FCT ALI RFI Questions.pdf

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FAA Contract Tower (FCT) Aviation Liability Insurance- Request for Information (RFI)
Solicitation number
FCTALI-RFI-27
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This is a Request for Information (RFI) from the Federal Aviation Administration (FAA) regarding aviation liability insurance for FAA Contract Tower (FCT) operations that may incorporate emerging Digital Tower technology.

The RFI contains ten questions directed at insurance providers to gather market information on the feasibility, underwriting requirements, and pricing considerations for aviation liability coverage as Digital Tower systems are developed and potentially deployed at non-federal and FAA Contract Tower facilities. Key topics addressed include: insurability and coverage limitations for Digital Tower air traffic control services; unique liability exposures compared to conventional towers, including technology-dependent risks such as equipment failures, communication disruptions, and loss of visual information; underwriting information requirements related to FAA approvals, operational procedures, system reliability, and contractor responsibilities; coverage structure and liability allocation when air traffic control services are performed by one contractor using technology owned or operated by another entity; options and procedures for extending coverage to Digital Tower operations during the anticipated contract period; cyber risk evaluation methodologies; fail-safe and backup power requirements; training certification mandates; premium pricing comparisons between digital and traditional tower operations; and policy structuring for hybrid or phased transitions from brick-and-mortar to digital tower operations to avoid coverage gaps or duplicate premiums. The RFI does not establish contract requirements, pricing terms, response deadlines, or award information, and serves solely to solicit industry input on insurance market capacity and conditions for this emerging operational technology.

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FCT ALI SOW _Section C_Draft.pdf PDF

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REQUEST FOR INFORMATION (RFI)

FAA Contract Tower (FCT) Aviation Liability Insurance Contract

Questions

1. Insurability of Emerging Digital Tower Operations: Because of the FAA's ongoing development and approval of Digital Tower systems for use at non-federal and FAA Contract Tower facilities, would your organization be able to provide aviation liability insurance coverage for air traffic control services conducted using this technology?

Please identify any anticipated limitations or conditions affecting coverage availability.

For reference, information concerning the FAA’s Digital Tower plans can be found at this link:

https://www.faa.gov/airports/planning_capacity/non_federal/digital_tower_systems

2. Potential Liability Exposure and Coverage Considerations: What additional or unique liability exposures would your organization anticipate with Digital Tower operations compared with conventional air traffic control towers? Please identify any potential coverage limitations, exclusions, or special conditions associated with technology-dependent operations, including equipment failures, loss of visual information, or communication disruptions.

3. Underwriting Information and Risk Assessment: What information would your organization require to evaluate aviation liability insurance coverage for Digital Tower operations? Please identify any anticipated underwriting considerations related to FAA approvals, operational procedures, safety assessments, system reliability, contingency procedures, or contractor responsibilities.

4. Coverage Structure and Allocation of Liability: How would your organization approach aviation liability coverage where air traffic control services are performed by one contractor using Digital Tower technology owned, operated, maintained, or supported by another entity? Please identify any anticipated considerations regarding allocation of liability, additional insured parties, policy exclusions, or coordination with other insurance coverage.

5. Future Coverage and Pricing Considerations: If Digital Tower operations are introduced at one or more FAA Contract Tower facilities during the anticipated contract period, what options might be available to extend aviation liability insurance coverage to those operations? Please describe any anticipated underwriting process, potential impacts on premiums or policy terms, and information needed to develop pricing once the operational requirements are defined.

6. Technology: How do underwriters evaluate the risk of a digital tower regarding cyber threats, data breaches, software glitches, or temporary network outages compared to a physical tower?

7. Technology: What specific fail-safe or backup power requirements do insurers expect to see in place to mitigate the risks of camera, sensor, or display degradation?

8. Operations: Are there any specific training certification requirements for digital tower operations do underwriters mandate to qualify for liability insurance?

9. Cost / Market: Based on current market trends, how does the premium pricing model structure for a digital tower compares to a traditional brick-and-mortar tower handling similar traffic volumes?

10. SOW: During a phased transition from a brick-and-mortar tower to a digital tower at a single airport, how should concurrent or hybrid operations be structured within the policy to avoid coverage gaps or double-premium exposure?

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