IFR Planning Alternates with a Twist

Trogdor

Trogdor

Pre-takeoff checklist
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Trogdor
Can you file an airport as an alternative IF ALL of the IAPs are listed as “A NA” but the weather is clear and a million?

Yes, I know you can file a different airport, cancel, and fly VFR to the one you really want. But is it legal for planning purposes to use an airport where all the IAPs are “A NA” but the weather is severe clear.
 
You don’t need any approach at all if the field is vfr.

91.169
https://www.law.cornell.edu/cfr/text/14/91.169
(2) If no instrument approach procedure has been published in part 97 of this chapter and no special instrument approach procedure has been issued by the Administrator to the operator, for the alternate airport, the ceiling and visibility minima are those allowing descent from the MEA, approach, and landing under basic VFR.
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No. The filed alternate must have some instrument approach which is not listed as "not authorized as an alternate." I don't have anyhting from the FAA specifically saying so, but everything else I've read on the subject leads to that conclusion.
 
midlifeflyer said:
No. The filed alternate must have some instrument approach which is not listed as "not authorized as an alternate." I don't have anyhting from the FAA specifically saying so, but everything else I've read on the subject leads to that conclusion.
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Interesting Mark. Do you have any good reading on this? I Googled but most talk about 135 operations.

What’s odd is that means the airport in question can not be used as an alternative for planning purposes no matter the weather outside but if it had NO published IAPs you could use it (see Salty).

Seems minimally strange and somewhat non-sensical to a certain extent.
 
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@Salty The right guy over there isn’t actually crying - he is just trying to stay decent since he is shy! LOL!
 
Trogdor said:
Interesting Mark. Do you have any good reading on this? I Googled but most talk about 135 operations.

What’s odd is that means the airport in question can not be used as an alternative for planning purposes no matter the weather outside but if it had NO published IAPs you could use it (see Salty).

Seems minimally strange and somewhat non-sensical to a certain extent.
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I agree.
 
Trogdor said:
Interesting Mark. Do you have any good reading on this? I Googled but most talk about 135 operations.

What’s odd is that means the airport in question can not be used as an alternative for planning purposes no matter the weather outside but if it had NO published IAPs you could use it (see Salty).

Seems minimally strange and somewhat non-sensical to a certain extent.
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midlifeflyer said:
I agree.
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I was on my way out when I made that short reply. Since you are interested in what I think is mostly an academic question, here's what I got. Not much.

Among the discussions of alternate airports is the 2015 Collins letter (@John Collins may be by to discuss it in more detail). The scenario postulated is one where the pilot does not have the equipment necessary to fly the approaches available at the destination. For example, the destination only has RNAV approaches and the pilot has no RNP APCH equipment. The question was whether it was ok to file it as the destination so long as the alternate has approaches the pilot can fly. "No," said the Chief Counsel. 91.205 says you gotta have the equipment for the approaches at the destination.

It's kind of similar to your scenario, but reversed. The letter doesn't make a distinction based on the weather. So, based on the letter, in CAVU conditions (which I think is implicit in John's question), while you can file to an airport with no instrument approaches, you can't file to one with them if you don't have the "navigation equipment suitable for the route to be flown," (in this case to use the IAPs).

Just as "minimally strange and somewhat non-sensical to a certain extent." Solution is equal to the question. In each case, as applicable, file to a destination or choose an alternate with no instrument approach :D (I'll agree with "minimally" and "somewhat." If you try hard enough you can probably come up with something sort of rational.)
 
Trogdor said:
Can you file an airport as an alternative IF ALL of the IAPs are listed as “A NA” but the weather is clear and a million?

Yes, I know you can file a different airport, cancel, and fly VFR to the one you really want. But is it legal for planning purposes to use an airport where all the IAPs are “A NA” but the weather is severe clear.
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In Canada, alternate minima is part of IFR groundschool training, and it's almost guaranteed to come up in the ground portion of an IFR flight test or IPC. Is it not on the IFR syllabus in the U.S.?
 
David Megginson said:
In Canada, alternate minima is part of IFR groundschool training, and it's almost guaranteed to come up in the ground portion of an IFR flight test or IPC. Is it not on the IFR syllabus in the U.S.?
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It definitely is covered and will come up in a IR checkride (might or might not on an IPC - ours sound more limited from a pure regulatory sense than yours).

The basic US rules when you need a filed alternate, what the standard alternate minima are, and recognizing and checking for non-standard alternate/when an airport is not authorized to be used as a filed alternate, are well-covered. Some of the more nuanced (and arguably academic) scenarios, like this one, are more rare.

Here you have an airport which has instrument approaches all of which are no authorized for use as an alternate. The applicable regulation says, if there are IAPs for the airport, they must meet the minima specified for that airport. The same regulation says if there are no IAPs, then it just needs to be VFR.

(c) IFR alternate airport weather minima. Unless otherwise authorized by the Administrator, no person may include an alternate airport in an IFR flight plan unless appropriate weather reports or weather forecasts, or a combination of them, indicate that, at the estimated time of arrival at the alternate airport, the ceiling and visibility at that airport will be at or above the following weather minima:
(1) If an instrument approach procedure has been published in part 97 of this chapter, or a special instrument approach procedure has been issued by the Administrator to the operator, for that airport, the following minima:
(i) For aircraft other than helicopters: The alternate airport minima specified in that procedure, or if none are specified the following standard approach minima:
  1. (A) For a precision approach procedure. Ceiling 600 feet and visibility 2 statute miles.
  2. (B) For a nonprecision approach procedure. Ceiling 800 feet and visibility 2 statute miles.
(ii) For helicopters: Ceiling 200 feet above the minimum for the approach to be flown, and visibility at least 1 statute mile but never less than the minimum visibility for the approach to be flown, and​
(2) If no instrument approach procedure has been published in part 97 of this chapter and no special instrument approach procedure has been issued by the Administrator to the operator, for the alternate airport, the ceiling and visibility minima are those allowing descent from the MEA, approach, and landing under basic VFR.​

So, can you use the airport with IAPs as an alternate if the conditions there are CAVU but all the approaches are NA? Is the answer "No, even though you could file the VFR-only airport 5 miles away as an alternate." Or, "Yes, the 'no' answer is ridiculous."

I think your basic Canadian regulation is simpler, the Air Regulations deferring to the Air Pilot publication. So, do you have a Canadian answer to the scenario with an Air Pilot or other reference to where one can verify it?
 
Mark is spot on! Let me go read that letter.

EDIT: I read the letter. Very interesting. I agree with you @midlifeflyer that John's question was motivated by the fact that he *could* fly to the destination in VMC conditions despite not having any RNP APRCH capable equipment installed. But since 205 requires that the plane has all the necessary equipment to fly the route (*regardless of actual weather conditions*), he can't file it.

Given the above, I see why you would believe that the FAA would rule that you can't use an airport as a filing alternate if all of its approaches are "A NA" even if it is severe CAVOK. Wild.
 
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Canada's a bit different in that we always require an alternate for IFR, even in CAVU. Alternate minima depend on the number of usable approaches (their term), which means you have the equipment and the winds etc allow. Leaving out some details, it's

2 usable straight-in precision (not LPV): greater of 400-1 or 200-½ above lowest usable minima

1 usable straight-in precision: 600+2 or 700+1½ or 800+1 (or 300-1, etc, above lowest usable minima if greater)

Non-precision only usable: 800+2 or 900+1½ or 1,000+1 (or 300-1, etc, above lowest usable minima if greater)

No usable approaches: 500 ft above minimum usable IFR altitude that will allow VFR approach/landing (with TAF); 1,000 ft above min IFR altitude + 3 sm + no CB in forecast (relying on GFA only)

For the 18 years that I've had my IR, my rule has been not to launch unless my primary destination (or an airport within a few miles of it) meets alternate minima. For a single pilot in a single-engine piston, that has seemed like the right amount of caution. I've never had to go missed, but even with that extra caution, I've had ILS approaches when I saw only a couple of approach lights at 200 ft AGL, not the runway itself.
 
I sent a follow up question to the FAA General Counsel in June 2020 because they did not answer the questions I posed. The FAA General Counsel declined to respond, but forwarded my questions to Flight Standards, who quoted my exact question and gave a specific response. See the attached response.
 

Attachments

John Collins said:
I sent a follow up question to the FAA General Counsel in June 2020 because they did not answer the questions I posed. The FAA General Counsel declined to respond, but forwarded my questions to Flight Standards, who quoted my exact question and gave a specific response. See the attached response.
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Very interesting — thanks for sharing. So in the U.S. if your destination airport had one RNAV approach but your plane wasn't equipped with an IFR GPS, you would not be allowed to file IFR to it even if the destination were forecasting CAVU? But you would be allowed to file IFR to an airport 5 nm away that didn't have any IAPs at all?

I'm not aware of any similar rule in Canada, but I'm just a PPL (+night +instrument). Perhaps any Canadian ATPs or instructors in this forum — who will have spent more time heads-down in the CARs — could confirm.
 
John Collins said:
I sent a follow up question to the FAA General Counsel in June 2020 because they did not answer the questions I posed. The FAA General Counsel declined to respond, but forwarded my questions to Flight Standards, who quoted my exact question and gave a specific response. See the attached response.
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Ah, the new Chief Counsel policy at work.

The Office of the Chief Counsel has reviewed its policy for responding to requests for interpretation submitted to the agency from members of the public. Effective immediately, only those requests that present a novel or legally significant issue, as determined by the Chief Counsel, will be considered as potentially warranting a legal interpretation. Each person submitting a request will be notified whether the FAA accepts the request for an interpretation.​

aka, "Y'know, we've answered this already, so we forwarded it to Flight Standards."
 
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