How do I file IFR to an airport with no nearby navaid?

John Collins said:
I am not aware of an "on point" deviation, but I know of at least one where the pilot was cited for violating 91.205 for making an approach he was not equipped for.
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I'm aware of that one, but there's a big difference between going ahead and flying an approach you're not equipped for, and diverting to an alternate that you are equipped for when you find out that the destination weather is not good enough for a visual approach. The latter is the same thing that happens when a person files to an airport that has no published approaches, which the FAA has never claimed is not allowed, as far as I know.

It will come up more often as so many VOR approaches are getting eliminated leaving only RNAV procedures at many smaller airports. There still are aircraft that are /A and /U that might file such a plan via IFR to one of these airports and it would be a shame to get a deviation due to ignorance of the rule.
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There's a difference between a rule and an interpretation. The former are easy to find. The latter can require a lot of digging, and it requires the pilot knowing that there is something to dig for.

This interpretation is not as obvious as the FAA seems to think, because one could argue that when the pilot files IFR with the expectation of flying a visual approach, then "the route to be flown" is a visual approach, not any of the published approaches. If the weather does not meet the minimums for that route, then one goes to an alternate airport. The exact same thing happens if the airport has published approaches and the aircraft is equipped to fly them, but the weather does not meet the minimums for those approaches.

I think I recall an attorney on one message board or another pointing out that one of the shortcomings of the interpretation process is that, unlike case law that has been argued before a judge, there are not attorneys briefing or arguing both sides of the question, and thus there may be issues that never get properly considered.
 
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Palmpilot said:
I think I recall an attorney on one message board or another pointing out that one of the shortcomings of the interpretation process is that, unlike case law that has been argued before a judge, there are not attorneys briefing or arguing both sides of the question, and thus there may be issues that never get properly considered.
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That's true, but given that the FAA's interpretation is likely to be upheld in litigation so long as it reasonably fits the rule, even briefing both sides is going to have a substantial effect in only a very small number of situations. Along with the expense of getting to a level where a court might realistically disagree with the FAA, the ordinary deference usually given to agency interpretations of its own rules (not just an FAA issue) is a reason that by far most enforcement cases are resolved without a trial.

The other thing to consider is the quality of the question. I've seen questions sent into the Chief Counsel which made me cringe because they worded in a way which makes the bad answer obvious. On the other extreme, particularly with business-related issues, it's an attorney who writes to the Chief Counsel and offers a tentative and supported interpretation favorable to the client, so there is at least some give and take.
 
dtuuri said:
Did you ask if you could file to an intersection and request a cruise clearance the remainder of the way in Remarks?
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Not sure what that would accomplish. The Chief Shyster acknowledged that if there are no Approaches to the airport, then it’s cool to file to it. In that case, just file to it and then get your Cruise Clearance when the time comes. If the airport has Approaches then nothing really changes about how you fly the Approach other than you don’t have to wait for the words “cleared for the approach” and you don’t have to get a bunch of altitude assignments from ATC on the way down. As far as the act of ‘filing’ the flight plan goes, putting “request cruise to KABC” is a de facto filing to the airport.
 
Sounds like filing to another airport via a lat/long that happens to be over your destination airport is the legal way to go.

Used to do that under 135...tended to **** the controllers off. ;)
 
MauleSkinner said:
Sounds like filing to another airport via a lat/long that happens to be over your destination airport is the legal way to go.

Used to do that under 135...tended to **** the controllers off. ;)
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So what would you do when over said lat/long?
 
luvflyin said:
So what would you do when over said lat/long?
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Request a visual approach, a contact approach, holding, or clearance to a new destination.

Nothing special about a Lat/Long fix. Any nearby fix, that you can navigate to, will work.
 
luvflyin said:
The Chief Shyster acknowledged that if there are no Approaches to the airport, then it’s cool to file to it. In that case, just file to it and then get your Cruise Clearance when the time comes. If the airport has Approaches then nothing really changes about how you fly the Approach other than you don’t have to wait for the words “cleared for the approach” and you don’t have to get a bunch of altitude assignments from ATC on the way down. As far as the act of ‘filing’ the flight plan goes, putting “request cruise to KABC” is a de facto filing to the airport.
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IIRC, I used to put an intersection at the end of my route description, the destination airport in the usual block and request to "cruise" after the intersection in Remarks. That was for an airport with no approaches. Cruising allowed me to overfly the intersection at MEA and descend to MIA. If I couldn't break out, it was back up to the cruising altitude given me (assuming I didn't call leaving it, and I wouldn't), then request a clearance to my alternate as I went back to the intersection. At least that was my plan as I remember it, but I only vaguely can remember having to do it a few times, never needed it to get VFR below MEA. Don't see why that doesn't work with waypoints and RNAV in these times. If somebody has an old KNS-80 they could overfly the airport at MIA. If just a VOR, a radial and plotted distance or DME. Just make sure it's done under a "cruise clearance" and within service volume. Maybe somebody should point out the definition in the FAA's own P&CG to the "Chief Shyster (as you so eloquently put it)? They shouldn't be opining on stuff of which they are obviously ignorant.

EDIT: Here's how NOT to do it. See Paragraph 1.17.2 (warning, does not reflect well on ATC). Note that the definition of "cruise" no longer states MEA/MOCA, but MIA:
https://www.fss.aero/accident-reports/dvdfiles/US/1975-09-12-US.pdf
 
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dtuuri said:
IIRC, I used to put an intersection at the end of my route description, the destination airport in the usual block and request to "cruise" after the intersection in Remarks. That was for an airport with no approaches. Cruising allowed me to overfly the intersection at MEA and descend to MIA. If I couldn't break out, it was back up to the cruising altitude given me (assuming I didn't call leaving it, and I wouldn't), then request a clearance to my alternate as I went back to the intersection. At least that was my plan as I remember it, but I only vaguely can remember having to do it a few times, never needed it to get VFR below MEA. Don't see why that doesn't work with waypoints and RNAV in these times. If somebody has an old KNS-80 they could overfly the airport at MIA. If just a VOR, a radial and plotted distance or DME. Just make sure it's done under a "cruise clearance" and within service volume. Maybe somebody should point out the definition in the FAA's own P&CG to the "Chief Shyster (as you so eloquently put it)? They shouldn't be opining on stuff of which they are obviously ignorant.

EDIT: Here's how NOT to do it. See Paragraph 1.17.2 (warning, does not reflect well on ATC). Note that the definition of "cruise" no longer states MEA/MOCA, but MIA:
https://www.fss.aero/accident-reports/dvdfiles/US/1975-09-12-US.pdf
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Yeah. Nothing against the rules to file 'short' and then later requesting clearance beyond it. Just that you don't 'need' to. When you get the Cruise Clearance the controller is going to have clear you to the airport when he gives the cruise clearance. You could have already been if not having been cleared 'short.' Yeah on MIA, you apply 91.177 (a) (2) (i) and (ii). And the gucci whiz bang avionics nowadays make it easier than it used to be. Yup, that wasn't ATC's finest moment. There was a Convair I think it was, that crashed late at night into KMFR and no one missed it. Sheriff just cruisin around the next morning found it. Happened at KVNY to. Plane crashed on the airport middle of the night and took a bunch planes out on the ramp. Airport patrol was doing his rounds and found it. Interesting about the roll yer own plate. Whoever made it is lucky he didn't get all proud about his work and 'signed' it.
 
luvflyin said:
Nothing against the rules to file 'short' and then later requesting clearance beyond it.
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I'm not saying to file short. I'm saying document in remarks how you intend to get to the airport, so nobody can claim you had an illegal let down in your mind. But you COULD do it your way as part of a composite flight plan, if you don't mind staying at MEA.
 
Well, I haven't seen the words "scud running" used, but that is an option as long as it's VFR underneath. Fly to the airport that has the approach and once you're clear under the clouds, cancel IFR in the air and fly VFR over to the other airport. You'll want to know any obstacles and set a floor for yourself. If ceilings are at least 1500 AGL, it's an easy flight, down to 1000 and it's borderline legal/smart. I don't think I'd go more than about 10 miles doing this.

If anything gets hairy, you can always get a popup IFR clearance and go back to your first destination.
 
dtuuri said:
I'm not saying to file short. I'm saying document in remarks how you intend to get to the airport, so nobody can claim you had an illegal let down in your mind. But you COULD do it your way as part of a composite flight plan, if you don't mind staying at MEA.
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Ah, you did "IIRC, I used to put an intersection at the end of my route description, the destination airport in the usual block." Looks like I quit reading at the end of "...end of my route description" and jumped to a conclusion, my bad. I think i had something in another post on my mind.
 
luvflyin said:
I think i had something in another post on my mind.
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Probably an earlier post I made where I said "File TO an intersection," thinking just about the routing. For the record, I walked into the FBO soon after that Commander took off from PIT. My day started in Grand Rapids, made a couple stops and wound up at PIT. They started in Pontiac. I checked my logbook, same day. I recall the ladies working the desk being all concerned because somebody (FAA, company?) was searching for the plane and they had just fueled it (? no record in report) and had talked to the pilots.
 
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bflynn said:
Well, I haven't seen the words "scud running" used, but that is an option as long as it's VFR underneath. Fly to the airport that has the approach and once you're clear under the clouds, cancel IFR in the air and fly VFR over to the other airport. You'll want to know any obstacles and set a floor for yourself. If ceilings are at least 1500 AGL, it's an easy flight, down to 1000 and it's borderline legal/smart. I don't think I'd go more than about 10 miles doing this.

If anything gets hairy, you can always get a popup IFR clearance and go back to your first destination.
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With thousands of miles flown below 1000 AGL, including the scenario you posed, I’d say it can be done safely.

I would, however, ensure that “hairy” was clearly defined in terms of ceiling/visibility along the route (to include “do I need to have an IFR clearance by the time it gets “hairy” or is “hairy” the time to start calling), ensure that I could adequately determine that it was or wasn’t “hairy”, and have frequencies handy/tuned/monitored to ensure that I could get a clearance in a timely fashion (and a plan of action in case of a delayed clearance).

All of the above assumes a solid competence in pilotage.
 
bflynn said:
“.....If anything gets hairy, you can always get a popup IFR clearance and go back to your first destination....”
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If it gets ‘hairy’ you may have to deal with hairy for awhile. You may request a clearance and not get it right away. And you better know where all the rocks, buildings and other obstructions are. Not just along the path you had chosen to fly, but in all directions because the may send you in any direction. You will likely have to say you can maintain your own terrain and obstruction clearance before they will give you a clearance. And it’s likely there can be a long delay because of traffic. You’re near an airport running IFR traffic. Remember, you were one of them a few minutes ago. If it looks like things could get hairy, relying on getting a pop up to get out of it is probably not good planning.

EDIT: like what @MauleSkinner said. Didn’t read down before replying. I’ll just leave this here as reinforcement of what he said
 
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MauleSkinner said:
With thousands of miles flown below 1000 AGL, including the scenario you posed, I’d say it can be done safely.
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Nitpick : Safe and successful aren’t the same thing.

We lower safety every time we strap in.

Or as Mike Rowe puts it, “Safety Third” to get things done.
 
Palmpilot said:
The argument would make sense to me if there was a history of pilots receiving violations for filing and flying an IFR clearance to an airport in the expectation of flying a visual approach or diverting to an alternate that had an approach they were equipped to fly. So far I haven't heard of such a history.
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I have done exactly that quite often and never heard a peep from atc or the FAA. In fact I have landed at that airport on an IFR flight plan to meet an ASI that was waiting to do a site inspection. I don’t know what the issue is here...
 
Tarheelpilot said:
I have done exactly that quite often and never heard a peep from atc or the FAA. In fact I have landed at that airport on an IFR flight plan to meet an ASI that was waiting to do a site inspection. I don’t know what the issue is here...
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Understand that neither of those arguments are valid indicators of legality.

The one could be just not getting caught, and the other could be an ignorant inspector.
 
MauleSkinner said:
Understand that neither of those arguments are valid indicators of legality.

The one could be just not getting caught, and the other could be an ignorant inspector.
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Either way I’m not going to write a letter to the chief counsel to ask and frankly I don’t care. How else you going to file IFR to an uncharted airport with no IAP’s? I’m sure not going to fly there VFR in a pressurized turbine twin. Sometimes folks just need to make a decision without having to be told exactly how to do everything by a regulation.
 
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Just because it isn't charted doesn't mean it doesn't have an identifier. It's at the discretion of the airport manager if it shows up on charts.

If it doesn't have an identifier, I suspect the person constructing it failed to give the required notice to the FAA.
 
flyingron said:
Just because it isn't charted doesn't mean it doesn't have an identifier. It's at the discretion of the airport manager if it shows up on charts.

If it doesn't have an identifier, I suspect the person constructing it failed to give the required notice to the FAA.
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Who says it’s required?
 
MauleSkinner said:
Understand that neither of those arguments are valid indicators of legality.

The one could be just not getting caught, and the other could be an ignorant inspector.
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Until a violation gets appealed, I'm not sure that FAA opinions are necessarily a valid indication of what's legal and what isn't either. The answer that John Collins received did not consider the argument that when a pilot files with the intention of flying a visual approach, the "route to be flown" includes a visual approach, not a published instrument approach.
 
flyingron said:
14 CFR 157.3 Note that you don't need approval, but you do need to give 90-day advance notice.
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If they didn’t comply with that requirement it happend almost 50 years ago. At this point I would say the FAA doesn’t care. Especially considering they have been on the property inspecting flight operations on a regular basis for all of the years.
 
Tarheelpilot said:
If they didn’t comply with that requirement it happend almost 50 years ago. At this point I would say the FAA doesn’t care. Especially considering they have been on the property inspecting flight operations on a regular basis for all of the years.
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So, it likely does have an identifier. I don't know of any CIVIL (or mixed-use) airport that the FAA considers to be an airport that doesn't have an identifier. Even many purely military fields have them.
 
flyingron said:
So, it likely does have an identifier. I don't know of any CIVIL (or mixed-use) airport that the FAA considers to be an airport that doesn't have an identifier. Even many purely military fields have them.
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It does now... they did the paperwork with the FAA about two years after I left for a new job ;-)

it did not for a very long time.
 
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