A Lost CRAFT

I think most instrument pilots know about CRAFT: it's the acronym for the order of the elements of an IFR clearance:

Clearance limit;

Route;

Altitude;

Frequency;

Transponder code.

My IFR Ground School has reached the point where we are starting to try to understand Air Traffic Control (ATC). Where do you begin understanding such a complicated system? I have always taught that the answer to every IFR puzzle begins "Well, in the event of lost communications, ..." That's where we began.

The lost comm rules (14CFR91.185) have puzzled pilots for years. Most of it is logical: if you fly into a big hole in the clouds, continue under VFR, and land as soon as practicable. Call Flight Service and tell them what happened, and continue on your way VFR. You don't even have to shut down.

You fly the highest (i.e. safest) of the minimum IFR altitude, the altitude you were cleared to, and the altitude you were told to expect. Still pretty simple.

You fly the route you were cleared, or told to expect, or what you filed. OK.

But when do you start down? The rule is complex, and I have heard a lot of silly interpretations over the year, some of them from my mouth, I am ashamed to say. "Just land and get out of their way" is the most common one. But what do the rules really say? And are they that hard to interpret?

Yes, they are that hard to interpret. The difficult time is when ATC clears you to someplace other than the airport. They may or may not give you an Expect Further Clearance (EFC) time. You do different things in each case. Let's look at an example and see what the rules say.

Let's fly from Provo, Utah (KPVU) to Idaho Falls, Idaho (KIDA). Checking skyvector.com shows that V21 goes from Fairfield VOR (FFU) to Idaho Falls VOR (IDA). The Departure Procedure takes you to FFU, so you file "FFU V21 IDA."

This route crosses the Salt Lake City Class B airspace, and a typical clearance is "Cleared to the Fairfield VOR via the Provo Three Departure, Squawk 4321." The altitude and Departure Control frequency are on the chart, so ATC leaves them out. The chart also says "...Expect clearance for filed route and altitude within 10 minutes after departure."

So far, the clearance limit is FFU, which is not an Initial Approach Fix for KIDA. The regulation is clear: your clearance limit is not an initial approach fix, and you do have an Expect Further Clearance (EFC) time. Start a timer when you're cleared for takeoff. If there is a communications problem, fly the departure procedure, hold at Fairfield until 10 minutes have passed, and proceed on your way. What has happened here is that ATC has given themselves 10 minutes to clear a path for you if something goes wrong. It's about 19 miles from KPVU to FFU via the Departure Procedure, so your 10 minutes will probably be up when you get to FFU.

If nothing goes wrong, as you get close to Fairfield you hear something like "Cleared to the Idaho Falls airport via fly heading 330 to intercept V21, then as filed, climb and maintain 11,000." The heading is a radar vector, so if you lose communications you know to fly toward V21.

Is this in the a gray area? The clearance limit, that is, the airport, is not an Initial Approach Fix. But since the airport is not an IAF, and you don't have an EFC time, if you lose radio contact you go to an IAF, then start the approach at your ETA. There should be an IAF in your flight plan route.

Approaching Idaho Falls, you hear "Proceed direct Idaho Falls VOR, expect ILS approach." The clearance limit is an IAF and but you have no EFC time, so if you lose communications before Idaho Falls then you hold there until your ETA. You are given a route to "expect," too, so that's the route to fly.

If it's busy, they'll spin you. "Hold South of the Idaho Falls VOR as published, maintain 11,000, expect further clearance at ... ." Now your clearance limit is an IAP, and you have an EFC. If the radios go bad, you leave IDA at the EFC and fly the approach.

That's not so bad, is it? Of course it is. Not. But one way to learn is to imagine a few scenarios of your own. What if the destination is your favorite Class B airport? What happens if the destination is shut down by weather (I once had to divert from Laramie because the VOR had been hit by lightning, and all they had was a VOR approach. I didn't want to go there, anyway.) Playing "What if..." is a great way to sort this stuff out.

Just remember to begin your answer with "Well, in the event of lost communications... ."

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Next: Unusual lost comm scenarios.

Looking in the Wrong Direction

My student and I were approaching Pocatello, Idaho, for some touch-and-goes with the tower. He is presolo. He tuned the tower in time to an interesting dialog. The weather was clear with visibility 10.

TOWER: "SkyWest 24W, we have a disabled aircraft on runway 21, can you accept runway 35?"

SKYW 24W: [after a short pause] "Sorry, no, we aren't authorized runway 35." That's not unusual; SkyWest operates under Part 121, which requires lots of runway analysis and the like.

TOWER: "SkyWest 24W, roger, hold over Pocatello VOR, maintain 6500."

You can see what happened on FlightAware, the best aircraft tracking site. The jet was
on downwind for runway 21, overflew the runway, and headed to the VOR. But this is where it gets interesting.

First, Pocatello is a VFR tower, and I imagine that they informed Salt Lake Center. Radar coverage is spotty and too far from the antenna; the tower does not have a BRITE display. I imagine...

Second, it was not a proper holding clearance. I assumed that it meant "hold as published," and was looking for the jet to the west of the VOR. The charted hold is "hold west on the 269 radial, left turns." I assumed...

Third, the jet got to the VOR and made a direct entry. They assumed that the AIM advice that in the absence of further holding instructions they should make a direct entry applied. They assumed...

Fourth, as we entered downwind at 5500 MSL, the RJ passed directly over us at 6500. Where did they come from? This is legal separation between a VFR and an IFR, but it was a surprise. I asked the tower ("What holding pattern is that RJ flying? I thought they'd be on the 269 radial."), but he did not sound surprised. So if he knew where they were why hadn't he called us as traffic for them and vice-versa?

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And so I conclude: Everyone was wrong.

Tower: Did not issue a proper holding clearance, which should have been "hold as published," or maybe "hold northeast on the 030 degree radial." See the Aeronautical Information Manual, 5-3-7b. Tower did not inform converging traffic (altitude separated though we were, although he had no way of knowing that.)

Me: Did not catch the improper clearance, and assumed it was"hold as published." Looked for the RJ west of the airport, when actually it was northwest through west.

SkyWest 24W: Took lack of proper clearance to mean "enter a standard pattern on the course on which the aircraft approached the fix," to quote AIM 5-3-7c. But that applies if unable to get holding instructions. [I admit that I am mind-reading here, but would prefer to give the RJ crew the benefit of the doubt as far as regulations go the alternative being that they just made it up as they went along.)

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Instrument regulations are maddeningly subtle. Important things are buried in the same banal prose as unimportant things. For example, are you required to have a visual descent point (VDP) on an instrument approach? (A VDP is the point on the approach after which a normal descent is impossible.) The regulations do not say directly that you do, but according to 14CFR91.175 "Operations below Minimum Descent Altitude" you need to have a descent rate that would allow touchdown in the touchdown zone if you are operating under part 135 or 121. In other words, a part 135 regulation is only listed under part 91. And this appears in the same bureaucratic prose as "truth in lending." There are many blank areas of interpretation to jump, lots of blank areas that do not seem to matter much, and little guidance on how to decide whether or how to jump them.

Instrument Departures

The IFR world is always changing, and change comes faster and faster.  

In the old days, there were two main sources of instrument charts in the USA, the government (under a continually changing variety of names) and  Jeppesen, a commercial provider.  I still use Jeppesen charts for most of my flying, but now government charts, which are public domain, are widely available on the internet, through sites like AOPA, FltPlan.com, Airnav, and probably others. For this trip, I have downloaded government charts for the airports I am likely to use, although I am unlikely to fly IFR.

Let me say it out loud: I am unlikely to fly IFR because the airplane does not have an IFR GPS.  Yes, I can and may fly IFR, but the lack of a GPS makes it much more difficult, and it reduces the options.

This was reinforced while catching up on my chart revisions.  (Actually, I was getting ahead, since some of the charts are not valid until Thursday, but I determined that none of them will affect my flying between now and then.)  One of the advantages of the Jeppesen charts is that they tell you why the chart has changed.   Lately, there have been a lot of changes to departure procedures.

Departure procedures are strange to begin with.  Generally, they are optional.    They are not optional when Air Traffic Control (ATC) includes the departure procedure in a clearance, which they will do if they need it for separation.  This tells me that when a departure procedure changes, ATC would like to use the new one in order to move more airplanes more efficiently.  Why change a procedure that has worked for 20 years unless you want to actually use the new procedure?  (It used to be that the exact statement about departure procedure being pilot's choice was only published in the controller's handbook, not in any publication for pilots, but now it is in the FAA's Instrument Procedures Handbook, FAA-H-8261, available online.)

Look first at Driggs, Idaho.  (Unless you have a Jeppesen subscription you'll have to wait until Thursday to look, because charts are not available online until they become effective.)  The chart had a minor change this time around, but in looking it over I noticed that there is no non-GPS departure.  There are no ground-based navaids at Driggs, which is in a narrow U-shaped valley, so the only alternative to a GPS-based departure is to pick a smart heading, climb steeply,  and hope that the winds aloft forecast is correct.  There is no radar coverage, so nobody looks over your shoulder.  No thank you.

The Cherokee Six we're in this week has DME but no GPS. Suppose that we decide to stop for lunch at Driggs on the way home (the restaurant there is excellent), and find that we need to depart IFR. No can do! This alone wouldn't keep us from stopping, but it still makes me pause.

Next, look at Pocatello, Idaho, which has a new departure procedure, even though the old one had worked well keeping airplanes out of the rocks for at least 15 years.  The new procedure involves a "departure gate" at SICOY; in other words, every departure ends up about 13 miles west of the airport, even for an easterly flight.  Also, you need DME (or some equivalent) to identify SICOY, so many KPIH-based airplanes cannot fly the procedure.  You can see SICOY on the VOR 3 chart at right.

I think a lot of Pocatello-based pilots will react to the change by saying "ATC seldom clears us via the departure procedure." But this is may be about to change.  Pocatello is generally below radar coverage, so ATC keeps airplanes apart procedurally.  The old departure procedure used the same airspace as the ILS missed approach, which meant that no airplane could depart while another was on the approach.  Now, ATC can send the departure to SICOY and be sure that the missed approach area is clear.  In other words, it will be easier to get out of Pocatello, as long as you have DME.

If you keep or rent an airplane in Pocatello, you have to ask whether departure delays will cost enough to justify an avionics upgrade.