Alternate Required?

mjburian

mjburian

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Just doing some chair flying tonight and wondered about a scenario:

I'm in a /A plane flying to 3D2, whose only approaches are RNAV. But, from one hour before to one hour after my proposed arrival time weather is forecast to be at least 2000' ceilings and 3 mi visibility. Do I need to file an alternate? I don't see anything in 91.169 that requires the approaches at an airport to be flyable in the aircraft used. Am I missing something? (Doesn't seem like a great idea, but is it legal?)

As a separate question, what if I filed that way, weather ended up below VFR minimums and I lost communication? How would ATC expect me to proceed?
 
If you ask anyone in Flight Standards, they'll tell you even though the regulation isn't explicit on this point, the ability to fly the approach in question is implicit in the rule. If you ask why, they'll ask you what the difference is between an approach you can't fly and having no approach at all. IOW, what good is an approach you can't fly? If you really need a reliable legal answer, you'll have to write to the Chief Counsel, as this one has never to my knowledge been addressed legally.

As losing comm and then being unable to land visually or successfully complete an SIAP at your destination, the regulations, the AIM, and the ATC Handbook are silent. Flight Standards expects you to do whatever you think will produce the safest result, and ATC will be doing their best to watch what you do and clear everyone else out of whatever way they think you're going. Note that there is nothing in the regulations or guidance suggesting that you either should or must go to your filed alternate. ATC has no direct access to that information, and there are any number of reasons why the airport you selected as your filed alternate some hours ago might not be your best choice, or even a suitable choice, at that point. So, in the highly unlikely case that this ever happens to you, use all the information you have available to make the safest choice at that point, and don't let concern over what ATC might think affect that decision.
 
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Another consideration is the MVA at your destination. 2000 ft ceilings do you no good if ATC can only vector you down to 3000 agl due to terrain or poor radar coverage.
 
Dave Theisen said:
Another consideration is the MVA at your destination. 2000 ft ceilings do you no good if ATC can only vector you down to 3000 agl due to terrain or poor radar coverage.
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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.
 
mjburian said:
As a separate question, what if I filed that way, weather ended up below VFR minimums and I lost communication? How would ATC expect me to proceed?
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They would have no specific expectation.
 
Looking at the approaches for the airport in question, your practical hurdle is having the necessary ability to identify the navigable waypoints, and it appears that you have some equipment deficiencies. Unless I miss something, the question is moot.

With that said, is there a guidebook, that describes (TERPS???) the location of each /G waypoint in a manner other than Lat/Long?
 
Aren't you by reg required to have appropriate nav equipment on board for the planned flight? Wouldn't that essentially require you to have IFR GPS on board if filing to an RNAV-only airport?
 
chemgeek said:
Aren't you by reg required to have appropriate nav equipment on board for the planned flight? Wouldn't that essentially require you to have IFR GPS on board if filing to an RNAV-only airport?
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91.205(d)(2) requires "Two-way radio communication and navigation equipment suitable for the route to be flown."

But doesn't specifically state anything about approaches. If I file KMWC MTW 3D2 I have suitable navigation equipment for the route to be flown (and, I believe, satisfy that portion of 91.205).

Are you suggesting that I can't file to an RNAV-only airport at all (even if I do provide and alternate)?
 
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mjburian said:
I'm in a /A plane flying to 3D2, whose only approaches are RNAV. ... I don't see anything in 91.169 that requires the approaches at an airport to be flyable in the aircraft used. Am I missing something?
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Look in 91.175 (my emphasis):
§91.175 Takeoff and landing under IFR.

(a) Instrument approaches to civil airports. Unless otherwise authorized by the FAA, when it is necessary to use an instrument approach to a civil airport, each person operating an aircraft must use a standard instrument approach procedure prescribed in part 97 of this chapter for that airport.
​

You'll be SOL if you get there and "it is necessary" to shoot an approach. Weather is a capricious thing. Could you be in trouble if you get ramp checked upon landing? Of course! The FAA can always make your life miserable, whether the inspector really understands the regs or not.

dtuuri
 
Jaybird180 said:
Looking at the approaches for the airport in question, your practical hurdle is having the necessary ability to identify the navigable waypoints, and it appears that you have some equipment deficiencies. Unless I miss something, the question is moot.



With that said, is there a guidebook, that describes (TERPS???) the location of each /G waypoint in a manner other than Lat/Long?
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The idea is that I'd file to the airport, but cancel in the air and land VFR. I know I can't use the approaches. The question is whether I need to file an alternate at that airport with the equipment I have. I know if it has no approaches I need one. I don't know (or don't see any references that state) whether "no approaches" carries over to "no approaches that you're equipped to fly" or not.
 
dtuuri said:
And if you can't due to lost comms, a situation your flight planning should always contemplate?



dtuuri
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That's also part of my initial question. For instance, you can file to an airport with no approaches and provide an alternate with no approaches (as long as the alternate weather mins are met). What happens when weather turns bad then and you have a lost comms situation?
 
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).
 
mjburian said:
That's also part of my initial question. For instance, you can file to an airport with no approaches and provide an alternate with no approaches (as long as the alternate weather mins are met). What happens when weather turns bad then and you have a lost comms situation?
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You follow 91.185, which you can't if never planned further than the point you intended to cancel IFR. Up the creek with no paddle then, aren't ya?

dtuuri
 
dtuuri said:
You follow 91.185, which you can't if never planned further than the point you intended to cancel IFR. Up the creek with no paddle then, aren't ya?



dtuuri
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Yep. Though, as Ron stated, if I somehow ended up in this situation I'd squawk 7600 and do whatever was necessary with the hope/understanding that ATC is keeping the area clear. Though I'd much prefer not going down that road...
 
mjburian said:
Yep. Though, as Ron stated, if I somehow ended up in this situation I'd squawk 7600 and do whatever was necessary with the hope/understanding that ATC is keeping the area clear. Though I'd much prefer not going down that road...
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Part 91.185 ends at DH/MAP if the airport has an approach you are equipped to fly. If not, you need an alternate listed and your last route fix becomes the logical endpoint.

dtuuri
 
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mjburian said:
91.205(d)(2) requires "Two-way radio communication and navigation equipment suitable for the route to be flown."

But doesn't specifically state anything about approaches. If I file KMWC MTW 3D2 I have suitable navigation equipment for the route to be flown (and, I believe, satisfy that portion of 91.205).

Are you suggesting that I can't file to an RNAV-only airport at all (even if I do provide and alternate)?
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Point taken. But it's going to be awkward when you are vectored or cleared for the RNAV approach and can't fly it. If the WX is good VFR, no big deal. But if it goes IMC, or you cant be vectored below the bases, this plan looks imprudent.
 
chemgeek said:
Aren't you by reg required to have appropriate nav equipment on board for the planned flight? Wouldn't that essentially require you to have IFR GPS on board if filing to an RNAV-only airport?
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Why? You can file to an airport without any SIAP at all. You do need an alternate in that case though.
 
chemgeek said:
Point taken. But it's going to be awkward when you are vectored or cleared for the RNAV approach and can't fly it. If the WX is good VFR, no big deal. But if it goes IMC, or you cant be vectored below the bases, this plan looks imprudent.
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You wouldn't be vectored for the RNAV unless you told ATC that you were accepting it. ATC will ask which approach you are planning and in this case the OP would answer, the visual.
 
chemgeek said:
Point taken. But it's going to be awkward when you are vectored or cleared for the RNAV approach and can't fly it. If the WX is good VFR, no big deal. But if it goes IMC, or you cant be vectored below the bases, this plan looks imprudent.
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You're not going to be vectored for those approaches, they're beyond radar coverage.

The method of getting into 3D2 before the GPS approaches existed, under conditions similar to those given in the OP, 2000' ceilings and 3 miles visibility, was to fly an approach to KMNM or KSUE, cancel, and proceed VFR to 3D2. That still works.
 
Jaybird180 said:
Looking at the approaches for the airport in question, your practical hurdle is having the necessary ability to identify the navigable waypoints, and it appears that you have some equipment deficiencies. Unless I miss something, the question is moot...
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He said the forecast was at least 2000 and 3, and the requirement for a visual approach is only 1000 and 3. It's well-accepted that one can file IFR to an airport with no approaches at all, as long as one files an alternate, so an airport with approaches he can't fly should be no different. And if the airport is within the service volume of a VOR, that would provide the capability of navigating there.
 
This thread nearly doubled in size since I started reading it this morning! :D
 
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I think the casting around is that as far as alternates (and most other practical matters) that if you can't fly an approach you pretend it doesn't exist even though the regs don't specifically say that, it only makes good sense.

The only time that I wouldn't sweat not having the ability to fly the approach is when making a contact approach. I would have no problems say, asking for a contact approach to an airport that only has an NDB approach or such.
 
Palmpilot said:
He said the forecast was at least 2000 and 3, and the requirement for a visual approach is only 1000 and 3. It's well-accepted that one can file IFR to an airport with no approaches at all, as long as one files an alternate, so an airport with approaches he can't fly should be no different. And if the airport is within the service volume of a VOR, that would provide the capability of navigating there.
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How do you suppose he get below the clouds and ID the next waypoint without ATC vectoring? He has no ability to navigate the airspace on his own with only a single VOR station nearby.
 
Jaybird180 said:
How do you suppose he get below the clouds and ID the next waypoint without ATC vectoring? He has no ability to navigate the airspace on his own with only a single VOR station nearby.
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You can have a ceiling with just half the sky covered. That leaves half the sky open, pretty easy to get down under VFR once the IFR is cancelled. Navigation with a single VOR nearby isn't very difficult.
 
mjburian said:
91.205(d)(2) requires "Two-way radio communication and navigation equipment suitable for the route to be flown."

But doesn't specifically state anything about approaches. If I file KMWC MTW 3D2 I have suitable navigation equipment for the route to be flown (and, I believe, satisfy that portion of 91.205).

Are you suggesting that I can't file to an RNAV-only airport at all (even if I do provide and alternate)?
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Chemgeek makes a good legal argument. If the regulations require an alternate if there's no approach, then it makes sense that you would have to have the nav gear to fly an approach there. Otherwise, the regulation is pointless. As they say in Latin, reductio ad absurdum.

Again, this point has never been addressed by the Chief Counsel, but Flight Standards has always said you have to be able to fly whatever approach you are using to meet 91.167/169.
 
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mjburian said:
That's also part of my initial question. For instance, you can file to an airport with no approaches and provide an alternate with no approaches (as long as the alternate weather mins are met). What happens when weather turns bad then and you have a lost comms situation?
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Then you do whatever it takes to get the plane on the ground safely in this emergency situation, and the FAA will congratulate you for accomplishing that goal.
 
Jaybird180 said:
How do you suppose he get below the clouds and ID the next waypoint without ATC vectoring? He has no ability to navigate the airspace on his own with only a single VOR station nearby.
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How about "Cleared direct Menominee VOR-DME, direct Ephraim-Gibraltar Airport. Upon crossing Menominee, descend and maintain one thousand eight hundred. Report airport in sight."

(Skyvector seems to be down right now, but according to this approach chart, the airport elevation is 773.)
 
Palmpilot said:
How about "Cleared direct Menominee VOR-DME, direct Ephraim-Gibraltar Airport. Upon crossing Menominee, descend and maintain one thousand eight hundred. Report airport in sight."
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The MVA there is 2500.
 
roncachamp said:
The MVA there is 2500.
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Does that limit how low the altitude can be when operating within the service volume of the VOR being used for navigation?

If it does, he would still be OK in the scenario presented, which included a ceiling of at least 2000, which works out to 2773 msl.
 
roncachamp said:
You can have a ceiling with just half the sky covered. That leaves half the sky open, pretty easy to get down under VFR once the IFR is cancelled. Navigation with a single VOR nearby isn't very difficult.
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Although it meets the definition, but that only matters to the academic. In practicality, it is imprudent to assume there is clear nearby, hence the reason for IFR fuel requirements.
 
Palmpilot said:
Does that limit how low the altitude can be when operating within the service volume of the VOR being used for navigation?
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It's the lowest altitude ATC can issue. To get lower would require an IAP, cruise clearance, or cancelling IFR. A cruise clearance would require the pilot to determine the altitude at least 1000 feet above the highest obstacle within a horizontal distance of four miles from the course to be flown.

If it does, he would still be OK in the scenario presented, which included a ceiling of at least 2000, which works out to 2773 msl.
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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. Of course, it's pretty unlikely anybody's watching him.
 
roncachamp said:
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. Of course, it's pretty unlikely anybody's watching him.
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I was talking about a visual approach, not canceling IFR.
 
Whenever you're discussing a visual approach, keep in mind that from a practical standpoint, you need to be able to see the airport from far enough out that the controller can clear you for the visual without interfering with other operations. Further, you will not be able to descend below the MIA/MVA/MEA (as appropriate) until you are so cleared. As a result, from a practical standpoint, if there are significant clouds below 2000-2500 AGL, or the vis is less than 5 miles, a visual approach is not a viable option because otherwise you won't be able to see the airport from high enough/far enough out.

Of course, none of that is relevant to the 91.167/169 alternate filing issues.
 
Ron Levy said:
Whenever you're discussing a visual approach, keep in mind that from a practical standpoint, you need to be able to see the airport from far enough out that the controller can clear you for the visual without interfering with other operations. Further, you will not be able to descend below the MIA/MVA/MEA (as appropriate) until you are so cleared. As a result, from a practical standpoint, if there are significant clouds below 2000-2500 AGL, or the vis is less than 5 miles, a visual approach is not a viable option because otherwise you won't be able to see the airport from high enough/far enough out.
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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?

Of course, none of that is relevant to the 91.167/169 alternate filing issues.
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The only relevance is that Jaybird180 thought the OP's question was moot, because he didn't see how one could get into the airport in question under IFR without RNAV capability.

http://www.pilotsofamerica.com/forum/showpost.php?p=1483964&postcount=7

In a later post, the OP added that he could deal with the situation by canceling IFR, but since the MVA is 2500, it looks like the ceiling would need to be at least 3000 - 773 = 2227 in order to do that. With a ceiling of 2000, it looks like his only option would be to remain IFR and fly a visual approach (or divert).
 
Palmpilot said:
He said the forecast was at least 2000 and 3, and the requirement for a visual approach is only 1000 and 3. It's well-accepted that one can file IFR to an airport with no approaches at all, as long as one files an alternate, so an airport with approaches he can't fly should be no different. And if the airport is within the service volume of a VOR, that would provide the capability of navigating there.
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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?
 
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