Curiosity Q - When do the airlines accomplish 30 day VOR tests

kontiki

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Kontiki
I've worked in the Engineering department for 3 major airlines, and I don't ever remember seeing or hearing about a 30 day VOR test. I'm now with an outfit that flies new 777s & 767s too. Does the FMS autotune one against the other once a flight or something? Anyone know how the 91.171 requirement is met?
 
My recollection was this: since the airline was under a continuous maintenance program, the 30-day VOR check was not required. OTOH, whenever we originated a flight at a station that had a VOT, we were required to check the VORs against the VOT during our pre-flight cockpit check.
 
At the regional airline I used to work for, the logbook had a sheet on which pilots operating had to ensure VOR checks were completed on the 15th and 30th of the month.
 
I dont know the specifics of what applies to airlines as I dont work for one but I'd note 3 things about your question:

1) VOR Tests, while included by pilots as part of the "required inspections" for IFR, are not really a "maintenance" issue or "inspection" like other IR inspections such as the pitot/static, elt, annual, etc so they aren't something the Engineering or Maintenance department is likely to be concerned with. They are generally conducted and signed off by the pilot flying the aircraft. In most cases this is an Instrument-rated pilot (or student) as the 30 day check procedure (including logging/signoff) isn't really discussed in private pilot curriculum but 91.171 itself does not really specify a requirement for who does this check. Unless it is radio repair station using a generated test signal (in which case they must be "certificated and rated appropriately" and must place an entry in the aircraft log in addition to the VOR check sheet), 91.171 does not list any real requirements of the person conducting the test. My reading of this is that as long as the test is conducted in accordance with the regulation, there is no reason your non-pilot friend sitting in the right seat cannot conduct and sign off on the VOR Test. Now I think most pilots, whether PIC or SIC, Captain or First Officer, wouldn't trust their navigation equipment and therefore life to just anyone (or even their First Officer/Co-pilot) and would check it themselves but it seems possible. Dual pilot-operations generally have both Captain and First Officer conduct the same tests as a cross-check and I again I doubt such dual operations groups would allow just anyone to conduct such a test. This is almost without a doubt true at an airliner.

2) The section that requires a 30 day VOR test is 91.171(a)2 but 91.171(a)1 lists no specific date requirement and states compliance is achieved when the VOR "is maintained, checked, and inspected under an approved procedure." 91.171(a)1 and 91.171(a)2 are "OR" regulations, meaning only 1 of the 2 needs to be complied with. I imagine this would cover most airliners since their planes undergo regular scheduled maintenance.

3) An aircraft as large as a 777 or 767 or A320 or really any "airliner" cannot be operated for hire under part 91, part 135 or even part 125 as it is too large to meet any of the definitions so even a "charter" airline flying for such a plane for hire would fall under the supplemental section of Part 121. I am unable to find any specific exclusionary grounds on why the aircraft couldn't operate part 91 as a private not-for-hire aircraft but I cant imagine there are many people out there flying them around in this manner. While the air carriers still ostensibly need to comply with part 91 regulations where undefined in part 121, there are many differences just within the regulations themselves (e.g. an operator under part 91 can initiate an approach to an airport when conditions are below minimums but a commercial operator under 135/125/121 cannot) but most importantly, the airline is free to deviate from Part 91 where necessary as long as it complies with their Ops Spec which must be filed with and approved by the FAA. Basically, the operate "outside of the law" and "write their own law" that is then signed off and sanctioned by the FAA as "compliance under the law" for that specific operation.

While I am unable to find anything specific about VOR testing under Part 121, there is a high likelihood that VOR testing is covered under the airlines Ops Spec allowing them to "skip" this check or is otherwise covered during regular maintenance by the "maintained, checked and inspected" clause of 91.171(a)1. Failing all of that it's an exceedingly easy and quick check to conduct and the pilots may still be conducting the test, even when compliant under other sections, using any of the prescribed methods. Many of the Class B and C airports capable of supporting such a large aircraft have VOR's right on the field and thus have good reception on the ground to conduct the dual VOR cross-check permitted by 91.171(c) at pretty much any time and location. Many also have designated VOR-system surface checkpoints which can be used under 91.171(b)2 or VOT systems which can be used under 91.171(b)1. The airlines also spend most of their time flying along specified routes where they probably regularly encounter designated airborne checkpoints to be used under 91.171(b)3 and/or can configure and use a known ground reference point under 91.171(b)4 (though exactly what an "acceptably low" altitude is and/or how to ensure you are directly over a ground fix when at 40,000 feet is unclear; I guess you could use another VOR station with DME in which case "directly over" should match your altitude).

Surprisingly enough, reading 91.171 I've found that one of the methods I was taught (and many other pilots I know in multiple regions of the country so not just my instructor's error) to conduct a VOR test, particularly useful in single VOR aircraft, is not in full compliance with 91.171. I was taught it was acceptable to plot a radial to known ground fix and we used it frequently at my previous airport where I did my instrument training and there was a prominent, off airway ground fix within 3 miles of the airport. The actual regulation of 91.171(b)4 read as a list of requirements not an "OR" and thus being on an established airway appears to be required. We also used the closest VOR station which was 10 miles to the North when the VOR station 20 miles to the South or even 35 miles to the East would appear to have been the FAA preferred station to use under 91.171(b)4(ii). I think low altitude and reception may have played a significant part in that though (It's been almost a year since I last flew there so dont really recall where and when we had sufficient reception to tune the VOR stations in question) and the regulation only states it as a preference so it would seem that it's not "unacceptable" so much as "less preferred."

Im also a little surprised (not really considering how long it takes the government to do anything) the Regs haven't been updated to allow a VOR cross check with a GPS receiver as this could be used just about anywhere provided sufficient GPS reception and would seem likely to be more accurate than any other airborne check and would not require the surveying and designation of ground checkpoints for the ground based checks.
 
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We operate a 747SP under part 91. It's definitely possible to operate a large airliner that way.

I don't know who does the VOR checks. I suspect it's the PIC. There is no VOT or formal VOR checkpoint at the base, but of course the dual VOR check is always an option.
 
We operate a 747SP under part 91. It's definitely possible to operate a large airliner that way.

I've also been on board (and in the cockpit) of an airliner sized aircraft operating under Part 91.

Ironically it was written into their ops rules exactly how to flip the aircraft to a Part 91 operation including special transponder code requests from ATC.

So you kinda "started off" 121 and did X, Y, and Z during pre-flight prep on the ground (technically the dispatchers did most of it) and the flight was magically Part 91 by the time you cranked to taxi.

Long before anyone went to the aircraft.

They still got to operate under the company callsign and were issued a special flight number (started with a 9 and was four digits, whether that was directly related to "9"1, I doubt it) but other than that, it was all Part 91.

Used for repositioning, maintenance test, all sorts of stuff. Our flight was repositioning.
 
At my shop, the VOR check is maintenance function for the most part. We can do the check under the direction of maintenance control. I guess they think we're too stupid to do it on our own.
 
I believe aircraft operators must comply with operational rules. If you operate in the domestic US, those rules are in part 91 and 97 (for IFR I believe). There may be a few rules that are obviated possibly by other part 121 or 135 requirements, but I can't think of any. I know of no airline that does not comply with 91.411 and 91.413 altimeter testing and transponder testing as part of their Mx program. I wouldn't be surprised to find there are others. Those work cards are usually accomplished by Mx. Typically, an airline engineering department handles configuration control of the aircraft. When I've been involved in STC approved transponder upgrades, it falls to engineering to ensure the test documentation in the Mx program work cards is applicable for the new gear. It sometimes obviates the OEM cards. It gets a little more complicated when the airline operates internationally and there are regional operational requirements too. As far as I know all must be met. I know I've had to take measures to support (demonstrate and document) that compliance when it came to transponder compliance and Nav Canada rules, Australian rules, and Euro-control rules.
 
I've also been on board (and in the cockpit) of an airliner sized aircraft operating under Part 91.

Ironically it was written into their ops rules exactly how to flip the aircraft to a Part 91 operation including special transponder code requests from ATC.

So you kinda "started off" 121 and did X, Y, and Z during pre-flight prep on the ground (technically the dispatchers did most of it) and the flight was magically Part 91 by the time you cranked to taxi.

Long before anyone went to the aircraft.

They still got to operate under the company callsign and were issued a special flight number (started with a 9 and was four digits, whether that was directly related to "9"1, I doubt it) but other than that, it was all Part 91.

Used for repositioning, maintenance test, all sorts of stuff. Our flight was repositioning.

That sounds complicated. At TWA, when we ferried any of our fleet, we operated under Part 91 only, not Part 121. If the airplane had no revenue cargo or passengers onboard, we were dispatched under Part 91. I recall picking up a new 727 at the Boeing Field delivery center. We had to go BFI-ICT-MKC-IND, then back to MKC. The legs BFI-ICT and ICT-MKC were Part 91. At MKC we loaded some revenue cargo, then offloaded it at IND, and loaded some new revenue cargo for the leg back to MKC. This was some kind of property tax dodge from the state of Missouri.

On the Part 91 leg from BFI-ICT we carried about 20 Boeing employees who needed to go to their ICT facility. They were on a free ride. We didn't need a flight attendant because several of the Boeing employees were qualified by Boeing on the cabin emergency procedures.

We departed BFI VFR and picked up our IFR clearance after a Mt. Rainer tour. The base of Class A in those days was FL 240. I believe we were VFR, not on a flight plan, for perhaps 100 miles, which would have been illegal under our Part 121 ops specs.
 
We sometimes operate part 91 for non-revenue maintenance test flights, stiff leg ferries, white tail ferries etc. We've done that to fly with test equipment installed, or with minor changes for troubleshooting too. I expect our STC test flights are done part 91 too. I don't think the part 91 requirements really go away away when part 135 or 121 ops resumes though.


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I don't think the part 91 requirements really go away away when part 135 or 121 ops resumes though.


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135 and 121 are more restrictive than 91. If it isn't mentioned in either of those then 91 applies.
 
I'm unfamiliar with these terms. What are they?

Stiff Leg - Gear locked down
White Tail - Aircraft acquired by company but not ready for entry into scheduled service (they get ferried around to mod centers, paint shops, in and out of the desert etc).
 
Never done one in my time at Delta on the 757/767 - also never heard of anyone doing them on any other fleet. (Doesn't mean they weren't done)
 
At my old airline we used to do it inflight at the same time we did engine trend stuff, but like EvilEagle, I don't do anything like that now. Can't find anything about it in any of my manuals either.

I'm told we don't do engine monitoring because these days the planes automatically send that info to MX for us. Perhaps the same is done for the VHF navs?
 
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