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Gbarentine's Blog

Non Movement Driving Training

  • August 17, 2011
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During my annual FAA certification inspection, the subject of Non Movement Driving Training came up. This training will include ANYONE that has access to a ramp, parking lots or any area inside your fence. Here in Hot Springs that will add an additional 300 people that will require the driver training. This will include the owner of the aircraft, all vendors who make deliveries, all employees that duties do not require them to drive in the movement area. I understand the reason; these people have the POTENTIAL of accessing movement areas unrestricted.  My concern is how many airport could comply with this? Non movement Driving

With the threat of losing EAS funding looming in congress and a constant increase of part 139 requirements how many small airports will give up their certificates? I know 3 airports in Arkansas that gave back their certificates because of the increased requirements and loss of airlines. These airports have not decreased their aircraft traffic but they are no longer inspected under part 139. So are they safer? Have they stopped conducting daily inspections, training, or safety improvements? I ask, with the FAA increasing the requirements for part 139 in the name of safety are they really just pushing the smaller airports away? 

 

 

 

The following is a list of Best Practices, I found on the FAA website. At a non towered airport how and will you comply with these "suggestions" and how will you enforce them when they are a requirement?

 

Best Practices for
Runway Incursion Prevention


The following Best Practices have been identified to provide an overview of
programs and procedures that have proven effective in preventing runway
incursions, and which can be adapted for use at other airports. These practices
can assist air traffic controllers and airport mangers in their efforts to eliminate or
reduce the risk of runway incursions.


Best practices for air traffic control (ATC) personnel:

 

  • Minimize the frequency of runway crossings by aircraft and vehicles where possible.
  • Reduce non-standard phraseology; standardize and simplify internal coordination.
  • Issue taxi instructions slowly and clearly. This will result in more accurate hear-back/read-back, eliminate expectation bias, and reduce confusion.
  • Issue instructions in a procedure referred to as “chunking.” Controllers define this as breaking long and complicated taxi instruction into short, easy-to- understand phrases. Chunking also alleviates the comprehension difficult that may be experienced by foreign air crews.
  • Establish standard taxi routes to reduce confusion and reinforce a routine flow of traffic. Local pilots know what to expect. A pilot familiar with the standard taxi routes who hears full route may be primed to listen more closely to taxi instructions.
  • Develop standard practices for coordination of unplanned runway closures, and incorporate these practices into existing agreements.
  • ATCT managers should regularly participate in airport construction and planning activities. Establish a consistent liaison representative throughout programmed activities to ensure continuity of operations.
  • Seek site-specific visual memory aids to act as runway occupancy reminders for local and ground control. These may take the form of strip bay headers, supplemental strip marking, opposite direction reminders, line up and wait new phraseology and visual/aural alarms.
  • Maintain a cooperative team environment with a high level of operational integrity, and consider adopting the sterile cockpit practice used by aircrews.
  • Work with the airport operator to develop and maintain a “ride along” program for new and newly certified employees. This practice can help new employees become more familiar with the airport from ground level.
  • Tower cab simulator. Training selects beneficial learning from operational errors and deviations and then recreates the incident in the tower cab simulator which allows crews to work on group performance and share lessons learned in a safe and controlled environment.

Best practices for airport operators:

  •  At general aviation airports, use enhanced marking and additional signage as recommended in the 150 series Advisory Circulars to draw attention to parts of the airport where traffic can create a safety hazard.
  • Modify airport geometry to reduce runway crossings and, if necessary, reconfigure airport geometry to eliminate taxiway choke points that confuse pilots and vehicle operators.
  • Develop standard practices for coordination of unplanned runway closures. Incorporate these practices into existing agreements.
  • Maintain an electronic forum for pilots to receive the latest airport safety-related information and as a means for them to provide direct feedback to the airport operator. Equip airport vehicles with transponders and GPS units.
  • Have a two-tier vehicle operator training program, with one for the movement area and the other for the non-movement area. Require all users to make a request through the airport manager to access taxiway and airport areas. This  aids in reducing the number of people who have access to the movement area.
  • When training vehicle drivers, supplement classroom and practical training with simulation where possible.
  • Consider developing an airport-specific pre-departure presentation for an FBO and make it available to all pilots prior to departing. One location uses an animated PowerPoint presentation on a computer located in the pilot  briefing room. This short (five-minute) presentation outlines past runway incursions with the ATC voice recording. The team noted it as a best practice for extra safety awareness in the prevention of runway incursions.

January 1, 2011 - Version 1

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We train everyone who gets a badge that allows them access inside the Perimeter Fence in Non-Movement Area Drivers Training. We have a study guide that they are supposed to read before come to take their security training. At the end of the Security video, they are given a test on the security stuff and another on the Driver's Training. Here is the link to our Class II Driver's Training Manual (non-movement area). http://www.flygpt.com/Operations/Forms/Class%20%20II%20Driver's%20License%20Information%20and%20Study%20Guide.pdf

If this rule only applied to persons that directly work for the Airport I could manage it.

The problem is that this rule applies to enyone who enters any of the AOA areas of our airport to include GA population, Military (which for us is 2 large National Guard units, one army and one air) Civilain FBOs, contractors that work for any and all of these businesses, etc.......

There can be as many as 1000 people in and out of the non-secure areas of our airport everyday and none of them go through the Airport authority to gain entrance so how do we manage that traffic in order to train it?

Hello Everyone,

The FAA NPRM on driver training was issued back in Feb 2011 (Federal Register / Vol. 76, No. 21 / Tuesday, February 1, 2011 ). Some clarifications: People who are escorted are proposed to be excluded from the training requirement. There is to be training curricula that closely mirrors that of movement area training ..."All training curricula would include, at a minimum, airport familiarization with airport markings, signs, and lighting, procedures for operating in the non-movement area, and duties required by the ACM or regulations." Also ... "The curricula would address procedures for access to, and operation in, ramp and apron areas." Also ... "The curricula also would include procedures for operating in the nonmovement area including wearing personal protective equipment and high visibility clothing, cautious driving and speed awareness, and backing up and spotting obstructions. " Lastly .... " Other duties that a person might encounter and require training for include fire prevention, hazardous weather, foreign object damage (FOD) prevention, reporting accidents/ incidents, safety around propeller and jet engine intakes, approaching an arriving aircraft, safely positioning ground servicing equipment, and other safety topics workers may encounter specific to the airport."

Not sure when the final rule may come. Sometime this fall. When it does, the requirement for initial training would be within one year of the final rule. Recurrent training is minimally one year. Record retention is necessary for all. Sources for such training include AC Nos. 150/5210–21 and 150/5210–20: Change 1; the FAA CD's Taxi 101 and Tug & Tow 101; AAAE and NATA; and private companies and individuals (such as myself... smqairportservices@gmail.com). 

Steve Quilty

Just to add to the confusion our Inspector has informed us that per the proposed regulation we would also be expected to train non-movement pedestians in the non-movement area program not just those who drive.

So how much does adding all pedestrians with AOA access to your training workload change things. 

My training workload increase will be threefold.

Yes it was all web based.  This was in the Western-Pacific region (AZ).  FAA was fine with it but they did question how we verified test takers.  We then put a box on the form where the test taker had to input their gate card number.  That satisified FAA.

Paul R makes a good point.  During dirt haul ops you often see different drivers from day to day, don't know how to handle that.

My issue with it is when we have a ramp reconstrution project or taxiway realignment and we have around 30-40 trucks running carrying out rubble or during a concrete pour.  These drivers get pulled from all over the state and don't stay on the job more than a day, spending a day in my class will cost them a day's salary.  They won't go for that when they can work on a highway job & get that extra day. 

Another situation.  Tornado pass through here in the spring.  Guess how many contractors were inside the fence for the clean up, how many people we pulled from downtown to help get the ramp passable for vehicles, let alone clean enough for aircraft.  Is the FAA going to sceam NO, you can't do that, these people haven't seen our Harrison Ford driver training video that's 20 years old. 

And then we would be the one's having to explain to the airlines, the media and the public why they can't make money or make it home to their families for weeks. 

I just don't see what's wrong with the escort procedure that is in place now.  Why not increase the punishments for violations instead of taking it out on operators. 

CHD Ops, everything was done on the Internet? Training and the Test? Was the FAA OK with it? What Region?

There's been a lot of hand wringing about this requirement but it really doesn't have to be a big deal.  At my last airport we had such a progam in place.  The non-movement driver training was a short power point available on our web page.  It was very basic, speed limit 15, no piggybacking, yield to aircraft, etc.  It also included where you could drive and where you couldn't along with associated markings.  This was followed up with a 15 question test which must be passed before a driver was issued a gate card and granted driving privleges inside the fence.  It was nowhere near as extensive or involved as movement area driver training.

I don't understand where the FAA thinks the airports are going to come up with the money or the time to comply with this amendment to the reg.  Basically it will force us to create a full time training position when the city is still trying to pass a budget that includes furloughs and possibly layoffs. 

Unfortunately we are the FBO (operations and maintenance) and because of the way hangars are laid out anyone that flies have to drive to their hangars and since they drive to their hangars they "could" drive onto a movement area. We only have 2 - 5 people on duty at any given time. Just going to be a headache, and no way will they allow us to hire more people.

Have the companies that vendors are supplying provide escorts.  Have the FBO personnel provide escorts for pilots that need vehcile access to the non-movement areas.  Pilots don't have to drive onto the apron every time they fly.

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