Alternate Required?

[Palmpilot]

Only you have to be below the clouds first. So 2000-3 doesn't mean squat if you are stuck on top, can't be vectored below, and can't fly the approach. In this case, it's wiset to file to a nearby airport where you can fly the approach, break it off if possible in VFR conditions and transition to the VFR destination. I would file an alternate in any case to have my bases covered. What's the harm?

The ceiling in his scenario was above the minimum vectoring altitude, so getting below the clouds under IFR should not be a problem.

Remember, the 2000 in 2000-3 is AGL, while the minimum vectoring altitude of 2500 is MSL.

 

[chemgeek]

The ceiling in his scenario was above the minimum vectoring altitude, so getting below the clouds under IFR should not be a problem.

Remember, the 2000 in 2000-3 is AGL, while the minimum vectoring altitude of 2500 is MSL.

Assuming the weather stays that way. Weather has a funny way of not cooperating. If everything goes as planned, no one will be the wiser. If for some reason you don't encounter the anticipated VFR, then you will have some 'splaining to do to ATC while wandering around in the clag without an alternative plan.

Many years ago, in my pre-Garmin GPS days, I had a similar situation at my home field on a MVFR day. Our lone VOR approach was OTS (again), and I could not fly the overlay becuase I didn't have IFR-GPS. I was going to be above a pretty solid deck with VFR beneath, but how to get there? IIRC, I filed for Syracuse (where I could fly the ILS) and asked the friendly folks there to vector me over my home field at the MVA on the way in (it was more or less on my route to SYR from the south), and I broke out in time to cancel and land at home VFR. ATC was happy. I was happy. It never crossed my mind to file for home and then figure out what happens if I wasn't VFR and couldn't fly the approach. Most importantly, I didn't mislead ATC into thinking I was able to fly the approach, which is what they would assume if I filed to my home field.

Cheers.

 

[Palmpilot]

Assuming the weather stays that way. Weather has a funny way of not cooperating. If everything goes as planned, no one will be the wiser. If for some reason you don't encounter the anticipated VFR, then you will have some 'splaining to do to ATC while wandering around in the clag without an alternative plan.

Why do you say "without an alternative plan"? I thought we established that filing an alternate was required.

As for explaining, I would think that "Field not in sight, so I need to divert to XYZ airport" would suffice.

Many years ago, in my pre-Garmin GPS days, I had a similar situation at my home field on a MVFR day. Our lone VOR approach was OTS (again), and I could not fly the overlay becuase I didn't have IFR-GPS. I was going to be above a pretty solid deck with VFR beneath, but how to get there? IIRC, I filed for Syracuse (where I could fly the ILS) and asked the friendly folks there to vector me over my home field at the MVA on the way in (it was more or less on my route to SYR from the south), and I broke out in time to cancel and land at home VFR. ATC was happy. I was happy. It never crossed my mind to file for home and then figure out what happens if I wasn't VFR and couldn't fly the approach. Most importantly, I didn't mislead ATC into thinking I was able to fly the approach, which is what they would assume if I filed to my home field.

If you filed /A, how would anyone have been misled? Was ATC unaware that the VOR approach was OTS?

In any case, if ATC gets the wrong idea about your capabilities, it's easy enough to provide them with the correct information.

 

[airheadpenguin]

That may be prudent thinking if you're planning on flying IFR somewhere that doesn't have an instrument approach, but it's not part of the regulation, MVA's are not part of standard flight publications, and I've never heard anyone in Flight Standards say it affects the answer to "Am I required to file an alternate?" OTOH, every DPE and Flight Standards person with whom I've discussed this says the ability to fly whatever approach is being considered does affect the answer. So, if you want to get this right on the practical test, I suggest deciding via the way I said.

I'm not sure I understand why this is in question, the expectation is that if you lose comms and in IMC you would be expected to fly from there to your first point of intended landing, and failing that TO YOUR FILED ALTERNATE. Now this does take a bit of a stretch of the imagination but if you did all of this and got to your alternate and you had no approach to fly what good have you exactly done yourself by fulfilling the requirement for filing an alternate? If you didn't lose comms and had to pick an alternate what good is it to have flight planned and briefed an alternate that you can't use? You would be better off to plan something doable so that when it comes up you're still ahead of the plane rather than scrambling to decide what you're really going to do as an audible.

The whole system is based on pilots accepting clearances they can fly with the equipment onboard.

 

[Palmpilot]

I'm not sure I understand why this is in question, the expectation is that if you lose comms and in IMC you would be expected to fly from there to your first point of intended landing, and failing that TO YOUR FILED ALTERNATE.

I don't see any mention in 91.185 of flying to your filed alternate. And as for what is expected, I have been told that ATC doesn't even know what your filed alternate is.

Your fuel planning is required to be based on flying to your filed alternate, if one is required, after reaching your original destination, but conditions can change during the course of a flight.

 

[poadeleted20]

In the OP's scenario, I'm not seeing how other operations would be interfered with. He postulated weather that was above the MIA, MVA, and some of the MEAs in the area, and good enough for visual approaches. Under those conditions, wouldn't ATC likely be offering visual approaches to everyone?

Sure, but I was responding to the comment about the legal min for visuals being 1000-3 -- with weather that low, it may be legal, but it generally isn't practical.

 

[poadeleted20]

I'm not sure I understand why this is in question, the expectation is that if you lose comms and in IMC you would be expected to fly from there to your first point of intended landing, and failing that TO YOUR FILED ALTERNATE.

That last part isn't true. There is no expectation whatsoever regarding where you'd go if you lose comm and then don't get in at your destination. ATC doesn't even know what your filed alternate is unless they contact FSS to get it dug out of the computer, and even then, there is no FAR requirement, AIM suggestion, or ATC Handbook guidance to controllers that your filed alternate is where you would or should go.

Anyway, given all the constraints involved in picking an alternate, and the fact that many hours may have passed since that decision was made, odds are not very good that it would be the best/safest choice at that point in time. If that actually happens, you should be picking the best option based on all the information you have at that point, not blindly following a decision made many hours ago on even older information.

 

[tomf188]

For the record, I tend to agree with Ron's answer but have no intention of getting clarification from the Chief Counsel. Mostly, it's an exercise in "what if" by a new IR pilot. But, truthfully, I do plan to file/fly KMWC MTW 3D2 and just wasn't clear whether an alternate was required or not (while obviously knowing that it's a good idea to have an option with an approach I'm capable of flying).

Why would you even hesitate to file an alternate? One with a long runway and an ILS that you could land at if the weather turns bad and you lose comms? Is this just an intellectual exercise? I don't understand why you would even contemplate not filing an alternate, whether it was required by the regs or not?

 

[poadeleted20]

Why would you even hesitate to file an alternate? One with a long runway and an ILS that you could land at if the weather turns bad and you lose comms? Is this just an intellectual exercise? I don't understand why you would even contemplate not filing an alternate, whether it was required by the regs or not?

Because filing an alternate does nothing other than fill a regulatory square in the flight planning process. Your filed alternate has no operational meaning after you hit the "File" button on your flight planner, and it definitely has nothing to do with lost comm procedures.

The only reason the FAA has the alternate requirement at all is to force pilots to carry enough fuel to have some viable options in case they can't land at their destination. It has nothing to do with lost comm. If pilots were all smart and foresighted, this regulation probably wouldn't exist -- all pilots would make sure they carried enough fuel that a problem at their destination wouldn't put them squarely behind the 8-ball. However, as with many (or even most) FAA regulations, this one exists because the FAA (or maybe it was the CAA when this got started) got tired of pilots running out of gas after the first unforecast problem, and they wrote a rule forcing pilots to plan more intelligently.

So, file all the alternates you want. However, nobody but the Inspector investigating the crash will ever look to see or care what you put in that box unless you run yourself out of gas on the ensuing flight.

 

[gismo]

Sure, if he's in VMC at that point. At 2500 MSL a 2000 foot ceiling could put him 273 feet below clouds in Class E airspace. He could have full view of the airport below but be unable to legally descend to it.

I don't believe that one needs to be in VFR conditions (i.e. 500 ft below the clouds in class E) to complete a visual approach assuming you haven't cancelled IFR. Are you implying otherwise?

 

[poadeleted20]

I don't believe that one needs to be in VFR conditions (i.e. 500 ft below the clouds in class E) to complete a visual approach assuming you haven't cancelled IFR.

You are correct. Legally, you need only have 1000-3 at the destination airport, have the airport in sight, and be able to remain clear of clouds while you fly it. However, regardless of the rules which apply to pilots, I believe controllers are not supposed to be offering vectors to the visual approach unless the ceiling is 500 above the MVA.

 

[Palmpilot]

Sure, but I was responding to the comment about the legal min for visuals being 1000-3 -- with weather that low, it may be legal, but it generally isn't practical.

You certainly have a lot more experience than I do, and what you're saying sounds reasonable.

 

[tomf188]

Because filing an alternate does nothing other than fill a regulatory square in the flight planning process. Your filed alternate has no operational meaning after you hit the "File" button on your flight planner, and it definitely has nothing to do with lost comm procedures.

The only reason the FAA has the alternate requirement at all is to force pilots to carry enough fuel to have some viable options in case they can't land at their destination. It has nothing to do with lost comm. If pilots were all smart and foresighted, this regulation probably wouldn't exist -- all pilots would make sure they carried enough fuel that a problem at their destination wouldn't put them squarely behind the 8-ball. However, as with many (or even most) FAA regulations, this one exists because the FAA (or maybe it was the CAA when this got started) got tired of pilots running out of gas after the first unforecast problem, and they wrote a rule forcing pilots to plan more intelligently.

So, file all the alternates you want. However, nobody but the Inspector investigating the crash will ever look to see or care what you put in that box unless you run yourself out of gas on the ensuing flight.

Or maybe there wouldn't have been a crash if I had planned for (and maybe even filed) a well thought out alternate.

I agree that lost comms are an entirely different issue so let's put that aside. The point is that it's prudent planning so why not do it? (And I'm talking about the planning, not the filing). And then once you've done it, why not put it in the flight plan?

 

[poadeleted20]

Or maybe there wouldn't have been a crash if I had planned for (and maybe even filed) a well thought out alternate.

Exactly my point regarding good planning -- do it right, and nobody will ever look.

I agree that lost comms are an entirely different issue so let's put that aside. The point is that it's prudent planning so why not do it? (And I'm talking about the planning, not the filing).

Sure, and if everyone always did, that regulation probably wouldn't exist.

And then once you've done it, why not put it in the flight plan?

Because what I would actually plan to do and what meets the FAA alternate rules may not be the same thing at all. Also, there may be situations when filing a non-required legal alternate would make it impossible to make the flight.

 

[Jaybird180]

Exactly my point regarding good planning -- do it right, and nobody will ever look.
Sure, and if everyone always did, that regulation probably wouldn't exist.
Because what I would actually plan to do and what meets the FAA alternate rules may not be the same thing at all. Also, there may be situations when filing a non-required legal alternate would make it impossible to make the flight.

Do tell.

 

[roncachamp]

I'm not sure I understand why this is in question, the expectation is that if you lose comms and in IMC you would be expected to fly from there to your first point of intended landing, and failing that TO YOUR FILED ALTERNATE. Now this does take a bit of a stretch of the imagination but if you did all of this and got to your alternate and you had no approach to fly what good have you exactly done yourself by fulfilling the requirement for filing an alternate? If you didn't lose comms and had to pick an alternate what good is it to have flight planned and briefed an alternate that you can't use? You would be better off to plan something doable so that when it comes up you're still ahead of the plane rather than scrambling to decide what you're really going to do as an audible.

Whose expectation is that? ATC's? They don't receive your filed alternate.

 

[roncachamp]

I don't believe that one needs to be in VFR conditions (i.e. 500 ft below the clouds in class E) to complete a visual approach assuming you haven't cancelled IFR. Are you implying otherwise?

You are correct and I did not intend to imply otherwise.

 

[flyingron]

Why would you file to an airport that's not your destination? That's silly. I fly out of a grass strip with no approaches. My listed alternate has an ILS and has 600-2 (at least) but it's only 5 miles away. If I can't get into the grass strip with the visual, I divert to the alternate (and either wait it out or go VFR once I arrive there).

That's sort of a weak thing because if I had filed to the alternate field as the destination, the nearest next suitable alternate would be 20 miles away. I always plan for that much fuel even if the FAA doesn't care if I do.

If you file to some place that's not your destination it technically violates the rules and you have some splainin' to do when you switch your destination (unless you just want to cancel IFR).

Of course, on the other hand getting FF, I always tell them I'm going to SVH. The controllers seem incapable of handling NC26 as a FF destination. Similarly when I was based at VKX I always told distant controllers I was going to ADW. When I got down over ADW, the controller there would just ask "Potomac or Hyde?"

 

[poadeleted20]

Do tell.

Imagine you're filing to an airport a long way off out in the Western US where airports are often far apart. Weather is expected to be 2500-5 pretty much everywhere, and your destination has several good approaches you can fly. However, it's a long way to the next airport and while you can fly the approaches at that other airport, they are all labeled A-NA because there's no weather reporting there, and the MEA there is 2800 AGL. The next airport that meets legal alternate criteria is so far away that if you file it as an alternate you won't have fuel to the destination, then to filed alternate, then 45 minutes reserve. So, if you don't file an alternate, you can file legally and you've got plenty of gas to get from departure to destination to the A-NA airport, but if you insist on filing an alternate even though one isn't required, you can't make the flight legally.

 

[Velocity173]

I don't see any mention in 91.185 of flying to your filed alternate. And as for what is expected, I have been told that ATC doesn't even know what your filed alternate is.

Your fuel planning is required to be based on flying to your filed alternate, if one is required, after reaching your original destination, but conditions can change during the course of a flight.

Correct. Go to any airport that suites your needs if you go missed. Could be the alternate but conditions could have changed and allow a different field to divert to.

Yes, ATC doesn't know the alternate. Years ago while working approach (NBC) I had 4 F-5s inbound to the field. SAV said they had enough fuel to do one approach and if they couldn't get in, divert to CHS. Each one was straight into the field for the PAR rwy 5 and each one went missed and continued straight ahead to CHS. I had no idea what their alternate was. Just threw the strip to flight data and had him amend each one with CHS as the destination. Gave CHS a heads up to so they wouldn't be caught off guard.

 

[RussR]

With that said, is there a guidebook, that describes (TERPS???) the location of each /G waypoint in a manner other than Lat/Long?

Figured I'd go ahead and answer this question, since it hasn't been yet (that I saw).

No, the location of a GPS waypoint is not generally also defined by any other means than lat/long. If you're asking whether you can find a GPS waypoint, then look at a reference to see what it is in terms of radial/DME from a nearby NAVAID, that's generally not possible.

Sometimes it is, if the waypoint is also used on a ground-based procedure. But otherwise, no.

Every navigational fix is documented by the FAA on FAA Form 8260-2, but as far as I know these forms are not readily available to the public, except when it is part of the coordination package for a new procedure published on the FAA's Instrument Flight Procedures Gateway:

https://www.faa.gov/air_traffic/flight_info/aeronav/procedures/

 

[Jaybird180]

Imagine you're filing to an airport a long way off out in the Western US where airports are often far apart. Weather is expected to be 2500-5 pretty much everywhere, and your destination has several good approaches you can fly. However, it's a long way to the next airport and while you can fly the approaches at that other airport, they are all labeled A-NA because there's no weather reporting there, and the MEA there is 2800 AGL. The next airport that meets legal alternate criteria is so far away that if you file it as an alternate you won't have fuel to the destination, then to filed alternate, then 45 minutes reserve. So, if you don't file an alternate, you can file legally and you've got plenty of gas to get from departure to destination to the A-NA airport, but if you insist on filing an alternate even though one isn't required, you can't make the flight legally.

Hmph....wondering if this is a recipe for an eventual fuel starvation NTSB report.

 

[poadeleted20]

Hmph....wondering if this is a recipe for an eventual fuel starvation NTSB report.

I don't see why it would be, but I suppose if you try hard enough you can create a scenario where it could result in fuel exhaustion, but I could do the same with just about any basic situation you could come up with. If you do your job as PIC properly, it doesn't happen short of unforeseeable mechanical failure.

 

[matthammer]

I'm fairly certain that if TSHTF the FAA would violate you on the basis of 91.103 and 91.13 even if they didn't (or couldn't) go after you for 91.169. As I understand it, ATC can't see your alternate anyway. The .169 requirement is more there to make sure you've adequately planned for fuel and contingencies. If you ended up unable to get into your destination, and were able to land safely somewhere else without needing any special attention, I'm pretty sure the FAA would be none the wiser.

 

[Palmpilot]

I'm fairly certain that if TSHTF the FAA would violate you on the basis of 91.103 and 91.13 even if they didn't (or couldn't) go after you for 91.169. As I understand it, ATC can't see your alternate anyway. The .169 requirement is more there to make sure you've adequately planned for fuel and contingencies. If you ended up unable to get into your destination, and were able to land safely somewhere else without needing any special attention, I'm pretty sure the FAA would be none the wiser.

"None the wiser" implies that something sneaky is going on, but in the scenario that Cap'n Ron proposed, the regs are being complied with as written. And the fact that alternates within fuel range don't meet the requirements of 91.169 doesn't necessarily mean that they don't meet the requirements of 9.103 or 91.13.

 

[Jaybird180]

I don't see why it would be, but I suppose if you try hard enough you can create a scenario where it could result in fuel exhaustion, but I could do the same with just about any basic situation you could come up with. If you do your job as PIC properly, it doesn't happen short of unforeseeable mechanical failure.

In this scenario where 1hr before/after forecasts dont meet mins, necessitating filing an alternate, if you make that "go" decision, you've painted yourself into the getthereitis corner.

Edit- nevermind. I just reread everything

 

[poadeleted20]

In this scenario where 1hr before/after forecasts dont meet mins, necessitating filing an alternate, if you make that "go" decision, you've painted yourself into the getthereitis corner.

Edit- nevermind. I just reread everything

Guess you realized this question was about filing an alternate when one is not required.

 

[nosehair]

It totally blows my mind that someone would think that you don't need the "appropriate nav equipment " to fly the approach at destination to file ifr. The approach is part of the route if you're filing to the airport.

 

[mjburian]

It totally blows my mind that someone would think that you don't need the "appropriate nav equipment " to fly the approach at destination to file ifr. The approach is part of the route if you're filing to the airport.

Show me where it's required since that proof, in essence, is what the question was meant to produce. Again, I'm not suggesting it's a smart idea. But I also don't think it's illegal.

 

[poadeleted20]

Show me where it's required since that proof, in essence, is what the question was meant to produce. Again, I'm not suggesting it's a smart idea. But I also don't think it's illegal.

As I said, the only way to prove that as a matter of law would be in an interpretation from the FAA Chief Counsel, and AFAIK, this question has never been raised to that office. Feel free to write that letter if you "gots to know". But as stated repeatedly above, if it isn't that way, the regulation makes no sense at all, and while there are those who might argue otherwise about some specific issues, pretty much all the FAR's make sense from a safety perspective.

 

[roncachamp]

It totally blows my mind that someone would think that you don't need the "appropriate nav equipment " to fly the approach at destination to file ifr. The approach is part of the route if you're filing to the airport.

What about airports that have no IAPs? Can they be filed to under IFR?

 

[mjburian]

As I said, the only way to prove that as a matter of law would be in an interpretation from the FAA Chief Counsel, and AFAIK, this question has never been raised to that office. Feel free to write that letter if you "gots to know".

Nope. As I said, I have no intention of doing so. I initially assumed that I was missing something in the regs that explicitly required it but, after further research (including the discussion here), I'm satisfied that it's not addressed in the regs. And, as I said all along, I'm not sure it's a great idea to do it.

Which begs the question: What is the best/safest way to file/fly IFR from KMWC, end up at 3D2 and be /A (also without ADF) in this situation? Filing to KSUE is no better than filing to 3D2, since the only non-RNAV approach there is an SDF that requires an ADF. I could file to KMNM, but then I'm on the other side of a 13nm(ish) wide bay at or below 1500' AGL (ie, crossing the bay puts me out of gliding range in an engine out scenario). File to KGRB in hopes of getting underneath, cancel and scud run the rest of the way? There just doesn't seem to be a good option for this flight in MVFR conditions and the equipment I have on board.

 

[roncachamp]

Nope. As I said, I have no intention of doing so. I initially assumed that I was missing something in the regs that explicitly required it but, after further research (including the discussion here), I'm satisfied that it's not addressed in the regs. And, as I said all along, I'm not sure it's a great idea to do it.

Which begs the question: What is the best/safest way to file/fly IFR from KMWC, end up at 3D2 and be /A (also without ADF) in this situation? Filing to KSUE is no better than filing to 3D2, since the only non-RNAV approach there is an SDF that requires an ADF. I could file to KMNM, but then I'm on the other side of a 13nm(ish) wide bay at or below 1500' AGL (ie, crossing the bay puts me out of gliding range in an engine out scenario). File to KGRB in hopes of getting underneath, cancel and scud run the rest of the way? There just doesn't seem to be a good option for this flight in MVFR conditions and the equipment I have on board.

That's a rather unusual setup. Did your airplane have an ADF that crapped out?

Your best route in MVFR is probably I-43, WI-57, WI-42.

 

[mjburian]

That's a rather unusual setup. Did your airplane have an ADF that crapped out?

Your best route in MVFR is probably I-43, WI-57, WI-42.

LOL. Sounds like the best route to me.

Yeah, the old ADF quit working in the club plane and there was very little interest in repairing/replacing it.

 

[roncachamp]

Yeah, the old ADF quit working in the club plane and there was very little interest in repairing/replacing it.

Then you and the other members should think about adding a GPS. No ADF or GPS makes you unable to get into a lot of airports in crappy weather.

 

[mjburian]

Then you and the other members should think about adding a GPS. No ADF or GPS makes you unable to get into a lot of airports in crappy weather.

There have been some discussions about adding a GPS, but there are 15 voters and only 5 or 6 who actually fly it... so not very confident the decision will go the way I'd like.

 

[gismo]

Hmph....wondering if this is a recipe for an eventual fuel starvation NTSB report.

IMO, less so than following the rules (alternate and fuel planning wise) when the viable choices for an alternate landing site are limited to one or there's a widespread area of LIFR that could go below mins. Both are rare but they can happen. In Ron's example there were all sorts of viable alternative landing sites, just none that qualify as a legal alternate.

 

[poadeleted20]

Nope. As I said, I have no intention of doing so. I initially assumed that I was missing something in the regs that explicitly required it but, after further research (including the discussion here), I'm satisfied that it's not addressed in the regs. And, as I said all along, I'm not sure it's a great idea to do it.

Being legal is great, but at the end of the day, being smart and safe is more important than jus being legal.

Which begs the question: What is the best/safest way to file/fly IFR from KMWC, end up at 3D2 and be /A (also without ADF) in this situation?

Pick a day when you can be reasonably sure the weather will allow a visual approach. File BAE V217 GRB V7 MNM direct 3D2, with a suitable alternate (like KMNM, which has a VOR approach you can use for an alternate). The MEA around there is about 2500 MSL, so you'd need a forecast of a lowest significant cloud deck of about 3000 MSL (about 2400 AGL) to be reasonably sure of getting in either by seeing the airport for a visual approach or cancel IFR and land at 3D2 under VFR. You could also, in marginal VFR, file to KMNM, fly the ILS or VOR approach to get below the clouds, then go VFR underneath to 3D2.

Filing to KSUE is no better than filing to 3D2, since the only non-RNAV approach there is an SDF that requires an ADF.

Yeah -- that doesn't really help.

I could file to KMNM, but then I'm on the other side of a 13nm(ish) wide bay at or below 1500' AGL (ie, crossing the bay puts me out of gliding range in an engine out scenario).

That's something you'd have to decide for yourself based on your own risk tolerance.

File to KGRB in hopes of getting underneath, cancel and scud run the rest of the way? There just doesn't seem to be a good option for this flight in MVFR conditions and the equipment I have on board.

In MVFR? Probably not unless you are comfortable with more risk than it appears you are happy to accept.

Guess this is the excuse you need to get that GTN650.

Edit: But now I see this is not your decision alone to make.