Visiual App

[topdawg]

An incident occurred recently at our company on an observation flight with the FAA aboard. They were about 15 miles out and called the visual. As they got closer they realized that they wouldn’t be able to circle at pattern altitude due to a couple low clouds (500 below -class E) and went below but stayed well above the circling MDA. The FAA claimed that since it was a visual app. you can not under any circumstances descend below the pattern altitude. Our operation specifications even tell us we can accept a visual with 1000 ceiling and 3 miles vis. Witch wouldn’t even be possible if you had to maintain a 1500 pattern altitude. I think the Fed is wrong…anybody?

 

[lawfly]

Without commenting on the merits (yet, anyway) just wondering, is this a pending enforcement action (FAA Regoinal Counsel), or is it an investigation (FSDO)? Or just some "informal" dialogue with someone at FAA? Just wondering.

 

[imacdog]

5-4-20 in the AIM doesn't mention minimum altitudes for the visual approach, only that you need 1000-3 to do the approach. I would think with those weather minimums there would be nothing preventing you from descending below pattern altitude as long as you have the airport in sight. If your pilots descended to 500 feet below the clouds, they did not need to do so. Cloud clearance requirements do not apply to visual approaches.

 

[topdawg]

Cloud clearance does apply to visual apps.,(91.129-131) you have to maintain the applicable cloud criteria for that particular airspace. But my point was our op. spec. allows us to accept a visual with 1000-3 which if there was a 1000 ceiling over an airport I would still be able to accept it with a 500ft traffic pattern (500 below). This Fed is saying that you you have to maintain 1500ft in the pattern and maintain cloud clearance (which would be a min of a 2000ft ceiling) or you can't accept it.

 

[imacdog]

This is directly from the AIM:

"Cloud clearance requirements of 14 CFR 91.155 are not applicable, unless required by operation specifications".

If they had cancelled their flight plan then clearance requirements would have applied. If they didn't cancel their plan then the above applies.

 

[EatSleepFly]

I'm confused.

You're talking about VFR cloud clearance requirements. They don't apply to you if you are on an IFR flight plan EVEN IF you accept a visual approach. The wx must be 1000' and 3sm, but that's it. You don't have to stay 500' below unless you cancelled IFR.

Sounds like the fed was drinking his bath water.

AIM 5-4-20 even says, and I quote:

"Cloud clearance requirements of 14 CFR 91.155 are not applicable unless required by operation specifications." (Emphasis added)

Tell the Fed to put that in his pipe and smoke it.

EDIT: Imacdog beat me to it, but yeah...what he said.

 

[Rez O. Lewshun]

What about maintaining 1500ft until lower altitude is needed for landing? (turbine aircraft in class D or C is in question?) This doesn't mean one could approach the airport a 500ft to stay below clouds?

 

[DirtyBeech]

nevermind, just saw it was class E airspace.

 

[EatSleepFly]

What about maintaining 1500ft until lower altitude is needed for landing? (turbine aircraft in class D or C is in question?) This doesn't mean one could approach the airport a 500ft to stay below clouds?

If you're on an IFR flight plan, and are cleared for the visual, you can have your tail and each wingtip in the clouds, as long as they're at least 1000', the vis is 3sm, and you can see (and will be able to continue to see) the runway out the front. In other words, if the weather's broken at 1000' and 3sm and you get the runway in sight, and can keep it in sight, I say the 1500' rule doesn't apply. At that point, being below 1500' is "necessary for landing" anyways, because in order to land, you need to see the airport. Am I wrong?

 

[Rez O. Lewshun]

At that point, being below 1500' is "necessary for landing" anyways, because in order to land, you need to see the airport. Am I wrong?

At this point I'd get an Instrument approach clearance. But I'm not a guru on this stuff...not by a long shot....

Anyone? Any TERPS geeks?