Vanquishing the V/PD 

4th Quarter 2015
 

A quarterly publication from the
 

Safety Section
 

Federal Aviation Administration Airports Division
 

Western-Pacific Region
 

This publication is directed primarily towards airport management to be disseminated to 

all levels of personnel working at your airfield. Vanquishing the V/PD can be 

accomplished through a solid partnership between the FAA and airport management. The 

responsibility of making sure that the proper safeguards are in place, however, lies 

squarely on the shoulders of airport management. Please use this information and all that 

follows as a guide by which to provide a safer environment at your airfield. 

Newly revised Advisory Circular (AC) 150/5210-20A, Ground Vehicle Operations to 

include Taxiing or Towing an Aircraft on Airports, incorporates major changes. Chief 

among these changes are: a definition of Vehicle or Pedestrian Deviation (V/PD), 

expanded guidance concerning aircraft being taxied and/or towed by non-pilots and an 

allowance for maintenance vehicles to be present and/or maintenance to be performed in 

the runway safety areas (RSA) during air carrier/aircraft operations. 

The official definition of a Vehicle/Pedestrian Deviation is now: “Any entry or 

movement on the airport movement area or safety area by a vehicle operator or pedestrian 

that has not been authorized by air traffic control.” This definition includes surface 

incidents involving aircraft operated by non-pilots, such as anyone. 

Certificated airports must now ensure that all mechanics who tow and/or taxi aircraft in 

the movement areas receive movement area training. Newly revised 14 CFR Part 329(e) 

requires initial and recurrent training for all persons who access the movement and safety 

areas. 14 CFR Part 139.329(e) states: “Ensure that all persons are trained on procedures 

required under paragraph (b) of this section prior to the initial performance of such duties 
and at least once every 12 consecutive calendar months, including consequences of 

noncompliance, prior to moving on foot, or operating a ground vehicle, in movement 

areas or safety areas.” An aircraft under tow and an aircraft being repositioned under their 

own power for maintenance purposes are considered and treated as “vehicles”. 

Furthermore, the definition of an aircraft in the Pilot Controller Glossary states in part: 

“An Aircraft is a device(s) that are used or intended to be used for flight in the air.” 

Therefore, given that a mechanic taxiing or towing an aircraft is not intended for flight, 

airport operators should include mechanics in their procedures, policies and training 

regarding vehicle access on the airside of the airport. The only exception to this is if the 

mechanic taxiing the aircraft is a rated pilot. 

Airport operators should consider requiring any person expected to operate vehicles on 

the airside and anyone authorized to taxi or tow an aircraft, to be able to communicate in 

and understand the English language. Airport operators can require vehicle operators to 

maintain a current driver’s license and may establish a means of identification that would 

permit the operation of a vehicle on the movement and safety areas of the airport. Airport 

operators should establish procedures to reduce distracted driving practices; e.g., talking 

or texting on mobile devices while the vehicle is in motion. 

Under special circumstances, maintenance activities and maintenance vehicles will be 

allowed in the runway safety areas during air carrier/aircraft operations. Examples may 

include NAVAID maintenance, mowing or other safety-related circumstances. A Letter 

of Agreement (LOA) will be required at each towered airport to clarify the specific 

activities. Signatories to the LOA will include the airport operator, the local Air Traffic 

Control Tower, FAA Technical Operations, and any other airport tenant that may be 

permitted into the RSA during air carrier/aircraft operations. The LOA will become part 

of the airport’s Airport Certification Manual if the airport is certificated. 

The overall responsibility for the operation of vehicles on an airport rests with the airport 

operator. And for mechanics taxiing or towing aircraft, there is a shared responsibility 

between the airport operator and aircraft operator. 

Column written by: 

Steven Oetzell 

Lead Airport Certification Safety Inspector, AWP-620.6 

Advisory Circular 150/5210-20A is available on FAA website: 

http://www.faa.gov/airports/resources/advisory_circulars/ 

Reproductions of this, past and subsequent issues of Vanquishing the VPD are available 

on FAA website: 

http://www.faa.gov/airports/western_pacific/newsletter/