Filing to the IAF

[Dave Siciliano]

We had a lengthy discussion in the past of where to file to when IFR. Is there some guidance that states what point one should file to at the destination? I know we discussed filing to the IAF as opposed to the airport, and that Don Brown and some others advocated filing to the IAF. The discussion has come up again and I'm looking for references.

Best,

Dave

 

[alaskaflyer]

Oh boy.

If you are brave enough there have been several discussions on the Red Board about this lately. Relevant FAR's and other guidance were discussed. However, at the moment I can't seem to access threads older than 9/1, and the search tool on the Red Board is about as useless as a hacked iPhone.

 

[alaskaflyer]

That being said, I think this reference in the AIM is one of the more key issues. It probably needs to be updated with a thought to today's technology and ATC practice, but it is still there.

5-1-8 c. Direct Flights

1. All or any portions of the route which will not be flown on the radials or courses of established airways or routes, such as direct route flights, must be defined by indicating the radio fixes over which the flight will pass. Fixes selected to define the route shall be those over which the position of the aircraft can be accurately determined. Such fixes automatically become compulsory reporting points for the flight, unless advised otherwise by ATC. Only those navigational aids established for use in a particular structure; i.e., in the low or high structures, may be used to define the en route phase of a direct flight within that altitude structure.

 

[ScottM]

5-1-8 c. Direct Flights

1. All or any portions of the route which will not be flown on the radials or courses of established airways or routes, such as direct route flights, must be defined by indicating the radio fixes over which the flight will pass. Fixes selected to define the route shall be those over which the position of the aircraft can be accurately determined. Such fixes automatically become compulsory reporting points for the flight, unless advised otherwise by ATC. Only those navigational aids established for use in a particular structure; i.e., in the low or high structures, may be used to define the en route phase of a direct flight within that altitude structure.

That is all fine and dandy but I still get 10c RV to EON direct KSMD from the ATC computer when I want to go to Fort Wayne. No matter what I file that is what I get. The leg form EON to KSMD is about 100NM and none of it will go over a nav aid. I have tried filling to the IAF for the GPS approach into KSMD but the computer always over rules me. When I get handed off to Fort Wayne approach I request the GPS approach and direct to the IAF.

What I try to do for other flights is just pick a nav aid close to the destination, hopefully one that is used by some of the approaches into my desired destination.

 

[poadeleted20]

It doesn't matter at all unless you lose comm. In any other case, you'll always end up flying a route you can fly, getting either a clearance via a route you can navigate yourself to an IAF, vectors to final, or a navigable routing or vectors to a position from which you can see the airport and fly a visual approach. So, what happens if you lose comm?

Assuming you're not in VMC (in which case you remain in VMC and fly under VFR to the nearest practicable airport, land, and call ATC on the phone), the 91.185(c) tells you to fly the route you were cleared/expected/filed. If that route is one you can fly with your own onboard equipment, and leads to/through an IAF for an approach you can fly, it's easy -- you fly that route to that IAF, hold there until your ETE runs out, descend to the IAF altitude, shoot the approach, and land. If your route does not take you to/through an IAF, but does take you through a transition/feeder fix, you go to that fix and straight on to the IAF from which the approach commences, hold there until your ETE runs out, descend to the IAF altitude, shoot the approach, and land. See 91.185(c)(3) for details.

But what if your route does not take you to an IAF or transition/feeder fix that leads to an IAF? Or your route goes direct to an airport with no navaid (and you don't a nav system that allows navigating directly to that airport from your last fix before the airport)? Now where do you go if you lose comm? Obviously you'll do whatever you have to do to get on the ground safely (with 91.3(b) to back you up if you're questioned on any deviation from 91.185), but ATC has a problem, too, trying to guess where you'll go (so they can get other aircraft out of your way), since it's hard to predict what you'll do since the regulatory procedure doesn't cover that part -- you don't have a means to go to the clearance limit and then to an IAF without first going somewhere else (which you will choose in the cockpit but be unable to tell ATC).

For those reasons, particularly if you don't have a point-to-point nav system like an IFR GPS aboard, ATC has the best idea of what to expect from you in event of lost comm if you file to your destination through an IAF to which you can navigate with only your onboard equipment. However, other than in a lost comm situation (and how often does it happen that some loses all communication with the ground including cell phone/handheld but still has navigational capability?), it doesn't really matter.

 

[Dave Siciliano]

It doesn't matter at all unless you lose comm. In any other case, you'll always end up flying a route you can fly, getting either a clearance via a route you can navigate yourself to an IAF, vectors to final, or a navigable routing or vectors to a position from which you can see the airport and fly a visual approach. So, what happens if you lose comm?

Assuming you're not in VMC (in which case you remain in VMC and fly under VFR to the nearest practicable airport, land, and call ATC on the phone), the 91.185(c) tells you to fly the route you were cleared/expected/filed. If that route is one you can fly with your own onboard equipment, and leads to/through an IAF for an approach you can fly, it's easy -- you fly that route to that IAF, hold there until your ETE runs out, descend to the IAF altitude, shoot the approach, and land. If your route does not take you to/through an IAF, but does take you through a transition/feeder fix, you go to that fix and straight on to the IAF from which the approach commences, hold there until your ETE runs out, descend to the IAF altitude, shoot the approach, and land. See 91.185(c)(3) for details.

But what if your route does not take you to an IAF or transition/feeder fix that leads to an IAF? Or your route goes direct to an airport with no navaid (and you don't a nav system that allows navigating directly to that airport from your last fix before the airport)? Now where do you go if you lose comm? Obviously you'll do whatever you have to do to get on the ground safely (with 91.3(b) to back you up if you're questioned on any deviation from 91.185), but ATC has a problem, too, trying to guess where you'll go (so they can get other aircraft out of your way), since it's hard to predict what you'll do since the regulatory procedure doesn't cover that part -- you don't have a means to go to the clearance limit and then to an IAF without first going somewhere else (which you will choose in the cockpit but be unable to tell ATC).

For those reasons, particularly if you don't have a point-to-point nav system like an IFR GPS aboard, ATC has the best idea of what to expect from you in event of lost comm if you file to your destination through an IAF to which you can navigate with only your onboard equipment. However, other than in a lost comm situation (and how often does it happen that some loses all communication with the ground including cell phone/handheld but still has navigational capability?), it doesn't really matter.

Thanks Ron. Of course, a radar v. non-radar environment matters here when you do have com. One point a controller on another board is making is approach doesn't get the route you file. All they get on the strip is where you are coming from and when; so, they don't know if you did file to an IAF and will route you where ever they need the flow of traffic to go. Of course, NORDO, they would just have a general idea where you're headed because of where you are coming from. Even if you filed to an IAF, this controller is making the point he wouldn't know that and would have to clear airspace based on what he thought you would do. So, he doesn't understand why one would file there other than for terrain clearance off an airway. Direct flight, he doesn't understand at all. (By the way, this is a SoCal guy.)

Would you mind if I cross post to the Beechlist?

Best,

Dave

 

[alaskaflyer]

Thanks Ron. Of course, a radar v. non-radar environment matters here when you do have com. One point a controller on another board is making is approach doesn't get the route you file. All they get on the strip is where you are coming from and when; so, they don't know if you did file to an IAF and will route you where ever they need the flow of traffic to go. Of course, NORDO, they would just have a general idea where you're headed because of where you are coming from. Even if you filed to an IAF, this controller is making the point he wouldn't know that and would have to clear airspace based on what he thought you would do. So, he doesn't understand why one would file there other than for terrain clearance off an airway. Direct flight, he doesn't understand at all. (By the way, this is a SoCal guy.)

Would you mind if I cross post to the Beechlist?

Best,

Dave

Interesting. Seems as though the left hand of FAA might not be working with the right hand?

 

[TMetzinger]

Well, as I understand it, the practical side of things is that when you go NORDO, and squawk 7600, ATC will do their best to keep everyone out of your way. If you're cleared to the airport, even if your last cleared fix is a long way out, they're going to move the others around you so that you get the terminal airspace as you arrive. In that case I'd proceed towards the airport, and when I got close, I'd head direct to an IAF for my preferred approach.

Of course, as soon as you reach a point where you can land under VFR, you're supposed to squawk VFR (which lets ATC know you've got your own terrain/traffic avoidance - and to be honest I don't recall if that's spelled out anywhere) and land, and then give them a call. Just don't do it inside the ADIZ.

 

[Teller1900]

I dunno, we never files to an IAF around here...active runways and approaches change too frequently to keep up. We just file, for example KBOS-BOS-PSM-ENE-V1-KAUG or KLEB-CTR-NOBBI4-KLGA. If a controller wants us to go to an IAF, they'll give it to us, but we've never filed for one, and I've never gotten one explicitly in a clearance.

 

[Ed Guthrie]

...If that route is one you can fly with your own onboard equipment, and leads to/through an IAF for an approach you can fly, it's easy -- you fly that route to that IAF, hold there until your ETE runs out, descend to the IAF altitude, shoot the approach, and land. ...But what if your route does not take you to an IAF or transition/feeder fix that leads to an IAF? ...Now where do you go if you lose comm? ... ATC has a problem, too, trying to guess where you'll go (so they can get other aircraft out of your way), since it's hard to predict what you'll do since the regulatory procedure doesn't cover that part -- you don't have a means to go to the clearance limit and then to an IAF without first going somewhere else (which you will choose in the cockpit but be unable to tell ATC)... ATC has the best idea of what to expect from you in event of lost comm if you file to your destination through an IAF to which you can navigate with only your onboard equipment.

Given that you aren't bound to the approach that starts at the IAF you filed, ATC must guess where you'll go in either case (IAF filed or no). FWIW, I suspect ATC has this "guessing" thing worked out better than you do.

 

[Ed Guthrie]

I dunno, we never files to an IAF around here...active runways and approaches change too frequently to keep up. We just file, for example KBOS-BOS-PSM-ENE-V1-KAUG or KLEB-CTR-NOBBI4-KLGA. If a controller wants us to go to an IAF, they'll give it to us, but we've never filed for one, and I've never gotten one explicitly in a clearance.

Yep. And which IAF you filed (or even if you filed an IAF) is a mere trivia item when dealing with the lost com regulations once you receive a route clearance to the destination airport that doesn't include an IAF in the clearance route.

Perhaps one day Ron Levy will finally understand this concept.

Doubtful.

 

[TangoWhiskey]

One point a controller on another board is making is approach doesn't get the route you file. All they get on the strip is where you are coming from and when; they would just have a general idea where you're headed because of where you are coming from.

I've heard this before, and always wondered how the controller can safely tell you "proceed direct XYZ, then as filed" if he doesn't know what you filed!? The pictures I've seen of flight strips shows the route assigned/cleared.

I don't have time to read through it all now, but maybe this would shed some light.

http://www.faa.gov/airports_airtraffic/air_traffic/publications/atpubs/ATC/Chp2/atc0203.html

(I see now--I think--that you were saying the APPROACH controller doesn't get the route you filed, though CENTER would... is that what is being asserted?)

 

[ScottM]

Well, as I understand it, the practical side of things is that when you go NORDO, and squawk 7600, ATC will do their best to keep everyone out of your way.

I had a talk recently with a Chi-Cnt controller about squawking 7600 and 7700. It the context of the conversation was that we were discussing how to get ATC attention in an emergency. This controller said that if you are already squawking some code other than VFR, i.e. a flight following code or other code for IFR flight, there is no need to do a 7600 or 7700 as ATC is already tracking you and knows where you are.

Interesting as that is somewhat opposite from what we are taught.

 

[Ed Guthrie]

...Even if you filed to an IAF, this controller is making the point he wouldn't know that and would have to clear airspace based on what he thought you would do. So, he doesn't understand why one would file there other than for terrain clearance off an airway.

I believe the controller's point is simply that the lost com regs revolve around your actual clearance (specifically your clearance limit), not your filed route (especially some arbitrary point (IAF)) along that route. IOW, the controller can't see your filed route and furthermore your filed route doesn't matter with respect to lost com. (Bold for emphasis, not shouting.)

Ron's treatise assumes that your filed route matches your cleared route, and Ron's treatise further: 1. assumes that your clearance limit was the IAF you filed (doubtful in 99.9% of cases), and 2. significantly deviates from lost com procedures--IOW, causes ATC to "guess" what he's doing.

 

[poadeleted20]

Ron's treatise is based on the writings of and discussions with controllers as well as the regulations as published. Yes, it's true that each controller's strip only shows your currently cleared route (which may be "as filed"), but if the route was amended, it says so, and the controller can obtain your original route, although under 91.185, your currently cleared route takes precedence over your original route (unless you were foolish enough to accept a clearance short of your destination that does not either rejoin your filed route or include an expected routing).

As far as transponder codes, two points. First, squawking 7600 lets the controllers know you know you're lost comm, and alerts them to be ready for you to take appropriate action. If you stay on your original code, they can't be sure what you think is happening. Second, if you do lose comm, you have no way of being certain that you haven't lost your transponder, too, so don't count on it being a means to communicate with ATC -- you may be nothing but a primary radar return to them. In any event, regardless of 91.185, ATC will be rooting for you to land as soon as practical and will cheer when you do.

I won't get into it with Ed on the issue of what you are "bound" to do. 91.185(c) clearly states that if your clearance limit is a fix from which an approach starts, you fly that approach. At the same time, 91.3(b) says that in an emergency (and I consider lost comm in IMC a definite emergency) you can deviate from 91.185 (or any other section of Part 91) to the extent necessary to get on the ground safely. If you don't like the approach that starts at your clearance limit, don't fly it -- fly one you think gives you the best chance of a prompt, safe conclusion to the flight. You might even feel that landing short of your destination is the best plan, and given 91.7(b)'s mandate to discontinue your flight if your airplane becomes unairworthy (and without comm, your airplane is unairworthy for IFR flight), the FAA could hardly argue with you for doing that (even in IMC -- again, see 91.3(b)).

 

[ScottM]

As far as transponder codes, two points. First, squawking 7600 lets the controllers know you know you're lost comm, and alerts them to be ready for you to take appropriate action. If you stay on your original code, they can't be sure what you think is happening.

I am just letting you know what a center controller a group of pilots. In his view when you stop answering his calls you are lost comm, he need not have to see a 7600 to figure that out. He also stated that by going to 7600 they then would have to re-identify you causing additional work. I am just passing it on to you Ron. If you like call Chi Center and explain to them what they should be doing.

 

[poadeleted20]

I am just letting you know what a center controller a group of pilots. In his view when you stop answering his calls you are lost comm, he need not have to see a 7600 to figure that out. He also stated that by going to 7600 they then would have to re-identify you causing additional work. I am just passing it on to you Ron. If you like call Chi Center and explain to them what they should be doing.

If Chicago Center wants folks to squawk something other than 7600 in event of lost comm, they should send that suggestion to AFS-410 so it can be changed in the AIM Section 6-4-2a. Until then, they should keep that idea to themselves rather than try to make their own special unwritten Chicago ARTCC lost comm squaking procedure.

And if you have a name/phone number of the person at Chicago ARTCC who's putting out that word (PM or email to me), I'd be happy to say the same thing to him/her, with copies to the Safety Rep at Chicago ARTCC, AFS-410, and the Regional FAASTeam Manager.

 

[Dave Siciliano]

Scott:
There was an incident at D/FW recently where an AA pilot thought he might be low on fuel, asked for a immediate landing to a runway that was opposite the direction of traffic. The controller denied his request and directed him to follow the flow of traffic. The controller (and his super) later stated they didn't believe an emergency was declared.

Squawking 7700 or 7600 (what ever is appropriate) is a clear way to convey to the controllers that there is a real problem. It was one of the suggestions make in response to this event. Had the pilot either said "May Day", that he was declaring an emergency on the radio, or squawked 7700, it would have made it clear in everyone's mind there was an actual emergency.

Best,

Dave

 

[ScottM]

Scott:
There was an incident at D/FW recently where an AA pilot thought he might be low on fuel, asked for a immediate landing to a runway that was opposite the direction of traffic. The controller denied his request and directed him to follow the flow of traffic. The controller (and his super) later stated they didn't believe an emergency was declared.

Squawking 7700 or 7600 (what ever is appropriate) is a clear way to convey to the controllers that there is a real problem. It was one of the suggestions make in response to this event. Had the pilot either said "May Day", that he was declaring an emergency on the radio, or squawked 7700, it would have made it clear in everyone's mind there was an actual emergency.

Best,

Dave

I just passed on what was said by a controller at a safety seminar. Take it up with Chi Center they are the one that said it. I am not defending it. We all questioned it too. Their response was that if you followed the regulatory advice it just made more work for them and did not necessarily get you anything more than what you already had. In their view the emergency squawks were to get a controller attention. If you already have a discreet code then if you declare an emergency you have their attention. Not answering the radio gets their attention too!

BTW for that AA flight wasn't part of the problem that it was a trainee controller that did not understand the minimum fuel message and the AA captain never did declare and emergency?

And Ron, if Ed has gotten a bug up your bottom this morning take it out on him or call the FAA they would probably enjoy the call. The number is in the AFD BTW.

 

[Ed Guthrie]

...91.185(c) clearly states that if your clearance limit is a fix from which an approach starts, you fly that approach.

Ron, when was the last time you were cleared to anywhere but the destination airport? How often does that happen to you (cleared only to the last fix in your filed route)? Why is your treatise missing the proviso that the IAF must be the clearance limit rather than the destination airport as would usually be the case? IOW, you go through a great explanation of how to handle radio failure, yet your explanation is the wrong explanation for 99% of cases.

 

[wsuffa]

Ron, when was the last time you were cleared to anywhere but the destination airport? How often does that happen to you (cleared only to the last fix in your filed route)? Why is your treatise missing the proviso that the IAF must be the clearance limit rather than the destination airport as would usually be the case? IOW, you go through a great explanation of how to handle radio failure, yet your explanation is the wrong explanation for 99% of cases.

Not Ron, but I've gotten a clearance limit to the Stinson (SSF) VOR a number of times enroute to KSSF, along with an EFC time..... SSF is the approach fix for the (only) approach/es into KSSF.

 

[poadeleted20]

Ed, you have your idea of what a "clearance limit" is for these purposes (the destination airport to which you are cleared), and I have mine (the last fix in the "Route of Flight" portion of your flight plan or the last fix in your clearance if not "as filed"). The FAA has never ruled on it one way or the other, and it has never come up in an NTSB Opinion/Order. Given that many (if not most) airplanes flying IFR cannot navigate directly to the destination airport from the last fix in their route of flight, and it's pointless to do that anyway (you'd just have to turn around and go back to an IAF to fly an approach -- see "reductio ad absurdum" in any text on logic), I think it's pretty obvious what they intend; you disagree. If you want to take it up with the FAA Chief Counsel in order to get a definitive ruling, mighty fine, but I will not debate it further with you.

 

[ScottM]

Given that many (if not most) airplanes flying IFR cannot navigate directly to the destination airport from the last fix in their route of flight, and it's pointless to do that anyway (you'd just have to turn around and go back to an IAF to fly an approach -- see "reductio ad absurdum" in any text on logic), I think it's pretty obvious what they intend; you disagree. If you want to take it up with the FAA Chief Counsel in order to get a definitive ruling, mighty fine, but I will not debate it further with you.

I am asking for clarification on your point. I am familiar with the ATC guy from ZTL center that used to write for AvWeb on this and I want to compare opinions. I am not arguing with you. So no need to be defensive, ok??

For all these assumptions lets assume in IMC as is the destination airport

Are you saying that if I am cleared direct to the airport I should fly to the appropriate IAF for the approach I will fly even though that is not in my clearance?
OR

2. That I should alway have a cleared to IAF and not accept a direct to airport clearance?

OR

3. Just get on the ground ASAP?

This is one of those areas that I have run into where it seems the smartest thing to do is not what is in the regs. And let us keep the assumption that you stated earlier that a loss of comms in IMC is an emergency so deviate from the FARs away and still be legal. What I am trying to figure out is what is the right thing to do in the real world that gets you down safely and keeps you out of FAA jail.

Also if it is number 2 from above and I find out the winds have changed making the approach I wanted unsafe will ATC expect me to fly the safer approach even though it is not the IAF I filled?

 

[poadeleted20]

Are you saying that if I am cleared direct to the airport I should fly to the appropriate IAF for the approach I will fly even though that is not in my clearance?

No. Fly your clearance unless the situation dictates otherwise. But ATC will not clear you direct to the airport unless conditions are good enough for a visual approach, in which case if you lose comm, you follow 91.185(b), not 91.185(c).

2. That I should alway have a cleared to IAF and not accept a direct to airport clearance?

It's all situations. If you think you'll be able to take a visual approach, and you have the onboard means to navigate direct to the airport (onboard-systems-compatible navaid on the field or IFR GPS), a clearance direct to the airport is fine. If not, demand a vector to the visual, vectors to final, or a clearance that includes an IAF for an approach you can fly. Don't put yourself in a corner!

3. Just get on the ground ASAP?

If you lose comm, and you're in VMC, there is no question that 91.7(b) and 91.185(b) demand that you "land as soon as practicable." If you're in IMC, you have to use your 91.3(b) authority to make a choice between the then-conflicting demands of 91.7(b) and 91.185(c) to either land ASAPrac or continue to your destination.

This is one of those areas that I have run into where it seems the smartest thing to do is not what is in the regs.

As long as you remember that 91.3(b) trumps all other regs in Part 91, you are still doing "what is in the regs." Be smart, choose wisely, and keep the "skin, tin, ticket" priorities in mind. And remember that the sooner you're out of their hair, the happier ATC will be (and the less likely they'll be to file a Pilot Deviation report with the FSDO).

And let us keep the assumption that you stated earlier that a loss of comms in IMC is an emergency so deviate from the FARs away and still be legal. What I am trying to figure out is what is the right thing to do in the real world that gets you down safely and keeps you out of FAA jail.

I have never seen the FAA or the NTSB criticize the pilot for expediting his/her landing or otherwise second-guessing a safety-enhancing decision in an emergency situation. OTOH, I have repeatedly seen them take a pilot's ticket for unnecessarily extending a flight in an emergency situation.

Also if it is number 2 from above and I find out the winds have changed making the approach I wanted unsafe will ATC expect me to fly the safer approach even though it is not the IAF I filled?

It's hard to say what ATC will expect, but it's your responsibility as PIC to make the safest choice in the situation as it exists at the time. That's why we get the big bucks.

 

[ScottM]

No. Fly your clearance unless the situation dictates otherwise. But ATC will not clear you direct to the airport unless conditions are good enough for a visual approach, in which case if you lose comm, you follow 91.185(b), not 91.185(c).

This is the one that causes the most confusion for me. I often fly to KSMD and never, ever get cleared to an IAF even if the field is IFR. I always get EON direct to KSMD. The airport is over 100NM from EON.

 

[alaskaflyer]

This is the one that causes the most confusion for me. I often fly to KSMD and never, ever get cleared to an IAF even if the field is IFR. I always get EON direct to KSMD. The airport is over 100NM from EON.

From my limited viewpoint ATC "ASS"umes the presence of RNAV/GPS way too much these days. As if Garmin was handing out free 530's to all those budget Cessna and Piper owners.

 

[Everskyward]

No. Fly your clearance unless the situation dictates otherwise. But ATC will not clear you direct to the airport unless conditions are good enough for a visual approach

Sure they will. I've numerous times gotten "blah, blah departure, direct" in the initial clearance, even when it's halfway across the country where ATC doesn't have a clue about the weather, especially 3 hours in the future. I think the computer often spits out the clearance based on your departure and destination airports regardless of what you file. If you want something different you can negotiate for it but it's much easier to do after you are airborne. Also it's pretty common to get some complicated full-route clearance initially, then after you have spent 10 minutes loading it into your user-unfriendly GPS, get cleared "direct destination" a couple fixes down the road.

 

[ScottM]

From my limited viewpoint ATC "ASS"umes the presence of RNAV/GPS way too much these days. As if Garmin was handing out free 530's to all those budget Cessna and Piper owners.

Didn't you get yours yet?

 

[AWACSEng]

I had a talk recently with a Chi-Cnt controller about squawking 7600 and 7700. It the context of the conversation was that we were discussing how to get ATC attention in an emergency. This controller said that if you are already squawking some code other than VFR, i.e. a flight following code or other code for IFR flight, there is no need to do a 7600 or 7700 as ATC is already tracking you and knows where you are.

Interesting as that is somewhat opposite from what we are taught.

Whenever we declare an emergency, we do not squwak anything other than our assigned code. The only change is we tack on "emergency" to the end of our call sign.

 

[Ed Guthrie]

Ed, you have your idea of what a "clearance limit" is for these purposes (the destination airport to which you are cleared), and I have mine (the last fix in the "Route of Flight" portion of your flight plan or the last fix in your clearance if not "as filed"). The FAA has never ruled on it one way or the other, and it has never come up in an NTSB Opinion/Order. Given that many (if not most) airplanes flying IFR cannot navigate directly to the destination airport from the last fix in their route of flight, and it's pointless to do that anyway (you'd just have to turn around and go back to an IAF to fly an approach -- see "reductio ad absurdum" in any text on logic), I think it's pretty obvious what they intend; you disagree. If you want to take it up with the FAA Chief Counsel in order to get a definitive ruling, mighty fine, but I will not debate it further with you.

Ron, if you could find one, just one, FAA reference that supported your definition of "clearance limit" for any purpose you might have a leg to stand on, but as it is (you can't find such a reference) I suggest you contact FAA Flight Standards Divsion to discuss your unique theories.

 

[poadeleted20]

Ron, if you could find one, just one, FAA reference that supported your definition of "clearance limit" for any purpose you might have a leg to stand on, but as it is (you can't find such a reference) I suggest you contact FAA Flight Standards Divsion to discuss your unique theories.

Having taken this one through a lot of IR practical tests conducted by AFS personnel and their designees, and lacking any FAA Counsel interpretation either way, I'll stick with my theory unless/until the FAA Counsel says in writing that I'm wrong.

However, since it matters only if you lose all your comm with the ground (including cell phones and handhelds) but not your nav capability, and you're in IMC, and you don't encounter VMC anywhere before your destination, and you don't choose under 91.3(b)/91.7(b) to land as soon as practical (and I can't find any example of that happening in recent history), it is little more than a theoretical debate of what to do in a most unlikely circumstance, and not worth worrying about other than for getting through the IR oral, in which the examiners are looking more for a good safe decision than regulatory hair-splitting.

 

[Ed Guthrie]

... it is little more than a theoretical debate of what to do in a most unlikely circumstance, and not worth worrying about other than for getting through the IR oral, in which the examiners are looking more for a good safe decision than regulatory hair-splitting.

Which comment brings us full circle to the original question--should you/must you file and IAF as the final en route waypoint/fix? Fact is, either way you are going to ad lib at the final clearance route fix and treat that final en route fix as a "clearance limit". BTW, the point of this ad lib will be the issued clearance's final route fix, not necessarily the filed route's final en route fix (unless by serendipity they are one and the same). You will then ad lib per the lost com regulations, and since those regulations cover either possibility (IAF or not IAF) it really doesn't matter whether or not you file an IAF, nor is filing an IAF required.

BTW, since you insist on pulling the "experience" card, the above is also time tested in front of DPEs, controllers, etc., through multiple checkrides, etc., etc.

IOW, fluff your chest at someone else.

 

[flyingcheesehead]

Squawking 7700 or 7600 (what ever is appropriate) is a clear way to convey to the controllers that there is a real problem. It was one of the suggestions make in response to this event. Had the pilot either said "May Day", that he was declaring an emergency on the radio, or squawked 7700, it would have made it clear in everyone's mind there was an actual emergency.

I've also heard of planes with a declared emergency getting handed off and the receiving controller not getting the message that the plane had declared an emergency.

There's a video floating around of a large airliner sucking in a bird at rotation and having an engine fail, and they prepended "mayday" to their call sign - for example, "Tower, Mayday Speedbird 1234 blah blah blah." I kinda like that idea.

Part of the problem with taking what a single controller says as gospel is that they only have one perspective, whereas the system theoretically was designed with input from many perspectives. Maybe changing the squawk is one thing that that particular controller doesn't like, but overall it works better, possibly for the reasons Dave mentions.

 

[flyingcheesehead]

But ATC will not clear you direct to the airport unless conditions are good enough for a visual approach,

Huh? I don't ever remember NOT getting cleared "to xxx airport as filed..." or "to xxx airport via..." And I'm pretty sure that the clearance delivery guy isn't looking up the weather at my destination either, nor have I ever seen anything in the 7110.65 that suggests such a thing.

 

[flyingcheesehead]

From my limited viewpoint ATC "ASS"umes the presence of RNAV/GPS way too much these days. As if Garmin was handing out free 530's to all those budget Cessna and Piper owners.

Almost all the time, it seems... Just about every time I fly IFR without /G, I'm still getting overly helpful "cleared direct ..." clearances I have to refuse.

For instance, last night it went like this:

Me: "Williamsport Ground, Cherokee 284M IFR to 4B8 Robertson."
IPT Gnd: "Cherokee 284M, cleared to 4B8 via as filed JUDDS, climb and...."
(I was filed FQM V58 JUDDS)

A few minutes after being handed off to New York Center:

ZNY: "Cherokee 284M, upon reaching 7,000 cleared direct JUDDS."
Me: "284M, unable."
ZNY: "Cherokee 284M, cleared direct Lake Henry, then join V58 to JUDDS."
Me: "Direct Lake Henry V58 JUDDS, 284M"
(checking the DME to see if I was within the service volume yet - LHY was the next VOR on the airway so I was already direct there though not sure if I was within its service volume yet)
ZNY: "Uh, 284M, how are you currently navigating?"
Me: "Well, I'm on V58 just east of Williamsport."
ZNY: "Oh, uh, well then just continue on V58." (I was. )

 

[poadeleted20]

Huh? I don't ever remember NOT getting cleared "to xxx airport as filed..." or "to xxx airport via..." And I'm pretty sure that the clearance delivery guy isn't looking up the weather at my destination either, nor have I ever seen anything in the 7110.65 that suggests such a thing.

That's not "direct," i.e., "cleared present position direct XYZ airport," which is what I was talking about. "Cleared to xxx airport as filed" (unless you filed direct in the route of flight block) or "cleared to xxx airport via ABC VOR V*** DEF VOR" are not "direct."

 

[ghogue]

That's not "direct," i.e., "cleared present position direct XYZ airport," which is what I was talking about. "Cleared to xxx airport as filed" (unless you filed direct in the route of flight block) or "cleared to xxx airport via ABC VOR V*** DEF VOR" are not "direct."

Ron,
I rarely file direct to my destination airport, but several of my colleagues do so regularly. Usually unless we're into the Northeast or Chicago areas, we almost always are "cleared to XXX airport as filed", i.e., direct to the airport, without regard to the weather at the destination. It's not unusual, of course, to get an amendment to the route while airborne, but the original clearance is direct to the airport.

gary

 

[swamppilot]

I'm not sure I understand what all the fuss is about, but I"ll make a couple of observations. When you get your clearance for the first time, it is to the airport of destination (sometimes ATC may have to give you a short range clearance). That clearance includes AN approach at the destination airport. At that point it is any approach. As you progress in the flight, you get amended clearances, and at some point may be cleared DIRECT to the destination airport. Theses clearances still include a clearance for any approach (all this is assuming you will be on the guages down to breakout). Finally, at some point you receive yet another amended clearance which either takes you to an IAF (or a fix on a transition route to an IAF) or radar vectors to a final approach course. With all that in mind, why file to an IAF?

On the matter of the squawk. If you are already squawking a discreet (assigned by ATC and are being worked by ATC), the first priority is to verbally declare an emergency. Squawking emergency doesn't help very much, but if it makes you feel better goa ahead. the lost comm is different however. It's true that ATC will notice that you son't answer them, but what if they haven't needed to call you? How would the know you weren't answering. You,on the other hand might have called them and could not get an answer, or have noticed that the radios are very silent. now you squawk radio failure, and if your xponder is still working, ATC has a heads up.

 

[swamppilot]

I'm not sure I understand what all the fuss is about, but I"ll make a couple of observations. When you get your clearance for the first time, it is to the airport of destination (sometimes ATC may have to give you a short range clearance). That clearance includes AN approach at the destination airport. At that point it is any approach. As you progress in the flight, you get amended clearances, and at some point may be cleared DIRECT to the destination airport. Theses clearances still include a clearance for any approach (all this is assuming you will be on the guages down to breakout). Finally, at some point you receive yet another amended clearance which either takes you to an IAF (or a fix on a transition route to an IAF) or radar vectors to a final approach course. With all that in mind, why file to an IAF?

On the matter of the squawk. If you are already squawking a discreet (assigned by ATC and are being worked by ATC), the first priority is to verbally declare an emergency. Squawking emergency doesn't help very much, but if it makes you feel better goa ahead. the lost comm is different however. It's true that ATC will notice that you son't answer them, but what if they haven't needed to call you? How would the know you weren't answering. You,on the other hand might have called them and could not get an answer, or have noticed that the radios are very silent. now you squawk radio failure, and if your xponder is still working, ATC has a heads up.

 

[poadeleted20]

I rarely file direct to my destination airport, but several of my colleagues do so regularly. Usually unless we're into the Northeast or Chicago areas, we almost always are "cleared to XXX airport as filed", i.e., direct to the airport, without regard to the weather at the destination. It's not unusual, of course, to get an amendment to the route while airborne, but the original clearance is direct to the airport.

If you're /G (or otherwise equipped for point-to-point IFR flight), that's fine -- just remember that if you lose comm and don't get to VMC, and the airport isn't an IAF for the approach you want to fly, 91.185(c)(3)(ii) will require you to overfly the airport before proceeding to an IAF for the approach, which lengthens your flight, eating into your fuel reserves and extending the time you fly with a broke airplane. That said, 91.3(b) and 91.7(b) still give you the option of breaking off the direct->airport route and proceeding direct to the IAF for the approach you want to fly.