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tow regional jets) can be identified as "MiniTug Participate in "Before Start" briefing with {Equipment #}." TBLT operator and escort, if applicable. Identify a TBLT repositioning to ATC as Act as primary communicator with ATC. "Maintenance {Equipment #}." Use proper aviation phraseology and phonetic alphabet at all times. Use satisfactory speech (slowly and clearly). 7.4Contingencies Apply brakes in case of an emergency and The TBLT operator should use a headset if when directed to do so by the TBLT operator ambient noise is too loud. Monitor aircraft brakes hydraulic pressure A backup form of communication with ATC (FAA AC 00-65). should be provided. A communications plan should include con- 8.3Towbarless Tractor Operator tingencies in case of lost communications. The TBLT operator has the following responsi- bilities: 7.5Emergencies Use a checklist (FAA AC 00-65). The TBLT operator and/or flight deck observer Acknowledge ATC instructions through read may communicate directly with ATC in case of an back procedures with the flight deck observer. emergency. Operate the TBLT in safe manner (FAA AC 00-65). Ensure placards specified in Section 4.8 are 8Operator Responsibilities visible inside the cab, check for temporary This section sets forth the responsibilities of all placards (FAA AC 00-65). parties involved in TBLT operations. Ensure equipment is serviceable and func- tioning properly before starting tow. Provide a "Before Start" briefing to the tow 8.1TBLT Owner team. When the TBLT owner is an aircraft operator Ensure compliance with aircraft lighting under Title 14 CFR Parts 91, 91K, 121, 125, requirements (FAR 91). Ensure ATC clearance is obtained prior to 129, and 135, it must establish guidance that entering the movement area. clearly defines duties and responsibilities and Ensure ATC clearance is clearly understood employs the use of a checklist. and acknowledged with flight deck observer. The TBLT owner should submit procedures Perform pre-tow circle check: to the Certificate Holder District Office Ensure all equipment and personnel are (CHDO), including at least (FAA AC 00-65): clear of the airplane prior to tow. Safety instructions, Check with flight deck observer that ad- Operating procedures (including day vs. equate hydraulic pressure has built up for night), aircraft brakes. Initial and recurrent training, Check proper positioning of torque links if Radio communication, and required. Towing procedures checklist. Turn on all TBLT exterior lights (FAR 91). The TBLT owner is required to maintain train- Turn on position lights between sunset and ing records (FAR 139). sunrise (FAR 91). Wear communication headset (except in limited 8.2 Flight Deck Observer cases where procedures dictate that the wing walker wears it for pushback). The flight deck observer has the following re- Remain in constant contact with flight deck sponsibilities: observer. Check ATIS, NOTAMs, airport diagram, ATC Stop TBLT upon losing communication with frequencies, and so forth. flight deck observer or ATC (FAA AC 00-65). 11