14-Appendix - HWO Safety Assessment Report (Final).pdf

TECHNICAL REPORT

AIRPORT SAFETY ASSESSMENT

North Perry Airport (HWO) Pembroke Pines, Florida

October 2021 prepared for:

Broward County Aviation Department prepared by:

uadrex Aviation, LLC Airport Development Services

Airport Safety Assessment Final Report

ES-1

North Perry Airport 10/27/2021

North Perry Airport

Executive Summary

Broward County, Florida is the owner of the North Perry Airport (HWO) and is operated by Broward County’s

Aviation Department (BCAD). The Airport is classified by the FAA as a “reliever airport” for southeast Florida with the purpose of attracting general aviation activity that would otherwise use the Ft. Lauderdale Hollywood

International Airport (FLL) and Miami International Airport (MIA). HWO has two sets of parallel runways aligned in north/south and east/west directions and is home for 430 aircraft. In recent years, HWO has accommodated close to 300,000 operations annually. Almost 70 percent of the aircraft operations are classified as “local“ and typically involve professional flight training where aircraft stay in the traffic pattern to practice takeoffs and landings or fly to and from practice areas located to the west.

HWO is surrounded by densely populated residential areas and with the increased number of total operations, safety concerns were raised regarding the various accidents and incidents on or near the airfield. To address those concerns BCAD initiated a Safety Assessment study which included an evaluation of existing conditions, comparative practices at other airports, a safety risk analysis, and recommendations for BCAD’s consideration for enhancing safety at HWO including the development of standard operating procedures and other useful information about the Airport that can be communicated among all users.

The study involved an analysis of available operations and accident data, on-site observations, and interviews with the leadership of the Airport’s air traffic control tower and operators of the various aviation services. In addition, there were meetings with pilot groups and community associations to better understand the perspectives of aviation and residential communities.

In general, the study found that HWO has a safety culture in place, primarily the result of the standardized practices of the professional flight training programs and pilots’ participation in safety-related meetings and other events. Over the past 20 years, there have been 38 accidents identified in the National Transportation

Safety Board’s database relevant to HWO and in most cases, the consequences were only damaged aircraft.

However, there have been several accidents involving injuries and fatalities where engine failures were cited as the primary cause. But in general, the accident rate at the Airport has been lower than the national average.

In addition to reinforcing BCAD’s current efforts to enhance the safety of the Airports’ operating environment, the study provided several recommendations for consideration including:

Review and update BCAD’s Minimum Standards for Commercial Aeronautical Service Operators

Review and update the County’s Code of Ordinances for HWO (Rules and Regulations)

Develop comprehensive set of recommended Standard Operating Procedures

Develop and implement a HWO Safety Management Program

The review and update of the Minimum Standards and the Rules and Regulations will require the collaboration of County Administration and BCAD staff. The development of Standard Operating Procedures will require the collaboration among the Air Traffic Control Tower, flight schools, and tenants. HWO’s Safety Management

Program could be developed as a stand-alone program or added to BCAD’s existing SMP for Ft. Lauderdale -

Hollywood International Airport.

BCAD has done much over the past several years to foster a safety culture at the North Perry Airport and is encouraged to continue its efforts to make HWO as safe and efficient airport for all its users.

TC-1

Table of Contents

EXECUTIVE SUMMARY ................................................................................................................... EC-1

I. INTRODUCTION

II. BACKGROUND INFORMATION

A. Facilities

B. Aircraft Operations

C. Airspace

III. SAFETY HISTORY AND CURRENT PRACTICES

D. HWO Accidents and Incidents (2001-2021)

E. FAA Ramp Inspections

F. Safety-Related Capital Projects

G. BCAD Policy Guiding Documents

IV. COMMERCIAL AERONAUTICAL SERVICE PROVIDERS

H. Flight Training Operations

I. Aircraft Fueling Operations

J. Aircraft Maintenance Operations

K. Helicopter Operations

L. Banner Towing Operations

V. COMPARABLE AIRPORTS

M. Comparable Airports & Practices

VI. RECOMMENDED DEVELOPMENT OF ADDITIONAL RESOURCES FOR HWO

N. HWO Pilot Resource Guide

O. HWO Safety Management Program

VII. IMPLEMENTATION PLAN

P. Implementation of Objectives

VIII. SUMMARY

ATTACHMENTS

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I. INTRODUCTION

North Perry Airport (HWO) accommodates general aviation traffic such as flight training, helicopter tours, airships, banner towing and recreational flying and intends to continue to do so. However with the increase of operations in recent years, safety concerns are rising regarding the accidents and incidents on the airfield. On March 29, 2021, the Broward County Aviation Department issued a request for proposals the services from a qualified firm with experience in airport operations and inspections, flight schools, Fixed Based Operators (FBO), Specialized Aviation Service Operators (SASO), aircraft accident investigations, and Safety Management Systems (SMS), to conduct a safety review of aircraft operations at HWO. On April 14, 2021, the project was awarded to Quadrex Aviation, LLC. The scope of the Safety

Assessment included an evaluation of existing conditions, comparative practices at other airports, a safety risk analysis, and recommendations for BCAD’s consideration for enhancing safety at HWO including the development of a resource guide for the airport users.

The following report presents the findings from the analysis of background information, interviews with key operators at the airports, and on-site observations that were used to develop a set of recommendations for BCAD. The comments and opinions expressed in this report are exclusively those of Quadrex Aviation and do not reflect the positions of the FAA, or any other federal, state, local agency, or organization.

II. BACKGROUND INFORMATION

The North Perry Airport (HWO) is owned by Broward County and operated by Broward County’s Aviation

Department (BCAD). The Airport is classified by the FAA as a “regional” airport1 which is indicative of its service as a general aviation transportation facility for the air transportation needs of a metropolitan area.

HWO is also classified by the FAA as a “reliever airport” for southeast Florida and as such, it is designed to provide the facilities and services for attracting general aviation activity that would otherwise use Ft.

Lauderdale Hollywood International Airport (FLL) and Miami International Airport (MIA).

A. Facilities

Originally constructed in 1943 by the U.S. Navy to serve as an auxiliary training facility for the Miami Naval

Air Station, the Airport is currently situated on 536 acres of property. The Airport has two sets of parallel runways aligned in north/south and east/west directions as shown in Figure A. The runways are comparatively short compared to many of its peer airports in the region, ranging from 3,241 feet to 3,350 feet. Besides the short runway lengths, the County has imposed a 12,500 pound maximum gross weight restriction which limits the size of aircraft able to use the airport. A complex network of taxiways provide access to the runways from various locations north and south of the airfield. HWO has an air traffic control tower in operation daily from 7:00 am to 9:00 pm. Between the hours of 9:00 pm and 7:00 am, the

Common Traffic Advisory Frequency (CTAF) frequency2 is used by pilots to coordinate their arrivals and departures with other aircraft using the airport. Figure A also illustrates three areas referred to as

“hotspots” which historically have been prone to runway incursions where aircraft have accidentally encroached onto an active runway without permission.

1 The FAA’s National Plan of Integrated Airport Systems (NPIAS) characterizes “regional” general aviation airports as having high levels of activity with some jets and multi-engine propeller aircraft averaging about 90 total based aircraft.

2 HWO’s CTAF frequency is the same as the Control Tower’s – 132.1 MHz

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Based Aircraft

The Airport is home for 430 aircraft among the various classes as presented in Table 1.

Table 1

Based Aircraft (FY 2020) North Perry Regional Airport

Aircraft Type No. of

Aircraft Percent of Total

Aircraft

Single Engine Piston 360 83.3%

Multi-engine Piston 53 12.3%

Jet 1 0.2%

Helicopter 16 3.7%

Total 430 100.0%

Source: FAA National Based Aircraft Inventory for HWO

Tenants

North Perry Airport hosts a wide variety of tenants who provide commercial aeronautical services such as flight training, aircraft maintenance, fuel providers and line services, helicopter/airplane tours, mosquito control, and banner towing to mention a few. The number of commercial tenants include:

Broward College maintains a campus adjacent to the Airport and offers an aviation academic program that includes professional flight training.

B. Aircraft Operations

Among the general aviation airports located in southeast Florida, HWO has consistently been the busiest.

Table 2 presents the historical number of aircraft operations over the past three years (2018-2020) for the GA airports in the region.

Typically, a significant majority of the aviation activity at HWO consists of local operations3 (flight training) compared to most of the other airports. The impact of the COVID pandemic on airport operations can be seen in the 2020 data however, 2021 general aviation traffic has seen evidence of a recovery. For HWO, the recovery of flight training activity is still constrained by international travel restrictions which is affecting the flight schools.

3 operation – an aircraft takeoff or landing itinerant operation - aircraft arriving from or departing to another airport local operation - aircraft staying within traffic pattern or within 20-miles

FBOs / Fuel Providers (4)

Aircraft Maintenance (7)

Flight Training Schools (10)

Helicopter Tour Operators (3)

Aerial Banner Towing (2)

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Fi gu re A ir p o rt

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Monthly flight activity at HWO is presented in Table 2. Peak activity occurs in the spring and fall months and until 2020, averaged over 23,000 operations per month. Further analysis of the operations data reveals daily and hourly peak traffic characteristics. Tables 3 and 4 illustrate the peak day and hour operations for the 2018-2020 period. The peak day for operations generally occurs on Mondays (followed closely by Tuesdays) indicative of the flight schools’ training schedules which primarily focus on weekdays.

The peak hour for operations generally occurs in late morning between 10:00 am and noon. Of particular note, on Saturday, February 8, 2020, HWO experienced 238 operations in one hour (2:00 – 3:00 pm) averaging over four operations per minute.

The significance of the aircraft operations data analysis is to demonstrate the level of air traffic that occurs on a regular basis at HWO, particularly within the constraints of the Airport’s airspace. Flight training, especially during the primary stage that involve student pilots with fewer flight hours of experience, places a heavy demand on the attention of the air traffic controllers and among all pilots operating in the traffic pattern and general vicinity of the airport. Safe operations at the Airport are facilitated by controllers experienced in working with flight students, the flight schools’ standard operating procedures, and the discipline of students who are being trained to become professional pilots. As will be discussed later, the complexity of North Perry Airport’s operational environment coupled with the significant level of activity, especially flight training during peak periods, are among the various other factors that can contribute to create conditions where safety should be emphasized.

C. Airspace

HWO is situated near the geographic center of southeast Florida which extends from the northern boundary of Palm Beach County down to Homestead in south Miami-Dade County as shown on Figure B.

The airspace above and around the Airport is impacted primarily by the Class B airspace for Miami

Table 2 Monthly Aircraft Operations

Source: FAA Air Traffic Activity Data System (ATADS)

Month 2018 2019 2020 2021

Jan 20,057 25,532 23,725 17,534

Feb 24,728 23,706 26,224 16,677

Mar 26,790 25,930 19,592 17,719

Apr 25,623 25,397 9,641 16,560

May 23,569 27,496 14,398 16,743

Jun 25,122 23,983 20,962 15,607

Jul 22,537 26,334 17,533 18,103

Aug 23,488 22,439 16,806 -

Sep 20,575 18,620 16,434 -

Oct 24,342 23,689 16,089 -

Nov 26,350 21,507 12,860 -

Dec 20,036 19,678 16,234 -

Total 283,217 284,311 210,498 118,943

Average 23,601 23,693 17,542 16,992

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International Airport (MIA), the Class C airspace overlay for Ft Lauderdale-Hollywood International Airport

(FLL), located 6 miles northeast, and Opa Locka Airport’s (OPF) Class D airspace 6 miles south.

In addition, there are several tall transmitter towers located within 2½ - 3 miles east and southeast of the

Airport, with most being over 1,000 feet high. The towers have prominent obstruction lighting (strobes).

The Hard Rock Stadium located 3 miles south also constrains the Airport’s airspace whenever there is an event (e.g., Miami Dolphins football game) where FAA issues a Temporary Flight Restriction (TFR) that prohibits nearby flights. Figure C illustrates the constraints of HWO’s airspace.

Because HWO has an air traffic control tower (ATCT), it has designated Class D airspace which extends out for a radius of 4 statute miles and overhead up to 2,500 feet. Nonetheless, the airspace of the surrounding airports and the tall towers still tends to compress the airspace available for HWO to accommodate aircraft activity.

With parallel runways aligned east/west and north/south, the control tower operates a standard traffic pattern with left turns for Runways 1L, 19L, 10L, and 28L) and a non-standard pattern with right turns for

Runways 1R, 19R, 10R, and 28R. Figure D illustrates the generalized flight paths of each traffic pattern when the control tower operates the runways in either an easterly or westerly direction (depending on wind direction). The typical legs for a standard traffic pattern (left turns) are also shown on Figure D.

Figure E shows the traffic patterns when the airfield is operated in a northerly or southerly direction including the typical legs for a non-standard pattern (right turns). It is important to note that the flight paths of the traffic patterns as depicted are not exact but will vary based on wind and other conditions.

Pilots are expected to climb to 400 feet above ground level (AGL) before turning either right or left for the for the crosswind leg. For the downwind leg of the pattern, the aircraft is flown at 800 feet AGL until turning to the base leg. The aircraft’s altitude for the final approach leg is generally around 500 feet AGL as it is aligned with the runway direction and configured for landing (e.g., engine throttle, flaps, landing gear, etc.).

Helicopters operating on the north side of the airport will usually depart HWO following Pines Boulevard and then turn north or south until clear of the control tower’s airspace or as otherwise directed. Some helicopters will be cleared to depart directly to the south. Helicopters generally will operate at 500 feet

AGL in the proximity of the airport.

Aircraft towing banners operate in the northwest corner of the airport and most often will arrive from and depart to the east at 1,300 feet AGL. The aircraft follow a flight path parallel to RW 10L/28R or RW

1L/19R to pick up and drop off banners.

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T ab le ve ra ge H o u rl y

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Figure B

SOUTHEAST FLORIDA AIRSPACE

Source: Skyvector.com

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Figure C

HWO TERMINAL AREA AIRSPACE

Source: Skyvector.com

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II. SAFETY HISTORY AND CURRENT PRACTICES

D. HWO Accidents and Incidents (2001-2021)

Overview

Historically, the national aviation transportation system has been among the safest in the world. As a significant component of the system, general aviation includes all activity not otherwise identified as commercial or military. The diversity of general aviation activity includes flights for personal and business purposes, flight training, emergency medical services, law enforcement, and agriculture among other uses. General aviation is comprised of wide variety of aircraft ranging from small single- and multi-engine light aircraft, and helicopters to large transport aircraft often used by the airlines. The extent of general aviation in the US is unmatched by any other country in the world.

Statistically, general aviation remains among the safest forms of transportation compared to other modes of travel. Data from the Department of Transportation’s Bureau of Transportation Statistics indicates that over the last 20 years, fatalities from vehicle accidents are 31 times more likely than from general aviation aircraft accidents4. Mechanical problems, weather, human factors are among the common causes for general aviation accidents. Aviation safety, particularly in the general aviation sector, has long been the focus of the FAA and the historical data supports that there has been significant improvement. Pilot education, expanded use of navigation and tracking systems (e.g., satellite-based global positioning system (GPS) , new aircraft technologies, weather reporting and forecasting have been among the efforts to reduce general aviation accident rates. And yet, despite these efforts, there will still be accidents, especially at or near airports like North Perry where the concentration of general aviation activity including flight training is among the busiest in the country.

Observations

HWO is a very busy general aviation airport with annual operations that has approached 300,000 in recent years with approximately 70 percent of operations categorized as local. Flight training comprises a major share of the local operations, much of those conducted by primary students training to be professional pilots. Each flight school has its own set of standard procedures for instructing student pilots how to operate on a complex airfield and within the HWO’s limited airspace. The discipline invoked by these standards have contributed to safe operations of the airport by all users. Nonetheless, 38 accidents5 have occurred at HWO over the past 20 years as is presented in Table 5. Fortunately, most of those resulted in aircraft damage but very few with injuries or fatalities.

4 DOT, Bureau of Transportation Statistics, Table 2-1: Transportation Fatalities by Mode (2001-2019) 5 “accident" means an occurrence associated with the operation of an aircraft which takes place between the time any person boards the aircraft with the intention of flight and all such persons have disembarked, and in which any person suffers death or serious injury, or in which the aircraft receives substantial damage. (NTSB considers damage to be substantial if it compromises the structural strength, performance, or flight characteristics of the aircraft and requires major repair or replacement of the affected component.)

https://www.bts.gov/content/transportation-fatalities-mode

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A cc id en t D a ta b a se http://www.kathrynsreport.com/2021/03/beechcraft-b36tc-bonanza-n236bc-fatal.html http://www.kathrynsreport.com/2021/01/tl-ultralight-sro-stingsport-n404n.html http://www.kathrynsreport.com/2020/12/socata-tb10-tobago-n5547y-accident.html http://www.kathrynsreport.com/2020/12/piper-pa-38-112-tomahawk-n2420f.html http://www.kathrynsreport.com/2020/11/lancair-legacy-fg-n3uh-fatal-accident.html http://www.kathrynsreport.com/2020/11/piper-pa-28-181-n84014-incidents.html https://app.ntsb.gov/pdfgenerator/ReportGeneratorFile.ashx?EventID=20070615X00736&AKey=1&RType=Final&IType=CA http://www.kathrynsreport.com/2021/06/abnormal-runway-contact-cessna-152.html http://www.kathrynsreport.com/2020/05/piper-pa-34-200-seneca-n887sp-fatal.html http://www.kathrynsreport.com/2018/06/cessna-172n-skyhawk-n734hf-incident.html http://www.kathrynsreport.com/2019/12/hard-landing-cessna-152-n904wa-accident.html http://www.kathrynsreport.com/2019/08/cessna-152-n65401-incident-occurred.html http://www.kathrynsreport.com/2019/03/cessna-172m-skyhawk-n20521-and-cessna.html http://www.kathrynsreport.com/2016/06/cessna-172n-skyhawk-aurora-enterprise.html http://www.kathrynsreport.com/2017/06/piper-pa-28-140-n9836w-accident.html

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D a ta b a se https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/87172/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/82046/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/81717/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/79052/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/78605/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/77634/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/68387/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/68387/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/68341/pdf https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/67475/pdf https://app.ntsb.gov/pdfgenerator/ReportGeneratorFile.ashx?EventID=20070616X00742&AKey=1&RType=Final&IType=CA https://app.ntsb.gov/pdfgenerator/ReportGeneratorFile.ashx?EventID=20041105X01763&AKey=1&RType=Final&IType=FA https://app.ntsb.gov/pdfgenerator/ReportGeneratorFile.ashx?EventID=20040604X00736&AKey=1&RType=Final&IType=CA https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/69538/pdf

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Loss of control of the aircraft was the most significant of the initial causal factors and represented 60 percent of the accidents. Often, they were the result of a hard landing, landing long, or the failure to compensate for crosswind conditions. Many of these resulted in a “runway excursion”6 in which the aircraft ran off the runway pavement and collided with airfield signage or incurred other damage. In all cases, there were no injuries or fatalities among these. Among this category of accidents, 10 of them (26 percent) occurred with a student pilot as the pilot in command and another 3 (8 percent) had both a flight instructor and student on board. Given that 70 percent of HWO’s total annual operations are classified as local, the cumulative loss of control accident rate over the past 20 years involving flight training is remarkably small.

There were a total of 15 accidents (40 percent) that were attributed to mechanical issues with the aircraft.

Most all of these were characterized by a loss of power on takeoff and resulted in an emergency landing, usually off the airport premises. Unfortunately, this type of accident resulted in a total of seven injuries and nine fatalities during the 20 year period. Also noted in the accident records search was a mid-air collision in 2008 involving two aircraft (one from HWO) operating in the practice area7 west of the Airport that resulted in four fatalities.

The accident rate at HWO appears to be significantly less than the current national average. Table 6 shows that during the 2018-2020 period, the Airport’s rate was 1.8 accidents per 100,000 general aviation operations and a fatal accident rate of 0.39. According to data compiled by the AOPA Air Safety Institute’s latest report8, the national average for total general aviation accidents during the same period was 3.68 per 100,000 operations while the fatal accident rate was 0.64. More detailed reports from the National

Transportation Safety Board (NTSB) regarding aircraft accidents at HWO for the past 20 years are included in Attachment 2.

Table 6

AIRCRAFT ACCIDENT RATES

(2018-2020)

Item

HWO National

No. 1 Rate per 100K Ops No. 2

Rate per 100K Ops

Accidents 14 1.80 2,906 3.68

Fatal Accidents 3 0.39 502 0.64

Fatalities 3 0.39 856 1.08

Total GA Ops 3 777,346 78,940,575 1 NTSB Accident Database 2 AOPA ASF, 30th Nall Report, Figure 1.2 – GA Accident Trends 2011-2020 3 FAA Air Traffic Activity Data System

Another source of information for assessing the airspace and air traffic environment relevant to HWO comes from data taken from NASA’s Aviation Safety Reporting System (ASRS)9 . The ASRS database contains detailed reports voluntarily submitted by pilots regarding flight safety issues including near mid-air collisions (NMAC), runway incursions, and other experiences. The ASRS database included 10 pilot reports between CY 2001 and 2021 that involved regarding aircraft operating on or near the Airport. There

6 runway incursion is defined as the improper positioning of an aircraft, vehicle, or person on a runway.

7 charted as Alert Area A-291B with the notation “concentrated flight training”. A-291B extends from the surface to 3,900’ AGL 8 AOPA Air Safety Foundation 30th Joseph T. Nall Report (Note: 2020 data is preliminary) 9 NASA Aviation Safety Reporting System Database Online https://data.ntsb.gov/carol-main-public/basic-search https://www.aopa.org/training-and-safety/air-safety-institute/accident-analysis/joseph-t-nall-report/nall-report-figure-view?category=all&year=2018&condition=all&report=true https://aspm.faa.gov/opsnet/sys/main.asp ttps://www.aopa.org/training-and-safety/air-safety-institute/accident-analysis/joseph-t-nall-report/nall-report-figure-view?category=all&year=2018&condition=all&report=true https://asrs.arc.nasa.gov/search/database.html

-15-were six NMAC reports including two involving the interaction of fixed wing aircraft and helicopters. Four of the ASRS reports were inadvertent runway incursions, particularly involving the intersecting ends of north/south and east/west runway. Detailed narrative reports for these incidents are included in

Attachment 3.

Recommendations

While BCAD cannot control the outcome of flight operations, there are some recommended actions it may take to enhance overall safety.

1. BCAD should consider establishing a preferential runway program that offers the best opportunities for an emergency landing immediately after takeoff. This alternative should be discussed among

HWO’s flight instructor community for their insight.

2. BCAD should promote pilot education regarding the limited options for conducting a successful off-airport emergency landing. Pilots should be encouraged to ensure their aircraft engine is performing normally before attempting a takeoff. Signage near the takeoff end of the runway may be an effective reminder

3. BCAD should review the County’s Code of Ordinances, Section 2-128(b) regarding the provision that pilots should be at or above an altitude of 400 feet after departure before turning to the crosswind leg of the traffic pattern or departing on-course10. HWO’s flight instructor community should be consulted regarding their standard operating procedures and recommendations for guidance and seek FAA’s concurrence with reinforcing or amending the minimum altitude provision.

4. BCAD should encourage the use of the aircraft’s best angle of climb (Vx) or other similar procedure

(e.g., NBAA close-in departure) for departing aircraft to gain the maximum altitude in the shortest distance when appropriate.

5. BCAD should coordinate with the flight training operators to develop standard traffic patterns and other procedures for inclusion in their flight standards guidance.

6. BCAD should consider the development of a handbook or other publication to promote safe operations at HWO.

7. BCAD should continue to sponsor and participate in safety meetings and other programs to promote aviation safety at HWO.

E. FAA RAMP INSPECTIONS

As part of its overall responsibilities to promote the safety of flight, the FAA’s Flight Standards District

Office (FSDO) conducts ramp inspections or ramp “checks” at airports to determine if an aircraft is in an airworthy condition and is carrying the appropriate documents required by federal regulations11. The

10 Section 2-128 (b), Broward County Code of Ordinances (see Attachment 5) 11 https://fsims.faa.gov/wdocs/8900.1/v06%20surveillance/chapter%2001/06_001_004.htm https://fsims.faa.gov/wdocs/8900.1/v06%20surveillance/chapter%2001/06_001_004.htm

-16-ramp check may also involve determining if a pilot is carrying or can produce the appropriate credentials such as licenses, ratings, logbook endorsements and medical certificates required for the operation of the aircraft.

A ramp check of a specific aircraft and/or pilot can be precipitated by the observation of an unsafe operation in the traffic pattern or on the ramp or by a referral from air traffic control of an unsafe operation. At other times, the FSDO may randomly conduct ramp checks of several aircraft/pilots as part its normal surveillance of an airport.

Aircraft Inspections

Specific items the FAA inspector will check for the aircraft includes:

A. Aircraft Documents

(1) Airworthiness Certificate – legible and displayed in full view of crew and passengers

(2) Aircraft Registration – N-number matches and issued to current owner

(3) Radio station license – certificate(s) matches and not expired

(4) Operators Manual - current, approved Airplane Flight Manual (AFM) on board

(5) Current Weight and Balance information in the AFM and matches actual equipment installed

Note: Pilots use acronym “ARROW” as reminder

B. Aircraft Physical Condition

(1) General airworthiness (no obvious issues e.g., leaks, damaged skin, cracked windshield, etc.)

(2) Seats and safety belts

(3) Current VOR Equipment Check

(4) Emergency Locator Transmitter (ELT) installation & battery expiration date

(5) Aircraft identification (data) plate secured to aircraft fuselage exterior

Pilot Certification

Specific items the FAA inspector may request include:

(1) Certificates, ratings and limitations are appropriate for operation types

(2) Certificates are genuine and legible

(3) Medical certificates are current for appropriate activity

(4) If available, pilot logbooks (or other records) that document current qualifications requirements

Endorsement for specific operating privileges (e.g., student solo, tail wheel aircraft)

Biennial flight review (every two years)

Pilot proficiency checks

Recent experience (90 days)

Night operations (90 days

Instrument flight (6 months)

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Enforcement & Corrective Actions

If FAA finds a discrepancy with the aircraft, the inspector will generally provide the pilot with a copy of

FAA Form 8620.1, Aircraft Condition Notice and will follow-up with a Letter of Correction notifying owner/pilot of discrepancy or condition notice and request a corrective action within 10 days. For serious issues, FAA inspector may issue a formal Enforcement Investigative Report (EIR) and can ground the aircraft until the issue is resolved. For a discrepancy with the pilot’s certifications, the FAA may request additional documentation be submitted to the FSDO office. With serious discrepancies, the FAA may submit a formal Enforcement Investigative Report (EIR).

The FAA appears to have begun concentrating on conducting multiple aircraft and pilot ramp checks at

HWO particularly during the weekends. From records supplied by the FAA, over 151 aircraft and 76 pilot ramp checks have been conducted between April 10th and August 22nd. Among these, 14 Aircraft

Condition Notices were issued (9.2 percent) but no discrepancies with pilot credentials were noted. There was only one case where an EIR was issued. There is no indication of the exact nature of the aircraft discrepancies but it is assumed most of the issues were complied with after the Letter of Correction was received. Attachment 3 presents the data from FAA regarding the ramp checks and the initial outcome of the inspections.

1. While the responsibility of conducting ramp checks belongs to the FAA, BCAD should continue to request the FAA FSDO inspection activity reports for review.

2. BCAD should provide information regarding the FAA’s ramp check program, including perhaps a redacted table of inspection results to encourage users and tenants to ensure their aircraft is maintained in an airworthy condition and that their documents are up to date. The information can be included in BCAD’s own communications such as tenant newsletters and bulletins as well as provided to airport tenants for their dissemination.

F. Safety-Related Capital Projects

A number of safety-related capital projects are proposed in the current Master Plan for the Airport. A hot spot is typically characterized as a complex or confusing runway/taxiway or taxiway/taxiway intersection with a history or potential risk of runway incursions which could lead to an aircraft/aircraft or aircraft/vehicle collision. Hot spots are depicted on airport charts to designate where heightened attention by pilots and drivers are necessary. As was depicted on Figure A, there are three (3) hotspots identified on the airfield. One such hotspot is currently being mitigated.

The 2020 Master Plan recommended several projects to mitigate the three hot spots and for other improvements to enhance the safety of the airfield.

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Hot Spot No. 1 Mitigation - Taxiway D Modifications

Taxiway D is the full-length west parallel taxiway for Runway 1R/19L. Hot Spot No. 1 is located where

Taxiway D crosses Runway 10L/28R and will eliminate the taxiway intersection crossing. This project is scheduled for construction in FY 2024 for an estimated cost of $1.1 million.

Hot Spot No. 2 Mitigation – Runway 1L and 10R Modifications

This project involves modifications to the ends of Runways 1L and 10R to provide a physical separation between the two. The location was identified by the FAA as “Hot Spot” No. 2 and a common hold-short line for both runways, which contributed to runway incursions. The project eliminates the common connection between the runways and also provides additional areas for pilots to conduct pre-flight aircraft checks and engine run-ups prior to take-off. Construction on the project started in FY 2020 and is expected to be complete by early 2022. The estimated cost of construction is $4.4 million.

Hot Spot No. 3 Mitigation – Taxiway L Modifications

Taxiway L is the south parallel taxiway for Runway 10R/28L. There are connecting taxilanes leading to the hangar and ramp areas near the ends of Runway 1R and Runway 28L. These layout of these taxilanes contribute to runway incursions especially by aircraft crossing Runway 1R to the end of Runway 1L for departure. This project will demolish the access taxilanes and is scheduled for construction in 2023 at an estimated cost of $800,000.

Other Safety-Related Projects

Taxiways D and E are full-length parallel taxiways for Runway 1R/19L. This project will eliminate the portions of the taxiways between Taxiway M and Runway 10R/28L and the portions of the taxiways that connect directly to various T-hangar and tie-down areas.

Taxiways N and P are full-length parallel taxiways serving Runways 10L/28R. Portions of these taxiways will be demolished where they cross Runway 1L/19R. A new Taxiway A will be constructed to provide access for aircraft departing 10L.

Airfield lighting and signage improvements are scheduled to provide enhanced safety features such as flashing runway intersection lights “wig-wags” at the entrance and exit taxiways.

Beyond the short-term planning horizon (1- 5 years), several taxiway pavements will be eliminated or redesigned to reconfigure the airfield to simplify and improve circulation and for enhancing safety and efficiency.

1. BCAD should continue to advance these projects as high priorities due to their contribution for enhancing safety. Development of “shovel ready” projects where the design is substantially complete may provide funding opportunities from FAA and FDOT resources.

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G. BCAD Policy Guiding Documents

There are key documents that provide opportunities for the County to promote its policies and practices for the operation, administration, and development of the North Perry Airport. Rules and regulations are commonly used to promulgate specific guidance regarding how tenants and users should conduct themselves while on the Airport, regardless if they are considered aeronautical or non-aeronautical activity.

Minimum (operating) standards are used to establish the conditions and facilities that entities must comply with in order to offer commercial aeronautical services to the public. Minimum standards are recommended but not required by the FAA to ensure that providers of commercial aeronautical services are qualified, capable, and safe and that no particular provider has an undue advantage over other providers of similar services. The County’s current Rules and Regulations and Minimum Standards were reviewed and the following discussion presents the observations and recommendations for consideration.

Rules and Regulations

Rules and regulations provide guidance and direction for the safe, orderly, and efficient operation and use of the Airport. The Rules and Regulations specifically for HWO are promulgated in the Broward County

Code of Ordinances and found in Chapter 2, “AIRPORTS AND AIRCRAFT”, Article V, “NORTH PERRY

AIRPORT”. Article V has two divisions with Division 1. “GENERALLY” which contain most of the regulations pertaining to operations at the Airport and Division 2.” AIRSPACE PROTECTION” which provides guidelines for preventing the construction of obstructions to HWO’s navigable airspace. A copy of Division 1 –

Generally is locate in Attachment 4.

Focusing on Division 1 – Generally, the ordinance includes the following sections:

Section Title Ordinance No. Last Updated § 2-135. Purpose. 1999-60, § 6 11/30/1999 § 2-136. Definitions. 2005-09, § 1 5/10/2005 § 2-137. General use restrictions. 2014-25, § 11 8/12/2014 § 2-137.1. Airport security at North Perry Airport. 2014-16, § 3 6/10/2014 § 2-138. Airport operations area. 2014-25, § 12 8/12/2014 § 2-139. Ground aircraft operations. 1999-60, § 6 11/30/1999 § 2-140. Ground vehicle operations. 2014-25, § 13 8/12/2014 § 2-141. Commercial operations. 1999-60, § 6 11/30/99 § 2-142. Fire and safety regulations. 2019-16 , § 7 5/21/2019 § 2-143. Minimum standards. 2002-15, § 12 5/14/2002

As can be seen, Division 1 was last updated in 2019 with the adoption of Ordinance No. 2019-16 which addressed Sec. 2-142. - Fire and safety regulations.

http://broward.elaws.us/code/coor_ch2_artv_div1

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Access to the HWO Rules and Regulations require navigating through the County’s Code of Ordinances and is not readily available to airport tenants and users. 12 Currently, there is no link to the HWO Rules &

Regulations 13 on the Airport’s website or for downloading a consolidated copy of the Rules & Regulations for reference.

Reviewing the HWO’s Rules and Regulations, safety-related provisions that specifically pertain to the operation of aircraft include:

Sec. 2-137. - General use restrictions.

(b) Multi-engine Aircraft. Multi-engine aircraft shall not make simulated engine out takeoffs, landings, approaches, or go-arounds.

(d) Modified Aircraft. The operation, keeping or storage of aircraft which has been modified or is being modified not in conformity with published FAA airworthiness standards is prohibited without the prior written approval of the Airport Manager. Such aircraft may be allowed if an application has been submitted to the FAA for approval of such modification.

Sec. 2-138. - Airport operations area.

(a) Runway in Use. Runway in use will be indicated by the Control Tower. When the Control Tower is not in operation, the lighted runway most nearly aligned with the wind shall be used.

(b) Takeoff Patterns. On takeoff, aircraft shall clear the boundary of the Airport and climb to an altitude of four hundred feet (400) before making the first turn.

(c) Right-of-Way. During the periods the Control Tower is not in operation, landing traffic shall have the right-of-way.

(d) Local Flights. Flights around the Airport shall conform to local traffic patterns. Acrobatics are prohibited over the Airport.

(e) Exceptions to Runway Takeoffs. With the exception of rotor craft and special purpose aircraft such as banner-tow operators specifically authorized to use turf areas, landings and takeoffs shall be conducted from the runways only.

(f) Intersection Takeoffs. No intersection takeoffs shall be made from the runway except when authorized by the Control Tower.

(g) Prohibited Operations. Glider, parachuting, hot air balloon, and ultra-light vehicle operations are prohibited.

12 Note: Access to the County Code is very difficult within the Broward.org website. It was much easier to enter a browser search externally to access the specific ordinance.

13 Available at http://broward.elaws.us/code/coor_ch2_artv_div1 http://broward.elaws.us/code/coor_ch2_artv_div1

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(j) Downwind Taxiing. Downwind taxiing on the runway or stopping on the runway in use to brief students is prohibited unless authorized by the Control Tower.

(k) Aircraft Crossing Movement Area. It shall be the duty of the pilot to observe traffic and obtain clearance from the Control Tower prior to taxiing on or across any taxiway or runway. Pilots shall contact the Control Tower for clearance during operational hours. When the Control Tower is not in operation, aircraft shall come to a complete stop and the pilot shall visually check in all directions prior to proceeding.

(l) Operations When Control Tower is Closed. During the periods when the Control Tower is not in operation, use of the appropriate Common Traffic Advisory Frequency (CTAF) to blind broadcast the position and or intentions of the pilot is recommended. Pilots are to listen for other aircraft that may be broadcasting in the blind. All pilots are to proceed with caution in the event other aircraft are not complying with recommended blind broadcast procedures. In addition, during periods when the Control Tower is not operational, no person or vehicle shall proceed onto the movement area, without first obtaining specific authorization from the Department, determining that no aircraft is approaching, and announcing his or her intention on the CTAF. Any movement on the runway or taxiway shall be made as expeditiously as possible.

While the intent of these regulations are clear, the ability to enforce some may be questionable and in cases where a specific regulation has been violated, the punitive or corrective action may be pre-empted by FAA.

1. BCAD should publish and post a document containing the rules and regulations available for downloading directly from the Airport’s website.

2. BCAD should consider reviewing and expanding the set of rules and regulations to enhance the guidance and direction for the safe, orderly, and efficient operation and use of the Airport.

Enforceability of specific regulations and due process for handling violations should be considered in the review.

Minimum Standards

The Minimum Standards for Commercial Aeronautical Activities for HWO were developed in part to promote fair business practices and non-discrimination and also to protect the interests of the Airport's existing and future business operators. They are designed to ensure that providers of commercial aeronautical services are qualified and capable to offer their services to the general public. A copy of the

Minimum Standards for Commercial Aeronautical Providers can be found in Attachment 5.

BCAD’s Minimum Standards appear to have last been updated in 2013, although the version available online has a 9/18/09 date in the footer.

The Minimum Standards cover the following commercial aeronautical services:

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Fixed Base Operators (FBOs)

Minimum Operating Service Standards

a. Aircraft Guidance, Parking & Tie-down Services

b. Retail Aviation Fuel Sales

c. Line Services

d. Aircraft Storage

e. Aircraft Maintenance & Repair Station

f. Flight Planning and Flight Service Facilities

g. Public Amenities.

h. Removal of Disabled Aircraft

i. Optional Permitted Services

Specialized Aviation Service Operators (SASOs)

a. Aircraft maintenance and repair

b. Avionics and instrument repair

c. Propeller repair

a. Aircraft painting

b. Aircraft upholstery

c. Aerial advertising

d. Flight training school

e. Aircraft rental

f. Non-scheduled and air charter services for transporting passengers, cargo, and mail

g. Aircraft sales & leasing

h. Aerial survey, photography, and mapping

i. Aerial ambulance

j. Aircraft storage and hangar rentals

k. Flying Clubs [new]

Full-service FBOs are generally required to provide all the services listed but there is a provision that each service can be listed (or omitted) by specifying such in the lease agreement. For example, most of the commercial service operators who are listed as FBOs generally offer retail fuel services but do not include aircraft maintenance and repair (or certified by FAA under Part 145 as a repair station).

As fuel providers, FBOs are not required by the Minimum Standards to demonstrate to BCAD that they follow basic quality control measures to ensure the bulk fuel delivered has been appropriately tested and is free from contamination. FBO’s are also required to provide “fully trained and qualified staff” to fuel an aircraft however, there are no specific requirements for what are the qualifications for a fully-trained person to fuel aircraft.

A Specialized aeronautical service operator (SASO) is an enterprise that offers one or two of the services listed in the Minimum…