Class B & VFR Practice Approaches

rd757

rd757

Well-Known Member
I've been out with students VFR a number of times working on various things and we need to do an approach (multi add-ons as of late). Called up Detroit Approach and requested vectors for a practice approach to our local airport. The approach we requested has a 3000ft intermediate MDA that is well within a 3000ft Bravo shelf. The controller gave us "maintain 3000 until ABCDE, cleared GPS XX approach, maintain VFR." I typically have the student file for practice approaches so this would usually be a non-issue, but this time we were VFR and the first time I've done that approach as such. I never heard anything about a Bravo clearance when he started vectoring us around for the approach. I understand what maintain VFR usually means when you get flight following, but in this case, it shouldn't have anything to do with remaining clear of the overlying Class B, right? How would you expect the pilot to execute the approach clearance without a clear-cut Bravo clearance?

Basically, I'm looking for a clarification, so I could explain it to a student that asked about the VFR/Bravo situation on approaches. Any help would be great!

Thanks!
 
Really seems like ATC should have issued a bravo clearance as well. Though there might be some cultural habits at play here that don't totally honor the regulations

JO7110.65
7−9−2. VFR AIRCRAFT IN CLASS B
AIRSPACE

a. VFR aircraft must obtain an ATC clearance to
operate in Class B airspace.

NOTE−
1. Assignment of radar headings, routes, or altitudes is
based on the provision that a pilot operating in accordance
with VFR is expected to advise ATC if compliance will
cause violation of any part of the CFR.
Click to expand...

I would request a bravo clearance specifically from the approach controller.
 
I've always wondered as well as a tag along question to this:

If you request a VFR practice approach with the published missed approach in a Class B, does your missed approach instruction have to include "execute published missed approach except cleared into XXX Class B airspace, maintain VFR at [altitude]"?
 
I'd say you are totally fine. That is, right up until you have a deviation (for some other non-related issue) that ticks a controller enough to file it and have an inspector follow up who then listens to the tape and asks "so why did you enter B without a clearance?".
 
rframe said:
I'd say you are totally fine. That is, right up until you have a deviation (for some other non-related issue) that ticks a controller enough to file it and have an inspector follow up who then listens to the tape and asks "so why did you enter B without a clearance?".
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Isn't a vector permission to enter Class B?

Maybe something has changed but last time a looked NO WHERE in FAA doc's for pilots could I find where one must hear cleared in class B. The only place I could find the word cleared was the 7110.65 and pilots are not required to know that.

In busy SoCal airspace I was VFR on a vector and altitude assignment that took me into LAX Class B. ATC was so busy I couldn't get a world in. The vector was for traffic avoidance so I wasn't about to turn or change altitude on my own. Didn't like the way it came down but I went into Bravo and considered a vector permission. Pretty soon a quick vector out of Bravo and that was it.
 
FM_Weasel said:
Unfortunately it isn't. VFR Pilots must receive a clearance to operate in the Bravo, and must be told when they're exiting it.
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Can you show me where it says that? When I looked a couple of years ago I could only find the word Clearance in the 7110.65.
 
fholbert said:
Can you show me where it says that? When I looked a couple of years ago I could only find the word Clearance in the 7110.65.
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§ 91.131 Operations in Class B airspace.​

(a) Operating rules. No person may operate an aircraft within a Class B airspace area except in compliance with § 91.129 and the following rules:
(1) The operator must receive an ATC clearance from the ATC facility having jurisdiction for that area before operating an aircraft in that area.
 
There are no special rules when doing VFR practice approaches in proximity to class Bravo airspace. You need to hear "XXX cleared into class bravo airspace" If you are IFR, no problem. But VFR is VFR is VFR. We are required to maintain our own separation from traffic, terrain, weather and airspace. I drive this into my students day after day.

Why even take the risk? "Approach, confirm class bravo clearance for XXX".... problem solved.
 
fholbert said:
In busy SoCal airspace I was VFR on a vector and altitude assignment that took me into LAX Class B. ATC was so busy I couldn't get a world in. The vector was for traffic avoidance so I wasn't about to turn or change altitude on my own. Didn't like the way it came down but I went into Bravo and considered a vector permission. Pretty soon a quick vector out of Bravo and that was it.
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You didnt specify if you were flying practice approaches or just flying VFR flight following, but if you were flight following this is an apples to oranges comparison to the OP's scenario of flying a VFR practice approach near bravo airspace. On a VERY busy So Cal freq I could see how a traffic vector would have taken priority over a (lengthy) specific bravo clearance and I probably would have done the same thing. However, in no way, shape, or form, does a vector that takes you towards or through a Bravo airspace a specific clearance into it, such as when flying VFR practice approaches.

Around here I presume that controllers get saturated with a constantly fluctuating ratio of VFR to IFR traffic and I have heard them give vectors without bravo clearance to VFR practice approach traffic, myself included. They are human. But as PIC its your job to catch the mistake, query the controller, and receive the proper clearance for your type of flight.
 
fholbert said:
Isn't a vector permission to enter Class B?
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Others (including ATC controllers) have already responded, but I'll add: no.

Here's an LOI from 2010, that explicitly says a vector is not a clearance into B.

no.jpg


http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/doremire - (2010) legal interpretation.pdf
 
That letter of interpretation covers the agency's stance on the issue. But I think it's funny that they consider a vector for traffic to NOT be an "ATC instruction." It sure sounds like an instruction to me.
 
rframe said:
I'd say you are totally fine. That is, right up until you have a deviation (for some other non-related issue) that ticks a controller enough to file it and have an inspector follow up who then listens to the tape and asks "so why did you enter B without a clearance?".
Click to expand...

To which I would hope a pilot would respond, "an approach clearance is a clearance," and go about their day.
 
rframe said:
Others (including ATC controllers) have already responded, but I'll add: no.

Here's an LOI from 2010, that explicitly says a vector is not a clearance into B.

View attachment 23730

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2010/doremire - (2010) legal interpretation.pdf
Click to expand...

Just to throw some more logs on the fire, (NTSB 649, NTSB ORDER NO. EA-3238):

The law judge reversed an order of the Administrator that charged respondent with entry into the New York Terminal Control Area (TCA) without appropriate authorization from air traffic control (ATC) before doing so. The law judge found instead that respondent's entry into the TCA had been "constructively and tacitly" approved by a controller who gave him "a heading, an altitude instruction, that would take that pilot through a TCA." Although the law judge pointed out that a specific request to enter and a specific affirmative response would have been preferred, she determined on the basis of the evidence that respondent was legally in the TCA.

The law judge found that "by giving a pilot a heading, an altitude instruction that would take that pilot through a TCA, that is tantamount to a clearance."


Granted, I always throw a bravo clearance at the end so there isn't any confusion if I'm actually CLEARING a VFR for an approach if a segment could/will encroach bravo - but I still say an approach clearance without the bravo clearance would be correct, even though I personally think it's a bit vague.
 
TripSix said:
Just to throw some more logs on the fire, (NTSB 649, NTSB ORDER NO. EA-3238):

The law judge reversed an order of the Administrator that charged respondent with entry into the New York Terminal Control Area (TCA) without appropriate authorization from air traffic control (ATC) before doing so. The law judge found instead that respondent's entry into the TCA had been "constructively and tacitly" approved by a controller who gave him "a heading, an altitude instruction, that would take that pilot through a TCA." Although the law judge pointed out that a specific request to enter and a specific affirmative response would have been preferred, she determined on the basis of the evidence that respondent was legally in the TCA.

The law judge found that "by giving a pilot a heading, an altitude instruction that would take that pilot through a TCA, that is tantamount to a clearance."


Granted, I always throw a bravo clearance at the end so there isn't any confusion if I'm actually CLEARING a VFR for an approach if a segment could/will encroach bravo - but I still say an approach clearance without the bravo clearance would be correct, even though I personally think it's a bit vague.
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Personally, I agree with this interpretation, though I would not want to test it. I think the whole bravo clearance is unnecessary verbiage. I can picture the scene on the other side of the mic:

Controller: Fly heading 270 maintain 4500
Pilot: [readback]- confirm cleared into bravo
Controller: cleared into bravo
Controller off frequency: I just assigned you a heading and altitude that takes you into bravo [explitive deleted] !

Maybe someone from approach can chime in, but if I assign a heading and altitude, I expect that is what will be flown. Something more pressing may have occurred, or if you are at an IFR altitude I may have just forgot.
 
greg1016 said:
Personally, I agree with this interpretation, though I would not want to test it. I think the whole bravo clearance is unnecessary verbiage. I can picture the scene on the other side of the mic:

Controller: Fly heading 270 maintain 4500
Pilot: [readback]- confirm cleared into bravo
Controller: cleared into bravo
Controller off frequency: I just assigned you a heading and altitude that takes you into bravo [explitive deleted] !

Maybe someone from approach can chime in, but if I assign a heading and altitude, I expect that is what will be flown. Something more pressing may have occurred, or if you are at an IFR altitude I may have just forgot.
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Problem with that is I dont really care how a controller feels and if they get butt hurt over a clarification on a clearance then they need a vacation, particularly if it puts me at risk of being violated, which the LOI specifically says it does. Say "cleared into bravo", it's not that hard.
 
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