Cardinal
Of The Kremlin
- Joined
- Nov 25, 2001
- Posts
- 2,308
Unfortunately for me, our FOM does not provide as much discretion. We are able to deviate from the route as long as its within 5 miles either side of the route.
I just looked at my old one, and it says the same things, specifically allows for deviations in an emergency. However the operating philosophy described above was how we taught the matter, and how we demonstrated it to the Feds I had on aircraft on a weekly basis. Would your POI be more impressed with reasonable judgement or getting into a pissing match with ATC on the frequency?
The guy even told me that I'm required to accept his clearance because that is regulation and it supersedes my terrain clearance regulation
He is probably right. I perused 7110.65 and 121.191 but can't offer evidence for the assertion.
Another thought experiment: Any driftdown plan, using .191(a)1 or .191(a)2 makes a number of assumptions, many are bunk. A key assumption is the climb profile. Your planning software - necessary to comply with (a)2 - in all likelihood uses a best angle, uninterrupted climb from the runway to your planned cruise level. That never happens, and we all know it. So the data we're working from is invalid and doesn't comply with 121.191 the second we're held at an intermediate level. Are you crosschecking ISA deviation in the climb? One more way your data is in error and compliance is in question from the beginning.
The reg is a good one, it ensures you have options should an engine fail at an innoportune time, Fate Is The Hunter style. But take the broad view, comply with the letter of the law to the extent possible, then consider the spirit and principles behind it. Although I imagine I'm wasting my breath.
Further, what are we actually going to do when the dreaded engine failure occurs? We had a leg from FMN-DEN, passed directly over ALS, which lies in an huge 80 mile wide valley, hemmed in on both sides by 14000' mountains. Most days the computer showed (a)2 compliance with no alternates, thus if an engine failure happened directly over ALS, one could make it over the intervening mountain range and stagger to DEN. So, given an engine failure on a VMC day over ALS, are we going to land at the near and suitable airport below us, or buzz the hikers for 170 miles to our "driftdown approved" destination? I know what I'd do.
Know the regs. Know that they are in conflict. Apply reasonableness.