Is it legal to fly in RVSM airspace with an inoperative autopilot?

Lnafziger
  • Is it legal to fly in RVSM airspace with an inoperative autopilot? Lnafziger

    FAR Part 91, Appendix G, Section 2 says:

    (c) Altitude-keeping equipment: All aircraft. To approve an aircraft group or a nongroup aircraft, the Administrator must find that the aircraft meets the following requirements:

    ...

    (2) The aircraft must be equipped with at least one automatic altitude control system that controls the aircraft altitude

    Note that it does not say that it must be engaged, or even operative. Simply "equipped", and also that this is to approve an aircraft for RVSM. From what I can find, there is no operational requirement for the autopilot to actually be working or engaged.

    Assuming that my MEL allows me to defer the autopilot and still fly, can I fly in RVSM airspace? Some people however say that if you are in RVSM airspace that the autopilot must be working and engaged. Right or wrong?

  • For RVSM, the autopilot (and altimeter) has to be operable, certified for maintaining a tight altitude tolerance, and maintained in an approved RVSM maintenance schedule.

    FAA Part 91, appendix G, Section 2.

    In the event the autopilot fails at RVSM altitudes, the pilot shall contact ATC and state "Unable RVSM Due Equipment". ATC will provide non-RVSM separation and/or clear the aircraft out of RVSM airspace.

    AIM 4-6-8.

  • About whether or not you can fly with an inoperative autopilot, take a look at §91.180:

    §91.180 Operations within airspace designated as Reduced Vertical Separation Minimum airspace.

    (a) Except as provided in paragraph (b) of this section, no person may operate a civil aircraft in airspace designated as Reduced Vertical Separation Minimum (RVSM) airspace unless:

    1. The operator and the operator's aircraft comply with the minimum standards of appendix G of this part; and
    2. The operator is authorized by the Administrator or the country of registry to conduct such operations.

    (b) The Administrator may authorize a deviation from the requirements of this section.

    You also can't say that your aircraft is allowed to operate in RVSM airspace:

    Section 4. RVSM Operations

    (a) Each person requesting a clearance to operate within RVSM airspace shall correctly annotate the flight plan filed with air traffic control with the status of the operator and aircraft with regard to RVSM approval. Each operator shall verify RVSM applicability for the flight planned route through the appropriate flight planning information sources.

    (b) No person may show, on the flight plan filed with air traffic control, an operator or aircraft as approved for RVSM operations, or operate on a route or in an area where RVSM approval is required, unless:

    1. The operator is authorized by the Administrator to perform such operations; and

    2. The aircraft has been approved and complies with the requirements of Section 2 of this appendix.

    If it's not operational, the aircraft no longer qualities for RVSM, and therefore must be provided with 2000 feet vertical separation (each way) between other aircraft. Alternatively, ATC can refuse entry into RVSM airspace.

    About whether you need the autopilot engaged, that is dependent on the FAA approved company policies, required as part of the operator's application to be authorised for RVSM.

    If it can be demonstrated to the FAA that safety is not compromised by flying without the autopilot engaged and there are procedures to mitigate this concern, then yes it would be possible in theory. However, in the vast majority of cases airlines choose to place in their policies that

    "autopilot must be on during climb, cruise and descent at FL290 or higher"

    or words to this effect. Anyway, not flying with an autopilot would defeat the purpose of having a requirement to equip RVSM aircraft with an autopilot, so the chance of that happening would tend towards 0.

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