Faa acknowledges turf operations

[Steve Pierce]

Read this from the RAF today and downloaded what the FAA said and posted below. I mow and operate on two 660 foot adjacent areas at my home airport. Trying tpo decide if I want to make it official and deal with the Feds on this or just keep doing what I do. From personal experience it is sometimes not worth the headache dealing with a Fed who interprets things differently than I do.

https://theraf.org/faa-acknowledges...xthaHdohLMHSfSR-Y7Kumif95LLTpWhR3mt96ewSDymBo

2.10.6 Aircraft Operations in the Unpaved Runway Safety Area (RSA).The primary function of a standard RSA is to enhance the safety of aircraft thatundershoot,
overrun, or veer off the runway. Pilots of certain aircraft (such asultralights, powered-parachutes, helicopters, gliders, agricultural aircraft, tailwheels,aircraft with large balloon type “tundra” tires, etc.) occasionally use the unpaved portionof the RSA adjacent to a runway for takeoffs, landings, or other operations (e.g., bannertowing). While aircraft operations from the unpaved portion of an RSA are notinherently unsafe, such operations have the potential to introduce various hazards andrisks to the pilot, as well as other aircraft, vehicles, individuals, and facilities on theairport.

2.10.6.1 Key risk factors to consider include:
1. The separation standards of Tables G-1 through G-12 in Appendix Gdo not consider landing and takeoff operations from the RSA adjacentto the paved runway surface.
2. Aeronautical studies do not cover operations to and from the RSAadjacent to the paved runway.

2.10.6.2 From an airport design perspective, the optimum approach for an airportwith a demonstrated need for operations from a turf surface is thedevelopment of a standard turf runway, per paragraph 3.20. Runwayjustification conditions and regular-use criteria apply if the airport desiresFederal assistance with development of a turf runway.

2.10.6.3 AIP Airport Sponsor Grant Assurance 19 requires the owner of an airportdeveloped with Federal grant assistance to operate its airport at all times ina safe and serviceable condition. Refer to AC 150/5000-17. An airportwith operations in the RSA adjacent to the runway pavement may need toassess the operational safety implications, with assistance from the FAA,to ensure an acceptable level of safety.

2.10.6.4 FAA Order 5190.6 establishes FAA policy for reasonably accommodatingthese activities while addressing safety considerations and coordinationwith other FAA offices. Flight Standards, working in conjunction with theOffice of Airports and/or ATO, will analyze supporting data anddocumentation to determine whether conducting a particular activity at anairport results in an acceptable level of safety.

2.10.6.5 The Flight Standards District Office (FSDO) specialist serves as the initialpoint of contact for a safety assessment. The FSDO engages other FlightStandards
offices, as appropriate, to assess and determine if an acceptablelevel of safety for aircraft operations within the unpaved portion of anRSA exists. In many cases, current FAA regulations, guidance, andoperational procedures are sufficient to establish an acceptable level ofsafety. In other cases, operational mitigations are necessary based onFlight Standards safety assessment and guidance. Contact the applicableFSDO specialist for questions related to the safety of aircraft operationswithin the unpaved portion of an RSA. Seehttps://www.faa.gov/about/office_org/field_offices/fsdo/ for FSDOcontact information.

2.10.6.6 Airport design standards do not account for these types of operations.Consider the following factors when assessing aircraft operations in theRSA:
1. Education of the pilot community to reflect an operation in the RSAadjacent to the paved runway surface represents an operation on thepaved runway.

2. The separation values and hold line locations on the runway side,where RSA operations occur, may be inadequate to mitigate identifiedrisk.
3. Provision for enhanced inspection and maintenance of the RSA toensure a serviceable condition.
4. Provision of airport informational notes in the Chart Supplement andAutomatic Weather Observation Systems (AWOS) broadcasts.
5. Provisions based on State laws on landing and takeoff areas.6. Consultation with the Part 139 inspector at certificated airports.

 

[mvivion]

Just remember, when landing a turf area adjacent an active runway on a tower controlled airport, that the ATC admonition “Landing in the grass adjacent to runway XX is at your own risk” does NOT authorize you to enter ANY controlled surface after landing.

That means you cannot cross the paved runway surface you just landed next to, nor can you taxi onto any CONTROLLED taxiway, without specific clearance from ATC.

Our local tower has long permitted operations in the grass adjacent runway 03. A pilot was chewed out (but not violated) for crossing a controlled surface after landing there.

Just understand in that situation, you are not “cleared” by ATC to do anything. Land adjacent a runway, then if you need to cross that runway, request clearance, just like any other case.

MTV

 

[hotrod180]

We talked with our airport administrators about having an "alternate grass landing area" (AGLA) added to our next official airport layout plan (ALP).
The idea was to provide a place for grass operations but without the legal ramifications of it being a runway.
Turns out there's almost as much red tape & BS involved as if it was an actual "runway",
and just about as much legal culpability.
I think everyone decided "don't ask, don't tell" (DA/DT) is a better policy, for us anyways.

 

[bob turner]

When we shut down our main runway for repaving for over two months I blocked out two 1000 foot turf runways to relieve the secondary runway. They laughed at me - said it would cost too much to hire a biologist.

Then, surprise - they hired a full time biologist! (Pleasant, attractive young girl with an office elsewhere). Still no turf runway.

Now all we want is for them to delay mowing until the flowers go to seed - nah - gotta mow when the grass exceeds two inches.

 

[bob turner]

And PS - Mike - I always wondered whose risk it is at when I land on the properly paved, marked, and certificated runway?

 

[akavidflyer]

And PS - Mike - I always wondered whose risk it is at when I land on the properly paved, marked, and certificated runway?

I have asked the tower that same thing. When they advised landing "at your own risk" I came back with "as apposed to any other landing in what way" and all I got was crickets. I think its just something they like to say.

 

[frequent_flyer]

I have asked the tower that same thing. When they advised landing "at your own risk" I came back with "as apposed to any other landing in what way" and all I got was crickets. I think its just something they like to say.

Things they should say versus things they may like to say are defined in Pilot/Controller Glossary - https://www.faa.gov/air_traffic/publications/media/pcg_10-12-17.pdf.

When I wondered what "at your own risk" implied I tried to find the phrase in the glossary. The word "risk" appears twice but neither reference is relevant.

However, this article provides a path to an explanation - https://www.aopa.org/news-and-media/all-news/2015/november/09/training-tip

The paragraph numbering has changed but the reference can be found in "VFR Helicopter Operations at Controlled Airports" para 4-3-17.

https://www.faa.gov/air_traffic/publications/atpubs/aim_html/chap4_section_3.html

The significant difference seems to be whether the tower has control over, and responsibility for, movements on the landing surface.

 

[mvivion]

I have asked the tower that same thing. When they advised landing "at your own risk" I came back with "as apposed to any other landing in what way" and all I got was crickets. I think its just something they like to say.

That statement is required terminology, and for good reason.

If you were to land on an “approved, certified runway”, there are all sorts of assurances that the airport and the FAA provide to you. If there’s a pothole, or major FOD on that runway, and you hit it, you MAY have standing to sue the airport for damages. This is a surface that was specifically prepared AND certified for landing aircraft.

And, ATC can clear you to operate (land/takeoff/taxi) on that surface.

But, land alongside that certified surface, and there are NO assurances, other than that no obstacles can penetrate the side slope requirements. But, there could be a ditch, a culvert, a massive badger den, ground squirrel colony, or ??? So, ATC cannot CLEAR you to land there. If you land and hit an obstacle…..tough deal, AND FSDO could investigate for careless operation.

Controllers can only clear you to operate upon certified surfaces and areas. Anything else is at your own risk….no assurances. You’ll also hear this statement from ATC when helicopters land somewhere other than a helipad or runway.

MTV

 

[bob turner]

Hear it all the time. They have stopped making me say "I will maintain visual separation" when what they really want is "waive the wake turbulence."

But there are times when it all gets silly - they had to change taxiway India so we wouldn't confuse it with Runway One. And now the notices are absorbed directly by the air missions, completely bypassing the learners on the flight deck. And don't get me started on "line up and wait."

 

[frequent_flyer]

You’ll also hear this statement from ATC when helicopters land somewhere other than a helipad or runway.

Also for operations from helipads that are outside the movement area.

 

[dgapilot]

Funny thing with all this, at FDK, years ago the FAA paid in part to install a grass operations area for the glider club. About 8 or 10 years ago the airport manager wanted to get rid of the glider club and in concert with the FAA Airports office decided that the grass operationas area was no longer suitable for glider (or airplane) operations. A legal battle resulted, FAA and the airport covered up and lied, and the airport and city won the case, then jacked up the rent for the club almost 3X what we were paying. Fortunatly we also had our own airport about 20 miles away, so consolidated operations at the one airport we own. I suspect that if that FAA Order revision had been done back then, we may have gotten our way.

 

[FdxLou]

We all owe our very own Jeff Russell (WI Jeff) a big thank you for all his efforts over the last 3 years to bring this program to life. He worked tirelessly with the RAF along with input from EAA and especially AOPA to open up this process.
Thanks Jeff!
Lou

 

[hotrod180]

I thought I'd see just what the new AC actually said.

AC 150/5300-13B, Airport Design, March 31, 2022 (faa.gov)

434 pages. I didn't get very far.
It made me think of this--
just substitute "AC decoder" for "TAF decoder".

 

[Steve Pierce]

I thought I'd see just what the new AC actually said.

AC 150/5300-13B, Airport Design, March 31, 2022 (faa.gov)

434 pages. I didn't get very far.
It made me think of this--
just substitute "AC decoder" for "TAF decoder".

View attachment 60965

I posted the pertinent part.

 

[jrussl]

We all owe our very own Jeff Russell (WI Jeff) a big thank you for all his efforts over the last 3 years to bring this program to life. He worked tirelessly with the RAF along with input from EAA and especially AOPA to open up this process.
Thanks Jeff!
Lou

Thanks, Lou! It was my pleasure to work on this effort on behalf of the RAF and in collaboration with EAA and AOPA.

And thanks Steve Pierce for posting the relevant info. All of the new turf references are in 2.10 and only two pages, 34&35.

Jeff


Sent from my iPhone using SuperCub.Org mobile app

 

[Steve Pierce]

Thanks Jeff for all you have done. I think my next step will be to contact my FSDO with details of our two operation areas and see what happens from there. Maybe a CYA in case anyone ever has a problem with where and how we operate

 

[mvivion]

Steve,

First person I'd contact is the Airport Manager, THEN talk to the FSDO. But, from the FAA standpoint, the Regional Airports folks are the ones the FSDO will/should refer you to. I'd get the local manager on board (or is that you??), then go to the FAA and TELL them what you're doing. I've talked to the airports guys for MT/ID about marking grass runways with "practice runways" like they're doing in AK, and they just said if it doesn't have an instrument approach, go for it.

MTV

 

[Steve Pierce]

Steve,

First person I'd contact is the Airport Manager

Good idea. That I don't step on any toes, besides, it is his job that he gets paid for.

 

[hawgdrvr]

I tried several times here at KFCI (central VA) as they have an ideal turf area on the side of runway 15. I even did a video showing the proposed landing areas, runway 15 being the ideal side. Airport manager isn't having any of it. This airport doesn't seem to care for GA traffic, they want the corporate customer. Their mission is "overflow from KRIC, our international airport" but there isn't, never has been, never will be a need to be an overflow for KRIC, not much traffic or volume. Anyways, here is the response I got and the latest from the RAF was a 3rd swing and I'm out. Throwing in the towel.

Video presented: https://youtu.be/Scwxaitq0RU

After reviewing the request with Virginia Department of Aviation this is what was relayed to me:

The Department would require FCI to amend its license. The proposed landing area falls under VA Code § 5.1-7. Licensing of airports and landing areas. In order to pursue a license for the turf landing area, FCI would need to undertake the following actions:
1. Update the Airport Layout Plan showing the location of the turf runway
2. Design of the turf runway must meet FAA AC 50/5300-13A separation standards
3. An Environmental effort to determine environmental impacts and mitigation measures must be completed
4. A public hearing to issue the license must be held.
If the airport decides to pursue this, I strongly encourage that you also include the FAA WADO with your plans. Feel free to call me if you have any questions or concerns.

This above list would be similar to an airfield capital improvement / construction project and would take quite some time, effort and funding. Currently, I would not be able to justify the efforts with the small amount of utilization of the grass area.

 

[Steve Pierce]

So can you now use this FAA document to allow operation on the RSA and not designate it as a runway?

 

[hawgdrvr]

So can you now use this FAA document to allow operation on the RSA and not designate it as a runway?

I provided him the RAF post and the PDF of the updated AC. His response:

Thank you for passing along this information. With the updated 150/5300-13B, the local FSDO must ensure that operations in the proposed area can take place safely in order to approve it.

50/5300-13A has not changed and the remaining list below would still need to be met. With that, the below remains the position of the Airport, we could not justify the efforts with the small amount of utilization of the grass area.

 

[Steve Pierce]

I provided him the RAF post and the PDF of the updated AC. His response:

I would contact the FSDO myself.

 

[daedgerton]

I tried several times here at KFCI (central VA) as they have an ideal turf area on the side of runway 15. I even did a video showing the proposed landing areas, runway 15 being the ideal side. Airport manager isn't having any of it. This airport doesn't seem to care for GA traffic, they want the corporate customer. Their mission is "overflow from KRIC, our international airport" but there isn't, never has been, never will be a need to be an overflow for KRIC, not much traffic or volume. Anyways, here is the response I got and the latest from the RAF was a 3rd swing and I'm out. Throwing in the towel.

Video presented: https://youtu.be/Scwxaitq0RU

I'll come down and use that "grass area" !

 

[hawgdrvr]

I think if you "ask" you're not going to like the answer when it comes to airport managers it seems. I was just north of me at KOFP getting a Garmin service done and figured I'd ask the airport manager there about the nice grass area between runway and taxiway. Yep, got the nope, wet lands, risk, etc. Back to KFCI, as a hangar tenant we have a rule book and it specifically mentioned off runway ops so my hands were tied. In my last round of efforts I told him all I need is a "land at your own risk" and not hold me in violation of the hangar tenant rules. Didn't work. I'm at the point now where I don't even want to try "not asking" and getting in hot water. I'd like to see airport notes reference "turf operations - land at your own risk" so I know of locations that allow this otherwise I have to ask and asking is never going to yield the answer we want it seems.

 

[mvivion]

You’re dealing with several layers of bureaucracy when proposing this kind of thing. All the “guidance” provided by the FAA in that AC does is says the highest level of that bureaucratic ladder is good with it.

Frankly, I don’t think that level of FAA ever gave a hoot about this…..it’s been going on at some airports for decades in any case.

But, the defining rule maker is nearly always the Airport Management. That is where you have to start. You can use this AC as “guidance”, but I guarantee every level of the FAA is going to tell you to talk to the Airport Management.

If, as hawgdriver describes, that management says flat no, it’s not going to happen. So, in those cases, it’s going to take a LOT of work, and maybe a new Manager. Is there an airport Commission? Talk to them, one on one at first. Get them on board, etc.

Nobody ever said dealing with bureaucrats is easy.

MTV

 

[hotrod180]

I think that a lot of us based at public airports are in the same position--
the airport management is pretty much spring-loaded to the no position
when it comes to doing anything GA that's not plain vanilla or at all out of the ordinary.
"Here, read this 434 page AC about grass ops" probably isn't gonna get any traction.
And it doesn't take much (if anything at all) to make them not want to stick their neck out by allowing grass ops,
esp when some yahoo is likely to ball up his airplane trying to emulate his youtube heroes.
Skagit airport (KBVS) near me developed a nice little grass strip adjacent to rwy 22 a few years ago,
but closed it after somebody who probably shouldn't have been out there had a mishap.
They don't need the liability, and I can't really blame them for avoiding it.

 

[dgapilot]

When I lived in Poughkeepsie, we got the airport manager to OK a grass runway, but the tower wouldn't let us use it. Part time tower, so we started going out every morning before they opened and did T&Gs on the grass. When the tower opened and they wouldn't clear us to land we simply responded that they lost X number of aircraft operations. It took a couple weeks for them to catch on as the number of operations sets the GS pay grade for the tower operators. Once they figured it was impacting their paycheck, the started letting us use the grass!

00286AD (faa.gov)

 

[hotrod180]

I think that a lot of us based at public airports are in the same position--
the airport management is pretty much spring-loaded to the no position
when it comes to doing anything GA that's not plain vanilla or at all out of the ordinary.
"Here, read this 434 page AC about grass ops" probably isn't gonna get any traction......

We had an "airport committee" meeting yesterday.
All three pilots in attendance were taildragger guys.
One of the other guys brought up this new AC, I immediately sent the port director (also in attendance) a link.
Like I thought though, he wasn't too interested, citing:
1) costs of preparing a suitable operating area
2) costs of maintaining said area
3) legal ramifications of having an official grass strip.
There are plans afoot to build a new parallel taxiway farther away from the runway,
the existing parallel has potential for being suitable for a grass strip after the pavement is removed.
But that project is 4 or 5 years down the road.

 

[mvivion]

We had an "airport committee" meeting yesterday.
All three pilots in attendance were taildragger guys.
One of the other guys brought up this new AC, I immediately sent the port director (also in attendance) a link.
Like I thought though, he wasn't too interested, citing:
1) costs of preparing a suitable operating area
2) costs of maintaining said area
3) legal ramifications of having an official grass strip.
There are plans afoot to build a new parallel taxiway farther away from the runway,
the existing parallel has potential for being suitable for a grass strip after the pavement is removed.
But that project is 4 or 5 years down the road.

You and your Manager are misconstruing the point of the AC. The point is not to suggest development of another "runway". This AC change is simply addressing operations in an unprepared area WITHIN the safety area of an existing runway. Essentially, these areas may require zero "preparation" and minimal maintenance. Here in Bozeman, pilots often land adjacent to runway 3/21. You are truly on your own there, though, since the airport does zero maintenance there, other than mowing alongside the runway, which they do for all runways. But, nobody "prepared" the area for grass operations, nobody monitors it, and there is NO "designated" landing area. You land wherever you like, as long as it's adjacent that runway.

This area is in fact kind of rough, unless you're running big tires, and there are some culverts out there. There is NO prep, only mowing, and the point is, as the admonition of the Tower suggests, landing there is at your own risk. Don't expect a "runway", cause there isn't one there.

And, in fact, BZN has a very nice turf runway. So, why do some folks land "off airport" within the airport? To significantly reduce taxi distance, which can be harder on Bushwheels than landing.



What your Manager is talking about is DEVELOPING a dedicated grass/unpaved runway, which is an entirely different subject, and has nothing to do with this AC. Someone should point this out to him.

MTV

 

[12Geezer2]

"at own risk" I have ALWAYS thought that ALL I DO is at my own risk. Not all at my home base were happy with my off runway operations but looked the other way MOST of the time. Snow plow guy did not always make it easy for ski operations but a bit of time with my snow shovel allowed access. Life is good !-----geezer Dan