IFR Filing ?

bc2209

bc2209

Well-Known Member
I've been having a bit of a discussion with someone I work with. Granted I have very little experience with actually filing an IFR flight plan, which could be the problem.

As far as I can tell from reading the AIM, I don't have to file to an initial approach fix.

He on the other hand is one hundred percent about filing to an initial approach fix because of a lost comms scenario.

For the life of me I can't find anywhere that actually talks about filing IFR to an IAF.

Any help? Thanks
 
You can file airport to airport direct but the clearance returned by ATC will almost always route you to a feeder fix if not an IAF.

There are some exceptions but ATC generally works traffic under the assumption of lost comms.
 
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91.185 (3) (ii) covers the scenario of the clearance limit not being an IAF:

§91.185 IFR operations: Two-way radio communications failure

(3) Leave clearance limit.

(ii) If the clearance limit is not a fix from which an approach begins, leave the clearance limit at the expect-further-clearance time if one has been received, or if none has been received, upon arrival over the clearance limit, and proceed to a fix from which an approach begins and commence descent or descent and approach as close as possible to the estimated time of arrival as calculated from the filed or amended (with ATC) estimated time en route

 
Here in the Midwest I will very rarely have my direct to route changed. Other parts of the country when I fly I get re routed all the time.
 
Then, there's always this part of the AIM that tends to be forgotten when people get anal about lost comm procedures:

6−4−1. Two-way Radio Communications Failure
a. It is virtually impossible to provide regulations
and procedures applicable to all possible situations
associated with two-way radio communications
failure. During two-way radio communications
failure, when confronted by a situation not covered in
the regulation, pilots are expected to exercise good
judgment in whatever action they elect to take.
Should the situation so dictate they should not be
reluctant to use the emergency action contained in
14 CFR Section 91.3(b).​
 
ATN_Pilot said:
The thought never even occurred to me. I've never filed a flight plan to an IAF.
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I don't think he means filing an IAF as his clearance limit or destination. I think he's talking about putting down an IAF (or point at which a feeder to an approach begins. Basically anything that can transition one from the enroute structure to the terminal structure without ATC's assistance in the event of lost comms) as the last point on the route chosen to get from point A to point B.
 
A150K said:
I don't think he means filing an IAF as his clearance limit or destination. I think he's talking about putting down an IAF (or point at which a feeder to an approach begins. Basically anything that can transition one from the enroute structure to the terminal structure without ATC's assistance in the event of lost comms) as the last point on the route chosen to get from point A to point B.
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Same answer.
 
A150K said:
It's nowhere near mandatory, but is something that always struck me as a good idea to make lost comms procedures a bit more straight forward in the unlikely event of a total loss of comms.
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What would not be straightforward? Let's look at a flight I'm doing tomorrow. KFFC SOONE MCN VNA KDAB. If you lost comms right before VNA, is there any confusion about what you'd do? Of course not. You continue to the destination and fly an approach. Making it ...VNA OMN HANAV KDAB doesn't make it anymore clear. In fact, it makes it a more complicated procedure that you're going to have to fly when you get there, because now those extra fixes are part of your clearance, and you have to fly them instead of heading straight to the FAF. Don't make flying more difficult than it needs to be.

Note: this example assumes a GPS equipped airplane, of course.
 
ATN_Pilot said:
What would not be straightforward? Let's look at a flight I'm doing tomorrow. KFFC SOONE MCN VNA KDAB. If you lost comms right before VNA, is there any confusion about what you'd do? Of course not. You continue to the destination and fly an approach. Making it ...VNA OMN HANAV KDAB doesn't make it anymore clear. In fact, it makes it a more complicated procedure that you're going to have to fly when you get there, because now those extra fixes are part of your clearance, and you have to fly them instead of heading straight to the FAF. Don't make flying more difficult than it needs to be.

Note: this example assumes a GPS equipped airplane, of course.
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And my point assumes a non GPS airplane. Most of my IFR experience is in /A airplanes (instructing and 135 freight), so I generally think from that standpoint. But yeah...your scenario would work fine in a GPS equipped situation.
 
A150K said:
And my point assumes a non GPS airplane. Most of my IFR experience is in /A airplanes (instructing and 135 freight), so I generally think from that standpoint. But yeah...your scenario would work fine in a GPS equipped situation.
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Gotcha. I didn't realize there were still many training airplanes out there without IFR GPS. All the local schools around me have Garmin 430s at a minimum. Yes, if you don't have nav equipment to get you straight to a fix on an approach, then definitely file to a feeder fix that will get you to an IAF. If you're GNSS equipped, then don't worry about it. You're more likely to bang a supermodel tonight than you are to lose both your GPS and your comms while still having your VORs.
 
ATN_Pilot said:
Gotcha. I didn't realize there were still many training airplanes out there without IFR GPS. All the local schools around me have Garmin 430s at a minimum. Yes, if you don't have nav equipment to get you straight to a fix on an approach, then definitely file to a feeder fix that will get you to an IAF. If you're GNSS equipped, then don't worry about it. You're more likely to bang a supermodel tonight than you are to lose both your GPS and your comms while still having your VORs.
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The school I mostly taught IFR at only had /A airplanes and 135 freight is....well...135 freight ;). The two schools I taught at before that had 430 equipped airplanes(and I got my IR in a 430 equipped airplanes) though, so having at least a basic IFR GPS is more common than not for sure.
 
And lastly, here's a few LOIs on clearance limits, where to hold until the ETA, and how to proceed to an IAF. See what you think, but as I read it, it's perfectly acceptable to fly to your destination, proceed to an IAF, and then begin the approach.

http://www.faa.gov/about/office_org...010/olshock - (2010) legal interpretation.pdf
http://www.faa.gov/about/office_org.../2010/turri - (2010) legal interpretation.pdf
http://www.faa.gov/about/office_org.../2011/tuuri - (2011) legal interpretation.pdf

Good luck on the CFII!
 
bc2209 said:
He on the other hand is one hundred percent about filing to an initial approach fix because of a lost comms scenario.
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It helps to put yourself in the shoes of a controller (ATC guys please chime in here) if they really had a nocom airplane.

The highest risk for a midair is the peroid of time that neither ATC or the PIC is aware of the breakdown in communications. The most important part of lost comm procedures is following a predictable plan during the first 5-10 minutes while ATC figures out that you are no longer talking to them and tries to figure out where you are going next. This is where AVEF and MEA come into play

By the time you reach your destination 30 minutes or more down the road, ATC has most likely cleared all traffic and a mid air is no longer your main concern. Personally at that point I would just want to get on the ground ASAP and wouldn't bother holding till my ETA. Also, don't forget lost comm in IMC would constitute an emergency in just about any scenario.


The above may or may not be the correct FAA answer, but it is what will work in the real world.
 
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USMCmech said:
Personally at that point I would just want to get on the ground ASAP and wouldn't bother holding till my ETA. Also, don't forget lost comm in IMC would constitute an emergency in just about any scenario.


The above may or may not be the correct FAA answer, but it is what will work in the real world.
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Had an ATL controller on the Jumpseat. Happened to talk about this. He said "We'd be $h!tting bricks if a plane held until it's ETA going to ATL."
 
fholbert said:
You can file airport to airport direct but the clearance returned by ATC will almost always route you to a feeder fix if not an IAF.

There are some exceptions but ATC generally works traffic under the assumption of lost comms.
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Depends where in the country you're flying. If there's airspace complicated by congestion or military working areas, then sure you'll usually be put on an airway. If there's not much around, then direct to the destination airport is a very common clearance to issue.
Also, IFR clearances can be filed to start at any point, it doesn't have to be the departure airport. A waypoint or radial and dme from a VOR are able to be used as well when filing. Just pick the point you want to start IFR.
 
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