U.S. Department of Transportation

Federal	Aviation	Administration

__________________________________________________________________________________________________________________

Regulatory	Impact	Analysis,

Notice	of	Proposed	Rulemaking	Regulatory	Evaluation

Revisions to Operational Requirements for the Use of Enhanced Flight 

Vision Systems (EFVS) and to Pilot Compartment View Requirements for 

Vision Systems

(14 CFR Parts 1, 23, 25, 27, 29, 61, 91, 121, 125, and 135)

RIN 2120–AJ94

OFFICE OF AVIATION POLICY AND PLANS

ECONOMIC ANALYSIS DIVISION (APO-300)
1

Regulatory	Evaluation	

for	the	Proposed	Rule	of	Enhanced	Flight	Vision	Systems	(EFVS)

Summary: The FAA is proposing to permit operators to use an Enhanced Flight Vision System 

(EFVS) in lieu of natural vision to continue descending from 100 feet height above touchdown

zone elevation to the runway and land on certain straight-in instrument approach procedures 

under instrument flight rules (IFR). This proposal would also permit certain operators using 

EFVS-equipped aircraft to dispatch, release, or takeoff under IFR, and to initiate and continue an 

approach when the destination airport weather is below authorized visibility minimums for the 

runway of intended landing. Under this proposal, pilot training, recent flight experience, and 

proficiency would be required for operators who use EFVS in lieu of natural vision to descend 

below decision altitude, decision height, or minimum descent altitude. EFVS-equipped aircraft 

conducting operations to touchdown and rollout would be required to meet additional 

airworthiness requirements. This proposal would also revise pilot compartment view certification 

requirements for vision systems using a transparent display surface located in the pilot’s outside 

view. This proposal would take advantage of advanced vision capabilities thereby achieving the 

NextGen goals of increasing access, efficiency, and throughput at many airports when low 

visibility is the limiting factor. Additionally, it would enable EFVS operations in reduced 

visibilities on a greater number of approach procedure types while maintaining an equivalent 

level of safety. 

The total estimated costs of this proposed rule over 10 years are approximately $5.3

million nominal value and $4.5 million present value at a 7% discount rate, which equals about 

$0.5 million annualized cost in current dollar value. Since the decision to conduct EFVS 
2

operations addressed by this proposal is voluntary, the FAA believes that operators who choose 

to conduct EFVS operations would demonstrate that the benefits of the proposal exceed the 

costs. Conversely, for operators who choose not to conduct EFVS operations addressed by this 

proposal, the proposed rule would not impose costs. Therefore, the FAA believes that benefits of 

the proposed rule exceed costs because it would improve cost-effectiveness of EFVS operations, 

save fuel and passenger time resulting from weather-induced delays and diversions, and provide 

manufacturers with an increased level of certainty by establishing specific airworthiness 

standards and eliminating the need for the issuance of special conditions. 

The Need for the Regulatory Action

Current Federal Aviation Regulations have some critical restrictions on EFVS operations. 

The enhanced flight visibility provided by an EFVS can only be used for operational benefit 

under § 91.175(l) in that portion of the visual segment that extends from decision 

altitude/decision height (DA/DH) or minimum descent altitude (MDA) down to 100 feet above 

the touchdown zone elevation. The regulations impose additional restrictions on EFVS 

operations conducted under parts 121, 125, or 135. An aircraft used to conduct an EFVS 

operation under those parts cannot be dispatched, released, or permitted to take off under IFR 

when the weather at the destination airport is forecasted or reported to be below authorized 

visibility minimums at the estimated time of arrival. Additionally, the pilot of an aircraft 

operating under these parts may not begin an approach or continue an approach past the final 

approach fix (or where a final approach fix is not used, begin the final approach segment of an 

instrument approach procedure) when the weather at the destination airport is reported to be 

below authorized visibility minimums. 
3

These regulatory restrictions prevent EFVS from being used for maximum operational 

benefits, which could be achieved by revising the current regulations to permit EFVS to be used 

to touchdown and rollout. In addition, current regulatory limitations related to dispatch, flight 

release, take-offs, initiating, and continuing an approach also prevent EFVS from being used for 

maximum operational benefit. If the FAA chooses not to take this regulatory action, persons 

conducting EFVS operations would have to face an efficiency gap between maximum 

operational benefit with EFVS capabilities and restricted EFVS operations under current 

regulations. Delaying the proposed rule or not changing the current regulations would continue 

to widen the efficiency gap. The FAA believes that EFVS capabilities could be better leveraged 

by this proposal to increase access, efficiency, and throughput at many airports when low 

visibility is a factor. In addition, the FAA believes that there would be a clear benefit of 

amending the operating rules for Category II and III operations to permit EFVS to be used during 

the conduct of those operations. The FAA also believes that the proposed training, recent flight 

experience, and proficiency requirements for EFVS operations would be the most cost effective 

way to provide an appropriate level of safety for the conduct of EFVS operations.

Finally, the current regulations contained in part 23, 25, 27, and 29, which address pilot 

compartment view requirements, do not contain airworthiness standards for vision systems. As a 

result, the FAA has been issuing special conditions under § 21.16 to provide airworthiness 

standards which could enable the installation of vision systems that would meet a level of safety 

equivalent to that established in the regulations. With over twelve years of experience, the 

process of developing special conditions for vision systems has become routine. The FAA 

believes, therefore, that it would be in the public interest to revise pilot compartment view rules 

to establish airworthiness standards for vision systems with a transparent display surface located 
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in the pilot’s outside view. This action would provide industry with known certification 

requirements and eliminate the time and cost resulting from the process of issuing special 

conditions for both the FAA and applicants. The decision to conduct EFVS operations is 

voluntary. Operators would choose to voluntarily comply with the proposed rule because it 

would allow increased access to airports under poor visibility. Thus it would stimulate the 

demand for EFVS equipped aircraft, improve cost-effectiveness of EFVS operations and save 

money on fuel and passenger time. Therefore the FAA believes that the proposed rule would add 

more benefits than costs to manufacturers and operators by permitting a greater range of 

operations.

Background

On January 9, 2004, the Federal Register published a final rule, Enhanced Flight Vision 

Systems, (69 FR 1620). The rule permits an EFVS to be used in lieu of natural vision to descend 

below DA/DH or MDA down to 100 feet above the touchdown zone elevation. The FAA 

proposes to establish regulations to expand certain conditions under which EFVS operations are

currently restricted and eliminate the need for special conditions. 

The proposed amendments are shown in Table 11, in which we identify provisions that 

might have an economic impact on manufacturers, operators, and consumers. Section A and 

Section B identify proposed changes in regulatory language, which do not apply to the cost and 

benefit analysis. The provisions proposed in Section C through Section F would have economic 

benefits, or both costs and benefits related to training, equipment requirements and certification. 

The FAA believes that there would be qualitative benefits associated with provisions proposed in 

Section D and Sections G through Section J, which will be discussed in the benefit analysis. 

 

1

The sections in Table 1 correspond to Sections III-A through III-L of the proposal.
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Sections K through M do not apply to the cost and benefit analysis. We estimate benefits and 

costs in the following sections compared to the baseline of common practice and current FAA 

regulations. 

Table 1. Economic Impact Assessment

Section III of the Preamble – Discussion 

of the Proposal Cost Benefit

A. Revise the definition for EFVS and add a 

definition for EFVS operation (§ 1.1) N/A N/A

B. Consolidate all EFVS requirements in a new 

section (§ 91.176) N/A N/A

C. Establish equipment, operating, and visual 

reference requirements for EFVS operations to 

touchdown and rollout (§ 91.176(a))

Possible equipment and certification 

cost. 

Risk mitigation and 

qualitative benefits

D. Revisions to current requirements for EFVS 

operations to 100 feet (§ 91.176(b)) None, because of current practice

Qualitative benefit to 

part 91, 121, 125, 

135 and 129

E. Establish training requirements for EFVS 

operations (§ 61.31)

Incremental training cost for pilots 

under parts 61, 121, 125, 135, and 

subpart K of part 91. Flight schools 

costs are estimated but not counted 

as these costs are included in pilot 

training costs.

Risk mitigation and 

qualitative benefits

F. Establish new recent flight experience and 

proficiency requirements for EFVS operations

(§ 61.57) None, because of current practice

Risk mitigation and 

qualitative benefits

G. Permit EFVS-equipped aircraft to be 

dispatched, released, or to initiate a flight 

when the reported or forecast visibility at the 

destination airport is below authorized 

minimums (§§ 121.613, 121.615, 125.361, 

125.363, 135.219) None

Qualitative benefit to 

part 121, 125 and 

135

H. Permit operators of EFVS-equipped aircraft 

to initiate or continue an approach when the 

destination airport visibility is below 

authorized minimums (§§ 121.651, 125.325, 

125.381, 135.225) None

Qualitative benefit to 

part 121, 125 and 

135

I. Revise Category II and III general operating

rules to permit the use of an EFVS (§ 91.189) None

Qualitative benefit to 

part 91
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J. Revise pilot compartment view rules to 

establish airworthiness standards for vision 

systems with transparent displays (§§ 23.773, 

25.773, 27.773, and 29.773) None for existing EFVS

Qualitative Benefit to 

manufacturers

K. Related Amendments (§§ 91.175, 91.189, 

and 91.905) N/A N/A

L. Conforming Amendments (§§ 91.175 and

91.189) N/A N/A

M. Implementation N/A N/A

Parties Potentially Affected by this Rulemaking

 Original equipment manufacturers (OEMs) producing enhanced flight vision 

systems (EFVS) or other vision systems with a transparent display surface located 

in the pilot’s outside view, in accordance with parts 23, 25, 27, or 29

 Persons installing EFVS or other vision systems with a transparent display surface 

located in the pilot’s outside view

 Persons conducting EFVS operations under parts 91, 121, 125, 129, or part 135 

 Persons conducting EFVS training

Principal Assumptions and Sources of Information

 A 10-year period for this analysis is used because this period captures all cost 

impacts

 Discount rate is 7 percent (Office of Management & Budget, Circular A-4, 

“Guidelines and Discount Rates for Benefit-Cost Analysis of Federal Programs,” 

October 29, 1992, p. 8, www.whitehouse.gov/omb/circulars/index.html)

 An average of 4 pilots assigned to each EFVS-equipped aircraft

 OEMs and two operators provided the number of EFVS-equipped aircraft
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 Operators of some aircraft equipped with older EFVS units would not seek 

certification for EFVS to touchdown and rollout

 The estimation of the incremental training cost per person is approximately $750

based on data collected from training centers.

 Certification costs of incremental EFVS capabilities to touchdown and rollout are

approximately $1 million as an aggregate estimation

 Aircraft operations over the next 10 years will grow about a 3.7% per year based 

on the FAA 2012 forecast (Table 28, FAA Aerospace Forecast Fiscal Years 2012-

2032)2.

Benefits of This Rule

This proposed rule comprises revisions to operational requirements for the use of 

enhanced flight vision systems and revisions to pilot compartment view requirements for vision 

systems using a transparent display surface located in the pilot’s outside view. Since the 

decision to conduct EFVS operations is voluntary, the FAA expects those who choose to engage 

in those operations would do so only if the expected benefit exceeds the cost to them. 

Revisions to operational requirements for the use of EFVS would enable expanded EFVS 

operations, which would increase access, efficiency and through-put in low visibility conditions, 

and minimize potential for missed approaches and delayed take-offs. In addition, EFVS permits 

low visibility operations on a greater number of approach procedure types. Changes in the U.S.

aviation infrastructure3, for example, the transition from incandescent to light-emitting diode 

(LED) approach lights, could potentially impact the near term benefits for persons using existing 

 

2

The FAA forecast for active general aviation (GA) turbojets is 3.7% for the period of 2011-2021. 

3

FAA airport infrastructure decisions are independent from this analysis.
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EFVS equipment, but may not impact future benefits of EFVS equipment designed to be 

interoperable with LEDs. These expected benefits cannot be quantified because both the 

infrastructure and EFVS capabilities are evolving. Benefits of this proposed rule would be 

realized by averting costs related to interrupted flight operations due to low visibility resulting in

lost passenger time and extra fuel consumption. 

Since aircraft currently cannot use EFVS to touchdown and rollout, we do not have 

sufficient historical data to quantify these benefits. We invite comments from existing EFVS 

operators about their expected benefits. We request comments to include airplane, type of 

operation, number of potential EFVS touchdowns, and extra costs of missed touchdowns and 

delayed take-offs. 

Revisions to pilot compartment view requirements for vision systems using a transparent 

display surface located in the pilot’s outside view would codify the current practice of issuing 

special conditions for each vision system by providing industry with known requirements for the 

certification of these systems under part 23, 25, 27, and 29. Because the proposed changes 

would streamline the certification process for these vision systems, the FAA would save the time 

and expense associated with developing, drafting, and publishing the special conditions in the 

Federal Register and responding to public comments. Since the FAA operates under a fiscal 

budget and issues annually a limited number of special conditions for vision systems, the time 

and resource savings would most likely be applied to other certification activities. This proposed 

rule would eliminate the time required for special conditions to be issued for these projects. The 

full extent of these benefits is not known and therefore has not been quantified in this analysis. 

We specifically request comments on the benefits of this proposal.
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Costs of This Rule

Here, we estimate the incremental differences in costs, resulting from the proposed 

changes in training, equipment and certification requirements. Data were obtained from EFVS 

manufacturers, training centers, and two operators. In the following discussions, we assess the 

training costs, the equipment costs and certification costs separately in detail. The methodology

and the sources of the data used in the cost estimation are explained as the cost analysis

proceeds.

Training Requirement Cost

Additional training would be required for persons to conduct EFVS operations under

parts 91,121, 125, and 135. We calculated the incremental training cost related to added training 

sessions for pilots covering EFVS operations from 100 feet to touchdown and rollout. Existing 

EFVS operations training curriculums already contain instructional techniques and flight 

instruction for IFR flight. The proposed rule would only require training centers to make minor 

changes. Training centers would have to adjust curriculum and train instructors. The FAA 

expects any related training center costs would be passed on to pilots and are included in our 

estimate of costs related to training pilots in the following analysis.

We requested and received data from part 142 training centers. The training schools 

provided estimated costs of EFVS training, which ranged from $2,000 to $7,700 per pilot. In

common practice, the price of a new EFVS-equipped aircraft includes a training package, 

covering a range of 3 to 4 hours of EFVS ground training and a range of 2 to 4 hours of 

simulator training. Since EFVS training cost cannot be separated from the price, we estimate

that the incremental training cost per pilot resulting from this rule is approximately $750 based 
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on data collected from training centers and two operators. We invite comments on the 

incremental training cost from training centers and operators. 

Based on data collected from OEMs and two operators, there are approximately 982

EFVS-equipped aircraft in service. We assume for the purpose of this analysis that all persons 

conducting EFVS operations would be trained to conduct EFVS operations to touchdown and 

rollout. The FAA believes the proposal would accelerate the growth of EFVS operations. We

estimate that the growth in U.S. EFVS operations would reflect an annual growth rate for aircraft 

of 3.7% in the next 10 years based on the FAA 2012 GA turbojet operation forecast (Table 28, 

FAA Aerospace Forecast Fiscal Years 2012-2032). The FAA expects this estimate to be an 

upper bound because some aircraft may not be modified for these operations.

The training cost would not recur because pilots trained for EFVS operations would not 

be required to repeat the training as long as they maintain their currency and proficiency after the 

initial training. Maintenance of currency is an ongoing requirement. However, because EFVS 

currency can be met simultaneously with instrument currency, the additional cost of maintaining 

EFVS currency should be minimal. 

The total training cost attributable to the proposed requirements equals the number of 

pilots conducting EFVS operations multiplied by the incremental training cost per pilot, plus the 

estimated growth of EFVS operations. We estimate 3,928 pilots would need training initially to 

meet the requirements of this proposed rule. This is the result of multiplying the number of 

EFVS-equipped aircraft (982) by an average of 4 pilots for each aircraft. Thus, the initial 

training cost is approximately $3.1 million if the rule would be promulgated in two years. This 

initial training cost resulted from multiplying the incremental training cost per pilot ($750) by the 

number of persons conducting EFVS operations (3,928), plus the growth based on the annual 
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rate of 3.7%. Using the above methodology, we computed the total training cost of this rule to 

be approximately $4.3 million nominal value in 10-year period and $3.5 million present value at 

a 7% discount rate. The computation of training costs in nominal value and the present value are

illustrated in Table 2. The FAA seeks comments on the training cost estimation. 

Table 2. Nominal Training Cost and Present Value Estimation ($ Million)

Year Cumulative Cost at 

3.7% Growth Rate

Incremental Cost

in 2012 Dollars

Present Value 

(7%)

2012 2.9 - -

2013 3.0 - -

2014 3.1 3.1 2.72 

2015 3.2 0.1 0.09 

2016 3.4 0.1 0.09 

2017 3.5 0.1 0.09 

2018 3.6 0.1 0.09 

2019 3.7 0.1 0.08 

2020 3.9 0.1 0.08 

2021 4.0 0.1 0.08 

2022 4.2 0.1 0.08 

2023 4.3 0.2 0.07 

Total - 4.3 3.47

Note: Details may not add up to totals due to rounding.

Equipment requirement cost

The proposed rule establishes equipment, operating, and visual reference requirements 

for EFVS operations to touchdown and rollout. Proposed § 91.176(a) would require a radio 

altimeter, flare prompt or flare guidance, and a repeater display to be installed on an aircraft used 

in EFVS operations to touchdown and rollout. Currently, aircraft are already equipped with one 

or two radio altimeters and flare prompt or flare guidance. Hence, there would be no additional 

costs resulting from this requirement. OEMs reported that a multi-function display installed on 

an EFVS-equipped aircraft can be used as a repeater display. The multi-function display in most 

cases comes standard with the capability of showing the EFVS image. Thus, this equipment 
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requirement would not result in additional costs. We note EFVS installed prior to 2007 may

require an upgrade. The operators of those aircraft might choose not to upgrade their EFVS 

capability to permit operations to touchdown and rollout. EFVS operators would choose not to 

upgrade when these costs would exceed the expected benefits. Those who choose not to upgrade 

can continue to conduct EFVS operations to 100 feet. A no-upgrade decision would not incur 

additional cost. Therefore, the regulatory costs of equipment requirements are negligible 

because there are no incremental costs required for EFVS-equipped operators. We ask for 

comments regarding this assessment. 

Certification Cost

Revisions to operational requirements for the use of EFVS would incur certification 

costs. These certification cost estimates are the incremental cost for certifying an expanded 

EFVS capability to touchdown and rollout. Some initial testing of EFVS to touchdown and 

rollout has already occurred for in-production airplanes. After EFVS are certificated for aircraft 

that are currently in-production, manufacturers will consider certificating EFVS for aircraft that 

are out-of-production as a separate business decision. Similarity of equipment may result in 

reduced certification cost not only for existing in-production airplanes, but also for other aircraft. 

The certification costs estimated herein are only those of current in-production airplanes and for 

the airplanes of a part 121 operator who expressed an interest in obtaining EFVS capability to 

touchdown and rollout. Additional certification costs, particularly for out of production aircraft

(e.g., for a supplemental type certificate or amended type certificate), and for new aircraft, will 

only be incurred if there is sufficient demand and the expected revenue exceeds the costs. 

The FAA requested and received from an OEM the certification cost for a single inproduction airplane equipped with an EFVS that meets the provision of the proposed rule. We 
13

took the OEM-provided certification cost for a single in-production airplane type with multiple 

airplane models, which they estimate to be approximately $1 million. We ask for comments

concerning this estimate and for costs that might be incurred to certificate new aircraft with 

EFVS systems that would be approved for EFVS operations to touchdown and rollout.

Revisions to pilot compartment view requirements for vision systems using a transparent 

display surface located in the pilot’s outside view would not result in additional certification 

costs compared to the current process of issuing special conditions for each vision system 

installation because the amendment would not require the FAA or an applicant to take additional 

actions to certificate these systems.

Total Cost Summary

The total incremental cost attributable to the proposed requirements equals nominal 

training cost ($4.3 million) plus the certification cost ($1 million). The compliance cost of 

equipment requirements is negligible. The total incremental cost of the proposed rule is 

approximately $5.3 million for the ten year period. The present value cost is approximately $4.5

million using a seven percent discount rate. We estimate separately the regulatory cost of 

paperwork, which is about $86,000 as described in the Paperwork Reduction Act section of the 

proposed rule. Table 3 presents the summary of the regulatory costs in nominal dollar value and 

present value.
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Table 3. Total Cost Summary

Cost Component Nominal Cost 

($ Million)

Present Value at 7% 

($ Million)

Training Cost $4.3 $3.5

Certification Cost $1 $1 

Total $5.3 $4.5

Revisions to pilot compartment view requirements for vision systems using a transparent 

display surface located in the pilot’s outside view would not result in additional regulatory cost 

because the FAA would spend fewer resources than the status quo by not issuing special 

conditions for each vision system installation to meet current operational requirements. 

Therefore, the FAA’s costs are expected to decline by an indeterminate amount as the number of 

vision systems that would require the issuance of special conditions in the future is unknown. 

The revisions would not increase costs to applicants seeking certification to meet current 

operational requirements because the proposed rule would not impose requirements that differ 

from currently issued special conditions. There may, however, be additional costs associated 

with the certification of EFVS to meet the proposed new operational requirements. 

Benefit/Cost Summary

The total estimated cost of this proposed rule over 10 years is approximately $5.3 million 

nominal value or $4.5 million present value at a 7% discount rate. The annualized cost of this 

proposed rule in current dollar value is a half million dollars. These estimated compliance costs 

would be incurred by those operators who want improved EFVS capabilities. OEMs are already
15

proceeding with efforts to expand EFVS capabilities, which indicate the benefits of conducting 

expanded EFVS operations would likely exceed the costs. Operators have also expressed an 

interest in obtaining EFVS capabilities to conduct operations to touchdown and rollout. The 

revisions to pilot compartment view requirements for vision systems with a transparent display

surface located in the pilot’s outside view would not impose additional costs from those currently

incurred using the special conditions process. The FAA believes the proposed rule would have 

benefits exceeding costs based on the likelihood that OEMs and operators would voluntarily

incur the costs of the proposed rule in order to realize expected benefits. To quantify benefits, 

we request comments about expected benefits attributable to the proposed rule.