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CFI Practical Test Standards: Technical Subject Areas

AC 91-73B - Parts 91 and 135 Single Pilot, Flight School Procedures During Taxi Operations

This advisory circular (AC) provides guidelines for the development and implementation of standard operating procedures (SOP) for conducting safe aircraft operations during taxiing to avoid causing a runway incursion.

In accordance with the current edition of Federal Aviation Administration (FAA) Order 7050.1, Runway Safety Program, the definition of a runway incursion is, any occurrence at an aerodrome involving the incorrect presence of an aircraft, vehicle, or person on the protected area of a surface designated for the landing and takeoff of aircraft.

This AC is intended for use by persons operating aircraft single pilot under Title 14 of the Code of Federal Regulations (14 CFR) parts 91 and 135, and flight schools. The FAA recommends that these guidelines become an integral part of all SOPs, Flight Operations Manuals (FOM), and formal flight training programs.

  1. Background
  2. Use of Standard Operating Procedures
  3. Single-Pilot Procedures
    1. General
    2. Planning: Review Items
    3. Planning: Briefing Items
    4. Pilot/Passenger Communications
    5. Situational Awareness (SA)
    6. Use of Written Taxi Instructions
    7. ATC/Pilot Communication
    8. Taxiing
    9. Use of Exterior Aircraft Lights to Make Aircraft More Conspicuous

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Runway incursions are kind of a big deal with the FAA, and they put a lot of effort into tracking these events. They also spend a lot of time educating pilots on how to best avoid runway incursions.

Advisory Circular 91-73 emphasizes that Standard Operating Procedures (SOPs) are necessary in order to "lessen the exposure to hazards and risks by holding the pilot's workload to a minimum during taxi operations." Thus, the FAA sees a direct correlation between pilot workload and runway incursion events (rather than, for example, lack of training). SOPs are presented in 91.73 as a mitigating strategy.

SOPs are so important, in fact, that they are required:

  • During the certification and proficiency training;
  • During all phases of flight, including ground operations;
  • During flight reviews.

AC 91.73 emphasizes ground planning as part of the overall flight plan. This includes both "review items" and "briefing items."

  • Review items: Any changes made to regulatory and guidance information sources, as well as NOTAMs and ATIS.
  • Briefing items: Timing and execution of checklists, passenger brief, sterile cockpit, route of taxi.

CFIs are expected to instruct students on the use of airport diagrams.

Pilots should be alert for the possibility of receiving instructions other than what they expect. It's easy for a pilot to acknowledge an instruction without listening to it and then proceed based on prior expectations. "Pilots need to follow the clearance or instructions that are actually received, and not the ones they expected to receive."

After the entire aircraft crosses over the landing runway's hold short line, pilots should conduct after-landing checklist items before contacting ATC for taxi instructions. (If there is insufficient space on the stub taxiway, ATC may request that pilots position aircraft on a taxiway in the direction of travel, complete required checklist items, and then contact ground for a taxi clearance.)

AC 91.73 discourages the use of mobile phones and other electronic devices by "everyone present in the aircraft" during ground operations.

Situational Awareness (SA)

Situational Awareness (SA) during ground operations is described in AC 91.73 as a "continuous loop" between the aircraft's current location and the next critical location, such as an intersection or hot-spot. The AC notes that "many pilot errors occur when one or more pilots are off frequency or doing heads-down work, such as programming an FMS/GPS. Therefore, pilots should perform all high workload duties before beginning to taxi. Otherwise, performing these duties during taxi can have significant safety implications."

Increased awareness is required when taxiing between parallel runways.

Written taxi instructions can be used as a reference for reading back the instructions to ATC and as a means of confirming the taxi route and any restrictions during the airport surface taxi operation. This is especially true for complex instructions.

During low visibility conditions, all resources available should be used during taxi. Resources include the airport diagram, the heading indicators, and airport signs, markings, and lighting. Any time the pilot is uncertain of their location on the airport or during taxi, stop the aircraft and immediately advise ATC.

Aircraft lighting

AC 91.73 includes several guidelines on the use of aircraft lights.

  • Turn on the rotating beacon whenever an engine is running.
  • Prior to commencing taxi, turn on navigation, position, anti-collision, and logo lights, if available.
  • To signal intent to other pilots, consider turning on the taxi light when the aircraft is moving or intending to move on the ground, and turning it off when stopped or yielding or as a consideration to other pilots or ground personnel.
  • Strobe lights should not be illuminated during taxi if they will adversely affect the vision of other pilots or ground personnel.
  • All exterior lights should be illuminated when crossing a runway.

Caution: Pilots should consider any adverse effects to safety that illuminating the forward-facing lights will have on the vision of other pilots or ground personnel during runway crossings.

When entering a runway, either for takeoff or when taxiing into LUAW pilots should make their aircraft more conspicuous to aircraft on final behind them and to ATC by turning on all lights…

  • except for landing lights that highlight the aircraft's silhouette.
  • however, strobe lights should not be illuminated if they will adversely affect the vision of other pilots.


AC 91.73 includes a Pilot Briefing Card in the appendices. This would be good to use as reference material during the oral portion of the practical test.

AC 91.73 also includes best practices for flight schools and instructors, also in the appendices.

Practical Test Standards: Flight Instructor

II. Technical Subject Areas
Task B: Runway Incursion Avoidance


  1. Single Pilot, Flight School Procedures During Taxi Operations (AC 91-73)
  2. Chart Supplement – Airport/Facility Directory (A/FD)
  3. Aeronautical Information Manual (AIM)
  4. Risk Management Handbook (FAA-H-8083-2)
  5. Airplane Flying Handbook (FAA-H-8083-3)
  6. Pilot's Handbook of Aeronautical Knowledge (FAA-H-8083-25)

Note: If this task has been previously performed in the aircraft during an earlier instructor rating, the determination of the required knowledge can be demonstrated during the brief, at the discretion of the examiner.

Objective: To determine that the applicant exhibits instructional knowledge of the elements of runway incursion avoidance by describing:

  1. Distinct challenges and requirements during taxi operations not found in other phases of flight operations.
  2. Procedures for appropriate cockpit activities during taxiing including taxi route planning, briefing the location of hot spots, communicating and coordinating with ATC.
  3. Procedures for steering, maneuvering, maintaining taxiway, runway position, and situational awareness.
  4. The relevance/importance of hold lines.
  5. Procedures for ensuring the pilot maintains strict focus on the movement of the aircraft and ATC communications, including the elimination of all distractive activities (i.e. cell phone, texting, conversations with passengers) during aircraft taxi, takeoff and climb out to cruise altitude.
  6. Procedures for holding the pilot's workload to a minimum during taxi operations which should increase the pilot's awareness while taxiing.
  7. Taxi operation planning procedures, such as recording taxi instructions, reading back taxi clearances, and reviewing taxi routes on the airport diagram,
  8. Procedures for ensuring that clearance or instructions that are actually received are adhered to rather than the ones expected to be received.
  9. Procedures for maintaining/enhancing situational awareness when conducting taxi operations in relation to other aircraft operations in the vicinity as well as to other vehicles moving on the airport.
  10. Procedures for briefing if a landing rollout to a taxiway exit will place the pilot in close proximity to another runway which can result in a runway incursion.
  11. Appropriate after landing/taxi procedures in the event the aircraft is on a taxiway that is between parallel runways.
  12. Specific procedures for operations at an airport with an operating air traffic control tower, with emphasis on ATC communications and runway entry/crossing authorizations.
  13. ATC communications and pilot actions before takeoff, before landing, and after landing at towered and non- towered airports.
  14. Procedures unique to night operations.
  15. Operations at non-towered airports.
  16. Use of aircraft exterior lighting.
  17. Low visibility operations.

Flight Instructor Test Questions

When approaching taxiway holding lines from the side with continuous lines, the pilot should not cross the lines without ATC clearance.

What is the purpose of the runway hold position sign? Denotes entrance to a runway from a taxiway.

What is the purpose for the runway hold position sign on the taxiway? Holds aircraft short of the runway.

What does a destination sign identify? Direction to takeoff runways.

What is the purpose of the taxiway ending marker sign? Indicates taxiway does not continue beyond intersection.

What is the purpose of No Entry sign? Identifies paved area where aircraft are prohibited from entering.

What is the purpose of the yellow demarcation bar marking? Delineates runway with a displaced threshold from a blast pad, stopway, or taxiway that precedes the runway.
— A tricky question, since the threshold is denoted with a thick white bar. See image 14-6. The demarcation bar is a line preceding the blast pad.

When turning on to a taxiway from another taxiway, what is the purpose of the taxiway direction sign? Indicates designation and direction of taxiway leading out of an intersection.

What purpose does the taxiway location sign serve? Identifies taxiway on which the aircraft is located.

Oral Exam Questions

  1. What is the Advisory Circular issued by the FAA that discusses runway incursions and mitigation techniques?
  2. What does the FAA suggest all pilots utilize in order to mitigate the risk of runway incursions and other ground-operations incidents/accidents?
  3. What are examples of review items? What are briefing items?
  4. When should pilots complete after-landing checklist items?
  5. When should pilots write down taxi instructions?
  6. What lights should be used during ground operations?
  7. In what circumstances would certain lights not be used during ground operations?

Robert Wederquist   CP-ASEL - AGI - IGI
Commercial Pilot • Instrument Pilot
Advanced Ground Instructor • Instrument Ground Instructor

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