A few years ago, my wife and I attended a landing at a friend’s farm in the Sacramento Valley. The markings on the edge of the runway seemed to beckon us as we touched down on his perfectly manicured lawn.
Slowly fading, the illusion became clear. The edge markers were indeed fluttering—dozens of inflated white disposable rubber gloves tied to small tent stakes, their fingers pointing upward and swaying merrily in the breeze.
While rubber gloves are certainly effective for marking runway edges, they fall far short of the Federal Aviation Administration’s runway marking standards. Guidelines for maintaining runway markings and runway safety areas, as well as nearly two dozen other standards, are contained in 14 CFR Part 139, Airport Certification.
As pilots, we understand the Federal Aviation Administration rules and regulations that govern our flying activities. These rules (Parts 61, 91, 135, etc.) are “parts” of Title 14 of the Code of Federal Regulations, which covers the aerospace industry. Like our flight rules, Part 139 governs the certification and operation of airports that service airline aircraft. Like pilots, airports must undergo a process similar to flight inspections.
Part 139 applies to all U.S. airports served by scheduled flights with more than 9 seats or non-scheduled flights (charter flights) with 31 or more seats. To obtain an operating certificate authorizing an airport to handle these aircraft, an airport manager must prepare and submit to the FAA its own Airport Certification Manual (ACM), a lengthy book that details how the airport meets all of the requirements of Part 139. It’s the “Aircraft Operations Manual” for airports.
The ACM at the airport where I work has 23 chapters, 3 appendices, a few exhibits, and is slightly thinner than the Manhattan phone book. (Anyone else remember the phone book?)
So, if you fly into an airport that serves airlines (regardless of whether your plane is an aerobatic plane or an Airbus), that airport must comply with federal Part 139 standards.
Private airports, like my friend’s Meadows Airport, are generally not regulated by the Federal Aviation Administration and are required to adhere to different government standards depending on their location. As the Aircraft Owners and Pilots Association (AOPA) states, “The general rule for private airports is that there is no one-size-fits-all rule.”
This test is administered to airline airport managers during our regular annual certification audits. During this audit, the FAA verifies that the airport is following ACM procedures, meets Part 139 standards, and is worthy of serving passengers.
Like a pilot’s flight check, our check includes a documentation check and a “hands-on test.” Inspectors will follow an official checklist covering 23 areas and 124 items, and the check will last several days.
We begin with a briefing with an inspector (or, at larger airports, a team of inspectors) and airport management. Our inspectors plan activities, including when to check airport records, when to conduct physical airport inspections (day and night), when to visit airport rescue and firefighting (ARFF) stations, and when to inspect tank farms and aircraft refuellers. After a short exchange, the fun begins.
The records review is our opportunity to make a good first impression. The 16 items included training records for ARFF personnel and other airport personnel with access to movement areas (tower controlled runways and taxiways). It also reviewed our mandatory daily airport self-inspection records and maintenance actions taken to correct any issues found. Finally, fuel facility inspection records, all NOTAMs issued in the last 12 months, wildlife threat management actions, and records of any accidents or incidents in the airport area are reviewed.
The “practice test” begins with an airport check. Just as private pilot flight checks comply with pilot certification standards, this check complies with Part 139 standards. If questions arise, guidance can also be found in numerous FAA advisory notices.
Taxiways, runways and aprons are carefully inspected for holes, cracks or edge differences greater than 3 inches in the road surface, as any of these could interfere with aircraft control. Inspectors patrol the airport, scanning for any foreign objects that could damage aircraft to assess the airport’s IFR management practices. We also check the track for excessive rubber build-up that could obscure markings or reduce friction under braking.
Runway and taxiway safety zones extend well beyond the edge of the road and are designed to provide a smooth, hard surface should an aircraft accidentally stray from the road. Therefore, these areas must be inspected for ruts, unevenness, potholes, and adequate drainage.
We also confirmed that the safe area was free of anything other than what was necessary for the navigation of the aircraft. REIL, PAPI, side lights and some signs are permitted, weathervanes, stop signs, fences, etc. are prohibited; Anything installed in the safe area must be secured to a breakable coupling so that the breakable point is no more than 3 inches from the floor.
Our airport marking inspection includes runway markings, taxiway markings, and threshold holding position markings or ILS critical area markings. Inspectors check that the marking locations meet FAA standards and that the paint is not dirty, faded, or peeling. Most markings should have reflective beads, and during night inspections we make sure they “pop” under the headlights, just like on an airplane.
Other items we inspect at night include taxiway and runway lights, REILS, PAPI or VASI systems, airport beacons and any approach lighting owned and maintained by the airport. Runway, taxiway and apron markings are also inspected to ensure they are well lit and legible.
Finally, obstacles (such as the ILS glide path or radio transmission antenna) should be marked with a red light and also checked.
Check traffic pattern indicators (segmented circles) and wind cones to ensure they are in good condition. A segmented circle that is overgrown with vegetation or a faded, broken wind cone will provide little information to the pilot.
If construction is underway at an airport, inspectors will check for lighted barricades, runway X closures, and other measures to ensure a safe environment for aircraft.
According to the FAA Advisory Circular, “Operational Safety in Airport Construction,” “the most common threats to airport operations are intrusions into protected areas, unauthorized and improper ground vehicle operations, and unmarked or uncovered pits and trenches near aircraft operating surfaces.”
For obvious reasons, aircraft fueling safety is a major focus for our inspectors. When inspectors inspect fueling stations, they check that all warning signs and fueling shut-offs are clearly visible and properly labeled. Inspectors also check the integrity of fuel tanks and pipes, as well as safety barriers and lighting.
Aircraft tankers are subject to special inspections. Inspections include grounding/grounding wires, fire extinguishers, warning signs, and general condition. Tires must not have exposed steel treads (steel tread + road surface = sparks), and ashtrays, lighters, or smoking materials must not be placed inside the truck.
One of the most important buildings at the airport is the fire station, which houses the fire and rescue personnel and firefighting equipment. When the inspector arrives, he or she will confirm whether the firefighting personnel are capable of responding to an aircraft emergency, whether the firefighters are properly trained and equipped, and whether the fire trucks are working properly.
A highlight of the ARFF inspection is the no-notice emergency response exercise, where we take the inspector to a remote taxiway or runway, call the control tower and instruct them to pick up the emergency phone and simulate an “Alert 3″.
Alert 3 is the FAA code for warning about aviation accidents that we hope will never happen. But if they do, the first fire engine must arrive at the airport and begin spraying fire extinguisher within three minutes. This is the survival window for passengers and crew trapped in a fire with the fuselage intact. All other fire engines must arrive within four minutes.
What is alarming is that when the simulated alarm 3 sounded in the tower, our inspector started the watch. It was an emotional moment for the pilot when three minutes later the trucks arrived and began spraying foam and water on the “crash site”.
After all these checks, on the third day of the visit, the inspector completed his work, and the airport management came to this conclusion after “summing up the results.”
At my airport, our president, vice president of operations and maintenance, director of public safety, director of airport maintenance, fire chief, and other managers gather to discuss the news. We understand what is going well and what needs improvement or correction.
If inspectors find any non-compliance, the airport will receive a “letter of compliance” stating the problem and a deadline for its resolution. Once the problem is resolved, the airport notifies the inspector, who will then issue a “Corrective Action Completion Letter.”
Often we learn of these issues during the inspection and correct them before the inspector leaves. Some years our flight inspection scores have been 100% and no differences have been found. Other years, although we strive for perfection, some of these 124 items cause us to make mistakes.
Typically no, but certain situations may prompt the FAA to take enforcement action. These include failure to take corrective actions following inspections or repeated noncompliance.
Violating regulations, falsifying or altering records, and reckless behavior can lead to trouble at the airport. Any of the above actions may result in civil penalties or suspension or revocation of the airport operating license.
Don’t think that the annual FAA inspection is the only test an airport must pass. Part 139 requires airports to conduct self-inspections every day – day and night (if the airport has overnight operations). An average of 730 documented inspections are conducted each year. If any of our trained inspectors find a non-compliance, they are required to document it and issue a work order so that our maintenance department can correct it.
That’s the whole point of Part 139 and airport inspections: to provide the best possible safety and service to pilots and passengers. For 30 years as a pilot, I took that for granted. Since coming into airport management, my perspective has changed, and now yours has too.
About the Author: After serving in the U.S. Air Force and as an airline pilot, Jim Roberts returned to his hometown airport where he learned to fly as a teenager. He is currently the Director of Airport Operations for the Metropolitan Knoxville Airport Authority at McGhee Tyson Airport. He enjoyed traveling with his wife, flying his 1946 Globe Swift, taking aerial photographs, and writing about his first love…flying.
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Great article on how to run a safe airport. A hot topic at the airport’s Section 139, which I help manage, is the Wildlife Hazard Management Plan and the Snow and Ice Management Plan. Another area receiving priority funding from the FAA is pavement management. We just repaved HPN’s main runway during the COVID-19 shutdown. The airport’s pavement above the snow line sustained significant damage.
West Houston Airport was the first private general aviation airport in the United States to be approved under FAR Part 139 in 1984. The hassle and expense we had to go through to get this approval was incredible. This article is well written as it explains why more and more airports across the country are not FAR 139 approved! In reality, the law is too broad for small communities. Small community airports could be served by airlines (FAR 121) if the requirements for these airports were less onerous. Expanding travel options for these communities using small aircraft, including jets and turboprops, will bring significant economic benefits to these communities. These airports can safely accommodate operations using 12 to 50 seat aircraft under 121 or 135 and truly bring prosperity to the region. Despite the FAA, the only thing a community can do is give a small airline a monopoly to serve the community for at least ten years to get the business going without a big player coming in and diluting their revenue. If the airline can afford it and make the right deals, you will see more small airline startups popping up in these communities. Of course, we need to beat Corona-19 first! Great article!
What the article discusses sounds simple and is safety related. I don’t think any responsible commercial operator would demand anything less.
Interestingly, most GA destination airports do not seem to meet these criteria. However, I will note this: standards exist, but figuring out what they are for a particular airport, especially for taxiways and ramps, can be tricky. For example, my electric powered glider has a 58-foot wingspan and about 34 inches of clearance between the wing root and the ground near the wingtips. Pick any airport and let me know if I can get between or over the runway and taxiway lights and markings using AFD, Foreflight, or any other readily available information source. I can get around most runways, but turns and taxiways are harder to tell, depending on the spacing between the lights (measured on the pavement) and the height of potential obstructions. No airport map I’ve ever seen tells you that distance, and certainly doesn’t tell you the height of the lights. I’m sure this information exists in countless digital files related to the airport’s construction and certification, but is it possible to find it? No way.
Generally speaking, southerners and desert dwellers have short light poles. In the north it snows, and the farther north you go, the taller the light poles get. An airport in my home state of Michigan gave me 55 feet (measured with a tape measure) of space to install a 58-foot wing. The pole is 30 inches tall. Luckily, the slope on the airport side was low enough for me to install it. Google Earth tells me that nearby airports seem to have the same distance, but I have heard that another plane similar to mine was unable to leave the runway because either the poles were taller or the slope was different.
And it doesn’t always help that airports are big, as general aviation parking spaces often fill up quickly.
”And I fit in,” meaning if I look at the center line, the wings can *exceed* the illumination… by about 8-12 inches.
Post time: Dec-12-2024