surface designated for the landing and takeoff of aircraft. This AC is intended for use by persons operating aircraft single pilot under Title 14 of the Code of Federal Regulations (14 CFR) parts 91 and 135, and flight schools. The FAA recommends that these guidelines become an integral part of all SOPs, Flight Operations Manuals (FOM), and formal flight training programs. The contents of this document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
2. CANCELLATION.
AC 91-73A, Part 91 and Part 135 Single-Pilot Procedures During Taxi Operations, dated September 26, 2003, is canceled.
3. FOCUS.
This guidance focuses on the development and use of mitigation procedures that will avoid a runway incursion and enhance safe taxi operations.
4. RELATED READING MATERIAL.
You can find this and other ACs on the FAA’s website at https://www.faa.gov/regulations_policies/advisory_circulars.
a. FAA ACs (current editions).
• AC 90-66, Non-Towered Airport Flight Operations.
• AC 120-57, Surface Movement Guidance and Control System.
b. Other Guidance.
• Safety Alerts for Operators (SAFO) 11004 Runway Incursion Prevention Actions.
• Aeronautical Information Manual (AIM).
• Pilot’s Handbook of Aeronautical Knowledge.
c. Websites.
• Aircraft Owners and Pilots Association (AOPA) Runway Safety: https://www.aopa.or g/training-and-safety/air-safety-institute/safety-centers/runway-safety.
• FAA Runway Safety Program: https://www.faa.gov/airports/runway_safety/.
• National Aeronautics and Space Administration (NASA) Aviation Safety Reporting System (ASRS): https://asrs.arc.nasa.gov/.
• Runway Status Light (RWSL) Program: https://www.faa.gov/air_traffic/technology/rwsl/.
• Notices to Airmen (NOTAM): https://pilotweb.nas.faa.gov/PilotWeb/.
5. BACKGROUND.
Runway incursions have sometimes led to serious accidents with significant loss of life. Although they are not a new problem, with increasing air traffic, runway incursions have been on the rise. One of the biggest safety concerns in aviation is the surface movement accident. As a direct result, the FAA has rapidly expanded the information available to pilots, including the addition of taxiway and runway information in FAA publications. The FAA has also implemented new procedures and created educational awareness programs for pilots, air traffic controllers, and ground operators. By focusing resources to attack this problem head-on, the FAA hopes to reduce and eventually eliminate surface movement accidents. This AC develops practical guidance toward the goal of increasing safety and efficiency of aircraft movement on the airport surface while reducing the risk of runway incursions.
Increased traffic and expansion at many airports creates complex runway and taxiway layouts. This additional complexity makes airport surface operations more difficult and potential for runway incursions more hazardous than in the past. To increase safety and efficiency, it is necessary to lessen the exposure to hazards and risks by holding the pilot’s workload to a minimum during taxi operations. This can be accomplished through SOPs that direct the attention of the pilot to essential tasks while the aircraft is in motion. The development and formalized training of safe operating procedures during taxi operations should be implemented by each operator.
In developing SOPs, it is important to consider pilot workload prior to takeoff and before landing. Considerations should be given to tasks that make up the normal workload of pilots, such as accomplishing checklists, configuring the aircraft for takeoff and landing, programming flight management systems (FMS), and managing communications with air traffic control (ATC). The more complex the activities within the flight deck work environment, the greater the need for explicit, yet simple and clear SOPs. The overall goal is for operators to develop standardized pilot procedures that will increase the pilot’s awareness but will not increase his/her workload while taxiing the aircraft.
6. USE OF SOPs.
The use of SOPs should be:
• Emphasized during the certification and proficiency training of all pilots;
• Emphasized and used during all phases of flight, including ground operations; and
• Evaluated during the flight review of all certificated pilots (refer to 14 CFR part 61, § 61.56).
7. SINGLE-PILOT PROCEDURES.
The potential for runway incidents and accidents can be reduced through adequate planning, coordination, and communication. The following guidelines are intended to help pilots cope more effectively with current airport conditions during taxi operations. All pilots will benefit from this guidance, which expands on and is grouped into seven major categories: Planning, Situational Awareness, Written Taxi Instructions, Pilot/Passenger Communications, ATC/Pilot Communication, Taxiing, and Exterior Lighting.
Thorough planning for taxi operations is essential for a safe operation. Pilots should plan for the airport surface movement portion of the flight just as they plan for the other phases of flight. Planning for taxi operations should be an integral part of the pilot’s flight planning process and should be completed in two phases: review items and briefing items.
Because of the constantly changing airport conditions and guidance information, the pilot must be aware of any changes made to regulatory and guidance information sources. The pilot also needs to have a thorough understanding of the items in this AC and other relevant reading material.
(a) FAA initiatives are updating airport signage, marking, and lighting. Be sure you are thoroughly familiar with the updates. Also, there are initiatives that are taking place in airport lighting, and it is important to know what the lighting is displaying to the flightcrews (e.g., Surface Movement Guidance Control System (SMGCS) and RWSL).
(b) Without explicit ATC clearance, do not cross any runway hold short lines or an instrument landing system (ILS) critical area if in use.
(c) Review the current airport NOTAM and the automated terminal information service (ATIS) for runway and taxiway closures, construction activity, and other airport-specific risks. It is assumed that ATC has firsthand knowledge of runway and taxiway status. If a clearance is received to use a runway/taxiway that a NOTAM/ATIS broadcast indicates is closed, query the controller for verification of clearance.
(d) Review the current airport diagram and hot spots and, if in use, a published textual description of standard taxi routes to provide an overall “big picture” of the airport and its potential areas for a runway incursion.
It is critical for safety that a thorough briefing of taxi operations is conducted and understood by the pilot. Briefing of the following items should take place at a time when they are relevant and fresh in the pilot’s memory (e.g., before taxi and prior to initial descent for landing). The following guidance should be used to conduct a briefing for all pilots.
(a) Pilots should brief the timing and execution of aircraft checklists and communications at times that will not interfere with the pilot’s responsibility to be aware of their taxi progress, location, and overall airport taxiing activity. When briefing these tasks, they should also consider the anticipated duration of the taxi operation, the locations of hot spots/complex intersections and runway crossings, and the visibility along the taxi route. If possible, pilots should conduct predeparture checklists only when the aircraft is stopped or while taxiing straight ahead on a taxiway without complex intersections.
(b) Remind all cockpit occupants of the importance of maintaining a sterile cockpit, but encourage the ability to speak up if anyone sees a potential conflict.
(c) Brief all pilots to display the current airport diagram to follow the progress of the taxi operation. (Refer to the NOTE below.)
(d) Brief the expected taxi route to include any hold short lines and runways to cross, hot spots, as well as any other potential conflicts. Once taxi instructions are received, the pretaxi route should be reviewed and monitored. It is essential that any changes to the taxi route be fully understood by pilots.
(e) Address previous experience at the airport and unusual procedures or techniques that are not typically used on an everyday basis, such as different pushback procedures or communication requirements.
(f) Identify critical locations on the taxi route (e.g., hot spots/complex intersections, crossing intervening runways, entering and lining up on the runway for takeoff, and approaching and lining up on the runway for landing) where enhanced vigilance is important to avoid a runway incursion.
(g) Complete as many checklist items as possible (e.g., setting the flaps, trim, loading final weight and balance data, and FMS/global positioning system (GPS) navigation inputs) before initial taxi, once the aircraft is clear of equipment and personnel. In addition, upon landing, no items should be changed or moved until the entire aircraft has crossed the respective runway’s hold short line.
(h) Conduct all after landing checklist items, contact ground control for taxi instructions, read back the instructions, review the airport diagram, and monitor your progress to parking.
(i) During low visibility operations, brief the requirements and special considerations such as the low visibility taxi chart, if published for the airport, and be alert if ATC states to hold short of the ILS critical area line.
(j) The use of cell phones and other electrical devices is discouraged during taxi and prohibited for air carrier operations. It is important to ensure that everyone present in the aircraft turn off their phones and devices during taxi operations to prevent any distractions.
When operating an aircraft that does not have a door between the flight deck and the passenger compartment, the pilot may need to ask passengers to maintain a sterile cockpit and refrain from unnecessary conversation from the time the preflight preparations begin until the time the aircraft is clear of the terminal area and at cruising altitude. The same procedure should be followed on arrival, from the time landing preparations begin until the aircraft is safely stopped at the terminal.
When conducting taxi operations, pilots need to be aware of their proximity to other aircraft and vehicles moving on the airport. This SA is comprised of, but not limited to, knowledge of the aircraft’s precise position. Pilots should use a “continuous loop” process to actively monitor and update their progress and location during taxi. This includes knowing the aircraft’s present location and mentally calculating the next location on the route that will require increased attention (e.g., a turn onto another taxiway, an intersecting runway, or hot spots). SA is enhanced by understanding the ATC clearance issued to the pilots, other aircraft, and vehicles in order to avoid potential conflicts. In addition to the above, the following are specific pilot actions to mitigate the pilot causing a runway incursion.
(1) Have a current airport diagram readily available for reference and check the assigned taxi route against the diagram with the heading indicator or compass, paying special attention to hot spots/complex intersections. While maintaining outside vigilance, the pilot(s) must follow the aircraft’s progress on the airport diagram of ensuring that the pilot is following the instructions received from ATC.
(2) Pilot(s) must monitor the taxi clearance and read back all hold short instructions. Verbalizing hold short instructions is a method to ensure that the pilot(s) have a clear understanding of the intended taxi plan and do not cross any runway hold short lines without ATC clearance.
(3) Know and use all of the visual aids available at the airport, such as the signs, markings, and lighting, as well as ground and/or tower ATC, to follow the taxi route.
(4) Prior to entering or crossing any runway, the pilot must be positive that ATC has cleared them to enter or cross the runway. Pilots should scan the full length of the runway and also scan for aircraft on final approach. If there is any confusion about the scan results, the pilot should stop and ask ATC to clarify the situation.
(5) When approaching an entrance to a runway, pilot(s) will ensure compliance with hold short or crossing clearance. Furthermore, bring the aircraft to a complete stop, or be in a phase of taxiing that has no risk of causing a runway incursion, before continuing with operational duties and checklists.
(6) Be especially vigilant if another aircraft that has a similar call sign is on frequency. Care should be taken to avoid inadvertently executing a clearance or instruction for another aircraft.
(7) If the pilot becomes disoriented, never stop on a runway and initiate communications with ATC to regain orientation.
(8) Pilots should be especially vigilant when instructed to taxi and “Line Up and Wait” (LUAW). Traffic Collision Avoidance Systems (TCAS)/traffic advisory systems (TAS) should be turned on in order to obtain an awareness of any aircraft that may be landing on their runway. When taxiing onto a runway either at the end of the runway or at an intersection, scan the full length of the runway and scan for aircraft on final approach or landing rollout.
(9) If a pilot has been instructed to LUAW without being advised of the reason/condition (wake turbulence, traffic on intersecting runway, etc.) or the reason/condition is not clearly visible (e.g., another aircraft has landed or is taking off on the same runway), the pilot should expect a communication from ATC within 90 seconds. If the pilot does not receive a communication from ATC within 90 seconds of the LUAW clearance, the pilot should initiate communication with ATC. Pilots should be especially vigilant when instructed to LUAW, particularly at night or during periods of reduced visibility.
(10) Pilots should use caution after landing on a runway that intersects another runway, or on a runway where the exit taxiway is in close proximity to another runway’s hold short line.
(11) After landing, ensure that the entire aircraft, including the tail section, has crossed over the respective landing runway’s hold short line. This will ensure that the entire aircraft is clear of the respective runway safety area. If you are constrained from clearing the landing runway by an adjacent parallel runway hold short line, stop and immediately advise ATC.
(12) After landing at a non-towered airport, or at an airport where the control tower is closed, remember that not all aircraft are radio-equipped; therefore, before entering or crossing a runway, listen on the appropriate frequency (common traffic advisory frequency (CTAF)) for inbound aircraft information. Scan the full length of the runway, including the final approach and departure paths of the runway(s) you intend to enter or cross.
(13) After landing, nonessential communications and nonessential pilot actions should not be initiated until clear of all runways (e.g., changing radio frequencies and repositioning flaps, and trim).
(14) During landing, do not accept last-minute ATC turnoff instructions unless you clearly understand the instructions and are certain that you can safely comply.
At many airports, taxi clearance can be very complex. The instruction can involve numerous turns, as well as intermediate hold short lines of other runways. Written taxi instructions can be used as a reference for reading back the instructions to ATC and as a means of confirming the taxi route and any restrictions during the airport surface taxi operation. This will mitigate any misunderstanding or forgetting of any part of the taxi clearance, which can lead to a runway incursion.
(1) While written taxi instructions are a good operating technique, common sense and flexibility should be used in determining the need for them at a specific airport. For example, if the departure runway is very near the aircraft parking location, or if the taxi route has been used numerous times, it may only be necessary to record the basic elements of the taxi clearance. However, when the taxi instructions are complex or the pilot is unfamiliar with the airport layout, a detailed transcription of all instructions is desirable. Additionally, individual pilots may choose to develop a set of symbols and shorthand notations which allow them to clearly record and later recall key items in the taxi instructions. As a technique, some pilots enter taxi instructions into the flight management computer (FMC) scratchpad.
(2) Examples include:
• The ATC clearance is: N123 taxi 9R via Bravo, Echo, Juliet, Hold Short 4L at Echo;
-
The ATC clearance written: 9R B E J
4L
E. Where the clearance limit of 4L at
Echo is circled;
• The ATC clearance entered into a FMC or other database scratchpad: 9R BEJ/4L E;
• Where the forward slash /, which represents the Hold Short line, proceed to the clearance limit of 4L at Echo;
• Symbols: Hold Short: (/), Cross (X);
• Then from the airport diagram, on a taxiway to make a left turn ( ), right turn ( ).
Radio communication is the primary method for pilots and ATC to communicate. The safety and efficiency of taxi operations at airports with operating control towers depends on this “communication loop.” Controllers use standard phraseology and require readbacks and other responses from the pilot in order to verify that the clearance is understood. It is the pilot’s responsibility to advise ATC when they do not understand an ATC clearance. Pilots should respond by using standard phraseology and include the aircraft’s complete call sign or registration number. Regulatory requirements, the AIM, approved flight training programs, and operational manuals provide information for pilots on standard ATC phraseology and communications requirements. The following are elements for clear communications. Pilots should:
(1) Use standard ATC phraseology at all times in order to facilitate clear and concise ATC/flightcrew communications. Be aware of the need for complete understanding of accents, terminology, and International Civil Aviation Organization (ICAO) procedures while operating at foreign airports.
(2) When making initial contact with any tower or ground controller, regardless of whether you previously stated your position to the previous controller, state who you are (make and registration number), where you are on the airport, what you want, and what you know. An example is: Cessna N1234, at SeaBreeze FBO, VFR to taxi, with information Alpha.
(3) Focus on the ATC clearance. Pilots should not perform any nonessential tasks while communicating with ATC. Given that many runway incursions occur even after the pilot reads back the “hold short” instruction, pilots should develop a technique to remind themselves to “hold short” of a hold line. For example, place something on an instrument knob or on top of the instrument panel, or hang it on the magnetic compass or the control yoke.
(4) Pilots are required to read back all clearances. Ensure that you include the complete call sign and runway designator when reading back a clearance to enter a specific runway, hold short of a runway, or taxi to LUAW. Avoid using “Roger” or “Wilco” in these instances.
(5) Pilots must actively monitor the assigned tower frequency or CTAF for potential conflicts involving their runway, or a crossing runway, when holding in position for takeoff and when on final approach. If not in use for a higher priority communication, the additional radio, if equipped, should be set to monitor guard frequency as a backup to stuck microphone or lost communications.
(6) Read back all takeoff and landing clearances, including the aircraft call sign and the runway designator, and, as applicable, state the intersection of the takeoff.
This paragraph suggests good operating practices regarding cockpit activities during taxi.
(1) Prior to taxiing, a current copy of the airport diagram should be available for use by the pilot. Review the taxi route and identify all airport-designated hot spots that are in or near the taxi route. The aircraft’s compass or heading display is an excellent tool, as a supplement visual orientation, or for confirming correct taxiway or runway alignment. It should be referred to as frequently as necessary, but especially at complex intersections and where the departure ends of two runways are close to one another.
(2) Pilots should complete all aircraft pretaxi checklist items and navigation data entry prior to taxi. So as not to distract from maintaining outside taxi vigilance, limit or eliminate all non-ATC communications. When approaching an entrance to a runway, pilots must be clear as to their clearance to either hold short of, cross, or enter the runway. If there is any doubt, the pilot should verify their clearance with ATC.
(3) When taxiing on an airport with a control tower, pilots must remember that the tower may lose communication capability at any time. To ensure you will not miss any tower communications, pilots should monitor guard frequency (if able) and scan the tower when taxiing or on a runway with a LUAW clearance.
(4) Low visibility conditions increase the risk of a runway incursion. During low visibility conditions, all resources available should be used during taxi. Resources include the airport diagram, the heading indicators, and airport signs, markings, and lighting. These resources help keep the aircraft on its assigned taxi route, and not crossing any runway hold lines without clearance. Therefore, it is extremely important that pilots perform all heads-down tasks (e.g., programming the FMS and calculating takeoff data) while the aircraft is stopped so they can maintain outside vigilance and SA.
(5) Any time the pilot is uncertain of their location on the airport or during taxi, stop the aircraft and immediately advise ATC, and, if necessary, request progressive taxi instructions. If located on a runway, immediately advise ATC and exit the runway as soon as possible. If unable to safely exit the runway due to low visibility conditions or other factors, immediately advise ATC. Remember that runways have white, segmented center lines; whereas taxiways have continuous, yellow center lines.
(6) When cleared to take off or cross a runway, or when exiting a runway, do so in a timely manner. Never exit the landing runway onto another runway without ATC clearance. ATC should also be informed of any anticipated delay for takeoff or of exiting a runway.
(7) Some cockpit displays of traffic information, (TCAS, Traffic Information System (TIS)) have the capability to display traffic behind the aircraft. When pilots are in LUAW, and waiting for takeoff clearance, these systems should be turned on to increase the pilot’s awareness of landing traffic.
(1) General. Exterior aircraft lights may be used to make an aircraft operating on the airport surface more conspicuous. Pilots may use various combinations of exterior lights to convey their location and intent to other pilots. Certain exterior lights may also be used in various combinations to signal whether the aircraft is on a taxiway or on a runway, in position on the runway but holding for takeoff clearance, crossing an active runway, or moving down the runway for takeoff.
(2) Exterior Lights. To the extent possible and consistent with aircraft equipage, operating limitations, and pilot procedures, pilots should illuminate exterior lights as follows:
Turn on the rotating beacon whenever an engine is running.
Prior to commencing taxi, turn on navigation, position, anti-collision, and logo lights, if available. To signal intent to other pilots, consider turning on the taxi light when the aircraft is moving or intending to move on the ground, and turning it off when stopped or yielding or as a consideration to other pilots or ground personnel. Strobe lights should not be illuminated during taxi if they will adversely affect the vision of other pilots or ground personnel.
All exterior lights should be illuminated when crossing a runway.
When entering a runway, either for takeoff or when taxiing into LUAW pilots should make their aircraft more conspicuous to aircraft on final behind them and to ATC by turning on all lights except for landing lights that highlight the aircraft’s silhouette. Strobe lights should not be illuminated if they will adversely affect the vision of other pilots.
Consider lining up slightly (approximately 3 feet) to the left or right of the centerline (CL) to enable a landing aircraft to visually differentiate your aircraft from the runway lights.
Landing lights should be turned on when takeoff clearance is received, or when commencing takeoff roll at an airport without an operating control tower.
8. SUMMARY.
Taxi operations require planning, SA, written taxi instructions, Crew Resource Management (CRM), ATC communications, taxiing, and use of exterior lighting. Safe aircraft operations can be accomplished and incidents eliminated if flightcrews are properly trained and correctly accomplish standard taxi operating procedures and practices as stated in this AC.
9. APPENDICES TO THIS AC.
Appendix 1 of this AC contains SOP items and Best Practices that are very similar to SOPs/Best Practices currently in use in the air carrier segment of the industry, and has been modified for single-pilot operations. Appendix 2 contains briefing information that should be adopted into the operator’s checklists or existing briefing material. Appendix 3 contains a sample outline for flight schools briefings, Best Practices, and SOP procedures to avoid students causing runway incursions. These appendices are not mandatory. SOPs may vary among aircraft and operators and may change over time. Operators and individuals may use the information contained in the appendices to integrate the basic tenets into their aircraft-specific, route-specific, and equipment-specific operations and checklists. They are shown to denote how the SOPs and Best Practices can be integrated into the context of specific flight operations.
/s/
for
John M. Allen
Director, Flight Standards Service