Roger Roger
Bottom of the list
So how can an OpSpec both require something (follow the ODP) and prohibit it (no climb in visual conditions) at the same time?
To ODP, or not to ODP, that is the question.
- Thread starter MNFlyboy
- Start date
JustinS
Well-Known Member
That's what I figured, that's an interesting thing to read. It totally makes sense though.
mastermags
Well-Known Member *giggity*
I believe he was talking about an ODP, not joining a SID.
Capt. Chaos
Well-Known Member
135.379 only applies to large transport category turbine engine airplanes, and only makes reference to required obstacle clearances, there are no references VFR or IFR in the paragraph.
We don't have OpsSpec C077, the only reference to it I found in our book was in C080 (e); Except as provided in operations specifications parapgraph C077, all Title 14 CFR 135 turbojet and all part 121 operations in the terminal area are conducted under instrument flight rules.
z987k
Well-Known Member
Well it's the only way out of Kodiak under IFR, so for all intents and purposes it's the same thing for the discussion at hand.
MNFlyboy
Well-Known Member
So I checked our OpSpec and we don't have C077, either. Our GOM does say that if the weather is MVFR or IFR, we MUST fly an ODP or SID, but doesn't give guidance for VFR departures. We are also required to be on an IFR or VFR flight plan. Now, it's been suggested that we are always operating under part 135 because....well we won't open that can of worms, but let's assume we're not applying Part 91.
MNFlyboy
Well-Known Member
@ppragman in regards to your reply, where it says to ..."climb in visual conditions to X altitude, thence...... climb to X altitude", what if this altitude does not join the MEA of the victor airway?
In another example;
TAKEOFF Minimums:.... "or 2500-3 for climb in visual conditions." BUT;
DEPARTURE PROCEDURE: there's no "for climb in visual conditions".
The T.O. Mins make me think that if I have 2500' I can climb on my own up to 2500 and then join my filed flight plan.
I'm still trying to understand the 135 reg that disallows me from taking of in VMC (not MVMC) under 135 after having received my clearance on the ground.
In another example;
TAKEOFF Minimums:.... "or 2500-3 for climb in visual conditions." BUT;
DEPARTURE PROCEDURE: there's no "for climb in visual conditions".
The T.O. Mins make me think that if I have 2500' I can climb on my own up to 2500 and then join my filed flight plan.
I'm still trying to understand the 135 reg that disallows me from taking of in VMC (not MVMC) under 135 after having received my clearance on the ground.
Dugie8
Well-Known Member
There is no such thing as a "VMC" climb.
Nothing is preventing from taking off into VMC conditions. BUT! Even if the conditions are VMC and you are VFR (didn't get your clearance on the ground) you still must meet the obstacle clearance requirements of subpart I of part135.
The "cross the airport in visual conditions at xxxx altitude" does not satisfy that for part 135 BECAUSE unless you have the aero data or runway analysis to show it, there is no real reliable way to compute it with the data we have available as line pilots.
If you have an airport that only has "visual" departures then you would use your OEI escape path as your ODP. Every 135 operator (pax, jet) is required to have that. Many don't.
Nothing is preventing from taking off into VMC conditions. BUT! Even if the conditions are VMC and you are VFR (didn't get your clearance on the ground) you still must meet the obstacle clearance requirements of subpart I of part135.
The "cross the airport in visual conditions at xxxx altitude" does not satisfy that for part 135 BECAUSE unless you have the aero data or runway analysis to show it, there is no real reliable way to compute it with the data we have available as line pilots.
If you have an airport that only has "visual" departures then you would use your OEI escape path as your ODP. Every 135 operator (pax, jet) is required to have that. Many don't.
fish314
Well-Known Member
@Dugie8, @MNFlyboy
I'm not an airline guy, I'm military flying big jets (or was until a week ago, anyways… class starts Tuesday for my new single engine ride!)... so I'm not sure about the OpSpecs side of the question having never seen them. Perhaps there is something in their that specifically prohibits a VCOA that makes the rest of this discussion moot. However...
I believe the VCOA (Visual Climb Over Airport) IS an ODP. So I don't think there is any real regulatory issue involved in doing the VCOA "rather" than the ODP, because the VCOA "is" an ODP. I base that argument on a couple of sources:
1. The TERPS manual (FAA Order 8260.3B http://www.faa.gov/documentLibrary/media/Order/8260.3B Incl Chgs 1-21.pdf) chapter 4 describes the VCOA as an "an alternative method for pilots to depart the airport where aircraft performance does not meet the specified climb gradient. Development of a VCOA is mandatory when obstacles more than 3 statute miles from the departure end of runway (DER) require a greater than 200 ft/NM climb gradient." This description and the rest of the regulations involved in building the VCOA all come from the instrument departures section of the manual where all of the other ODP information comes from.
2. Section 5-2-8 of the AIM (about ODPs and SIDs) also states that "Some DPs established solely for obstacle avoidance require a climb in visual conditions to cross the airport or an on-airport NAVAID in a specified direction, at or above a specified altitude. These procedures are called Visual Climb Over the Airport (VCOA)." Seems to imply to me that VCOA's are a subset of ODPs.
3. At least 1 FAA document that I found relatively easily specifically spells out that the VCOA is part of the ODP: http://www.faa.gov/about/office_org...0/afs420/acfipg/open/media/Hist_10-01-292.pdf. Of course, this isn't a FAR, so it probably isn't exactly gospel, but it seems to lend credence to the same idea.
If that's the case, then the other point that you raised still stands: Even if I am legally allowed to fly a VCOA, I'm still required to keep the airplane at least 35 feet vertically clear, or 300 feet horizontally clear of the obstacles (outside the airfield boundary). How do I confirm that I am able to do that in a VCOA? Well the answer comes from the TERPs manual. The VCOA is only authorized when an obstacle is outside of 3SM from the airport and it penetrates the obstacle identification surface (the 40:1 OIS slope) requiring a greater than 200'/NM climb to clear it. So they calculate an altitude that you will be climbing to within a particular radius of the airport (these become the ceiling and vis restriction), and from there you are expected to continue to climb at 200'/NM. By raising the starting point of your climb from ground level to the climb-to altitude you avoid all of the obstacles outside of the visual climb area (VCA). So long story short, by doing the VCOA, you are guaranteed to clear all of the obstacles OUTSIDE the VCA by same rules you would be clear of them on a diverse departure.
That still leaves the obstacles INSIDE the VCA. To calculate the climb-to altitude, the TERPsters find the highest obstacle within that radius (usually they use 2.8 NM plus the distance from the Airport Reference Point to the most distance Departure End of the Runway-- generally that's 3 NM minimum, and usually more). From the height of that highest obstacle, they raise the level another 250' and then round up to the nearest even multiple of 100 (plus any adjustments if necessary). So at that altitude, you are guaranteed to be at least 250' vertically above all obstacles WITHIN the VCA. So the only question then is the period from take-off to the VCA…
And from there you are expected to avoid the obstacles visually, which is why there are the higher ceiling and vis mins. But I don't read that as a violation of FAR 135.379. 135.379 just says to avoid obstacles by 35' vertically, or 200' horizontally (within the airport boundary) or 300' horizontally (outside the airport boundary). It doesn't forbid you using see-and-avoid to do so when in visual conditions.
To summarize, I think a part 135 jet could still do the VCOA legally, based on the above.
I'm not an airline guy, I'm military flying big jets (or was until a week ago, anyways… class starts Tuesday for my new single engine ride!)... so I'm not sure about the OpSpecs side of the question having never seen them. Perhaps there is something in their that specifically prohibits a VCOA that makes the rest of this discussion moot. However...
I believe the VCOA (Visual Climb Over Airport) IS an ODP. So I don't think there is any real regulatory issue involved in doing the VCOA "rather" than the ODP, because the VCOA "is" an ODP. I base that argument on a couple of sources:
1. The TERPS manual (FAA Order 8260.3B http://www.faa.gov/documentLibrary/media/Order/8260.3B Incl Chgs 1-21.pdf) chapter 4 describes the VCOA as an "an alternative method for pilots to depart the airport where aircraft performance does not meet the specified climb gradient. Development of a VCOA is mandatory when obstacles more than 3 statute miles from the departure end of runway (DER) require a greater than 200 ft/NM climb gradient." This description and the rest of the regulations involved in building the VCOA all come from the instrument departures section of the manual where all of the other ODP information comes from.
2. Section 5-2-8 of the AIM (about ODPs and SIDs) also states that "Some DPs established solely for obstacle avoidance require a climb in visual conditions to cross the airport or an on-airport NAVAID in a specified direction, at or above a specified altitude. These procedures are called Visual Climb Over the Airport (VCOA)." Seems to imply to me that VCOA's are a subset of ODPs.
3. At least 1 FAA document that I found relatively easily specifically spells out that the VCOA is part of the ODP: http://www.faa.gov/about/office_org...0/afs420/acfipg/open/media/Hist_10-01-292.pdf. Of course, this isn't a FAR, so it probably isn't exactly gospel, but it seems to lend credence to the same idea.
If that's the case, then the other point that you raised still stands: Even if I am legally allowed to fly a VCOA, I'm still required to keep the airplane at least 35 feet vertically clear, or 300 feet horizontally clear of the obstacles (outside the airfield boundary). How do I confirm that I am able to do that in a VCOA? Well the answer comes from the TERPs manual. The VCOA is only authorized when an obstacle is outside of 3SM from the airport and it penetrates the obstacle identification surface (the 40:1 OIS slope) requiring a greater than 200'/NM climb to clear it. So they calculate an altitude that you will be climbing to within a particular radius of the airport (these become the ceiling and vis restriction), and from there you are expected to continue to climb at 200'/NM. By raising the starting point of your climb from ground level to the climb-to altitude you avoid all of the obstacles outside of the visual climb area (VCA). So long story short, by doing the VCOA, you are guaranteed to clear all of the obstacles OUTSIDE the VCA by same rules you would be clear of them on a diverse departure.
That still leaves the obstacles INSIDE the VCA. To calculate the climb-to altitude, the TERPsters find the highest obstacle within that radius (usually they use 2.8 NM plus the distance from the Airport Reference Point to the most distance Departure End of the Runway-- generally that's 3 NM minimum, and usually more). From the height of that highest obstacle, they raise the level another 250' and then round up to the nearest even multiple of 100 (plus any adjustments if necessary). So at that altitude, you are guaranteed to be at least 250' vertically above all obstacles WITHIN the VCA. So the only question then is the period from take-off to the VCA…
And from there you are expected to avoid the obstacles visually, which is why there are the higher ceiling and vis mins. But I don't read that as a violation of FAR 135.379. 135.379 just says to avoid obstacles by 35' vertically, or 200' horizontally (within the airport boundary) or 300' horizontally (outside the airport boundary). It doesn't forbid you using see-and-avoid to do so when in visual conditions.
To summarize, I think a part 135 jet could still do the VCOA legally, based on the above.
Dugie8
Well-Known Member
The problem isn't the obstacle clearance created by terps it's showing you can meet the performance required to meet or exceed the terps design (under 135). Now, any sane person can see that any two engine jet can more than exceed even the steepest ODP requirement with all engines turning and that is what terps is for, all engine(s).
The problem arises with OEI, show you can make the required performance. People use the VCOA as a "freebie" for not having an approved escape plan, ie APG, runway analysis, etc.
See and avoid is not a valid escape maneuver. The performance requirements must be met for the takeoff path, regardless of what path you choose. Be it a VCOA, published ODP or SID, or the standard climb to 400 AGL and on course.
Go to your AFM and find the data for climb performance at V2 while in a 15 degree bank turn. Matter of fact find the chart for all engines climb performance (fuel, time, distance to climb) doesn't count
The problem arises with OEI, show you can make the required performance. People use the VCOA as a "freebie" for not having an approved escape plan, ie APG, runway analysis, etc.
See and avoid is not a valid escape maneuver. The performance requirements must be met for the takeoff path, regardless of what path you choose. Be it a VCOA, published ODP or SID, or the standard climb to 400 AGL and on course.
Go to your AFM and find the data for climb performance at V2 while in a 15 degree bank turn. Matter of fact find the chart for all engines climb performance (fuel, time, distance to climb) doesn't count
z987k
Well-Known Member
You have to be talking about transport category aircraft only. Which is a hell of a modifier.
Dugie8
Well-Known Member
I said that a few posts back.m
Check out 135.398
Last edited:
fish314
Well-Known Member
Dugie8, on that score you are absolutely right. Just doing a VCOA doesn't relieve all climb gradient restrictions… it just reduces them to 200'/NM, and you still need to meet that AND still be able to perform the VCOA with one engine out… which requires at a minimum turning to remain within a particular distance from the airfield. Depending on your airframe, that may not be possible on a takeoff where you've lost an engine, particularly if you've lost the engine at or just after V1.
And actually, I just noticed the requirement to maintain straight and level until 50' AGL and then not exceed 15 degrees of bank on the climbout (FAR part 135.379 (2) (f), and a similar restriction on FAR 121.189). Just being limited to 15 degrees of bank alone might eliminate the VCOA as a valid option for parts 121 and 135. Since the VCOA requires remaining within a distance that is usually 3 mi. from the field. Not sure if you'd be able to do that at 15 degrees of bank… military doesn't have that restriction.
MNFlyboy
Well-Known Member
Ok, for my sake since I don't fly a Large Trans Cat Aircraft, and those regs don't apply to this situation, let's assume we're all out flying in a Caravan or a King Air 200 under 135. For what it's worth I recently read over our GOM and it states; during IMC or Marginal Visual Meteo Conditions (which it goes on to define), an ODP or SID MUST be flown, so there goes my visual ambiguity, except for conditions better than 3000 and 5. So in severe clear, the question still stands. Does being on an IFR clearance basically imply that since ATC has taken over the responsibility of your safety to a certain extent, that now I must adhere to their publications and directions in order to be compliant, whereas if I was VFR, the responsibility to not CFIT is completely yours!?
Dugie8
Well-Known Member
Well, if you are IFR, ie on an IFR plan and have a clearance, YOU MUST fly the ODP, UNLESS the TOWER gives you something else. KAVL is a great example. Tower open you can get "Cleared for take off fly heading 090" You take off, climb to 400 feet (or if the 10-9 has a no turns before XXXX, you climb to XXXX and turn) to 090. Tower is closed and you get your clearance from FSS but in that clearance it says "As filed, after departure fly heading 090" you must takeoff, fly the ODP THEN fly heading 090.
If you are VFR and not on an IFR clearance, yes terrain clearance is on you (just like a part 91 flight with a student). HOWEVER, I think a King Air 200 falls under the Commuter category, then 135.398 applies. You would have to look in the AFM to see what category (normal, commuter, etc) the airplane falls under.
For a Caravan, I believe 135.399 applies and provides some relief
With 135.385 .387 being landing at destination and alternate airports requirements.
If the king air falls under 135.399 then you are pretty much free to take off at AFM limits in terms of weight (runway, structural, etc).
Dugie8
Well-Known Member
Let me clear up what I may have caused in terms of confusion.
Part 135, on an IFR plan and release you must fly the ODP. ref 91.175 (I may have misstated and said at all times fly the ODP)
So, from that reg. Under IFR, that meaning on the clearance regardless of weather, you must fly the ODP UNLESS ATC gives you something different. If you are VFR, meaning not on a clearance, section (i) still applies.
Subpart I of part 135 tells you how much you have to miss the obstacles by. That has to be computed by some means, you cannot just say "I will see and avoid". The see and avoid is where everyone gets caught up in the VCOA stuff. They take those weather mins for a VCOA to mean, as long a the weather is, for example, 5000 and 3, I can just take off and I won't hit anything because I will see it first.
To further complicate, if you don't have OpSpec C077, you cannot take off VFR (135 operator). Even if you have C077 you have to be unable to get your IFR clearance, pretty tough to not get a clearance with cell phones today. Yes there are airports that make it impossible. Those being the exception, not the rule.
Maybe we can get a Center Controller to chime in here on what they are allowed/supposed to give us for issuing clearances from uncontrolled fields that have ODPs.
Part 135, on an IFR plan and release you must fly the ODP. ref 91.175 (I may have misstated and said at all times fly the ODP)
So, from that reg. Under IFR, that meaning on the clearance regardless of weather, you must fly the ODP UNLESS ATC gives you something different. If you are VFR, meaning not on a clearance, section (i) still applies.
Subpart I of part 135 tells you how much you have to miss the obstacles by. That has to be computed by some means, you cannot just say "I will see and avoid". The see and avoid is where everyone gets caught up in the VCOA stuff. They take those weather mins for a VCOA to mean, as long a the weather is, for example, 5000 and 3, I can just take off and I won't hit anything because I will see it first.
To further complicate, if you don't have OpSpec C077, you cannot take off VFR (135 operator). Even if you have C077 you have to be unable to get your IFR clearance, pretty tough to not get a clearance with cell phones today. Yes there are airports that make it impossible. Those being the exception, not the rule.
Maybe we can get a Center Controller to chime in here on what they are allowed/supposed to give us for issuing clearances from uncontrolled fields that have ODPs.
Similar threads
