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speed limit 12 miles offshore

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This is really interesting. I was assigned 300kts the other day in the decent and to cross an intercetion at 8000 and 250. The controller expressed he wanted us at 300 and slow as late as possible. It was Miami approach, and the intercetion is more than 12 off.

The instructions were "Maintain 300 kts. and slow to cross 'intersection x' at 250kts."

Previous clearance was issued to cross "int. x." at 8000ft.

Has everyone been slowing to 250 below 10K when 12+ offshore?

So I guess the new question becomes - "what is the interaction between 91.119 and 91.123" If the controller gives you "maintain 300 knots" can you do it?

In the situation you described - I am sure you did what the controller intended - however, if it were reviewed, it would be very easy for the controller to say that he did not intend for you to violate the rule and it would have been possible for you to comply with his clearence without violating the rule.

For example couldn't you have stayed at 10,000 until the last second at 300 knots and then dump down to cross at 8 and 250.

Not saying that's what I would normally have done, but it seems that that is what the rule requires.

Later
 
So I guess the new question becomes - "what is the interaction between 91.119 and 91.123" If the controller gives you "maintain 300 knots" can you do it?

In the situation you described - I am sure you did what the controller intended - however, if it were reviewed, it would be very easy for the controller to say that he did not intend for you to violate the rule and it would have been possible for you to comply with his clearence without violating the rule.

For example couldn't you have stayed at 10,000 until the last second at 300 knots and then dump down to cross at 8 and 250.

Not saying that's what I would normally have done, but it seems that that is what the rule requires.

Later

You make a great point, but the only problem is that It's difficult enough to get the plane slowed down in a normal descent and it just won't slow in a steep descent. You are most likely right if it were to get reviewed. I wonder if the contollers have seen this letter.
 
So I guess the new question becomes - "what is the interaction between 91.119 and 91.123" If the controller gives you "maintain 300 knots" can you do it?

91.119 will prevail. A controller cannot clear you to operate contrary to the regulations. This is stated in the AIM, reminding pilots an ATC clearance does not authorize a pilot to deviate from the regulations and that they are responsible for rejecting such a clearance. It is also stated in the Controllers handbook, reminding that they cannot clear a pilot to violate the regulations and that a pilot is obligated to reject such a clearance.
 
91.119 will prevail. A controller cannot clear you to operate contrary to the regulations. This is stated in the AIM, reminding pilots an ATC clearance does not authorize a pilot to deviate from the regulations and that they are responsible for rejecting such a clearance. It is also stated in the Controllers handbook, reminding that they cannot clear a pilot to violate the regulations and that a pilot is obligated to reject such a clearance.

As the interpretation of the rule itself is relatively new, and this interpretation is misunderstood by the controller in this case, it seems that a call to the facility to clarify this scenario would be in order. There certainly is no reason to get into a discussion over the freq. Might as well slow down at 10k and if the controller has a problem with that, ask to speak with them over the phone.

No argument, just my humble opinion.
 
As the interpretation of the rule itself is relatively new, and this interpretation is misunderstood by the controller in this case, it seems that a call to the facility to clarify this scenario would be in order. There certainly is no reason to get into a discussion over the freq. Might as well slow down at 10k and if the controller has a problem with that, ask to speak with them over the phone.

No argument, just my humble opinion.

No argument at all, I agree. I was just commeting on the general principle that would apply (which isn't new). Certainly, like you say it would be best to deal with the situation as professionally as possible and a call later to clarify would be a good idea.
 
Aren't you guys always at 250 KIAS or less below 10,000'? ;) If you ever doubt me, just ask me to say airspeed.

(Just Kidding!)

LS
 

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