91.117 question. Aircraft speed below class B

The 220KIA speed limit used to affect us when we flew the J41 to White Plains NY. White Plains is underneath the NY Class B and our route took us underneath, but not inside, the Class B. I heard that a couple of guys got tagged breaking the speed limit.
 
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The 220KIA speed limit used to affect us when we flew the J41 to White Plains NY. White Plains is underneath the NY Class B and our route took us underneath, but not inside, the Class B. I heard that a couple of guys got tagged breaking the speed limit.

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Typo alert. 220 vs 200.
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This is true, we deal with this speed restrcition all the time as our home airport lies underneath the Class B... Our last 15-20 miles are at 200 (or so
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) knots... A few years ago the Tracon in ATL was busting guys left and right for violating this... they were having some kind of internal controller raffle to see who could cite the most busts... that went over like a lead balloon when that bit of info became public...
 
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I guess the thing to do is just say you are doing 200 when they ask and let them figure it out....

[/ QUOTE ]"Yes sir, we're showing 40 knots tailwind here...must be a little gust front or something"
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91.117d does apply in the scenario posted, and with that you can accelerate to your clean mms but not above that, so the rule is 200 or clean mms which ever is more, just as in class B or below 10k the rule is 250 or clean mms, which ever is higher.

As for the ILS critical area, yes, it is an ATC responsibility, but it doesn't hurt for the crew to know the rule and inquire if there is any doubt that the controller dropped the ball on it.
 
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Also, if the weather is less than 800 and 2, is it ATC's responsibility to have you hold short of the ILS critical area?

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We're taught at Della Southernjets, Inc that the 800/2 is only the criteria that ATC uses when they consider it necessary to have aircraft hold short of the ILS critical area.

As far as we're taught (and what I heard in recurrent) is that it's more or less an arbitrary number to us pilots. Probably one of those questions a student gets when he's acing all of the check airman's oral questions.

"Ok Doug, on this slide, is this MD-88 an original 88 or a modified -82?"
 
Thanks Seagull....I bow to the master and appreicate your response. It would be great if I could cite a reg or an interpretation, or something just written down on your opinion. Most of the opinions I've seen seem to suggest you gotta slow down to 200...put the flaps out. There is a very long time management Capt in the training dept at UPS who is telling everyone they need to slow below 200 if they have the capability to do so.

I feel like I scored some points by citing the 7110.65, which shows ATC is primarily responsible for the ILS critcal hold, but this arguement is the big Kahuna....
 
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91.117d does apply in the scenario posted, and with that you can accelerate to your clean mms but not above that, so the rule is 200 or clean mms which ever is more, just as in class B or below 10k the rule is 250 or clean mms, which ever is higher.

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That's what I figured. Living under 117(d) all the time does make interpertation easy, though.

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As for the ILS critical area, yes, it is an ATC responsibility, but it doesn't hurt for the crew to know the rule and inquire if there is any doubt that the controller dropped the ball on it.

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ATC has always included the "taxi...hold short ILS hold" in all the taxi clearances I've received where the WX required, or they wanted that for whatever reason. Never yet have had to query on the WX days,
 
Some airports like ATL say "Just get to 250 ASAP" after takeoff.
 
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Some airports like ATL say "Just get to 250 ASAP" after takeoff.

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Gotta love the ATC waivers.
 
Yeah, Doug, had an instructor tell me a couple of days ago that it was the pilots responsibility to know the weather and to hold short of the ILS critical area...no matter what ATC says. I didn't say anything, but that didn't sit too well with me.

With the magic of the internet, I was able to look up the answer in nano seconds, and suitably impressed the guy. He said we had a crew get a warning from ATC in MHT over this issue. I'm thinking the controller in MHT screwed up....
 
Even Houston allowed you 250+ below 10,000 for a few years. Or if you're flying more than 12 (I think) miles offshore from FLL on the arrival and you're doing anything less than 330 KIAS, you're going to get rear ended!
 
I recently wrote an article on the aircraft speed issue. ATC can only waive the speed requirements under 91.117b, the other ones can only be exceeded if waived by the Administrator (such as IAH, and ATC is NOT the Administrator) or under the auspices of 91.117d.

As to how do I know, well, there are letters of interp, but not handy for me here in TPE today. However, absent that, just consider: if 91.117d was NOT applied the way I stated, then all the large heavies would have to leave their slats/flaps out to stay under 250kts below 10k. That is absolutely not the case, and you can probably find the .65 reference from the ATC perspective on this to support what I am saying.

As for the 800-2 issue on ILS critical areas, I can't recall if that is listed in the AIM, but I do not recall it being listed under pilot responsibilities in any event. Shouldn't be too hard to trace that one down. If pilots are responsible, it would state it in the AIM or CFR.
 
If you're required to hold short of the ILS critical area everytime, then shouldn't you always ask for clearance to cross a runway if ATC only said "taxi to runway XYZ?" When I was shadowing a controller at ORL, he was complaining that a lot of people ask if it's clear to cross a runway after he gave them clearance to taxi. Personally, I think it's just an added safety measure in case they forgot about you or where you were going. The controller saw it as another annoying pilot trick I guess.
 
Let's see if I remember everything in this thread.

About the speed limit under class B, yes, you must maintain a speed below 200 knots any time you are operating under class B airspace. We run into this ALL the time. However, due to Chicago approach requirements (the fact they sequence most airlines on a 250 knot plan) coming inbound most people don't bother slowing. Outbound, some do, some don't. I usually do, since they see you slowing and give you a climb sooner.
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Not sure about the staying in class B when operating into the primary class B airport, but I remember hearing that before.

ILS hold short: Check airman taught me it's good to hold short of the ILS critical lines when the weather is below 800 and 2 just to be polite to aircraft inbound on the approach. You have no idea how often the G/S goes balistic and the airplane starts porposing when someone taxis in front of the antenna.
 
The reg says ATC can't waive the 200 knot below class B. Do this for me....bring it up a few times on your way into MDW and let me know what they say...hehe.
 
Me: "Sorry, we can't go over 200, below class B regulation."
ATC: "Ok Windy, turn right 090, you will be number 15 for arrival now."
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I just called upstairs to the tower and asked about the ILS critical area. He told me that if the tower is open then its the controllers responsibility to protect that area, however if the tower is closed it is then the pilots responsibility. However, I thought i read somewhere, but I am not sure where, that if the tower is closed then the ILS critical area didn't apply.
 
According to the 7110 (ATC bible), that ATC can not allow for aircraft or vehicles to operate with in the ILS critical area when and aircraft is between the OM and the airport or until that aircraft has the runway in sight.

Just thought I would through that in.
 
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