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5.2Mechanical Although it is recommended that all of the afore- mentioned lights be turned on, only those specified The full aircraft braking system should be avail- in FAR Part 91.209 are mandatory. Aircraft anti- able for use at all times. An aircraft under tow should be mechanically sound and able to maintain collision beacon lights should be turned on any time minimum speeds that will preclude impeding air- the aircraft engines are running. Furthermore, any port operations. Additionally, the aircraft under tow supplemental lighting not specified in FAR Part must not exceed towing speeds as determined by the 91.209 would require prior FAA approval. TBLT manufacturer, aircraft manufacturer, airport, or TBLT operator for the existing operating and air- 5.5Equipment/Accessories field conditions. It is recommended that the following be con- spicuous inside the flight deck and TBLT cab to in- 5.3Communication crease the safety of the operation: The flight deck observer will be the primary A current airfield map showing all non- communicator with ATC and the TBLT operator movement and movement areas, will be the secondary communicator. The aircraft's All ATC and pertinent frequencies (ramp permanently mounted, fully programmable, two- control, company, etc.), and way radio will be the primary means by which the Backup communications procedures (includ- flight deck will communicate with ATC. Communi- ing phone numbers). cation between the flight deck and the TBLT cab is also required. This is typically provided through the TBLT intercom system that is connected directly to 5.6Personnel the aircraft by wire. The TBLT operator and flight A qualified flight deck observer is required on deck observer must monitor all radio communica- the aircraft flight deck to communicate with ATC tions and are equally responsible for adhering to all and to apply aircraft brakes, which are only to be ATC communications and instructions. applied in case of emergency and communicated as such to the TBLT operator and/or ATC. 5.4Lighting To increase conspicuity the following aircraft 6Towbarless Tractor Procedures lights may be turned on depending on operational This section describes the recommended proce- conditions unless otherwise specified under written dures to conduct a safe and efficient towing operation. agreements and/or understandings between desig- nated representatives of the airport, aircraft opera- tors, and local ATC and FAA: 6.1Before Start Procedures (Prior to Pushback and Towing) Aircraft interior lights (night or reduced vis- ibility operations), The following procedures are recommended be- Navigation lights (day or night operations), fore the start of any tow operation. The TBLT op- Anti-collision lights (per the discretion of erator and flight deck observer will be responsible operator), for adhering to these recommendations: Upper and lower rotating beacons (aircraft Review planned operating procedures with under tow), and flight deck observer. (An aircraft towing op- Other supplemental lighting (requires FAA eration by TBLT requires at least two quali- approval). fied employees: one in the aircraft and one in It should be noted that under certain conditions the TBLT.) it is possible that an aircraft with lights turned on Review current airport/airfield conditions with may incorrectly suggest to outside observers, in- the flight deck observer (NOTAMs, ATIS, cluding ATC, that the lighted aircraft is under its ATC, airport layout and geometry, pavement own power. The flight deck observer should ensure conditions, etc.). through direct communications that ATC clearly Review planned route with the flight deck understands that the aircraft is under tow. observer. 7

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Review contingency plans with the flight deck At the initiation of pushback, the TBLT should observer, including: push the aircraft straight back until clear of Weather, all objects before proceeding with any turning Alternate tow routes, maneuvers. Lost communications, and The aircraft may be pushed back with engines Emergencies. operating if permitted by airport or company Provide a visual check of overall condition of procedures. TBLT (FAA AC 00-65). Engines may not be started during the push- Provide a visual check of overall condition of back operation. If required, aircraft engines aircraft (cargo doors, latches, struts, tires, etc.). should be started before the pushback. Close entrance doors, retract or remove lad- Prior to starting the pushback: ders, install landing gear down locks (if The TBLT operator should be facing in the required) (FAA AC 00-65). direction of pushback. Test TBLT transponder (if applicable) and check The TBLT operator should have thorough proper working condition of minimum operating knowledge of the delineation of movement/ equipment (radios, lights, safety equipment, etc.). non-movement areas. Verify the airport diagram (movement/non- ATC approval is required before entering movement) placard is available to both the the movement area. TBLT operator and flight deck observers TBLT operators must have a thorough un- (review Surface Movement Guidance Control derstanding of airport right-of-way rules. System (SMGCS) Plan/diagram if applicable). Check the pre-charged aircraft brake accumu- 6.3 Aircraft Towing Procedures lator pressure before each tow, and do not use TBLT if aircraft brake pressure is below nor- The following procedures are recommended for mal operating limits. aircraft towing operations beyond the pushback. Do not hang any equipment on the aircraft The TBLT operator will be responsible for adher- exterior (FAA AC 00-65). ing to these recommendations: When connecting a tow vehicle, personnel The tow team shall maintain contact with should be extremely vigilant to any sudden ATC through the proper ATC frequencies movement of the tow vehicle or aircraft (FAA (ramp, ground, or tower). AC 00-65). Proper phraseology shall be used while in Ensure all ground equipment and FOD is radio contact with ATC. removed from the vicinity of the aircraft and Prior to starting the tow: pushback area. The TBLT operator should be facing in the Ensure properly charged fire bottles/ direction of tow. extinguishers are accessible. ATC approval is required before entering TBLT operators and flight deck observers the movement area (if applicable). must wear their seatbelts/safety belts prior to The TBLT operator should have thorough push back and at all times during the tow. knowledge of the delineation of movement/ non-movement areas. 6.2 Aircraft Pushback Procedures TBLT operators must have a thorough un- derstanding of airport right-of-way rules. The following procedures are recommended for TBLT operator must hold short of all manda- any aircraft pushback operation. The TBLT opera- tory instruction signs until cleared by ATC. tor will be responsible for adhering to these recom- TBLT operator should perform smooth starts/ mendations: stops. (FAA AC 00-65); the aircraft should Wing walkers and tail walkers are recom- not be towed with engines operating. Engines mended during pushback when other aircraft may be operating if the TBLT is only used to or objects are positioned in adjacent parking push the aircraft away from the terminal gates positions/gates. (FAA AC 00-65). 8

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TBLT operator should maintain slow speeds Inspect aircraft for damage upon completion and high turning radii during turning maneu- of the tow per manufacturer's recommenda- vers. For example, Boeing recommends the tions and report any damage. maximum allowable steering angle be 80 per- Prohibited operations: cent of the conventional towbar limits. The Passing other vehicles or aircraft, conventional towbar limits were reduced for Leaving a TBLT unattended with the engine towbarless towing to provide a margin of safety running, and for the absence of shear protection furnished Driving a TBLT under an aircraft. by the towbar/tow lug connection. Aircraft brakes should not be used except in the case of an emergency. 6.4Towbarless Tractor Repositioning Maximum allowable towing speed should Procedures be determined by the operator based on the TBLT repositioning consists of driving the TBLT TBLT model and aircraft under tow. Recom- without an aircraft in tow. It is sometimes referred to mendations for towing speeds in good weather as "TBLT operating empty." During repositioning, conditions: the following is recommended: Towing speed in apron/ramp areas should be no faster than walking pace. Use service roads if the service road weight Towing speed in close quarters, turns and bearing capability and width are adequate near gates should be restricted to less than (FAA CertAlert 08-06). When the use of ser- 2 mph. vice roads is not practical, the TBLT may use Towing speed limited to 6 to 8 mph on airport movement areas in accordance with long hauls, straight portions not to exceed rules, regulations, or agreements with the air- speeds as recommended by the TBLT or port. While on airport movement areas, the aircraft manufacturer. TBLT operator must be in radio contact with Reduce towing speeds according to aircraft ATC at all times. weight and airfield conditions (snow, ice, wet Driving under aircraft is prohibited. pavement) (FAA AC 00-65). Driving under passenger boarding bridges is Towing personnel should not place them- prohibited. selves in the direct path of aircraft wheels nor ride on any external portion of an aircraft or 6.5 Dispatch Towing Procedures tow vehicle (FAA AC 00-65). The TBLT operator should have knowledge 6.5.1Overview of aircraft nose gear operating specifications Dispatch towing is the towing of a fully loaded to ensure the nose gear maximum allowable revenue airplane (passengers, cargo, and fuel) from steering angle is not exceeded and the nose the terminal gate or remote parking position to a gear is not overstressed. location near the departure runway made possible Upon completion of the tow operation, the by the increased towing speeds achievable with a aircraft should be positioned such that the TBLT. Dispatch towing with a TBLT has been iden- nose gear is aligned with the aircraft. tified as a strategy to reduce aircraft taxi fuel burn Wing walkers should be used in congested and engine emissions. areas such as the gate areas or non-movement areas having short separation distances from 6.5.2 Dispatch Towing Issues fixed or moveable objects. Tail walkers should be used during towing Dispatch towing has been used at some airports operations when the aircraft is turned in areas in the U.S. However, a number of issues related having short separation distances from fixed to dispatch towing have been identified that limit or moveable objects. widespread use. First, TBLT towing places heavy Prior to disconnecting the TBLT from the air- stress loads on the nose gear. Tests conducted by craft, the aircraft parking brake should be set Virgin Atlantic and Boeing found that dispatch tow- and/or chocks placed on the aircraft. ing with TBLTs resulted in a reduced operational 9