Short cuts below MSA.

[16024]

Ask three trainers and you'll get four answers.
What is the official, rather than company preferred line on this.
For example, on a SID in day VMC "Cleared direct to (end of SID)".
What about in night IMC?
The kneejerk response is "Can't accept it", but we take radar vectors or "Direct to CF" every day, on to the ILS, descending to platform below MSA.
Any thoughts?

[MrHorgy]

I think surely it depends who is asking. If ATC clear you direct to a point, then they remain responsible for terrain seperation. If you ask then it's a bit more hazy. I've been a big believer of "if you can see it you can avoid it" - I would have no issue asking for, and accepting a shortcut in day VMC below the MSA, but it would be silly to ask for it in IMC or at night when you can't see the obstacles.

[Checkboard]

OPS 1.230
Instrument departure and approach procedures
(a) An operator shall ensure that instrument departure and approach procedures established by the State in which the aerodrome is located are used.
(b) Notwithstanding subparagraph (a) above, a commander may accept an ATC clearance to deviate from a published departure or arrival route, provided obstacle clearance criteria are observed and full account is taken of the operating conditions. The final approach must be flown visually or in accordance with the established instrument approach procedure.

That should cover it.

[qwertyuiop]

:ugh::ugh:MrHorgy:ugh::ugh:

As a trainer I spend most of my time insisting it is the crew that are responsible for terrain separation.

NEVER blindly follow ATC instuctions!!! :ugh::ugh::ugh:

[172_driver]

Just a little note, in US (probably same in Europe) the MSA is based on 25 nm from a NAVAID for reference. This navaid is not always located on the aerodrome, sometimes 15-20 nm away which makes the MSA less than helpful in some cases.

The departures I used to fly was "after departure fly heading XXX vectors XXX" initial climb clearance below MSA and grid MORA due to airspace restrictions. I was quite aware of the terrain but had to trust ATC and their minimum vector altitude to get out of the airspace/terrain safely. This was in a light twin with benign single engine performance. I knew the escape manoeuver was to head west. How different the world can be….

[fireflybob]

16024, what does your Company Operations manual say?

[aterpster]

172 Driver:

Just a little note, in US (probably same in Europe) the MSA is based on 25 nm from a NAVAID for reference. This navaid is not always located on the aerodrome, sometimes 15-20 nm away which makes the MSA less than helpful in some cases.

Do you have an example of a U.S. MSA that is that far from the airport? In any case, in the U.S. MSAs are not operational altitudes and don't provide required obstacle clearance in designated mountainous areas. Further, on RNAV IAPs MSAs are not sectorized so they often have no usefulness in mountainous areas whatsoever. But, you probably knew all this.

[aterpster]

qwertyuiop:

As a trainer I spend most of my time insisting it is the crew that are responsible for terrain separation.

NEVER blindly follow ATC instuctions!!!

So true. Sadly, it's a message that is often not heard. Today, we do have EGPWS to make the final save (unless the terrain is too steep and too high).

[172_driver]

15-20 seems a bit excessive at second look, apologies, first thought about KSEE which is 13 nm from MZB. Also KSBA has 14 nm to GVO. Wasn't aware the MSAs didn't provide required obstacle clearance, even though I've never used them for any operational purpose (in US). But I agree they don't provide much usefulness for any accurate terrain assessment in SoCal. Especially not for my type of flying machine.

[buzzc152]

My understanding is that you can go below MSA when you are either :

i) under positive radar control
ii) on a published procedure (SID, STAR etc)
iii) visual

[misd-agin]

Company provides Jepps 10-1R page. Provides min vectoring altitude information. Nice to have in mountainous terrain.

[Checkboard]

An IFR flight in the EU may descend below the en-route lowest safe altitude when:
within 25 miles, and descending to a published MSA
Operating under the VFR
conducting an Instrument approach
under Radar vectors, and above the minimum vectoring altitude
established in a published holding procedure, and above the minimum altitude for holding.

[Johnny Tightlips]

My company SOP:

Daytime VMC: No short cuts below MSA during the climb.(I was told it's due to poorer visibility during the climb, and if you had an engine failure below the MSA and your not on an airway/SID which have a certain terrain clearance margin you might be in a spot of bother.) In the descent below MSA it's not a problem as long as you can maintain VMC and don't hit anything!

Nighttime VMC: No directs below MSA in climb or descent.

Of course if we are given radar vectors it's not a problem.

[aterpster]

misd-agin:

Company provides Jepps 10-1R page. Provides min vectoring altitude information. Nice to have in mountainous terrain.

Jeppesen provides the 10-1R to all subscribers but only when the ICAO member state publishes the MVA data in the AIP.

Countries such as the U.S. and Canada do not provide source MVA data, thus no 10-1R pages for those countries (and others as well).

[OPEN DES]

An IFR flight in the EU may descend below the en-route lowest safe altitude when:
within 25 miles, and descending to a published MSA
Operating under the VFR
conducting an Instrument approach
under Radar vectors, and above the minimum vectoring altitude
established in a published holding procedure, and above the minimum altitude for holding.

I suppose you mean in ground visual contact rather than VFR. We routinely go below MSA/MVA when in ground visual contact....

[BOAC]

I reckon 'VMC/VFR' is fine - as long as you can see any prospective cumulo-granitus.

[main_dog]

If ATC clear you direct to a point, then they remain responsible for terrain seperation.

Beware, ATC are responsible for your separation ONLY IF THEY ARE RADAR VECTORING YOU. Being cleared direct to a point is NOT a radar vector: for it to be a radar vector they have to issue you a heading. As such terrain separation remains your responsibility.

In answer to the question, if cleared off a SID direct to a point while still below MSA (and in absence of company guidance), it's up to the PIC to decide whether to accept it or not, and terrain separation is up to him/her.

The other night departing an unfamiliar Chinese airport, immediately after departure I was cleared off a lengthy SID direct to a point: being unfamiliar with the airport and the surrounding terrain, we politely accepted but only started our turn once above MSA. If it had been day VMC at a familiar field, different story...

[bookworm]

Beware, ATC are responsible for your separation ONLY IF THEY ARE RADAR VECTORING YOU.

Not according to ICAO. PANS-ATM 8.6.5.2 says:

When vectoring an IFR flight and when giving an IFR flight a direct routing which takes an aircraft off an ATS route, the controller shall issue clearances such that the prescribed obstacle clearance will exist at all times until the aircraft reaches the point where the pilot will resume own navigation. (My bold.)

The usual caveats about division of responsibility apply.

[9.G]

cleared direct to is radar vectoring however resume own navigation isn't with the responsibility always resting on commanders shoulders regardless. Many are unaware of difference in cleared direct to during descent and climb. Self-understanding is that in descent direct to clearance should provide adequate terrain clearance whereas in climb below MSA it's solely commander's responsibility. Having said that him/her must account for contingency in case of EO. Merry Xmas.:ok:

[16024]

Thanks for the replies. Clearly EU ops is not easy to interpret. But the concensus is more or less what I thought. Broadly this:
Yes, it is ok to accept.
VMC or IMC makes no legal difference, common sense aside.
Know where you are in relation to terrain (yeah, I know..!).
Your company may have a more restrictive guideline.

[Pugilistic Animus]

when cleared from present position direct to a fix the pilots are responsible for terrain avoidance and must confirm sector altitude requirements...

remember the AA flight in Colombia although several other factors were responsible for that accident...if 411A were still here he would pontificate exactly what those factors were...:)

[STBYRUD]

Edited:

I am an oaf - just looked the specifics up again, enroute and terminal clearances direct to some point are NOT vectors and thus are not subject to MVAs but to "minimum flight altitudes", so usually MSA with the PIC being responsible for terrain clearance.

[Pugilistic Animus]

I'm so out of it myself, very busy... regarding MSA the controllers have MVA as STBYRUD writtenthat may be lower than MSA, this information may or may not be available to pilots, but it's perfectly legal to accept radar vectors below MSA...even in IMC of course minimums for the specific IAP still apply:O

[STBYRUD]

Yep, to put it simply vectors are (well, they have to be) safe in terms of terrain clearance, in case of "direct-to"s the pilot has to ensure terrain clearance.

[9.G]

STBYRUD, Doc 4444 - PANS ATM § 8.6.5.2 When vectoring an IFR flight and when giving an IFR flight a direct routing which takes the aircraft off an ATS route , the controller shall issue clearances such that the prescribed obstacle clearance will exist at all times until the aircraft reaches the point where the pilot will resume own navigation. When necessary , the relevant minimum vectoring altitude shall include a correction for low temperature effect.

Note 2.- It is the responsibility of the ATS authority to provide the controller with minimum altitudes corrected for temperature effect.
Let's stick to the facts, shall we? Merry Xmas.:ok:

[STBYRUD]

Damn and blast, thats the paragraph I was looking for yesterday so I edited my original post again - a JAA presentation from 2002 threw me further off track... Thanks for that, happy holidays ;)

[main_dog]

PANS-ATM 8.6.5.2 says:

When vectoring an IFR flight and when giving an IFR flight a direct routing which takes an aircraft off an ATS route, the controller shall issue clearances such that the prescribed obstacle clearance will exist at all times until the aircraft reaches the point where the pilot will resume own navigation.

Every time I think I know something it turns out I knew f£$k-all... :}

Thanks for the reference bookworm. For the avoidance of doubt, I assume a SID counts as an ATS route in this context and so the paragraph applies?

Having said all that, it's still my rear end on the airplane and I will continue taking all instructions with a hefty serving of salt... :)

[MrHorgy]

It was always my belief that if you are issued an instruction by air traffic control, and have been positively identified, then they are primarily responsible for terrain separation. My previous post was perhaps poorly written - it's very bad SA if you blindy accept what ATC tell you without question. When operating near mountains or other obstacles I would always refer to MSA and reject any clearance I was not happy with, regardless of who is TECHNICALLY responsible.

Bookworm - thanks for that reference, I was beginning to doubt myself!

Horgy

[mgTF]

DOC 8168:

1.7 RADAR VECTORS

Pilots should not accept radar vectors during departure unless:

a. they are above the minimum altitude(s)/height(s) required to maintain obstacle clearance in the event of engine failure. This relates to engine failure between V1 and minimum sector altitude or the end of the contingency procedure as appropriate; or

b. the departure route is non-critical with respect to obstacle clearance.

[Checkboard]

I suppose you mean in ground visual contact rather than VFR. We routinely go below MSA/MVA when in ground visual contact....
Actually, no I don't. If you are routinely flying below MSA without the required VFR in flight visibility, but just "ground visual contact" (and not meeting any of the other provisos) you are operating outside the regulations, and rather unsafely.

[seat 0A]

So how do you land your aircraft in 1200 meters visibility?

[Checkboard]

You conduct an instrument approach. Read the thread!

[cosmo kramer]

Actually, no I don't. If you are routinely flying below MSA without the required VFR in flight visibility, but just "ground visual contact" (and not meeting any of the other provisos) you are operating outside the regulations, and rather unsafely.

I beg to differ:

Visual Approach:
EU OPS 1.430
An operator shall not use an RVR of less than 800 m for a visual approach.

EU OPS 1.435
“Visual approach”. An approach when either part or all of an instrument approach procedure is not completed and the approach is executed with visual reference to the terrain.

Those are the regulations, you decide what you think is safe.


I will give and example of when that in my opinion may be safely applied:

You are flying an arrival that lines you up for a straight in approach, you are at 7000 feet. Only there is a big 6000 feet hill 15 nm prior to the field to screw up your descent, the arrival dictates to maintain 7000 feet till overhead the VOR at the field, join a holding, an out bound and a base turn (or something long winded that you rather avoid).

Just before passing the hill, the controller ask you if you are visual with the terrain. The visibility is 2 km and you see the hill unmistakably and the lake that lies after the hill and between the hill and the field. You hoped for this to happen because the controller asked you this on many previous occasions when visiting that airport (only those times you were too fast to make a straight in). But you learned and, hence you are already at flaps 5 and flying 180 knots, ready to put your gear down and start descent and configuring as soon as you are safely clear of the hill.

You reply affirm and the controller clears you to "descent 3000 feet with visual reference to terrain cleared straight in ILS runway xx".

You did not have VMC. You completed part of the approach visually with reference to the terrain below the MSA, according to the rules specified above.

And by the way:
An IFR flight in the EU may descend below the en-route lowest safe altitude when:

2. Operating under the VFR
How can an IFR flight operate under VFR? :confused:
Did you mean VMC or did you actually copied that from some official text (in that case which??)

[Broomstick Flier]

Around here, whenever given a direct to on a SID, it normally comes as a conditional clearence, i.e. "After xxxxft, cleared direct to ...". When descending, sometimes we get cleared below a given MSA or MVA upon stating to ATC we are indeed VMC.

But, as much as I like directs, I always like to make sure we can comply with "cross at or above xxxxft" as depending on the direct, we can end with insuficient horizontal distance for compliance, but I guess that is why we are paid for :)

[Checkboard]

EU OPS 1.430
An operator shall not use an RVR of less than 800 m for a visual approach.

Paragraph (g) in Appendix 1 to para 1.430, actually, but I get your point. Written just below circling approaches (different para, I concede) and quite an anomaly - think about it - 800m! That's ILS territory!

The US equivalent is:


• “[A visual approach is] an approach conducted on an instrument flight rules (IFR) flight plan which authorizes the pilot to proceed visually and clear of clouds to the airport;
• “The pilot must, at all times, have either the airport or the preceding aircraft in sight;
• “[The visual] approach must be authorized and under the control of the appropriate air traffic control facility; [and],
• “Reported weather at the airport must be ceiling at or above 1,000 feet and visibility 3 miles or greater.

The Australian rules are something similar. (Yes, I know we are talking the EU here :rolleyes:)

... but the point is: 800m as a minima for a visual approach?? :confused: That simply has to be an error, or intended to refer to something entirely different.


... The visibility is 2 km and you see the hill unmistakably and the lake that lies after the hill ...
A shortcut if you are visual is fine - do 'em myself. 2000m vis is pretty foggy to be flying a jet around terrain, based on personal knowledge, though.

[Nick 1]

In 2004 in Italy a Citation was on IFR to Cagliari (Sardegna) ,on final stage of flight they request a Visual APP , the ATC man after having request the positive sight of the field and the surroundind obstacles (mountain area) cleared the visual. .
The aircraft crashed on a mountain killing all o/b , the two ATC's man where sentenced of 3 (later changed in 2 ) years of prison .
The judge state that the ATC forgot to advise the pilots of their potential dangerous trajectory .

[Richardatnos]

As buzzc152 said can only below MSA either:
Published poce/radar vector/visual

Could somebody give me the material source, what documentation cover these statements?

Tks a lot.

[TyroPicard]

... but the point is: 800m as a minima for a visual approach??
That's an RVR limit... could be CAVOK in flight with a thin fog/mist layer....