I don't have the authority to interpret anything and neither do you. So, until I read something from someone that does have that authority, I'll protect my certificates by putting the extra 15 minutes of gas in the tanks...even in beautiful day weather.
You can operate your aircraft however you choose. Just don't cry the blues if your interpretation isn't consistent with someone's that matters. I do hope that you're right, but until I see something from an official source, I'm not willing to put my tickets on the line over 15 minutes of gas. Sorry if that inconveniences you.
The problem I have is the wording in this interpretation. http://www.faa.gov/about/office_org...nterpretations/data/interps/2009/Negron-2.pdf
"The FAA requires that, for IFR operations, aircraft carry enough fuel to fly for an additional 45 minutes from an alternate airport "at normal cruising speed." § 91. I67(a)(3)."
The word "conditions" is not there (in that sentence...just IFR operations) either purely accidentally or because that's how the legal counsel interprets the regulation. (Bottom of page 1 into page 2). So, I need to know which it is. No offense, but your opinion on the matter won't keep me (or my students) from having to do a carpet dance.
-mini
Your questions all address § 91. 167(a) which generally establishes
that when a pilot plans a flight in IFR conditions, he or she must carry enough fuel to: (1)
complete the flight to the intended destination; (2) fly from the intended destination to an
alternate airport; and (3) fly after that for 45 minutes at normal cruising speed.
So if I come within 499' of a cloud in Class E, C, or D airspace do I need 45 minutes of reserve just for the time I'm within 499' (since I'm now operating in "weather conditions" less than that required for VFR) or for the whole flight?
Do I need 30 or 45 minutes of reserve above FL180?
What about after I've descended back through FL180 on the way down? Can I go back to 30?
What if I'm VFR in class G airspace and fly through a cloud? How much do I need?
-mini
You'd have to ask them. I don't have the authority to interpret regulations.From that letter:
Why would they define it first, then change it later?
Dude. Have a beer, and take a break. You're taking this way too seriously.
So if I come within 499' of a cloud in Class E, C, or D airspace do I need 45 minutes of reserve just for the time I'm within 499' (since I'm now operating in "weather conditions" less than that required for VFR) or for the whole flight?
Do I need 30 or 45 minutes of reserve above FL180?
What about after I've descended back through FL180 on the way down? Can I go back to 30?
What if I'm VFR in class G airspace and fly through a cloud? How much do I need?
Fair enough. So you're going to have to tell ATC you need to climb/descend/turn to avoid that cloud. I could buy that.1. I think that to put this to use, you would have to be able to complete the entire flight in VFR.
So what are "VFR conditions" in class A airspace? That would be a new one to me.2. I don't know why FL180 would change this requirement. If I'm in VFR conditions, the 30 minute reserve would apply.
Likewise.3. See 2.
So what are "VFR conditions" in class A airspace? That would be a new one to me.
-mini
3-2-2. Class A Airspace
a. Definition. Generally, that airspace from 18,000 feet MSL up to and including FL 600, including the airspace overlying the waters within 12 nautical miles of the coast of the 48 contiguous States and Alaska; and designated international airspace beyond 12 nautical miles of the coast of the 48 contiguous States and Alaska within areas of domestic radio navigational signal or ATC radar coverage, and within which domestic procedures are applied.
b. Operating Rules and Pilot/Equipment Requirements. Unless otherwise authorized, all persons must operate their aircraft under IFR. (See 14 CFR Section 71.33 and 14 CFR Section 91.167 through 14 CFR Section 91.193.)
I just try to keep it easy. If filing IFR, I plan for a 30 min reserve, assuming no alrernate required. VFR, plan for a 20 min reserve. Just keeps it simple. I try not to stretch fuel too much or cut it tight enough to really have to worry to much about getting to where I'm up against these walls.
Aside from being "Cleared into the class bravo" I can't think of any other time I've heard that I was "cleared" anywhere under VFR.
-mini
You're cleared into the class Delta surface area from the west, maintain at or below 4000, report the field in sight.
You only need two way radio communications to operate in class D airspace though.
-mini
Somebody has constipation of the brain, or they haven't flown a little airplane in a long, long time. Think hard mini, when was the last time you were issued a "special" clearance into class D?
That's tight in my book...I personally want no less than 1 hr if at all possible.
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D'Oh!
-mini