To ODP, or not to ODP, that is the question.

[Roger Roger]

Depending on 91, 135 121 it’s not always that simple. 135 you can’t just blast off providing your own terrain clearance unless you have a charted visual procedure that meets all the terrain clearance requirements single engine. Hence why a lot of places using APG to provide the alternate procedure that meets the regs requirement.


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Sure you can. If you’re not flying a turbojet.

 

[STS-41B]

Then how do you do your job?

Look up 91.175, then get back to us, it says exactly what you need to do.

Quite well, thank you. Just because you can quote regs like some can quote bible verses or shakespeare quotations or poetry, doesn't mean anything.

So it says
"Except as provided in paragraph (f)(4) of this section, no pilot may takeoff under IFRfrom a civil airport having published obstacle departure procedures (ODPs) under part 97 of this chapter for the takeoff runway to be used, unless the pilot uses such ODPs or an alternative procedure or route assigned by air traffic control."

SO, that makes it sound like it's a required procedure.. but the exception they note says
"For part 121 and part 135 operators, the pilot uses a takeoff obstacle clearance or avoidance procedure that ensures compliance with the applicable airplane performance operating limitations requirements under part 121, subpart I or part 135, subpart I for takeoff at that airport; or..."

So, Mr Superpilot, you tell me.

 

[Deleted member 27505]

Well, what are the options a guy would have in this situation?

1. Depart VFR, do whatever the • you want.

2. Fly the ODP, go way the hell out away from where you want to go .

3. Ask ATC of you can climb in VMC (if this is possible). You'll get a clearance like, "maintain your own terrain and obstruction clearance through 12,000, climb and maintain FLXXX.

4. You may have alternative procedures in your opspecs, consult those.

5. Just do what OP said, but recognize that you're likely breaking the law.

Take your pick.

Oh... No. I think you're misunderstanding me. I think we're in agreement. I'm saying fly it by the regs, of course. But I'm also saying that sometimes, even if you're flying by the regs, ATC might be surprised. It doesn't happen often, but when it does, it can lead to a bit of heartburn for everyone. I'm all about avoiding heartburn.

I'm just saying, for example, if you're 91, authorized to fly a VFR departure, and it's VMC, then fly the route ATC gives you (as long as it doesn't drive you into rocks). If you're 135 and it's VMC, you might be proscribed from ATC's route, so just let 'em know you're going to fly the ODP so you're sure everyone's on the same page.

At the end of the day, I don't think anyone is ever going to get into trouble for flying a published ODP from an uncontrolled airport, at least not lasting trouble. Hell, the way things have been going lately, maybe we should get merit badges for doing so.

 

[STS-41B]

Oh... No. I think you're misunderstanding me. I think we're in agreement. I'm saying fly it by the regs, of course. But I'm also saying that sometimes, even if you're flying by the regs, ATC might be surprised. It doesn't happen often, but when it does, it can lead to a bit of heartburn for everyone. I'm all about avoiding heartburn.

I'm just saying, for example, if you're 91, authorized to fly a VFR departure, and it's VMC, then fly the route ATC gives you (as long as it doesn't drive you into rocks). If you're 135 and it's VMC, you might be proscribed from ATC's route, so just let 'em know you're going to fly the ODP so you're sure everyone's on the same page.

At the end of the day, I don't think anyone is ever going to get into trouble for flying a published ODP from an uncontrolled airport, at least not lasting trouble. Hell, the way things have been going lately, maybe we should get merit badges for doing so.

posted same questions in pilot-controller forum.......

 

[z987k]

Well, what are the options a guy would have in this situation?

1. Depart VFR, do whatever the • you want.

2. Fly the ODP, go way the hell out away from where you want to go .

3. Ask ATC of you can climb in VMC (if this is possible). You'll get a clearance like, "maintain your own terrain and obstruction clearance through 12,000, climb and maintain FLXXX.

4. You may have alternative procedures in your opspecs, consult those.

5. Just do what OP said, but recognize that you're likely breaking the law.

Take your pick.

Barring what inverted said, the only safe and legal departure under 135 is option 2.

 

[z987k]

Quite well, thank you. Just because you can quote regs like some can quote bible verses or shakespeare quotations or poetry, doesn't mean anything.

So it says
"Except as provided in paragraph (f)(4) of this section, no pilot may takeoff under IFRfrom a civil airport having published obstacle departure procedures (ODPs) under part 97 of this chapter for the takeoff runway to be used, unless the pilot uses such ODPs or an alternative procedure or route assigned by air traffic control."

SO, that makes it sound like it's a required procedure.. but the exception they note says
"For part 121 and part 135 operators, the pilot uses a takeoff obstacle clearance or avoidance procedure that ensures compliance with the applicable airplane performance operating limitations requirements under part 121, subpart I or part 135, subpart I for takeoff at that airport; or..."

So, Mr Superpilot, you tell me.

It means he can do his job safely and legally. Which I have found rather lacking in 135. And I think the origonal question is a glaring example of this. That your company's check airman are unfamiliar with 91.175 is terrifying.

So you don't need to memorize ALL the regs, but you sure as hell have to know the ones that allow you to do your job. 91.175 sure is one of them. It'd be like if you didn't know C055, how would you ever plan a flight legally and how would you know how much fuel you need? The answer is you wouldn't or you got lucky. Or even if you have someone plan flights for you, it's not like you don't check that.

 

[ppragman]

Quite well, thank you. Just because you can quote regs like some can quote bible verses or shakespeare quotations or poetry, doesn't mean anything.

I might suggest that if you're flying for a living and don't know this then perhaps not as "quite well, thank you" as you suspect you are. If you don't know how to plan your departures there are cascading things this effects.

You don't need to be able to quote writ and verse, but if you operate airplanes for a living you should know where to find this information. My, "what does 91.175 say" comment was to point you in that direction.

"Except as provided in paragraph (f)(4) of this section, no pilot may takeoff under IFRfrom a civil airport having published obstacle departure procedures (ODPs) under part 97 of this chapter for the takeoff runway to be used, unless the pilot uses such ODPs or an alternative procedure or route assigned by air traffic control."

So you need:

An ODP, or a DP or vector departure, or something assigned by ATC in that part of the reg.

SO, that makes it sound like it's a required procedure.. but the exception they note says
"For part 121 and part 135 operators, the pilot uses a takeoff obstacle clearance or avoidance procedure that ensures compliance with the applicable airplane performance operating limitations requirements under part 121, subpart I or part 135, subpart I for takeoff at that airport; or..."

What does part 135 subpart I require? Well, this depends on the airplane and operation. That's where you'll get into the meat and potatoes of this sort of thing if you're using APG or whatever. Basically, this means if you can't meet the climb the performance requirements of subpart I you still can't go fly, even if there is a departure.

So, Mr Superpilot, you tell me.

No need to get snippy, this stuff is RIGHT in the reg. Perhaps your previous hostility might be a bit unwarranted, and perhaps you might do a little detective work before getting defensive, because perhaps you may not be as good at this as you think you are.

Now, I'm done rubbing your nose in it, and I apologise for being a bit of a dick, but you MUST know how to navigate the regs to do your job. You don't need to be able to quote them, but if you can't find at least 1 defensible answer when someone gives you the regulation to look at... well that's a big deal.

In short, you CANNOT just turn out and go fly direct without flying the departure under 135 under IFR if you are issued no further instructions. It's not optional.

But you need to know this to do your job, I recommend hitting the books some more. This isn't some arcane knowledge, this is a fundamental aspect of flying 135. There are a lot of good resources on the web and in print to help you learn this stuff. If you don't already have it buy Everything Explained and read it cover to cover. Further, check out Austin's Very Easy Guides to flight planning under IFR. Good luck, we're all counting on you.

Edit: formatting jacked

 

[ppragman]

Depending on 91, 135 121 it’s not always that simple. 135 you can’t just blast off providing your own terrain clearance unless you have a charted visual procedure that meets all the terrain clearance requirements single engine. Hence why a lot of places using APG to provide the alternate procedure that meets the regs requirement.


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Source? That may be only for turbojets and part 121, and nothing that I'm aware of in subpart I requires that for anyone else. 135.215 talks about this some but only in reference to places that don't have an approach.

 

[ppragman]

Yet, there still may be some level of ambiguity. If ATC gives you one thing, but the regs stipulate a different thing, in some cases at least, you'll have to trust that local ATC understands.

This is fair, the "straight in approach," versus flying the procedure turn is a perfect example of this.

 

[STS-41B]

The intersection for the ODP off runway 21 is Marke.
So, if you're flying the ODP, I guess you should enter that in the FMS, and head that way, and once in contact with Denver center and they radar contact you, you are then cleared to turn on course?? (asking to clarify this, not be smart-ass)
Looking at flightaware and tracks departing DRO.. looks like Trans States and Skywest head towards Marke each time but never make it to the intersection... however Mesa turns directly on course without headed that way.. seems like a fundamental misunderstanding that needs to be addressed. I've heard the argument in the crew-room before as well, with about a 50/50 split.
I always think, the most conservative the better; no harm in doing the ODP, even if not necessary. But if it is indeed required, I want to be sure to do it each time and be doing the right thing.

I also recall departing MTJ (Montrose) which is in mountainous area, and doing the ODP and once in contact w/ Denver they were pissed we weren't turning directly on course. So you can't win for losing.

 

[STS-41B]

Obstacle Departure Procedures - PilotWorkshops

clearly, I'm not the only one confused on this, especially reading the comments.

 

[Inverted25]

Source? That may be only for turbojets and part 121, and nothing that I'm aware of in subpart I requires that for anyone else. 135.215 talks about this some but only in reference to places that don't have an approach.

Yes I was assuming we were talking about flying jets. In a jet 135 you must have a charted visual departure procedure if you want to takeoff and maintain your own obstacle clearance in VMC conditions. I would have to dig into it again but there’s an AC that specifically spells this out. We went through this at our company because some pilots wanted to take off VMC at KEGE and just look outside to maintain obstacle clearance if they lost an engine even though APG said they didn’t have the performance to make it work. The AC for 135 turbojet spells out you must have a charted visual procedure that meets the required terrain clearance to be legal


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[ppragman]

The intersection for the ODP off runway 21 is Marke.
So, if you're flying the ODP, I guess you should enter that in the FMS, and head that way, and once in contact with Denver center and they radar contact you, you are then cleared to turn on course?? (asking to clarify this, not be smart-ass)
Looking at flightaware and tracks departing DRO.. looks like Trans States and Skywest head towards Marke each time but never make it to the intersection... however Mesa turns directly on course without headed that way.. seems like a fundamental misunderstanding that needs to be addressed. I've heard the argument in the crew-room before as well, with about a 50/50 split.
I always think, the most conservative the better; no harm in doing the ODP, even if not necessary. But if it is indeed required, I want to be sure to do it each time and be doing the right thing.

I also recall departing MTJ (Montrose) which is in mountainous area, and doing the ODP and once in contact w/ Denver they were pissed we weren't turning directly on course. So you can't win for losing.

What you could do (operations permitting), "Center, we're airborne off of KABC, we're in VMC conditions, we'd like to turn direct to FIXIE and climb in VMC. We have all the terrain in sight."

Yes I was assuming we were talking about flying jets. In a jet 135 you must have a charted visual departure procedure if you want to takeoff and maintain your own obstacle clearance in VMC conditions. I would have to dig into it again but there’s an AC that specifically spells this out. We went through this at our company because some pilots wanted to take off VMC at KEGE and just look outside to maintain obstacle clearance if they lost an engine even though APG said they didn’t have the performance to make it work. The AC for 135 turbojet spells out you must have a charted visual procedure that meets the required terrain clearance to be legal


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If you have a link I'd love to read it

 

[Inverted25]

What you could do (operations permitting), "Center, we're airborne off of KABC, we're in VMC conditions, we'd like to turn direct to FIXIE and climb in VMC. We have all the terrain in sight."


If you have a link I'd love to read it

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC120-91.pdf

I believe this is the correct one. If you scroll down to the visual course guidance section it says that crews must have a written or pictorial description of the route to be flown. It says even for a visual departure a flight track analysis must be performed to prove you meet the required obstacle clearance requirements.


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[ppragman]

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC120-91.pdf

I believe this is the correct one. If you scroll down to the visual course guidance section it says that crews must have a written or pictorial description of the route to be flown. It says even for a visual departure a flight track analysis must be performed to prove you meet the required obstacle clearance requirements.


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So I'm reading this, and I think the opposite is actually true with respect to visual flight procedures.

c. Allowance for Visual Course Guidance.

(1) Visual ground reference navigation is another form of course guidance. However, to take advantage of visual course guidance, a Flight Track Analysis must be performed.

(2) The ability to laterally avoid obstacles by visual reference can be very precise, if the obstacles can be seen and are apparent. It is the operator’s responsibility to operate in weather conditions, including ceiling and visibility at the time of the operation, that are consistent with the use of the visual ground reference points for the navigation upon which the obstacle analysis is based.

(3) To take advantage of visual course guidance, the flightcrew should be able to continuously determine and maintain the correct flightpath with respect to ground reference points so as to provide a safe clearance with respect to obstructions and terrain.

(a) The procedure should be well defined with respect to ground reference points so that the track to be flown can be analyzed for obstacle clearance requirements.
(b) An unambiguous written and/or pictorial description of the procedure must be provided for crew use.

(c) The limiting environmental conditions (wind, ceiling, visibility, day/night, ambient lighting, obstruction lighting, etc.) must be specified for the use of the procedure so that the flightcrew is able to visually acquire ground reference navigation points and navigate with respect to those points.

(d) The procedure must be within the one-engine-inoperative capabilities of the airplane with respect to turn radius, bank angles, climb gradients, effects of winds, cockpit visibility, etc.

(4) When visual course guidance is used for Flight Track Analysis, the following minimum allowances (in addition to turn radius) apply:

(a) If the obstacle itself is the reference point being used for visual course guidance, the minimum allowance is 300 feet for lateral clearance from that obstacle.

(b) When following a road, railroad, river, valley, etc., for course guidance, the minimum allowance is 1,000 feet on each side of the width of the navigation feature. This width should include the meandering and/or curves of the navigation feature being used or the definable center of the valley or river.

(c) When using a lateral visual reference point to initiate a turn, the minimum allowance is plus/minus 0.25 nm along the track at the turn point.

(d) When initiating a turn directly over a visual reference point, the minimum allowance is plus/minus 0.50 nm along the track at the turn point.

(e) When initiating a turn to avoid overflight of a visual reference point, the minimum allowance is plus/minus 1 nm along the track at the turn point.

(5) Visual course guidance may be used as part of an IFR procedure (e.g., SID, DP) or in conjunction with IFR flight during that portion of the operation which is in visual meteorological conditions (VMC). The visual course guidance may be used in combination with other forms of course guidance to construct a one-engine-inoperative departure procedure.

So looking at this I don't think a visually charted procedure is necessarily required. APG with "unambiguous textual" instructions would work for part 135. It's also worth mentioning that:

18. ALTERNATE MEANS. The methods and guidelines presented in this AC are not the only acceptable methods. An operator who desires to use an alternate means should submit an application to the CHDO. The application should describe the alternate assumptions, methods, and criteria to be used along with any other supporting documentation. The CHDO will forward the application through the FSDO (CMO/certificate management unit (CMU)) to the Director, Flight Standards Service, AFS-1, for review and approval, if appropriate.

If your POI says you can look out the window to navigate...well, you can look out the window.

 

[ppragman]

It's also worth mentioning that this only applies under 135 if you have to meet the requirements of Subpart I.

 

[Inverted25]

So I'm reading this, and I think the opposite is actually true with respect to visual flight procedures.



So looking at this I don't think a visually charted procedure is necessarily required. APG with "unambiguous textual" instructions would work for part 135. It's also worth mentioning that:



If your POI says you can look out the window to navigate...well, you can look out the window.

Sure we did ask. The answer was you still had to do a flight track analysis to prove you would meet the clearance requirements. I agree the text description from APG is legal. My point was 135 was you can’t just look outside and say I’ll just turn as needed to miss those mountains. For good reason. We ran the KEGE scenario in the sim and the results were surprising. Even in situations it seemed like no big deal to just look outside guys crashed trying to stay clear single engine


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[ppragman]

Sure we did ask. The answer was you still had to do a flight track analysis to prove you would meet the clearance requirements. I agree the text description from APG is legal. My point was 135 was you can’t just look outside and say I’ll just turn as needed to miss those mountains. For good reason. We ran the KEGE scenario in the sim and the results were surprising. Even in situations it seemed like no big deal to just look outside guys crashed trying to stay clear single engine


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This is basically only the case in a jet, turboprop (other than one certified in the Commuter Category) and see-and-avoid with no prior airport analysis is totally reasonable. All that aside, if you can get your POI to go for "visually see and avoid" you're in the clear.

Now, a step further, what about airports with a published VCOA?

 

[ppragman]

We ran the KEGE scenario in the sim and the results were surprising. Even in situations it seemed like no big deal to just look outside guys crashed trying to stay clear single engine

To be totally fair, you're right about it being risky. I saw this in the King Air sim in Eagle and Telluride, too. A lot of guys don't have a lot of "mountain sense" and couldn't hold their airspeed accurately enough to keep climbing at Vxse instead of at blue line OEI, and couldn't look out the window and tell if they were going to hit something or not.

I wonder if you couldn't actually make a gouge that would let you "see and avoid" obstacles by the required altitude with a grease pencil. From a given eye height, there's a spot on the windshield where if the obstacle goes below that and you're climbing at a particular ft/nm you'll clear the obstacle by more than 300'.

 

[STS-41B]

It's also worth mentioning that this only applies under 135 if you have to meet the requirements of Subpart I.

and I fly 121. So why are you so obsessed with quoting 135 stuff??