/U filing for an intersection as first waypoint

[dtuuri]

If the field were, say, 5 miles from the airway, would it be an illegal flight plan then, even though for sure the departure clearance would include a heading to intercept the airway?

If that is true then there are a lot of places, including my home field, where you're several miles from the nearest airway, but could easily track to V133 upon reaching the MEA.

I can give you some background that might help. In the original TERPS the departure assessment ended at MEA, see paragraph 1206 (1106?). Around change #18 or #20 or something they conclude the assessment at 25 NM (46 mountainous) instead. So, if your home drome was assessed back then, the first airway that a 200'/NM climb gradient could achieve MEA was as far as you'd dare go in that direction if relying on TERPS criteria for obstacle clearance. In your case, although V133 is beyond V103, the MEAs are the same and the two airways look like they merge/overlap so it would theoretically work.

If the diverse departure assessment is under the more recent change, then V133 is close to the 25 NM limit which means you'd have to acquire the centerline above MEA in a very narrow arc if relying on only TERPS obstacle clearance.

Whichever criteria was used, getting ATC to approve and their computer to accept is an entirely different matter. In Maine and upstate New York, Boston Center won't even clear aircraft along an airway overlying the airport (3B1) because it isn't within 30 NM of a VOR despite the diverse departure assessment.

Now, I'm not a TERPS expert, like Wally Roberts (aterpster), but have had a bunch of conversations with FAA TERPS people in the past over this very topic. If my memory is mistaken I hope someone will correct me for your sake, but right now that's how I believe it works.

dtuuri

 

[Velocity173]

Getting back to my previous post on the example route in the AIM: MDW V262 BDF V10 BRL STJ SLN GCK

I was studying the route today and was wondering, where would you all intercept V262 at?

 

[azure]

No, as long as the aircraft is cleared on a route they are capable of flying, then there shouldn't be a violation of 91.205. In cases where the filing system doesn't provide an option that the aircraft is capable of flying, you have to file something and negotiate an appropriate clearance you can accept.

Yes, that's kind of what I'm getting at. In your example, KRHP HRS is a routing that a /U aircraft can actually fly. In mine, KVLL POLAR is not. The system should accept it just fine (it accepted KHYA FREDO), but /U I would have to negotiate something that I can fly. KVLL SVM is flyable /U. So am I obligated to file something that I can fly if it is available, or can I say, I don't want to fly to SVM, I'll file to POLAR and negotiate a legal clearance? Obviously unless I accept something like "cleared direct POLAR" I haven't violated 91.205.

(Though again, if I accept "cleared to KTVC via radar vectors POLAR, V133 TVC", is that illegal because in case of lost comms before reaching POLAR I have no way to proceed direct POLAR? I can always intercept V133 and proceed to POLAR, but that was not my clearance.)

 

[azure]

Getting back to my previous post on the example route in the AIM: MDW V262 BDF V10 BRL STJ SLN GCK

I was studying the route today and was wondering, where would you all intercept V262 at?

You can't file that though. "Invalid entry to airway"

Maybe MDW JOT V262... ?

 

[dtuuri]

I was studying the route today and was wondering, where would you all intercept V262 at?

At the AIM Twilight Zone where V44 takes you to SWANN:

EXAMPLE−
BWI V44 SWANN V433 DQO​

dtuuri

 

[Jaybird180]

 

[Velocity173]

You can't file that though. "Invalid entry to airway"

Maybe MDW JOT V262... ?

That's what I was thinking. V262 takes a bend before it even goes to BDF. That's a huge piece of sky to go to. JOT V262 makes the most sense. I wondering if anyone proof reads these AIM examples to see that they actually work in the real world.

 

[John Collins]

Whichever criteria was used, getting ATC to approve and their computer to accept is an entirely different matter. In Maine and upstate New York, Boston Center won't even clear aircraft along an airway overlying the airport (3B1) because it isn't within 30 NM of a VOR despite the diverse departure assessment.

dtuuri

Dave,

The service volume issue for the VOR is 40 NM (not 30 NM). All centers are obligated to follow the rules that Boston Center follows, they just decided on their own not to. Back in Feb, the rules changed. They were being enforced by whatever center handles North Dakota. It caused emails to be sent to numerous airport operators that they would no longer be allowing IFR departures. Several were on Indian reservations. Senator Thune got involved and the FAA broke loose an update to the policy for GPS equipped aircraft. It had been making its way thru the system for at least 3 years. This provides relief for GPS equipped aircraft, but is still a problem for /U. Here is what resulted and is now in effect. BTW, Boston center follows these rules.

N JO 7110.613 FEDERAL AVIATION ADMINISTRATION Air Traffic Organization Policy Effective Date: February 20, 2013
Cancellation Date: February 19, 2014
SUBJ: Exception for GNSS-Equipped Departures

...

5. Procedures. JO 7110.65, Paragraph 4-1-1, Altitude and Distance Limitations, is revised by adding the following EXCEPTION and NOTE, to the end of the text of the paragraph and before the REFERENCE. The tables and figures for Paragraph 4-1-1- remain unchanged.
EXCEPTION
Notwithstanding requirements for radar separation or radar monitoring of RNAV aircraft on random (impromptu) routes at FL 450 and below as specified in JO 7110.65, Air Traffic Control, the altitude and distance limitations of this paragraph do not apply to GNSS-equipped aircraft departing from an airport, under the following conditions:
a. The GNSS-equipped departure must be cleared via, or reported to be established on, point-to-point route segments.
b. The points must be published NAVAIDs, waypoints, fixes or airports recallable from the aircraft’s navigation database. The points must be displayed on controller video maps or depicted on the controller chart displayed at the control position. The maximum distance between points when applying non-radar separation must not exceed 500 miles.
c. Protect 4 miles either side of the route centerline.
d. Assigned altitude must be at or above the highest MIA along the projected route segment being flown, including the protected airspace of that route segment.

NOTE
1. GNSS-equipped aircraft may be determined by /G or /L equipment suffix, examination of the ICAO equipment field, or pilot advisory that the aircraft is GNSS-equipped.
2. At airports that have a published RNAV Departure Procedure (DP) (i.e. RNAV SID) that includes a transition to the en route structure or RNAV graphic Obstacle Departure Procedure (ODP), GNSS-equipped aircraft may receive IFR clearances and the provisions of Paragraph 4-1-1 will not apply. Textual ODPs are not considered published departure procedures and cannot be used in lieu of the provisions of Paragraph 4-1-1.

 

[comanchepilot]

Why not put in a Lat/Long first fix thats where GAILS is located . . .

then V141 - how are you going to navigate to the fix? Why ded reckoning of course -

You have a compass, and watch and two course indicators that you dial to the airport and the simply change the course as you come north until you intercept the fix . . . .

and use a handhelp GPS to 'back up' your ded reckoning procedure .. .

Seems easy. Also the benefit of being legal.

 

[dtuuri]

The service volume issue for the VOR is 40 NM (not 30 NM).

John,

The service volume limits don't apply to airways under 7110.65U:

4-1-1
When specifying a route other than an established airway or route, do not exceed the limitations in the table on any portion of the route which lies within controlled airspace.​

The departure procedure is meant to take aircraft up to MEA on the overflying airway at 3B1, same as at HYA. At 200'/NM, by the time MEA is achieved it will be within service volume just the same as if it were a random route. I think they're all confused.

Btw, the 30 NM miles I referred to was based on a pilot report of the imposed limit over on the Red Board.

dtuuri

 

[dtuuri]

Why not put in a Lat/Long first fix thats where GAILS is located . . .

then V141 - how are you going to navigate to the fix? Why ded reckoning of course -

You have a compass, and watch and two course indicators that you dial to the airport and the simply change the course as you come north until you intercept the fix . . . .

and use a handhelp GPS to 'back up' your ded reckoning procedure .. .

Seems easy. Also the benefit of being legal.

Suspicions confirmed: You're a better pilot than a lawyer.

dtuuri

 

[John Collins]

John,

The service volume limits don't apply to airways under 7110.65U:

4-1-1
When specifying a route other than an established airway or route, do not exceed the limitations in the table on any portion of the route which lies within controlled airspace.​

The departure procedure is meant to take aircraft up to MEA on the overflying airway at 3B1, same as at HYA. At 200'/NM, by the time MEA is achieved it will be within service volume just the same as if it were a random route. I think they're all confused.

dtuuri

Dave,

They most certainly do. You stopped your quote too soon.

4−1−1. ALTITUDE AND DISTANCE LIMITATIONS
When specifying a route other than an established airway or route, do not exceed the limitations in the table on any portion of the route which lies within controlled airspace. (For altitude and distance limitations, see TBL 4−1−1, TBL 4−1−2, TBL 4−1−3, and TBL 4−1−4.) (For correct application of altitude and distance limitations see FIG 4−1−1 and FIG 4−1−2.)

Usually it is table 4-1-1 that is relevant and is where the 40 NM value comes from.

 

[dtuuri]

Dave,

They most certainly do. You stopped your quote too soon.



Usually it is table 4-1-1 that is relevant and is where the 40 NM value comes from.

View attachment 29813

View attachment 29814

As Table 4-1-1 says, "Normal Use of Altitudes and Radius Distances". Airways can exceed the "normal" limit (Order 7400.2J). The AIM amplifies the subject in Chapter 5 under "Direct Routes" par 3.(c)"

"(c) Operation off established airways below 18,000 feet MSL − Use aids not more than 80 NM apart. These aids are depicted on enroute low altitude charts."​

Anyway, does Boston think an aircraft less than 40 NM from a VOR has reliable positive course guidance when below MEA during a departure climb? I'd say it's just as unreliable as at, say, 60 NM. In either case, though, by the time a 200'/NM climb reaches MEA it will be within 40 NM (at 3B1 at least)--as TERPS intended all along.

So, we'll just have to disagree. :wink2:

dtuuri

 

[John Collins]

I agree that along airways, the service volume can be beyond 40 NM as they are flight tested at the relevant MEA. My understanding of the flight testing around the VOR, a 40 NM radius circle is flown to verify the service volume for random routes. BTW, I get my information from the fellow who writes the 7110.65 and has a thorough understanding of the intent. Also, don't confuse TERPS criteria with AIM or 7110.65 guidance. They are related, but procedures are often more conservative than the TERPS would permit. An example is the TERPS on a PT. It is based on the PT maneuver starting at the standard 10 NM at 250 to 260 Kts and 50 Kts of wind. However, the AeroNav Charts specify "Remain within 10 NM", not start no later than 10 NM.

 

[dtuuri]

I get my information from the fellow who writes the 7110.65 and has a thorough understanding of the intent.

Well, let's see what the "intent" was from TERPS between 1976 and 2002:

​

Then along comes Change #19...:

​

Which states:

GENERAL.
Evaluate diverse “A” and “B” areas to a distance of 25 NM for nonmountainous areas (see figure 2-1) and 46 NM for mountainous areas. If obstacles do not penetrate the OCS, unrestricted diverse departure may be authorized; publish standard takeoff minimums.​

Since that distance barely attains the minimum altitude under 91.177, it may not be high enough for MEA. Was the intent to leave pilots floundering in the gap?

Also, don't confuse TERPS criteria with AIM or 7110.65 guidance. They are related, but procedures are often more conservative than the TERPS would permit. An example is the TERPS on a PT. It is based on the PT maneuver starting at the standard 10 NM at 250 to 260 Kts and 50 Kts of wind. However, the AeroNav Charts specify "Remain within 10 NM", not start no later than 10 NM.

All those folks work for us. It makes no sense to allow aircraft to make an IFR approach, but not let them depart IFR after they land. So, they have departure procedures under TERPS. Along comes some new broom in the FAA, claims to know the "intent" and by decree sweeps long-established departure procedures out the door--even though they still leave them published!

As for the buffer for procedure turns, the 10 mile limit is a TERPS requirement, not ATC's. It's protected six miles beyond the limit because timing is imprecise and the exact maneuver is left to the individual pilot. The technique used may easily wander beyond the published limit. I have a free tutorial on my website [B]www.AvClicks.com[/B] titled "To the rear, March!".

dtuuri

 

[Palmpilot]

...All those folks work for us...

As I like to say, "Governing is a privilege, not a right!"

 

[John Collins]

Dave,

Regardless of what you believe, it is still an issue for non GPS equipped aircraft. It is not a new requirement.

 

[dtuuri]

Dave,

Regardless of what you believe, it is still an issue for non GPS equipped aircraft. It is not a new requirement.

John,

Let me quote from a memorandum to Paul Best, AFS 420, by persons who worked for him and were tasked with answering questions I asked and which he then faxed to me on 5/17/94:

"Evaluate all obstacles until the 40:1 slope (152 feet per NM) reaches (1) the applicable minimum altitudes prescribed in Parts 95 and 97 OR (2) the Part 91.177 requirement for random route operations, i.e., 1000 feet (2000 feet in designated mountainous terrain) above all obstructions within a four mile radius of the point at which you discontinue the 40:1 evaluation.

In other words, do it the way you always have in getting the aircraft to a published route; for random route approval, extend the 40:1 to the appropriate elevation AGL, i.e., 1000 or 2000 feet, then evaluate everything within a 4 mile radius of that location."​

I think the part about reaching MEA is being forgotten and only the part about random routes are being remembered. At 3B1, like at HYA, the airway overlies the airport; a departure along V300 is NOT a random route any more than a departure at HYA via V141. Finessing the computer to take the flight plan by lying to it as though it IS a random route doesn't make it one.

You are entitled to your opinion, of course. The newbie FAA guys that won't honor an IFR departure where published are not.

dtuuri

 

[azure]

How do I fly the feeder route in this approach. http://155.178.201.160/d-tpp/1305/00162L11L.PDF.

It's a radial off of a VOR. The IAF SOKRE has a cross radial to identify it. I don't see the problem.

 

[gismo]

If I am in a /U aircraft and dead reckoning is illegal under 91.205, how do I comply with FAR 91.185 (c)(1)(ii) if I have a comm failure?

How do I ever complete a procedure turn?

How do I fly the feeder route in this approach. http://155.178.201.160/d-tpp/1305/00162L11L.PDF.

Ded reckoning isn't specifically illegal AFaIK, it's just not an approved method for navigating to a distant fix. PTs, holds, etc are described in multiple FAA publications which goes a long ways to categorizing them as "legal". And IMO, intercepting an airway after departing an airport underlying the airway or even reasonably close either is or ought to be legal as long as the pilot recognizes that he's responsible for terrain/obstacle separation until established on the airway at or above the MEA.

 

[roncachamp]

If I am in a /U aircraft and dead reckoning is illegal under 91.205, how do I comply with FAR 91.185 (c)(1)(ii) if I have a comm failure?

How do I ever complete a procedure turn?

How do I fly the feeder route in this approach. http://155.178.201.160/d-tpp/1305/00162L11L.PDF.

You use your VOR receivers. Track outbound from PXN on the R-056 to SOKRE intersection, which is determined by the HYP R-132.

 

[roncachamp]

I tried to file several routes out of KHYA last night as a /U aircraft. KHYA GAILS works, KHYA V141 GAILS does not. A similar situation is departing northwest from KIKW, where you're barely off of V133. But the only way to file that the system will accept is to a fix, e.g. WHIPP. Since there's no other way a /U aircraft could file a route out of IKW (there's no DP and you can't receive the MBS VOR on the ground), I have to assume that's legal.

Au contraire.

 

[azure]

Au contraire.

Interesting. Sounds like it isn't the system then, but maybe a DUATS limitation -- I tried it through Foreflight.

 

[Velocity173]

Interesting. Sounds like it isn't the system then, but maybe a DUATS limitation -- I tried it through Foreflight.

Or a FSS limitation. I called FSS 2 days ago and the briefer said his computer won't accept direct an airway. He said even when it goes directly over the airport it won't take. Then I brought up preferred IFR routes and you'd think I was speaking Chinese. He wasn't aware that some went directly to an airway.

 

[dtuuri]

Dave,

Regardless of what you believe, it is still an issue for non GPS equipped aircraft. It is not a new requirement.

I've been thinking about this some more and don't see how being GPS-equipped helps in the least. Prior to TERPS Change #19, diverse departures went all the way to an airway at the actual MEA, 360° around the airport. After the change, they only go to 25/46 miles. You can see by my drawing that, due to line-of-sight limitations, an aircraft climbing out under TERPS criteria would not have positive course guidance even if less than 40 NM from a VOR. If obstacles existed in the vicinity of where I drew a flagpole, under the new system, it couldn't safely reach the actual MEA as it did under the old. Having GPS guidance for the same intended flight path offers no advantage:

​

Hopefully, the diverse departure procedure will have been an old "legacy" one that can be relied on to reach the actual MEA instead of just the minimum possible one (1000' above obstructions at 25/46 NM). But, how is a pilot to distinguish the better old DP from the new?

dtuuri