The airport’s checkride

Some years ago, my wife and I attended a fly-in at a friend’s farm in the Sacramento Valley. As we landed on his beautifully-manicured grass strip, it appeared that the runway edge markings were waving at us.

Slowing to turn off, the illusion became clear. The edge markings actually WERE waving — they consisted of dozens of inflated white disposable rubber gloves tied to small tent stakes, fingers pointing to the sky and swaying merrily in the breeze.

While certainly effective at marking the runway edges, the rubber gloves fell far short of FAA standards for runway markings. Guidance for maintaining runway markings and the Runway Safety Area, along with nearly two dozen other standards, are found in 14 CFR Part 139, “Certification of Airports.”

As pilots, we know the FAA rules and regulations that govern our flying activities. These rules (Parts 61, 91, 135, etc.) are “parts” of Title 14 of the Code of Federal Regulations, which encompasses the realm of Aeronautics and Space. Like our flight rules, Part 139 regulates the certification and operation of airports that serve air carrier aircraft. And just like pilots, airports have to go through something similar to a checkride.

Part 139 applies to all airports in the U.S. that are served by scheduled air carrier aircraft with more than nine seats, or unscheduled air carriers (charter flights) with at least 31 seats. To earn an operating certificate authorizing the airport to serve these aircraft, airport management must produce and present to the FAA their very own Airport Certification Manual (ACM), a lengthy tome that describes in detail how the airport will comply with all the requirements of Part 139. It’s the “Pilot’s Operating Handbook” for the airport.

The ACM at the airport where I work has 23 chapters, three appendixes, multiple exhibits, and is slightly thinner than the Manhattan phone book. (Anyone remember phone books?) 

So if you fly into an airport serving air carriers — whether your mount is an Aerobat or an Airbus — that airport is held to the Federal standards in Part 139.

A general aviation airport receiving state funds is held to state standards. 

Private airports, like my friend’s grass strip, are normally not regulated by the FAA and are held to varying state standards depending on their location. As the Aircraft Owners and Pilots Association (AOPA) says, “The prevailing rule about private airports is that there is no prevailing rule.”

Are you with us so far? Don’t worry, you won’t be tested.

The test comes for managers of air carrier airports during our annual periodic certification inspection. During this inspection the FAA verifies the airport is complying with procedures in its ACM, meeting Part 139 standards, and is worthy of serving the flying public.

Similar to a pilot’s checkride, our inspection covers a review of paperwork and a “practical test.” The inspector is guided by a formal checklist, covering 23 areas and 124 items that are examined over the course of several days. 

The checkride

We begin with an in-brief between the inspector (or at larger airports, a team of inspectors) and airport management. Our inspector will lay out his plan of events, including when he will review airport records, conduct the physical inspection of the airfield (both day and night), visit the Airport Rescue and Fire Fighting (ARFF) station, and inspect the fuel farm and aircraft fuel trucks. Following this in-brief, the fun begins.

The records inspection is our chance to make a good first impression. Among the 16 items reviewed are training records for ARFF personnel and other airport staff who have access to the movement areas (tower-controlled runways and taxiways). He also checks records of our required daily airfield self-inspections and maintenance actions taken to correct any problems found. Finally, fuel facility inspection records, all NOTAMS issued in the last 12 months, wildlife hazard management actions, and records of any accidents or incidents on the airport movement area all get reviewed.

As with pilot and aircraft logbooks, neatness and organization count!

The “practical test” begins with the airfield inspection. Just as the Private Pilot checkride is guided by Airman Certification Standards, this inspection is guided by standards in Part 139. Multiple FAA Advisory Circulars also provide guidance if questions arise.

Taxiways, runways, and aprons get close scrutiny to ensure the pavement is free of holes, cracks, or edge drop-offs greater than 3″ as any of these could hinder aircraft control. The airport’s FOD management practices are evaluated, as the inspector tours the airfield, scanning for any foreign objects that could damage an aircraft. We also inspect the runway for excessive rubber buildup that can obscure markings or reduce braking friction.

Runway and Taxiway Safety Areas extend well beyond pavement edges, and are designed to provide a smooth, firm surface in the event an aircraft inadvertently departs the pavement. Accordingly, they are checked for ruts, humps, holes, and proper drainage.

We also verify that nothing is located in a Safety Area unless it is necessary for aircraft navigation. REILs, PAPIs, edge lights, and some signage are all examples of allowable objects; wind indicators, stop signs, guard rails, etc., are prohibited. Any object installed in a safety area must be mounted on frangible (break-away) couplings, with the frangible point no more than 3″ above the ground.

Our inspection of airfield markings includes runway markings, taxiway markings, and holding position markings for runway entrances or ILS critical areas. The inspector checks that the marking layout meets FAA standards, and the paint is not dirty, faded, or flaking. Most markings are required to have reflective beads, and during the night inspection we ensure they “pop” in the headlights, just as they would for an aircraft.

Other items we inspect at night include taxiway and runway lights, REILS, PAPI or VASI systems, the airport beacon, and any approach lighting that the airport owns and maintains. Runway, taxiway, and apron signs also get the once over to ensure they are well-lit and clearly legible.

Finally, obstructions, such as the ILS glide slope antenna or radio transmission antennas, must be marked with red lights, and these get checked as well.

Traffic pattern indicators (segmented circle) and wind cones are inspected to be sure they are properly maintained. A segmented circle overgrown with vegetation, or a faded, torn windcone are not very helpful to pilots.  

If construction is present on the airfield, the inspector will check that lighted barricades, runway closure “Xs” and other measures are in place to provide a safe environment for aircraft.

According to the FAA advisory circular, Operational Safety on Airports During Construction, “Safety area encroachments, unauthorized and improper ground vehicle operations, and unmarked or uncovered holes and trenches near aircraft operating surfaces pose the most prevalent threats to airport operational safety during airport construction.”

Aircraft fueling safety, for obvious reasons, gets our inspector’s close attention. A visit to the fuel farm includes verifying that all warning signs and emergency fuel shutoffs are in plain view and properly labeled. Fuel tank and plumbing integrity is also checked, as is security fencing and lighting.

Aircraft fuel trucks receive individual inspections. Grounding/bonding wires, fire extinguishers, warning placards, and general condition are covered. Tires cannot have any steel tread showing (steel + pavement = sparks), and no ashtrays, lighters, or smoking materials are allowed in the trucks.

One of the most important buildings on the airport is the fire station, home to our ARFF officers and firefighting equipment. When arriving, the inspector verifies adequate staffing to meet an aircraft emergency, the firefighters are properly trained and equipped, and the fire trucks are in good working order. 

A highlight of the ARFF inspection is the no-notice emergency response drill, during which we drive the inspector to a distant taxiway or runway, phone the control tower, and brief them to pick up the crash phone and call out a simulated “Alert 3.”  

An Alert 3 is FAA code for an aircraft accident, something we hope to never experience for real. But if we do, the first fire truck must respond to an on-airport accident scene and begin discharging extinguishing agent in three minutes or less. That’s the survivability window for passengers and crew caught in a fire with the fuselage intact. All other trucks must arrive within four minutes.

Sobering stuff, and when Tower calls the simulated Alert 3, our inspector begins timing. For this pilot, it’s an emotional moment when those trucks arrive in under three minutes and begin dispensing foam and water at the “crash site.”

Following all this scrutiny, day three of the visit finds the inspector wrapping things up, and their “out-brief” is when airport management gets the verdict. 

At my airport, our president, vice president of operations and maintenance, director of public safety, airport maintenance superintendent, fire marshall and fire captains, and other managers gather for the news. We learn what we are doing well, and what needs improvement or correction. 

If the inspector finds any non-compliant conditions, the airport receives a “Compliance Letter,” identifying the problem and noting a deadline for correction. Once the condition is fixed, the airport notifies the inspector, who then issues a “Letter Acknowledging Completion of Corrective Action.”

Often, we are made aware of these issues while the inspection is in progress, and a correction is made before the inspector leaves. Some years we score 100% on the checkride and experience no discrepancies. Other years, though we always strive for perfection, some of those 124 items trips us up.  

Can an airport “bust” the checkride? 

Typically not, but there are circumstances that can prod the FAA into legal enforcement action. Among these is failure to complete a corrective action following an inspection or repeated non-compliance.

And acting in a manner contrary to regulations, falsification or altering records, and reckless conduct can all land an airport in hot water. Any of the above can lead to civil penalties, or suspension or revocation of the airport’s operating certificate.

Lest you think the annual FAA inspection is the only exam the airport must pass, Part 139 requires daily airport self-inspections — daytime as well as nighttime, if the airport has night air carrier operations. That’s 730 documented inspections in an average year. If any of our trained inspectors finds a discrepancy, they must write it up and issue a work order for correction by our maintenance department.

So that’s what Part 139 and the airport checkride is all about: The highest possible level of safety and service for pilots and passengers. During a 30-year piloting career, I mostly took this for granted. Since entering the airport management profession, I know differently — and now, so do you. 

Blue skies and tailwinds!

About the author: Following careers as a USAF and airline pilot, Jim Roberts returned home to the airport where he learned to fly as a teenager. He is now Director of Airfield Operations for the Metropolitan Knoxville Airport Authority at McGhee Tyson Airport. He enjoys traveling with his wife, flying his 1946 Globe Swift, taking aviation photos, and writing about his first love…flying.