Be prepared and understand what inspectors might look for
We hear about FAA ramp checks, but have you ever experienced one? I have not personally, but I know that there have been times when neither I, nor my aircraft were even prepared for the possibility. This is one of the primary reasons that we began developing Coflyt®: to improve awareness of aircraft readiness and provide aircraft owners with an app that can equip them with tracking and real-time insights to their aircraft right from the palm of their hands. Without Coflyt, I’d literally have no mental recollection of my ELT, transponder or aircraft registration renewal dates, much less the airworthiness directives associated with my aircraft. Of course they are all correctly recorded in my aircraft log books, but we shouldn’t be carrying those around in an aircraft with us. As a matter of fact, most “old school” pilots will tell you not to have aircraft log books with you, just in case you do get inspected. Which allows you the opportunity to go home and review any discrepancies, before providing them to the FAA. Probably true, but maybe not the best plan!
As a refresher, here are the two pertinent paragraphs directly from the FAR’s:
§91.3 Responsibility and authority of the pilot in command.
(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.
§91.7 Civil aircraft airworthiness.
(a) No person may operate a civil aircraft unless it is in an airworthy condition.
(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur.
So, in general if you land at an airport and are approached by an FAA inspector who identifies themselves with a proper identification, they have the authority to conduct an appropriate ramp check. I will be referencing the link below throughout this article, and you can always use this link as a resource for the details to be anticipated during a ramp check.
CONDUCT A FAR PART 91 RAMP INSPECTION
While ramp checks are seemingly rare, per the attached link from the FAA, Part 91 ramp inspections are the most numerous! Wait, Part 91? That’s us! According to the FAA, ramp inspections may result when an inspector:
- Observes an unsafe operation in the traffic pattern or on the ramp.
- Is notified by ATC of an unsafe operation.
- Conducts normal surveillance. (Is it just me, or does this seem to allow for ‘whenever they want to’?)
Imagine that on a beautiful VFR day, you decide to take your spouse or a close friend on a short flight to a great beach town like Pensacola, FL (PNS). The flight was perfect, operationally you have met the very definition of safe operations, and you taxi up to the local FBO, Pensacola Aviation. You’re looking forward to grabbing the crew car and taking the short 20 minute ride to the beach for a great lunch at a gulf front spot you found the night before. As you communicate with the lineman and close up your airplane, you see an individual walking up who identifies himself as an FAA Inspector, properly displaying his identification. And suddenly, your quick trip to grab lunch has just turned into an intimidating event, which you were not expecting and you may not be prepared for. The inspector informs you that he is “conducting normal surveillance’. “Are you kidding!” is probably one of the first and most appropriate of the thoughts running through your mind. So what now?
What should you have available and what can be expected of the inspector?
A sample of the FAA Job-Aid used by the Inspector is available via the link posted above and is also depicted at the end of this blog. In a nutshell, there are essentially two categories that the inspector can cover: Airmen Inspection and Aircraft Inspection. The Airmen Inspection includes what you would expect: proper ratings for the aircraft and operation being flown, currency compliance and medical. While there are great tools available to help track these items, I want to focus on the aircraft readiness inspections, where support can be provided by Coflyt.
From the FAA link included, here are the expectations of an aircraft readiness check:
(1) Determine that the proper airworthiness certificate is displayed at the cabin or cockpit entrance. Note that it is legible to passengers and/or crew.
(2) Examine the registration certificate to ensure that it is issued for that specific aircraft. Determine that the N-number on the certificate matches the N number on the aircraft. Check that the certificate is issued to the present owner of the aircraft. (Can be tracked in Coflyt)
(3) Check the radio station license and note its expiration date. If it has expired, inform the operator of the pertinent FCC requirements. (Can be tracked in Coflyt)
(4) Determine that there is a current, approved Airplane Flight Manual (AFM) on board the aircraft.
(5) Determine if there is current weight and balance information in the aircraft by examining the AFM. Compare equipment listed on the weight and balance form to the actual equipment installed.
(6) If applicable, check the MEL to determine that it has:
(a) Been issued by N-number and serial number to the aircraft operator
(b) A Letter of Authorization from a district office; check deferred items for placards and dates (Refer to Related Task #58, Approve a Minimum Equipment List.)
(7) If a Letter of Deviation from FAR Part 125 has been issued, ensure that a true copy is in the aircraft.
(8) If the aircraft is leased, determine that a copy of the lease agreement or contract is being carried in the aircraft. Note the expiration date on the lease and determine if the lease is still valid.
(9) Determine if pertinent and current aeronautical charts are available.
(10) Ask the operator what type of instrument operations are conducted, for example: ILS, DME, RNAV. Determine if the required radio and navigational equipment is installed for the specific operations conducted. (Maintenance and communications on instruments, such as VOR checks, can be easily tracked in Coflyt and shared with others who may fly the aircraft.)
(1) Determine the general airworthiness of the aircraft by inspecting the aircraft’s exterior in a manner similar to a preflight inspection.
(2) Inspect seats and safety belts for installation and condition.
(3) If applicable, determine if a current VOR Equipment Check has been performed. (Track on Coflyt)
(4) Determine if an ELT (Emergency Locator Transmitter) is installed. Check the expiration date of the battery. (Track on Coflyt)
(5) Determine that the aircraft identification plate exists and is secured to aircraft fuselage exterior. (FAR § 45.11(a))
Wow! I am a little intimidated from studying this list, as I am writing this. As aircraft owners or operators we bear a tremendous responsibility for ensuring the aircraft is compliant with prescribed FAR’s and is airworthy for the mission we plan on flying. Seldom do I remember these requirements being emphasized in any flight instruction I have received or as part of a bi-annual flight review. It is up to us as pilots to dig into the FAR’s and other information available via the FAA, such as the link I have provided here, to assure we are meeting the expectations of our operating environment. As I mentioned earlier, one of the key values Coflyt brings to operators is the awareness of aircraft readiness before you begin your flight. At a glance, you will know you have met the requirements for your aircraft, and when the next requirement is due, so that you can enjoy flying with #PilotPeaceofMind!