ADVISORY

CIRCULAR
CAA-AC-GEN029
April 2018

REDUCED VERTICAL SEPARATION MINIMUM (RVSM)

1.0 PURPOSE

This Advisory Circular (AC) provides information and guidance material that should be used by air
operator certificate (AOC) holders to ensure compliance with RVSM regulatory requirements. The
AC also provides background information for operators to assist them in ensuring they meet
continuing airworthiness requirements for RVSM approved aircraft and operations requirements for
flight in RVSM airspace.

2.0 REFERENCE

2.1 Civil Aviation (Instruments and Equipment) Regulations, as amended

Civil Aviation (Operation of Aircraft- Commercial Air Transport) Regulations, 2018,

Regulation 7and 131, 132

2.2 FORM: AC-OPS029 - RVSM Application Form

2.3 ICAO Doc 9574 — Manual on 300 m (1 000 ft) Vertical Separation Minimum Between FL
290 and FL 410 Inclusive;

2.4 Joint Aviation Authority (JAA) Temporary Guidance Leaflet (TGL) No. 6 — Guidance
Material on the Approval of Aircraft and Operators for Flight in Airspace above Flight Level
290 where a 300 m (1 000 ft) Vertical Separation Minimum is Applied — or any subsequent
version thereof;

2.5 Federal Aviation Administration (FAA) Document 91-RVSM, Guidance Material on the
Approval of Operators/Aircraft for RVSM Operations, as amended.

3.0 INTRODUCTION

Civil Aviation (Operation of Aircraft- Commercial Air Transport) Regulations, 2018, Regulation 131
(7) requires that prior to granting (RVSM) approval the Authority shall be satisfied that-

(a) the vertical navigation performance capability of the aircraft satisfies the requirements of
the altimetry system performance for operations in RVSM airspace as prescribed by the
Authority;

(b) the operator has instituted appropriate procedures in respect of continued airworthiness
(maintenance and repair) practices and programmes; and

CAA-AC-GEN029 APRIL 2018 Page 1 of 13

 (c) the operator has instituted appropriate flight crew procedures for operations in RVSM
airspace.

In addition Civil Aviation (Operation of Aircraft- Commercial Air Transport) Regulations, 2018,
Regulation 132 (1) requires that a minimum of two aeroplanes of each aircraft type grouping of the
owner or operator have their height-keeping performance monitored, at least once every two years or
within intervals of 1, 000 flight hours per aeroplane, whichever period is longer.

4.0 TERMINOLOGY

4.1 Definitions

The following definitions are intended to clarify certain specialized terms used in this manual.

Aberrant aircraft. Those aircraft which exhibit measured height-keeping performance that is
significantly different from the core height-keeping performance measured for the whole population
of aircraft operating in RVSM airspace.

Aircraft type groupings. Aircraft are considered to belong to the same group if they are designed and
assembled by one manufacturer and are of nominally identical design and build with respect to all
details which could influence the accuracy of height-keeping performance.

Airworthiness approval. The process of assuring the State authority that aircraft meet an RVSM
MASPS. Typically, this would involve an operator meeting the requirements of the aircraft
manufacturer service bulletin for that aircraft and having the State authority verify the successful
completion of that work.

Altimetry system error (ASE). The difference between the altitude indicated by the altimeter
display, assuming a correct altimeter barometric setting, and the pressure altitude corresponding to the
undisturbed ambient pressure.

Altimetry system error stability. Altimetry system error for an individual aircraft is considered to be
stable if the statistical distribution of altimetry system error is within agreed limits over an agreed
period of time.

Altitude-keeping device. Any equipment which is designed to automatically control the

aircraft to a referenced pressure altitude.

Assigned altitude deviation (AAD). The difference between the transponder Mode C altitude and the
assigned altitude/flight level.

Automatic altitude-keeping device. Any equipment which is designed to automatically control the
aircraft to a referenced pressure-altitude.

Collision risk. The expected number of mid-air aircraft accidents in a prescribed volume of airspace
for a specific number of flight hours due to loss of planned separation.

Note.— One collision is considered to produce two accidents.

Flight technical error (FTE). The difference between the altitude indicated by the altimeter display
being used to control the aircraft and the assigned altitude/flight level.

CAA-AC-GEN029 APRIL 2018 Page 2 of 13

Height-keeping capability. The aircraft height-keeping performance that can be expected under
nominal environmental operating conditions with proper aircraft operating practices and maintenance.

Height-keeping performance. The observed performance of an aircraft with respect to adherence to

cleared flight level.

Non-compliant aircraft. An aircraft configured to comply with the requirements of an RVSM

MASPS which, through height monitoring, is found to have a total vertical error (TVE) or an assigned
altitude deviation (AAD) of 90 m (300 ft) or greater or an altimetry system error (ASE) of 75 m (245
ft) or more.

Operational error. Any vertical deviation of an aircraft from the correct flight level as a result of
incorrect action by air traffic control (ATC) or the aircraft crew.

Overall risk. The risk of collision due to all causes, which includes the technical risk (see definition)
and all risk due to operational errors and in-flight contingencies.

RVSM approval. The term used to describe the successful completion of airworthiness requirements
and operational approval (if required).

Target level of safety (TLS). A generic term representing the level of risk which is considered
acceptable in particular circumstances.

Technical risk. The risk of collision associated with aircraft height-keeping performance.

Total vertical error (TVE). The vertical geometric difference between the actual pressure altitude
flown by an aircraft and its assigned pressure altitude (flight level).

Vertical separation. The spacing provided between aircraft in the vertical plane to avoid collision.

Vertical separation minimum (VSM). VSM is documented in the Procedures for Air Navigation
Services — Air Traffic Management (PANS-ATM, Doc 4444) as being a nominal 300 m (1 000 ft)
below FL 290 and 600 m (2 000 ft) above FL 290 except where, on the basis of regional agreement, a
value of less than 600 m (2 000 ft) but not less than 300 m (1 000 ft) is prescribed for use by aircraft
operating above FL 290 within designated portions of the airspace.

4.2 Acronyms and Abbreviations

AAD assigned altitude deviation

ACAS airborne collision avoidance system

ACC area control centre

ADS-B automatic dependent surveillance–broadcast

ASE altimetry system error

ATC air traffic control

ATS air traffic services

CAA-AC-GEN029 APRIL 2018 Page 3 of 13

CFL cleared flight level

FAA Federal Aviation Administration

FL flight level

FTE flight technical error

GMS GPS-based monitoring system

GMU GPS-based monitoring unit

GPS global positioning system

HMU height-monitoring unit

JAA Joint Aviation Authority

MASPS minimum aircraft system performance specification

MNPS minimum navigation performance specification

NAT North Atlantic

RMA regional monitoring agency

RVSM reduced vertical separation minimum

SMS safety management system

SSE static source error

SSR secondary surveillance radar

TLS target level of safety

TVE total vertical error

VSM vertical separation minimum

CAA-AC-GEN029 APRIL 2018 Page 4 of 13

5.0 AIRWORTHINESS APPROVAL

5.1 RVSM MASPS

Airworthiness approval must in all cases be in accordance with the requirements of the RVSM
MASPS. As stated in ICAO Doc 9574 Chapter 3, the RVSM MASPS, in addition to characterizing
the ASE and automatic height-keeping capability requirements, also contains specifications and
procedures for type approval and continued airworthiness.

All approvals will be applicable to an individual aircraft or to a group of aircraft, that are nominally
identical in aerodynamic design and items of equipment contributing to height-keeping accuracy.

5.2 Definition of aircraft type groupings

For aircraft to be considered as part of a group for the purposes of airworthiness approval, the
following conditions should be satisfied:

a) the aircraft should have been constructed to a nominally identical design and should be approved
on the same Type Certificate (TC), TC amendment, or Supplemental TC, as applicable;

b) the static system of each aircraft should be nominally identical. The static source error (SSE)
corrections should be the same for all aircraft of the group; and

c) the avionics units installed on each aircraft to meet the minimum RVSM equipment criteria should
comply with the manufacturer’s same specification and have the same part number.

Note: Aircraft that have avionics units which are of a different manufacturer or part number may be
considered part of the group if it can be demonstrated that this standard of avionics equipment
provides equivalent system performance.

If an airframe does not meet the above conditions to qualify as a part of a group, and is presented as
an individual airframe for approval, it will be considered to be a non-group aircraft. The significance
of this is that the certification processes for group and non-group aircraft are different.

5.3 Continued airworthiness

5.5 It is imperative that all aircraft continue, during their service life, to satisfy the requirements of the
RVSM MASPS. While height-monitoring data from independent sources, as recommended by ICAO,
should help to detect any long-term deterioration in altimetry system performance, it is nevertheless
essential that certifying authorities ensure that, as part of the approval process, operator maintenance
and inspection practices are reviewed and updated to reflect the specific airworthiness requirements
applicable to RVSM operations.

5.4 Responsibilities

Operators will ensure they submit aircraft, maintenance programmes together with the RVSM
operations documentation to enable the Authority’s issuance of OpSpecs authorizing the operator to
conduct flight in RVSM airspace.

CAA-AC-GEN029 APRIL 2018 Page 5 of 13

The operator shall submit the RVSM application and all aircraft eligibility documents, evidence of
capability of operating and an RVSM maintenance programme for maintaining each aircraft or
aircraft group to which the application relates for approval.

5.5 Aircraft Compliance

An aircraft may be authorized to conduct RVSM operations if the Authority finds that it complies
with the RVSM requirements as set out in this AC. The operator shall ensure all relevant Service
Bulletins (SB), Service Letters (SL), or Supplemental Type Certificates (STC), which apply to the
specific aircraft type or group as applicable have been complied with.

Aircraft compliance review - the operator shall be required to demonstrate the following through the
aircraft’s RVSM documentation:

(a) In-Service Aircraft. inspections and/or modifications required for aircraft compliance have
been performed and documented;

(b) Equipment. the aircraft has the required equipment in accordance with Reg. 17 of the Civil
Aviation (Instruments and Equipment) Regulations.

(c) In-Production or New Production Aircraft. RVSM compliance is stated in the aircraft
flight manual (AFM) or aircraft Type Certificate Data Sheet (TCDS).

3.3.3 The RVSM compliant aircraft equipment shall include at least the following:

(i) Two independent altitude measurement systems. Each system should include:

a) Cross-coupled static source/system, with ice protection if located in areas subject to ice
accretion.

b) Equipment for measuring static pressure sensed by static source, conveying it to pressure
altitude and displaying the pressure altitude to the flight crew.

c) Equipment for providing a digitally encoded signal corresponding to the displayed pressure
altitude, for automatic altitude reporting purposes.

d) Static source error correction (SSES).

e) Signals referenced to a pilot selected altitude for automatic control and alerting.

(ii) One secondary surveillance radar transponder with an altitude reporting

System that can be connected to the altitude measurement system in use for

altitude keeping.

(iii) An altitude alerting system.

(iv) An automatic altitude control system.

CAA-AC-GEN029 APRIL 2018 Page 6 of 13

5.6 RVSM Maintenance Programme

The RVSM maintenance programme shall outline procedures to maintain aircraft in accordance with
the requirements. The approved RVSM maintenance programme may be a stand-alone or part of the
standard aircraft maintenance programme.

RVSM maintenance programme elements should be specific to the operator and aircraft for which
they are approved and are not transferable.

Each RVSM maintenance programme shall include the following:

(a) Identification of components considered to be RVSM critical, and identification of structural

areas noted as RVSM critical areas;

(b) The name or title of the responsible person who will ensure that the aircraft is maintained in
accordance with the approved programme;

(c) The method the operator will use to ensure that all personnel performing maintenance on the
RVSM system are properly trained, qualified, and knowledgeable of that specific system;

(d) The method the operator will use to notify the crew if the aircraft has been restricted from
RVSM but is airworthy for an intended flight;

(e) The method the operator will use to ensure conformance to the RVSM maintenance
standards, including the use of calibrated and appropriate test equipment and a quality assurance
programme for ensuring continuing accuracy and reliability of test equipment, especially when
outsourced;

(f) The method the operator will use to verify that components and parts are eligible for
installation in the RVSM system, as well as to prevent ineligible components or parts from being
installed;

(g) The method the operator will use to return an aircraft to service after maintenance has been
performed on an RVSM component/system or after the aircraft was determined to be non-compliant;

(h) Periodic inspections, functional flight tests, and maintenance and inspection procedures with
acceptable maintenance practices for ensuring continued compliance with the RVSM aircraft
requirements;

Note 1: These elements may be listed in detail or described by reference to an acceptable

programme that is identified and controlled by revision or issue number.

Note 2: The need for functional flight tests may be limited to only after repairs or modifications
that are deemed to warrant such testing and may be accomplished through monitoring height-
keeping performance

(i) The maintenance requirements listed in Instructions for Continued Airworthiness (ICA)
associated with any RVSM associated component or modification;

(j) Any other maintenance requirement that needs to be incorporated to ensure continued
compliance with RVSM requirements.

CAA-AC-GEN029 APRIL 2018 Page 7 of 13

6.0 OPERATIONAL APPROVAL

6.1 Where RVSM is applied, the specific aircraft type or types that the operator intends to use will
need to be approved by the Authority. RVSM approval will encompass the following elements:

a) Airworthiness approval (including continued airworthiness) process. The aircraft will be approved
as meeting the requirements of the appropriate State airworthiness document derived from the height-
keeping capability requirements as defined by the airworthiness certification requirements.
Furthermore, the aircraft altimetry and height-keeping equipment must be maintained in accordance
with approved procedures and servicing schedules; and

b) Operational approval process. In addition to the airworthiness process described above an operator
is required to meet Operational Approval requirements to be allowed to operate in RVSM airspace.
Achievement of operational approval requirements will culminate in issuance of RVSM approval in
the applicable aircraft type Operations Specifications

6.2 Validity of approval

RVSM approval issued for one region (or state) will always be valid for RVSM operations in another
region (or state) provided specific restrictions have not been imposed on the operator by the State of
the Operator or State of Registry.

6.3 Confirmation of approval status

Continuity of RVSM operations is dependent on the establishment of an aircraft approval

confirmation process by the Authority, which is intended to exclude unqualified aircraft and operators
from operating in RVSM airspace unless the appropriate separation is applied.

A secondary responsibility rests with the air traffic services (ATS) provider States to institute routine
checks of the approval status of aircraft operating within their area of authority and intending to
operate in RVSM airspace.

Depending on State regulations, ATC clearances may be withheld for operations that are not in
compliance with the airspace requirements.

In conjunction with the ATS provider, a further level of confirmation of approval can be affected by
the Regional Monitoring Agency (RMA) of a region in which RVSM applies. This can be achieved
by the RMA taking action, following a query by a controlling authority, to obtain confirmation of
approval status from the State of the Operator/State of Registry of aircraft which are not listed in an
RVSM-approvals database.

7.0 PROCEDURES

7.1 Cruising levels

The table of cruising levels specified in Appendix 3 of Annex 2 to the Convention on International
Civil Aviation, for use in RVSM airspace, shall be used.

7.2 Flight Crew Operating Procedures

In-flight procedures

CAA-AC-GEN029 APRIL 2018 Page 8 of 13

2.1 Generally, flight crew operating procedures in RVSM airspace are no different from those in any
other airspace; however, the continuity of RVSM operations will require periodic review of
procedures specific to a region, e.g. contingency procedures, and should be reflected in regional
documentation.

Given the safety requirements and the effect large height deviations could have on the risk levels,
crews should be reminded to exercise vigilance to minimize the occurrence of deviations from the
cleared flight level. To this end, during routine training, flight crews should be reminded of the
importance of adhering to the following in-flight procedures:

a) in level cruise it is essential that the aircraft be flown at the cleared flight level (CFL). This requires
that particular care be taken to ensure that ATC clearances are fully understood and complied with.
Except in the event of an emergency, the aircraft should not intentionally depart from CFL without a
clearance from ATC;

b) during cleared transition between levels, the aircraft should not be allowed to overshoot or
undershoot the new flight level by more than 45 m (150 ft);

Note: The transition should be accomplished using the altitude capture feature of the automatic
altitude-keeping device, if installed.

c) an automatic altitude-keeping device should be operative and engaged during level cruise, except
when circumstances such as turbulence or the need to re-trim the aircraft require its disengagement.

In any event, adherence to cruise altitude should be done by reference to one of the two altimeters
required by the RVSM MASPS;

d) the altitude-alerting device should be operating and engaged;

e) regular (hourly) cross-checks between the altimeters should be made, and a minimum of two
RVSM compliant systems must agree within 60 m (200 ft). Failure to meet this condition will require
that the system be reported as defective and notified to ATC;

f) the operating altitude-reporting transponder should be connected to the RVSM MASPS-compliant

altimetry system being used to control the aircraft;

g) before entering RVSM airspace, the pilot should review the status of equipment required. The
following equipment should be operating normally:

i. two altitude measurement systems, as defined by the RVSM aircraft systems specifications;
ii. automatic altitude-keeping device(s);
iii. at least one altitude-reporting transponder (if required for operation in that specific RVSM
airspace) capable of being switched to operate from either of the two altimetry systems
required by the RVSM aircraft systems specifications; and
iv. one altitude-alerting device;
Should any of this equipment fail prior to the aircraft entering RVSM airspace, the pilot should
request a new clearance so as to avoid flight in this airspace;

h) the following contingency procedures should be adhered to after entering RVSM airspace:

i. the pilot should notify ATC of contingencies (equipment failures, weather conditions) in
which the ability to maintain CFL is affected and coordinate a plan of action ;

CAA-AC-GEN029 APRIL 2018 Page 9 of 13

 ii. equipment failures should be notified to ATC. Some examples are:

- failure of all automatic altitude-keeping devices on board the aircraft;

- ii) loss of redundancy of altimetry systems, or any part of these, on board the aircraft;
- iii) failure of all altitude-reporting transponders;
- iv) loss of thrust on an engine necessitating descent; and
- v) any other equipment failure affecting the ability to maintain CFL;
iii. the pilot should notify ATC when encountering severe turbulence; and

iv. if unable to notify ATC and obtain an ATC clearance prior to deviating from the assigned
CFL, the pilot should follow established contingency procedures as defined by the region of
operation and obtain ATC clearance as soon as possible.
7.3 Operations manual

Where applicable, aircraft operators should revise their operations manuals to reflect any differences
in standard operating procedures that result from operation in RVSM airspace.

7.4 ATC Procedures

7.4.1 General

3.1 The continuity of RVSM operations safely in relation to the provision of air navigation services
requires that ATC procedures be periodically reviewed and appropriate recurrent training provided.
As a basis for the periodic review of regional procedures, consideration should be given to the
appropriate action to be taken by controllers in the following situations, as applicable:

a) aircraft known not to be suitably equipped are flight planned into RVSM airspace;

b) an aircraft informs ATC that the capability to maintain a CFL appropriate to RVSM requirements
has been lost;

c) the pilot advises that the automatic altitude-keeping device has been turned off; and

d) the displayed altitude differs from the CFL by 90 m (300 ft) or more.

Note 1: While not necessary to support RVSM operations, the availability of altitude display is
beneficial.

Note 2: Surveillance systems should be capable of supporting RVSM operations.

7.4.2 ATC contingency procedures

In addition to emergency conditions that require immediate descent, such as loss of thrust or
pressurization, ATC shall be made aware of any conditions that may make it impossible for an aircraft
to maintain its CFL. Controllers should be trained regarding the appropriate action to take in the event
that they are notified by the pilot of any such condition, as described above. Suggested actions in the
event of such an occurrence are:

a) obtain the pilot’s intentions;

CAA-AC-GEN029 APRIL 2018 Page 10 of 13

b) assess the traffic situation to determine if the aircraft can be accommodated through the provision
of lateral, longitudinal or increased vertical separation and, if so, apply the appropriate minimum;

c) when the aircraft cannot be accommodated in accordance with b), ascertain if the aircraft can
maintain altitude in accordance with the requirements applicable below RVSM airspace. If so, and if
the pilot confirms it to be operationally feasible, the controller should issue a revised clearance to a
level outside RVSM airspace when traffic permits; and

d) handle aircraft that cannot be accommodated in accordance with either b) or c) as an emergency

and take whatever action is necessary to provide the appropriate separation.

7.4.2 RVSM Phraseology

Flight crew should report RVSM approved status with ‘Affirm RVSM’ and report RVSM non-
approved with ‘Negative RVSM’ followed by reason.

Flight crew denying ATC clearance into RVSM should state ‘Unable RVSM’ followed by the reason,
for example ‘Unable RVSM due turbulence’ or ‘Unable RVSM due equipment’.

Flight crew able to resume RVSM should use the phrase ‘Ready to resume RVSM’.

ATC should be informed when a non-RVSM approved State aircraft is requesting climb into RVSM
airspace thus ‘…Request FL330, Negative RVSM’.

If able, ATC will give the clearance as follows ‘…Climb to FL 330, Negative RVSM’. Notice that
the term ‘Negative RVSM’ is used in the clearance and the read-back, thus ‘Climb to FL 320,
Negative RVSM…’. Otherwise ATC will state that they are unable to issue the clearance into RVSM
airspace.

7.5 Meteorological conditions

7.5.1 Meteorological conditions that can cause turbulence which can be detrimental to accurate
height-keeping include:

a) gravity shear waves;

b) thunderstorms;

c) orographic flow.

7.5.2 Orographic flow, more commonly known as mountain wave activity, has been identified as
being particularly detrimental to accurate height-keeping. Prior to implementation of RVSM, States
known to have airspace susceptible to orographic flow should:

a) assign responsibility for forecasting such conditions; and

b) detail the action required by ATC on receipt of such forecasts.

7.5.3 When reports of severe turbulence are received, ATC must ascertain the capability of the
aircraft to maintain CFL. Upon confirmation that meteorological conditions are affecting, or are likely
to affect, height-keeping accuracy, ATC should be required to provide alternative separation as soon

CAA-AC-GEN029 APRIL 2018 Page 11 of 13

as possible. Additionally, when any significant meteorological conditions are expected to prevail over
an area for an extended time period, the appropriate ATC authority should consider:

a) issuing a NOTAM specifying the routes or area affected; and

b) temporarily suspending the use of 300 m (1 000 ft) VSM in the affected area.

Application Documentation

The operator should submit an application letter with completed FORM: KCAA/FOPS/RVSM/001.
This should be accompanied by an application package of relevant documents and revisions including
the following:

a) Airworthiness documents - Documentation that shows that the aircraft has RVSM
airworthiness approval. This should include an aircraft flight manual (AFM) amendment or
supplement;
b) Description of aircraft equipment - A description of the aircraft appropriate to operations in
an RVSM environment;
c) Training programmes, operating practices and procedures - The operator should submit
training syllabi for initial and recurrent training programmes together with other relevant
material. The material should show that the operating practices, procedures and training
items, related to RVSM operations in airspace that requires State operational approval, are
incorporated;
d) Procedure Manuals - The appropriate manuals (and checklists as applicable) should be
revised to include information/guidance on standard operating procedures. Manual references
should include any RVSM operating limitations or conditions established for that aircraft
type. Manuals and checklists may need to be re-submitted for review by the competent
authority as part of the application process;
e) Past performance - Relevant height-keeping performance history, where available, should be
included in the application. This should include any required changes that have been made in
training, operating or maintenance practices to improve height keeping;
f) Minimum equipment list (MEL) - A minimum equipment list (MEL), adapted from the
master minimum equipment list (MMEL), should include items pertinent to operating in
RVSM airspace;
g) Participation in height keeping monitoring programmes. The operator should establish a plan
for participation in an RVSM monitoring programme acceptable to the competent authority.
This plan should include, as a minimum, a check on a sample of the operator's fleet by the
AFI regional monitoring agency (ARMA)’s independent height-monitoring system; and
h) Continuing airworthiness - Aircraft maintenance programme and continuing airworthiness
procedures in support of the RVSM operations.

CAA-AC-GEN029 APRIL 2018 Page 12 of 13

 Kenya Civil Aviation Authority

CAA-AC-GEN029 APRIL 2018 Page 13 of 13