Special Terminal Operation Procedures (STOP) for Operations in a Noncontiguous State

Introduction

Air carriers often need to release flights to locations with missing weather reports (e.g., surface observations such as METAR), missing elements of weather reports, or locations that do not have an ASOS or AWOS facility or human weather observers.

The STOP program is designed for 14 CFR part 121 domestic and supplemental operations at airports in a noncontiguous state (e.g., Alaska) without a complete surface observation and/or forecast.

This guidance provides acceptable methods and guidelines for the certificate holder (CH) to use to develop the STOP program. The Aviation Safety Inspector—Aircraft Dispatcher (ASI-AD) and the POI may refer to this guidance as they review part 121 domestic or supplemental operations conducted in a noncontiguous state to airports with no METARs, missing METAR elements, or no weather reporting facilities.

Weather Information

General

In accordance with part 121, § 121.599(a), no aircraft dispatcher may release a flight unless thoroughly familiar with reported and forecast weather conditions on the route to be flown. Section 121.601 requires the aircraft dispatcher to provide the PIC with all available current reports or information on airport conditions and irregularities of navigation facilities that may affect the safety of the flight. Section 121.601 applies to every phase of flight. In accordance with § 121.599(b), no PIC may begin a flight unless thoroughly familiar with reported and forecast weather conditions on the route to be flown. Section 121.597 refers to the individuals authorized by the CH to exercise operational control over the flight and to execute a flight release setting forth the conditions under which the flights will be conducted.

IFR operations under part 121 require current weather reports and forecasts. Those approved sources are official surface observation (e.g., METAR) and a TAF. If no NWS TAF is available, an approved EWINS TAF may be used. Refer to FAA Order 8900.1 Volume 3, Chapter 26, Section 4, Enhanced Weather Information Systems, for additional information about EWINS.

Landing limitations and aircraft performance require a CH to consider forecast (anticipated/probable) winds at the destination airport. Therefore, weather forecasts that include wind information for the destination airport are always required.

Supplements to NWS or EWINS TAFs

The AAG forecast product provides TAF-like information for locations where an NWS or EWINS TAF is not available at the intended destination in Alaska. AAG is intended for use under VMC. Operators conducting operations under part 121 cannot use AAG at alternate airports. The AAG is also limited for

flight times of 2 hours or less in duration. The AAG, in conjunction with METARs, PIREPs, the FA, SIGMETs, and AIRMETs, helps inform operators of the weather conditions at the ETA and whether those conditions will be at or above the minimums, which determines whether operations can be conducted within the performance limitations of the aircraft per § 121.101. In addition, the AAG does not indicate blowing snow or convective activity. If precipitation is forecasted, other products, including SIGMETs and NEXRAD weather radar, where available, can determine if hazardous convective weather will be present when the aircraft arrives. InFO 20002 provides more information on the AAG.

Table D-1 lists weather products that supplement NWS or EWINS TAFs.

Table D-1. Weather Products to Supplement NWS or EWINS TAFS

Weather Product			Location in Handbook (Section)	Website
AIRMET			26.3	https://www.weather.gov/aawu/airmets https://www.weather.gov/aawu/
Alaska Aviation Guidance (AAG)			27.15.1	https://www.weather.gov/arh/aag
Alaska Graphical Forecasts	AAWU Flying Weather		27.6.1	https://www.weather.gov/aawu/#map
	Alaska Surface Forecast		27.6.2
	Alaska Icing Forecast		27.6.3
	Alaska Turbulence Forecast		27.6.4
	Alaska Convective Outlook		27.6.5
Alaska Significant Weather Forecasts			27.8.4	https://www.weather.gov/aawu/4panelsigwx
Area Forecast (FA)1			27.5	https://weather.gov/aawu/AreaForecasts
Center Weather Advisory (CWA)			26.4	https://aviationweather.gov/cwamis
FAA Aviation Weather Cameras			24.9	https://weathercams.faa.gov/
Graphical Forecasts for Aviation (GFA)			28.2	https://aviationweather.gov/gfa
Localized Aviation Model-Output Statistic (MOS) Product (LAMP)			27.15	https://www.nws.noaa.gov/mdl/gfslamp/stnplots.php?& region=Alaska&elm=flight
Pilot Weather Reports (PIREP)			24.5.1	https://aviationweather.gov/airep
Real-Time Mesoscale Analysis (RTMA)			25.7	https://nomads.ncep.noaa.gov/pub/data/nccf/com/rtma/ prod/airport_temps/
SIGMET			26.2	https://weather.gov/aawu/sigmets https://aviationweather.gov/sigmet
Weather Product			Location in Handbook (Section)	Website
Surface Observations2		METAR	24.4.1	https://www.weather.gov/aawu/obs https://www.weather.gov/aawu/
		SPECI	24.4.2
		ASOS	24.3.1
		AWOS	24.3.2

Notes: 

1. An FA alone, without a valid TAF, is not an acceptable standalone forecast to satisfy the relevant part 121 weather reporting requirements. The FA is not intended for use in operational decision making or as a substitute for a TAF. However, the FA may provide vital weather information for the entire en route portion of flight, from point of origin to destination and all applicable alternates.
2. Aircraft performance is predicated on aircraft weight, ambient temperature, wind direction, wind speed, and altimeter setting. In order to ensure aircraft takeoff and landing limitations are met and obstacles are avoided, a surface observation contains at least the following elements:
   1. The station identifier (e.g., airport code),
   1. Date and time of observation (to establish relevance of the report),
   1. Ambient air temperature at the station (e.g., airport or seaport),
   1. Wind speed and direction,
   1. Altimeter setting at the station (unless the current published approach plate lists an alternate source),
   1. Visibility (for obstacle avoidance and IAPs), and 
   1. Ceiling.

Manual Surface Observations by Flightcrew Using a Portable Weather Observation Device at STOP Airports

Portable Weather Observation Device

A portable weather observation device is issued to the flightcrews who conduct STOP flights as part of the preflight preparation. An acceptable portable weather observation device provides the following:

1. Date and time.
2. Wind direction (degrees magnetic north).
3. Wind speed (knots).
4. Temperature (°C).
5. Dewpoint temperature (°C).
6. Altimeter or pressure (inHg).

Note: Apply the appropriate variation to get the wind direction in true north, which is needed for documentation and reporting.

Calibration of the device is done in accordance with the manufacturer’s procedures. A log with the date of last battery change, latest calibration date, the result (satisfactory or unsatisfactory), and the name of the individual who performed the calibration should be kept with the device.

Visibility Estimation by the Pilot

Estimates of visibility can be made using the runway length (e.g., a 5,300-ft runway is 1 sm, geographical features or prominent obstructions at a known distance, markers placed for the purpose of measuring distance visually or with FAA cameras).

Ceiling Estimation by the Pilot

Ceilings can be estimated using geographical features or prominent obstructions of a known elevation of height. Ceilings can be estimated using:

• Known geographic points;
• The conditions on arrival, provided they have not radically changed; and
• Temperature/dewpoint spread, which is the difference between the temperature and dewpoint, divided by 2.5, multiplied by 1,000. o If the temperature is 18 °C and the dewpoint 9 °C, a difference of 9 °C exists. o This result indicates that the lowest cloud layer should be 3,600 ft AGL.

o Comparing this to a visual assessment, the forecast (TAF (NWS or EWINS)), and PIREPs (your own on arrival or provided by other aircraft) should provide reasonable estimated ceiling information.

Documentation and Reporting

Prior to departure, the PIC records all required elements on the weather record log, then communicates with the responsible aircraft dispatcher or flight follower. A mutual agreement is achieved on these conditions for a flight release. In this process, the PIC advises, and the aircraft dispatcher records the following information:

• Station identifier.
• Date and time.
• Wind direction (degrees true north).
• Wind speed (knots).
• Visibility (sm).
• Ceiling (BKN, OVC).
• Temperature (°C).
• Dewpoint temperature (°C).
• Altimeter (inHg).

This information is part of the dispatch and flight release documents and is retained in the company’s 3-month retention file.

Airport Data

Data Maintenance

All airports and runways on which STOP operations are conducted are documented in the CH’s Safety Assurance System (SAS), which is maintained and updated by active surveillance.

Airport Analysis Program

For airports that do not appear in the Alaska Chart Supplement, the CH uses an airport analysis program to ensure the facility is adequate for the proposed STOP operation. This may require a full airport risk assessment, strip check, or airport condition report to be completed. If the airport appears in the Alaska Chart Supplement but runway conditions are not monitored, only the runway contaminants section of the strip check or an airport condition report is completed. The CH determines how this will be accomplished and requests the POI’s approval.

For airports not listed in the Alaska Chart Supplement, or non-part 139 in the State of Alaska only, the airport risk assessment, strip check, or airport condition report includes airport pictorials to familiarize the flightcrew with the area. Suitable pictorials include pictures taken from the air or from the ground, satellite pictures, and excerpts from aeronautical charts, etc.

Flight operations to airports with weather reporting deficiencies are thoroughly evaluated to ensure the facility is adequate for the proposed operation. For all STOP flight operations to temporary runways (frozen bodies of water or flat open terrain), the CH may need to accomplish a physical, onsite inspection of the runway and facilities and complete the company’s documented report.

The dispatcher, flight follower, and flightcrew member use the completed airport analysis, airport risk assessment, strip check, or airport condition report during the crew briefing. If during the crew briefing the PIC, dispatcher, or flight follower determines the conditions at the destination airport are not adequate for safe operations, the flight is not released.

Civil Twilight Considerations

Flight operations to airports with weather reporting deficiencies are initiated unless the ETA and estimated time of departure falls within the hours of the start of morning civil twilight and the end of evening civil twilight. Dispatchers or flight followers note these hours in the “Remarks” section of the dispatch or flight release.

Civil  twilight is determined by the following U.S. Military database: https://aa.usno.navy.mil/data/RS_O neYear.

Night operations may be authorized if the airport is equipped with lighting at least equivalent to medium intensity edge lights (easily identifiable as lighting during daylight conditions). No operations outside the start of morning civil twilight and the end of evening civil twilight will be conducted where this lighting standard is not met.

The flightcrew determines the wind direction from an illuminated wind direction indicator or ground communications before landing.

If temporary lighting (e.g., flare pots) are used, they are evenly spaced on each side of the runway, to replace at least 50 percent of the normal lights. If permanent lighting is not installed at the airport, the temporary light spacing is 200 ft apart. Four lights are placed at each runway end to clearly mark the threshold and runway end. Lights are turned on 30 minutes prior to arrival and for 30 minutes after departure.

The Director of Operations (DO), PIC, dispatcher, or flight follower should agree that the lighting is adequate for the proposed operation, with the approval by the DO or designee annotated on the flight release. Temporary lighting may be placed and illuminated by qualified company personnel who are familiar with these procedures.

Flight Planning

General

Flight operations to airports with weather reporting deficiencies are operated under IFR with the exception of operations in the terminal area. In the terminal area of the STOP airport, flightcrews maintain the basic cloud clearance as specified in § 91.155, and maintain the minimum altitudes prescribed in § 91.126, § 91.129, § 91.130, or § 91.131, as applicable for the airspace class in which the flight is operated.

IFR Flight Plan

Both domestic and supplemental flights under STOP are planned as an IFR flight plan when the intended flight is 50 NM or more from origin to destination.

Composite IFR/VFR Flight Plan

When the flight is to be greater than 50 NM but will exit the IFR structure within 50 NM of the destination under VFR, a composite flight plan is filed. The IFR portion will change to a VFR transition point, at which the PIC will activate the VFR flight plan.

VFR Flight Plan

Only to be used when the intended STOP flight is less than 50 NM from origin to destination. Only Group I airplanes (propeller-driven, including reciprocating and turbopropeller-powered) operate under a part 121 VFR flight plan.

Note: For a VFR flight, this distance will consider the route most likely to be flown. For example, a 50 NM direct route would not be appropriate to consider if high terrain would make point-to-point direct impracticable. In this case, the flight would be released on an IFR flight plan.

Fuel Requirements

Domestic and supplemental STOP flights, regardless of aircraft type, are not released without considering fuel to meet the requirements of § 121.647. This includes a landing area visual inspection (flyover) of 15 additional minutes of the intended landing strip. This fuel is noted on the release in a manner which is readily identifiable to the flightcrew. The CH determines according to aircraft type if an additional 15 minutes of fuel is sufficient, or adjust accordingly to accommodate a possible flyover pass of the intended airstrip or airport.

Weather Minimums at STOP Destination Airports

The Administrator considers the ETA at the destination and the arrival minimums that are listed below, to contribute to mitigating risks and hazards to STOP destinations, and will allow the CH to operate at the highest level of safety. These weather minimums apply regardless if the whole weather report is missing or only missing a required element.

Domestic Operations

Forecast weather conditions 1 hour before and 1 hour after ETA at the STOP destination airport to be at least a cloud ceiling of 3,500 ft above the airport elevation and visibility of 5 sm, and appropriate wind velocity and direction.

Supplemental Operations

Forecast weather conditions 1 hour before and 1 hour after ETA at the STOP destination airport to be at least a cloud ceiling of 3,000 ft AGL and visibility of 3 sm, and appropriate wind velocity and direction. If the STOP destination airport has an approved IAP the required release minimums are a ceiling of 1,500 ft above the airport elevation and visibility of 3 sm 1 hour before and 1 hour after ETA.

Required Destination Primary Alternate

A destination’s primary alternate is always included for both domestic and supplemental operations when the STOP process is applied. It always includes the appropriate fuel requirements for the alternate. The destination primary alternate must have a TAF and all required reporting elements of a METAR, and meet the air carrier’s alternate minimum requirements.

Designation of Secondary Destination Alternate

When weather conditions at the destination airport and the first alternate airport are marginal, § 121.619(a) requires that at least one additional alternate airport be designated. The term “marginal,” as applied to domestic alternate minimums, is not defined by regulation. To some extent this is because the definition of what constitutes marginal depends on the nature of the weather phenomena, the operation conducted, and the equipment used.

If marginal conditions at the primary alternate are forecast, the CH must, per §§ 121.619, 121.623, and 121.625, list a second alternate in the dispatch or flight release the flightcrew briefed prior to release. When marginal conditions are present at destination and primary alternates, the secondary alternate may not be less than 2,000 ft above the airport elevation and the visibility must be at least 3 sm. Both the primary and the secondary alternates must have a complete METAR and TAF at ETA.

Minimum Equipment List (MEL) Restrictions

When required by an MEL, flight operations to airports with weather reporting deficiencies are not to be initiated with, or continue with, the following items deferred or inoperative:

• Any long-range navigation systems (LRNS) (e.g., GPS) that may be installed on the aircraft. In a dual installation, one must be operational.
• OAT reporting system installed on the aircraft.
• One or both flight management system(s) (FMS).
• One or both radio altimeter system(s).
• Ground proximity system.
• Satellite voice communication available over the entire route and at any destination airport.

Preflight Planning and Briefing to STOP Airport

D.5.1 Preflight Planning

See Sections D.2, D.3, and D.4 for weather, airport data, and flight planning information.

Preflight Briefing

Before releasing any flight, both the aircraft dispatcher or flight follower and the PIC should become thoroughly familiar with the reported and forecast weather conditions, including adverse weather phenomena, the status of communications, navigation, and airport facilities. This requires the dispatcher or flight follower to provide the PIC with information on each of these items. It also requires a preflight briefing between the dispatcher or flight follower and the PIC.

The preflight briefing is either delivered verbally or in writing. Communication facilities must be available for the aircraft dispatcher or flight follower and the PIC to communicate directly by voice if direct communication is required or desired. If communications are conducted verbally, the preflight briefing communication is documented.

Prior to conducting a STOP flight operation on a flight to an unfamiliar destination, over an unfamiliar route, or a route they have not flown over in the last 90 days, the PIC and second in command (SIC) update themselves using all information pertinent to the safe conduct of the flight. This may include, but is not limited to, one or more of the following resources:

• Personal briefing (route qualification required by § 121.463).
• Aeronautical charts, with regard to prominent geographical features such as mountain ranges and passes, rising terrain, locally hazardous areas, lakes, rivers, and coastlines.
• FAA webcams (https://weathercams.faa.gov/).
• The Alaska Airport/Facilities Directory website (https://dot.alaska.gov/airport-portal.shtml).
• Appropriate company wind chart(s) for airport runway reports (if available).
• NOTAMs.

En Route, Flight Monitoring, and Communications

General

An aircraft dispatcher or fight follower monitors the progress of each flight under that individual’s control until the flight has landed or passed beyond the area of control, or until the individual is properly relieved by another dispatcher or flight follower. Flight monitoring, at a minimum, consists of the monitoring of each aircraft’s fuel state, flight time remaining, destination and alternate airport weather trends, en route winds and weather (including PIREPs), ATC constraints, and the status of airport and navigational facilities. Section 121.99 requires that reliable and rapid two-way communications between each flight and the aircraft dispatcher be available at any point in the flight, including overwater portions of international flights.

Domestic Operations

Section 121.601(c) requires the aircraft dispatcher to report to the PIC any additional information that could affect the safety of the flight. This information may be delivered by voice message or by other means, such as the ACARS.

Supplemental Operations

Section 121.603(b) requires that during a flight, the PIC shall obtain any additional available information of meteorological conditions and irregularities of facilities and services that may affect the safety of the flight.

Flight Monitoring

All flights released under STOP are monitored, tracked, and controlled by a dispatcher or flight follower. For flights to remote sites without phone service, flightcrews are provided with appropriate satellite communications. During the flight:

• The dispatcher or flight follower:
  • Provides the PIC with any additional available information of meteorological conditions (including any changes in primary weather information or adverse weather phenomena, such as clear air turbulence, thunderstorms, or low-altitude wind shear) that may affect the safety of the flight.
  • Provides the PIC with any additional available information regarding irregularities of facilities and services that may affect the safety of the flight, including any changes in NOTAMs (refer to § 121.601).
  • Monitors any and all information available for weather at the destination and alternates, as well as the progress of the flight. All flights on an IFR flight plan are tracked using aircraft situation display software.
• The PIC:
  • Ensures contact is established with the dispatcher or flight follower as soon as practical after takeoff, reaching cruise altitude in nonturbine airplanes or leaving 10,000 MSL in turbine airplanes.
  • Requests any available updated information for the destination and alternate airports at approximately 30 minutes before ETA when a flight has a cruise time of more than 1 hour. If the report does not indicate conditions suitable for a visual approach, the flight proceeds to the alternate airport. Ensures that the dispatcher or flight follower is informed of the intent, either directly or via relay.
  • When contacting the dispatcher or flight follower, or forwards progress reports to the dispatcher or flight follower, includes ETA at the destination (or alternate), fuel remaining, and aircraft maintenance status.

En Route Terrain Clearance

Part 121 subpart I contains limitations on weights at which aircraft may be dispatched due to terrain clearance requirements. These limitations apply to all types of aircraft operated under part 121.

En Route IFR to VFR Transition Point

Filing to the destination will normally be IFR to a point where VFR can be expected to be achieved. The IFR to VFR transition point should be no more than 50 NM from the intended destination. If upon arrival at the transition point the crew is unable to establish and maintain VFR through landing, then the flight proceeds to the primary alternate. If the weather unexpectedly begins to deteriorate while en route to the destination, but after transitioning to VFR, a course change may need to be made to maintain VFR. If VFR cannot be maintained to destination, coordinate with ATC for an IFR clearance to the alternate airport.

Maintain terrain clearance visually until at or above minimum safe altitudes and an IFR clearance has been obtained.

Destination Approach and Arrival

General

Flight operations to destination airports with weather reporting deficiencies proceed no further than the final approach fix on an instrument approach to the airport, or descend no lower than the minimum en route altitude, unless the flightcrew has visual contact with the runway and can maintain VFR in VMC.

Visual Inspection

In VMC conditions, the flightcrew conduct a visual inspection of the airport prior to landing. This inspection will allow the flightcrew to assess the winds using a windsock and/or environmental factors (e.g., blowing/drifting snow, wind over water, or leaf and tree movement). When available, these visual cues are compared to the onboard FMS-derived wind calculations, ensuring optimum situational awareness. This wind check prior to landing ensures an approach and landing into the wind and compliance with the company’s crosswind limitation. On final approach, the flightcrew verify the indicated air speed is greater than the aircraft’s ground speed.

Barometric Altimeter Validation

In addition to verifying wind conditions, the visual inspection of the airport prior to landing allows the flightcrew to validate or correct the barometric altimeter using the aircraft’s radio altimeter system.

Radio Altimeter Setting

Prior to the descent for approach to the airport, the flightcrew obtain and set the nearest reporting station in accordance with § 91.121(a)(1) and the AIM Chapter 7, Section 2, Paragraph 7-2-2, Barometric Pressure Altimeter Errors, subparagraph a. To ensure an equivalent level of safety, the STOP requires the nearest reporting station to be within 75 NM of the destination airport. During the visual inspection, the flightcrew note the aircraft’s radio altimeter reading. This above-ground height is added to the airport’s elevation, which then gives an MSL height. When required, the flightcrew makes an adjustment of the barometric altimeter to synchronize and ascertain the correct MSL altitude.

Departure Procedures From a STOP Airport

General

Airports with weather deficiencies are likely to not have instrument departure procedures (i.e., a Standard Instrument Departure (SID) or Obstacle Departure Procedure (ODP)).

Departures

Departures from airports with weather deficiencies are done in VFR until reaching the minimum IFR altitude. Where an ODP is published, it is briefed immediately before departure and adhered to as published until:

• A safe altitude is reached,
• The flight has joined the IFR structure, or
• The flight is in VMC where the terrain and obstacles are clearly identified and avoided by a minimum of 1,000 ft.

Departure Data

Departure data is determined using reported METAR elements. When elements are missing, weather data elements are obtained from portable weather observation device or estimation techniques (see Section D.2.3).

Training for Dispatchers, Flight Followers, and Flightcrew

General

The training curriculum ensures that the dispatcher, flight follower, and flightcrew learn and are able to demonstrate understanding of the following policies and procedures associated with STOP:

• When the program applies.
• The requirements for releasing flights under the program.
• A proven understanding about the pilot and management notification requirements when a flight is released under the program.

The STOP training is required for both initial and annual recurrent training events. Documentation of both initial and annual recurrent training is maintained for each individual.

Introduction for Dispatchers and Flight Followers

Introduction to STOP training for dispatchers and flight followers covers the following topics:

• Regulatory basis for the approved program.
• Minimum weather requirements.
• Dispatch and flight following procedures in accordance with STOP.
• Verification of need for STOP.
• Notification and approval requirements.
• Contents of the weather package.
• Civil twilight or nighttime operational requirements.
• Fuel requirements.
• Briefing requirements.
• Airport risk assessment, strip check, or airport condition report.
• Flight operation in accordance with STOP.
• Airport and runway requirements.
• Operations in Class G Airspace.
• Portable weather observation devices.
• Usage.
• Storage.
• Weather Device Observation Log.

Introduction for Flightcrews

Introduction to STOP training for flightcrews covers the following topics:

• Regulatory basis for the approved program.
• Flightcrew member procedures in accordance with STOP.
• Verification of a need for STOP.
• Notification and approval requirements.
• Weather and daylight requirements (or lighting).
• Fuel requirements—inclusion of 15 minutes additional fuel for airport survey.
• Briefing requirements, including pictorials as available and risk assessment factors, in accordance with § 121.463 route qualification.
• Flight operation in accordance with STOP.
• Flight planning (IFR and/or VFR).
• Airport and runway requirements.
• Operations in Class G Airspace.
• Operations within 50 NM of the departure point.
• Operations 50 NM from the IFR en route system.
• Operations when an approach is not possible (diversion).
• Required communications during STOP.
• Use of portable weather observation devices.
• Storage of devices.
• Weather Device Observation Log.
• Classroom training with devices.
• Calibration training.
• Taking a weather observation and recording that information.

Approval

STOP programs are approved by the CH’s certificate management office (CMO).

The approved STOP program can be a standalone approved manual, or it may be incorporated into the CH’s accepted manual system.

Compliance Monitoring, Quality Assurance (QA), and Auditing

Compliance Monitoring

Compliance monitoring is intended to ensure, through a department audit, the following:

• The dispatcher, flight follower, and flightcrew comply with the procedures, provisions, and limitations of the STOP program.
• They all perform the process and procedures required to support the STOP,
• Compliance monitoring is documented, including the individual who conducted the audit and the date it was completed.

Quality Assurance (QA)

The QA process is an audit of the CH’s compliance in the use of STOP process and procedures. STOP procedure audits are conducted at the conclusion of each STOP flight by the CH’s designated individual. QA audits are documented with the individual who conducted the audit and the date it was completed.

STOP Audit

The contents of each STOP flight envelope are audited for compliance; to include procedures, weather reports, NWS and EWINS TAFs, manager approver signatures, and the portable weather observation log, as well as a complete audit of all flightplan paperwork. The STOP audit is documented with the individual who conducted the audit and the date it was completed.

All or any deficiencies identified as a result of the monitoring and QA audits are reported to the DO and followed through with the CH’s Safety Management System (SMS) program followup. If systemic deficiencies with the STOP procedures are identified, a plan for corrective action is developed. The evaluation of these discrepancies is conducted in accordance with the CH’s SMS program. For any identified deficiencies, an analysis is conducted to ascertain whether the deficiencies are addressed through Safety Risk Management (SRM) (per 14 CFR part 5, § 5.73(b)) or a correction (per § 5.75). If the root cause of the deficiencies is a shortfall in compliance with the designed operational process (e.g., required training was not completed), the deficiency is addressed through a correction (per § 5.75). However, if the deficiency is associated with the basic design of the control (e.g., inadequate training curriculum), the SRM process would be repeated to revise the procedure in the areas where it was found deficient (per § 5.73(b)). The performance, results, and corrective actions of these audits are measured at least annually through the company’s quality audit program.