Airport Self-Inspection Practices (2011)

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45 For certificated airports, regulatory oversight of airport self-inspection programs is provided by the FAA. For non- certificated airports, oversight is often provided at the state level. Specifically, the department of transportation in some states is responsible for inspecting non-certificated airports to ensure standards are being maintained. This chapter presents insight into both FAA and state-level oversight of airport self-inspection programs. FAA OVERSIGHT In addition to guidance at the national level (in the form of FAA CertAlerts, ACs, and regulations) addressed in chapter one, the FAA carries out oversight of certificated airports by conducting annual Part 139 inspections. During a certifica- tion inspection, FAA inspectors are observing two distinct aspects of the operation of the airport: • The documentation of the airport’s operation (including training, self-inspection, procedures, etc.); and • The actual condition of the airport and a demonstration of its operation (movement area inspections, ARFF drill, etc.) (Lammerding 2009). Ideally, the inspection will see documentation that Part 139 requirements are being met and an airport condition that confirms the documentation (Lammerding 2009). It is in the airport’s best interest to provide sufficient documenta- tion and a Part 139-compliant airport; however, it is possi- ble that an FAA inspection may find one of the following situations: • The documentation states that requirements are met, but the current airport condition does not show it. • The documentation does not show that the requirements are being met, but the current airport condition meets Part 139 requirements. • The documentation does not show that requirements are being met, and neither does the condition of the airport (Lammerding 2009). Regarding the condition of the airfield, FAA inspectors often notice larger issues that may not be noted in self- inspection reports. For instance (Lammerding 2010b), FAA inspectors may notice: • Things that take a long time to deteriorate: – Pavement – Paint and sign panels • Long-term issues: – Safety area obstructions – Ponding/drainage – Wildlife • Difficult-to-access areas: – Runway safety areas To assist airports in improving their self-inspection pro- grams and in better meeting the requirements of Part 139, this synthesis examined FAA oversight at the regional level. This was designed to gain specific insight into quality practices within each region. FAA-Observed Best Practices for Training In an effort to highlight successful training practices, each lead certification safety inspector was asked to share best practices among airports in his or her region for training self-inspection personnel (Appendix H). Although responses were richly varied, several themes emerged. First, successful airports take advantage of industry training. Whether this training is provided by an industry organization (such as the American Association of Airport Executives ACI, or a private provider), it is seen as a successful practice by several lead certification inspectors. A second theme was on-the-job training. Although classroom training with airport-specific photos, as well as photos of items considered a discrepancy, is considered a successful practice, it is most effective when com- bined with on-the-job training. A final theme that was shared by more than one inspector was the practice of visiting peer air- ports. By taking time to send personnel to airports with well- developed training programs, lessons can be learned, new ideas can be generated, and an airport’s training program may be improved as a result. Summarizing most of the comments, one lead certification inspector shared the following successful practices for training: Regular self-inspection training, including reviews of FAA Advisory Circulars. Conducting ‘mock’ 139 inspections in-house, by assigning an employee to act as if they were the FAA doing an inspection. Developing airfield-specific training programs with actual pictures of the airfield and pictures of discrepancies versus corrected items. Power[P]oint presentations. Testing. Hands-on training is one of the best tools, after someone reads CHAPTER SEVEN OVERSIGHT

about it in the Advisory Circulars. Being able to go to other airports and conduct inspections with other people that do the same job. Networking with other airports. When asked whether their region’s expectations differed from Parts 139.303 and 139.327, it became apparent that there were no differences (Appendix H). However, one lead certifi- cation inspector, offering further explanation, shared: Airport familiarization, as an example, is more than what is the color of the markings. Each individual must know the type of marking, the correct name, and location of each marking used on the airport. The same process is used for the signs and lighting. Training requirements are based on the level of responsibility. The higher the level of responsibility, the more in-depth and detailed the training requirements. Training curriculums and training programs are required for each assigned task, including fuel safety inspections and wildlife control. FAA Suggestions for Strengthening a Self-Inspection Program Lead certification inspectors were also asked how airports could strengthen their self-inspection program, including the training of personnel conducting self-inspections. Although inspectors mostly offered unique responses, several themes emerged (Appendix H). First, by reaching out to other cer- tificated airports with exceptional self-inspection programs, airports can gain insight into successful practices currently in use. This knowledge of the practices of peer airports was a theme that continued to appear in comments by certification inspectors. Next, airports can strengthen their programs by using a variety of training materials and techniques. As one inspector shared, “Ensure that airports know that well-rounded self-inspection training should include knowledge of the law, the Airport Certification Manual, and the associated Advisory Circulars.” Additional comments included requiring personnel to teach the subject, hiring an individual with experience in training, and nurturing the personnel and resources to develop an effective self-inspection program. FAA-Observed Best Self-Inspection Practices Lead certification inspectors were also asked to share some of the best self-inspection practices they have observed within their region. In response to this question, many unique prac- tices were shared (Appendix H). Although few themes were identifiable, the comments were beneficial nonetheless, and are categorized below. Training • Visit peer airports; • Assign specific training topics to personnel to create ownership and knowledge acquisition; and • Use photos of items considered acceptable and non- acceptable in training. 46 Inspecting • Rotate personnel conducting self-inspections; • Conduct self-inspections during both daylight and darkness; • Conduct in-depth focus area inspections; • Conduct inspections slowly, including slow-moving FOD inspections; • Conduct runway inspections near the edge, both sides, then center (three passes total); • Don’t stay on the taxiway centerline during taxiway inspection; • Get out of vehicle and walk runway and taxiway safety areas; • Conduct multiple inspections daily; • Utilize computer- and web-based inspection tools with GIS mapping; • Use nonstandard inspection patterns; • Establish standards to determine when a condition is no longer acceptable; • Inspect runway lighting on step 1; and • Close pavement for detailed inspections. Reporting discrepancies and findings • Utilize an electronic work order system. General FAA Suggestions Lastly, each lead certification inspector was encouraged to share any remaining thoughts regarding self-inspections (Appendix H). Although responses were too unique for any themes to emerge, the feedback was informative. Self-inspection dos • Visit peer airports; • Rotate personnel to ride along with the FAA during a Part 139 inspection; • Use photos in training to show personnel what to look for; • Work with the regional FAA office for assistance in developing a training program; • Adopt a comprehensive self-inspection checklist with an airport diagram; and • Adopt a method to show closed-out discrepancies (electronically is preferred). Self-inspection do-nots • Do not allow fire department personnel to conduct self- inspections, when these same personnel are dual-tasked with firefighting duties;

47 • Do not drive too fast during an inspection; and • Do not continually stay in the vehicle during an inspection. Additionally, the FAA regional offices provide helpful resources for airports. PowerPoint presentations, quick ref- erence guides, sample training topics, and CertAlerts are just some of the resources made available to airports by FAA regional offices. Summary of FAA Oversight Clearly, each regional FAA office has unique perspectives and information to share with airports. Because airports typ- ically only gain input from the office located within their region, the insight provided by the regions that responded to the survey may prove helpful to airports in considering perspectives of lead certification inspectors throughout the United States. Overall, it appears that several ideas are shared by most of the regional lead certification inspectors. First, visiting peer Part 139 airports with successful practices is considered good business. For airports so inclined, each FAA regional office can provide names of airports to consider, with contact information. Next, airports might consider using airport-specific photos with examples of discrepancies and items meeting standards in their training. By supplementing self-study of the ACs and Part 139 with photos of what to look for and what to consider a discrepancy, inspection per- sonnel will be more effective in conducting self-inspections. Next, requiring self-inspection personnel to become subject matter experts and teach the subject matter to their cowork- ers will encourage ownership and stimulate knowledge. Lastly, it is important that self-inspection personnel adopt effective techniques for conducting self-inspections, such as performing multiple inspections each day during both daylight and hours of darkness, conducting inspections slowly and thoroughly while occasionally exiting the vehi- cle to walk pavement and safety areas, and adopting non- fixed inspection patterns. STATE OVERSIGHT Responsibility for Inspecting In states in which non-certificated airports are inspected, the state department of transportation is typically responsible. These inspections are often not as in-depth as inspections con- ducted by the FAA for certificated airports, but are important nonetheless. Often, the state aviation agency conducts an inspection to fulfill the requirements of the Airport Safety Data Program. This program is the conduit through which important airport information is collected and disseminated to airport users through the Airport Facility Directories. Although there is no regulation requiring that non-certificated, public-use airports must be inspected at any regular interval, there are measures in place to ensure that these airports are inspected at least on a triennial basis. The purposes of the airport inspections are to (1) verify the accuracy of the data on FAA Form 5010, (2) update the data as necessary, and (3) report conditions to airport users. All airport facilities in the United States are inspected on a regular basis, whether they are certificated or non-certificated. Under contract to the FAA, GCR & Associates, Inc. (GCR) developed 5010Web.com, a secure, web-based application allowing federal and state airport inspectors the ability to transmit inspection data directly to the FAA over a secure Internet application. The inspection data are transmitted to the FAA on a 56-day cycle, and are ultimately published in the Airport Facility Directories (M. Romero, personal com- munication, Oct. 14, 2010). Since 2004, through an annual grant from the FAA, GCR has been responsible for the National Airport Safety Data Collection Program (collection of safety data for all non-primary public and private airports in the National Flight Data Center database). The program consists of field inspections of public-use airports conducted by state aviation departments. In cases in which the state agency expresses a need for assistance, GCR subcontracts the inspection services to Southern Illinois University Carbondale. GCR compensates those state departments and Southern Illinois University Carbondale for all public-use airport inspections through the FAA’s GCR grant (M. Romero, personal communication, Oct. 14, 2010). Training for non-certificated airport inspection per- sonnel is provided by GCR as part of the Airport Safety Data Collection Program. Under the terms of the FAA’s GCR grant, GCR designs and arranges training seminars in FAA Form 5010-1 inspection procedures twice each year. The training program provides attendees with a basic knowl- edge of inspection requirements, such as identifying and amending data elements on FAA Form 5010, conducting obstruction analyses, uploading the inspection results to www.5010web.com, and many other airport inspection prac- tices. It can be noted that www.5010web.com is a secure site and is designed to provide direct access to the Aeronautical Information Services (ATA-100) database. Through the site, both state and federal airport inspectors with an authorized username and password can review and edit all data for each airport in the ATA-100 database for which they have inspection authority (M. Romero, personal communication, Oct. 14, 2010). States are provided with funding to inspect one-third of their airports every year. Each state receives a certain amount per airport, with Hawaii and Alaska receiving double compen- sation. If the states contractually agree to inspect their eligible airports, then the states receive the funding for each eligible airport. Rather than receiving funding in a lump sum, states receive funding after the results of each airport inspection are submitted to www.5010web.com. Most states agree to

inspect their airports, submit their inspection results, and collect their funds, but there are some exceptions to the norm. Some states opt out of the inspection process altogether. In these cases, a private contractor is hired to conduct the inspections. In other cases, states agree to conduct the inspec- tions but fail to uphold their obligations. A private contractor is then hired to conduct the airport inspections, and the fund- ing is diverted from the states and used to compensate the private inspector. Airports can be inspected by state airport inspectors or by private airport inspection contractors. By utilizing contract personnel, states are relieved of the finan- cial obligations associated with employing one or more air- port inspection personnel year-round (M. Romero, personal communication, Oct. 14, 2010). To determine the degree of state oversight of airport self- inspection programs, each of the 50 state aviation agencies (typically in the form of a DOT) were surveyed. A total of 49 states responded, with some survey data verified by GCR. Currently, 43 states inspect non-certificated, public-use airports using state airport inspection personnel generally employed by state departments of aviation. Seven states currently elect to have airports in their state inspected by contractors rather than by state personnel. These numbers account for the state of Texas handling some airport inspections in-house and contracting out the inspection of others. Also, the state of Florida handles its own inspections, but does not participate in the 5010 program with GCR, uploading inspection data directly to the FAA. Table 6 shows the inspection practice by state. Frequency of Inspection When queried as to how often inspections are performed, the majority of states said they inspect either annually or tri- ennially. Figure 45 presents the frequency with which states inspect airports. Areas of Focus During an Inspection Participating states were also queried as to what areas or practices were inspected during the state inspection. As seen in Figure 46, the most emphasis is placed on markings, signs, and lighting, as well as on obstructions, pavement areas, and safety areas. Interestingly, only 11% of states inspect training records during the state inspection. Issuance of Licenses or Certificates Additionally, 61% of states actually issue airport licenses or certificates. Of those that issue licenses, 85% require a successful inspection to obtain or renew the license. Finally, in 21% of states, a successful airport inspection is required to be eligible for state funding for airports. In 47% of states, 48 State State-Conducted Inspections Contracted Inspections Alaska X Alabama X Arkansas X Arizona X California X Colorado X Connecticut X Delaware X Florida X Georgia X Hawaii X XawoI Idaho X Illinois X Indiana X Kansas X Kentucky X Louisiana X Massachusetts X Maryland X Maine X Michigan X Minnesota X Missouri X Mississippi X Montana X North Carolina X Nebraska X New Hampshire X New Jersey X New Mexico X Nevada X New York X XoihO Oklahoma X Oregon X Pennsylvania X Rhode Island X South Carolina X South Dakota X TABLE 6 STATES RESPONSIBLE FOR CONDUCTING INSPECTIONS OF PUBLIC-USE AIRPORTS (continued on next page)

49 state funding is contingent upon more than a successful inspection. State Guidance When queried whether their state had guidance for airports in preparing for a state inspection, 44% answered in the nega- tive. When asked if their state had guidance for airports in developing self-inspection programs, 77% of states answered in the negative, although more than half of those states direct airports to the FAA for guidance. Training Oversight In the majority of states (51%), the training of personnel conducting airport self-inspections is an issue of importance. Tennessee X Texas X X XhatU Virginia X Vermont X Washington X Wisconsin X West Virginia X Wyoming X Source: Survey data, supplemented by GCR data. State State-Conducted Inspections Contracted Inspections TABLE 6 (continued) 48% 7% 41% 5% 0% 10% 20% 30% 40% 50% 60% Once every three years Once every two years Once every year Once every month FIGURE 45 Frequency of state inspections. 98% 98% 96% 86% 64% 61% 55% 43% 43% 25% 18% 18% 14% 14% 11% 2% Markings, signs, and lighting Obstructions Pavement areas Safety areas Navigational aids Fueling operations Construction areas Public protection Wildlife hazard management Ground vehicles Snow and ice control Other Airport Certification Manual Aircraft Rescue Firefighting Training records Emergency Response Manual FIGURE 46 Areas/practices inspected during state inspection.

However, the majority of states (61%) indicated that training practices are not an area of inspection by the state. Further, 89% of states do not offer guidance to airports in developing training programs for their self-inspection personnel. However, 47% direct airports to the FAA for guidance. Summary of State Oversight Although practices vary to some degree among states, there are commonalities. Most airports inspected by state avia- tion agencies are non-certificated, public-use airports and are inspected either annually or once every 3 years. Although 50 different areas may be inspected during a state inspection, the following areas are most common: • Markings, signs, and lighting; • Obstructions; • Pavement areas; and • Safety areas. Finally, although some states offer guidance to airports in preparing for a state inspection, developing a self-inspection program, and training self-inspection personnel, many states direct airports to the FAA for guidance in these areas.