“Takeoff minimums - NA” Implications (USA)
Posted by Yung_lettuce@reddit | flying | View on Reddit | 20 comments
If an airport states “runways x,y,z, NA - Environmental”, Does that imply that you cannot depart under imc, ifr, or both?
I figured that if conditions are Vmc and you’re under an Ifr flight plan, there’s no practical reason you couldn’t depart from said runways, as long as you can keep visual separation from obstacles.
kmac6821@reddit
Takeoff minimums with Not Authorized means than an IFR departure is not authorized from that runway. It’s that simple. It doesn’t matter if you are VMC. If you’re on an IFR flight plan, you cannot use that runway.
See the 8260.46, Appendix D
randombrain@reddit
91.175(f) says that published takeoff minimums only apply to operations under Part 121, 125, 129, or 135. Regular GA Part 91 operations are not bound by takeoff minimums.
Understanding that none of us are aviation lawyers, do you have any opinion regarding how that relates to "NA" minimums?
kmac6821@reddit
My opinion is just that… totally non-authoritative on this topic.
My take is that an IFR departure (including Part 91) is not authorized from the runway. The presence of a departure procedure (including diverse) is the first logical step in the establishment of takeoff minimums. Since there is no authorized departure procedure from that runway, there is no possibility for takeoff minimums to exist. Therefore, Takeoff Minimums - NA is not a statement about visibility/ceiling, but that you cannot takeoff IFR at all. Therefore 91.175 does not apply.
How the framework of information is listed on the 8260-15A and in the IFR Takeoff Mins section causes a logical problem if other options had been used.
Not listing anything in that takeoff mins section would indicate standard minimums, which is not true. Listing N/A would make it seem that there were no minimums for a diverse departure, which is also not true.
Maybe I will bring this up at the end of tomorrow’s Departure working group. It’s an interesting question.
randombrain@reddit
Please let us know! I'm curious now.
Really it would need to be an LOI from the Chief Counsel's office... I wonder if it's been asked before. They changed from their old webpage with a really good search function to the Dynamic Regulatory System a little while ago, and I've found that the DRS isn't great for search. But I can try to look.
kmac6821@reddit
Ok, here’s the answer. It’s not 91.175 that is important, but whether a pilot can be considered reckless for taking off on an IFR clearance from a runway that is not authorized for an IFR departure. In this case, it’s part 91.123 that matters (accepting of the IFR clearance).
The AIM may be updated to address this.
randombrain@reddit
Hm, yeah, that would be a really good thing to add to the AIM (and to get the Chief Counsel's eyes on, I would imagine).
randombrain@reddit
To answer my own question, searching the DRS for 91.175 returned a handful of interpretations. Most were regarding landing, but
Nothing about whether "NA" applies to Part 91.
randombrain@reddit
/u/kmac6821 is our charting expert here, but I think he knows some stuff about the TPP as well. We'll see what he says.
Note that NA and N/A have different meanings—N/A is "not applicable" while NA is "not authorized." Just so we're all on the same page here.
Taken at face value, I believe this would mean you cannot depart IMC or IFR from the given runways. However (and I'm not an expert) I would be inclined toward /u/KronesianLTD's view: Takeoff minimums are not binding on Part 91 operations in the first place, so the fact that the minimum WX conditions are "not authorized" is also not binding on Part 91.
That doesn't make it a smart move to ignore the information, of course.
GeneratedUserHandle@reddit
This should just be deleted because OP wont even give an example.
Yung_lettuce@reddit (OP)
Runway 21 at KBLM and runways 10, 13, 28, 31 at N51
GeneratedUserHandle@reddit
Part 91 and able to see and avoid, have fun cowboy. Until you hit something and are tagged with 91.13.
Yung_lettuce@reddit (OP)
You’re extremely aggressive lol
AlexJamesFitz@reddit
If it's VFR, I'm not following why takeoff minimums would be relevant at all. You'd be wise to understand the obstacles etc, of course.
sniper4273@reddit
One can always depart IFR in VMC.
AlexJamesFitz@reddit
Of course. In a case like this, though, I'm not seeing the material difference in departing IFR from the ground versus departing VFR and picking up your clearance in the air.
I guess maybe they wouldn't clear you from the ground to begin with?
sniper4273@reddit
I don't think you would be cleared for this departure IFR, even in VMC. So yeah, I agree this would be a good reason to depart VFR and pick up in the air. Assuming you were aware of what obstacle was causing the problem and were mitigating the threat some other way.
randombrain@reddit
Perhaps not at a towered airport. Or perhaps yes at a towered airport; depends on the local ATC procedures, and we aren't taught a lot of stuff about the TPP and takeoff minimums.
But at a non-towered airport, unless ATC assigns a runway-specific departure procedure, you can use whatever runway you like... as far as we're concerned. It's on you to figure out what's legal for your operation, and make sure you're doing that.
KronesianLTD@reddit
Under Part 91, Takeoff Minimums do not have to be adhered by (unless you accept a clearance to fly a certain departure procedure from ATC)... but it could still could be considered reckless operation if you depart from those NA'd runways in pure IMC (91.13). Is it a good idea? I wouldn't think so. From what I found (someone correct me if I am wrong), Environmental means something like a grass runway.
The move I think here is if you really want to use those runways, departing VFR and picking up a clearance in air is the safest move.
GeneratedUserHandle@reddit
It would be easier if you named the airport.
rFlyingTower@reddit
This is a copy of the original post body for posterity:
If an airport states “runways x,y,z, NA - Environmental”, Does that imply that you cannot depart under imc, ifr, or both?
I figured that if conditions are Vmc and you’re under an Ifr flight plan, there’s no practical reason you couldn’t depart from said runways, as long as you can keep visual separation from obstacles.
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