IFR departures - SID, Omnidirectional, ATC clearance
 

Hi all,

I'm trying to better understand the compliance of IFR departures for CAT operations, where no published SID or omnidirectional departure exists in the aerodrome's AIP (i.e. there is no notified IFR departure).

CAT.OP.MPA.125(a) states - The operator shall ensure that instrument departure and approach procedures established by the State of the aerodrome are used.
CAT.OP.MPA.125(c) goes on to state - Notwithstanding (a), the operator may use procedures other than those referred to in (a) provided they have been approved by the State in which the aerodrome is located and are specified in the operations manual.

CAA CAP 778 Chapter 1 Section 3.2 (IFR Departure Procedures) states - At many aerodromes, a prescribed departure route is not required for ATC purposes...
CAA CAP 778 Chapter 1 Section 3.3 (IFR Departure Procedures) states - PANS-OPS criteria for omnidirectional departures are not currently applied in the UK. Consequently, omnidirectional departure procedures are not published in the UK Aeronautical Information Publication (AIP).
CAA CAP 778 Chapter 2 Section 3.1 then goes on to contradict this and state - Omnidirectional departures shall be promulgated in the UK IAIP Part 3 AERODROMES (AD) AD 2.22 in accordance with the following example:

https://cimg3.ibsrv.net/gimg/pprune....4f27158036.png
I may be overcomplicating this, but my question is, if there is no SID, and no omnidirectional departure (or minimum climb gradient) notified in the AIP for a given aerodrome regularly used for CAT IFR departures, such as Cambridge or Gloucester, is it sufficient to simply have received an ATC clearance? And what of a departure from an unlicenced aerodrome such as Dunsfold? In such cases, where compliance with CAT.OP.MPA.125(a) cannot be met (no instrument departures are established by the state of the aerodrome), are operators required to have a section in their OM for IFR departures from aerodromes without a notified instument departure?

In nearly all cases the helicopters we are flying would easily outclimb any published climb criteria at most UK locations, but where no SID/omnidirectional procedure is published I'm not sure what must be in place for an IFR departure to be compliant.

Any ideas?

Hi Aucky
I'm afraid I can't answer your question because I've been asking myself the same one for ages. I don't really understand why the UK don't have published departures at places like Gloucester and Cambridge as PANS-OPS volume 2 states:

Chapter 2
GENERAL CONCEPTS FOR DEPARTURE PROCEDURES
2.1 ESTABLISHMENT OF A DEPARTURE PROCEDURE
2.1.1 For each runway at aerodromes where instrument departures are expected to be used, a departure procedure
shall be established and promulgated.

....and they seem to have plenty of IFR departures.

Cheers
TeeS

Because in the UK there was no real push to implement them, and, furthermore, they have to be designed by an Approved IFP Design Agency and put through the CAA regulatory process, and the last time I heard it took ages because CAA DAP were snowed under and short staffed. Also, unless someone actually flags up the requirement to airfield operators, they turn a blind eye to avoid the cost of having them designed.

Thanks TeeS, I suspect one of the reasons they don’t have a SID is that a SID has to remain wholly within controlled airspace. Easier done in the continent where they use Class D/E airspace extensively, but I would have thought that in place of a SID the simple solution for most IFR aerodromes in the UK would be to publish the omnidirectional departure information for each of their instrument runways?

Surely the airfield license and inspection process should flag it? Maybe it’s because they are in benign obstacle/terrain environments?

I thought that might be the reason for the statement in CAP 778 that ‘At many aerodromes, a prescribed departure route is not required for ATC purposes...’ but then I haven’t found any way to qualify that statement with any critera.

I think this is a case of the CAA just carrying on doing things the way they did before EASA, when there was no requirement for a procedure to be published. It was all down to the operator to make sure their OM procedures were safe.

Bottom line is that you are responsible for obstacle clearance. The easiest way to do this would be to follow any published missed approach procedure until MSA is reached for the sector you are departing in.

Hi Apate
Although that seems like a sensible choice and I might well be guilty of having taken that approach (departure!) in the past when no published departure was available, it doesn't really give you protection. The missed approach procedure generally starts before or at the runway threshold at a significant altitude, whilst a departure (unless designed for helicopters only ) starts at a point 5m above the departure end of runway (which includes any clearway), so the protections for both procedures are very different.

Cheers
TeeS

Hi Aucky
I have never heard of that and with a quick search of PANS, I can't find any reference to a requirement for controlled airspace (that obviously doesn't mean anything except that I probably don't know what I'm talking about), please can you point me to where that is laid down?
Thanks
TeeS

I’m certainly no authority on it, and it may be outdated, but CAP 778 (which still shows as current on the CAA website) Chapter 1 Section 1.3 states “Within the UK, the term Standard Instrument Departure (SID) is the sole term to be used in the context of routes providing designated IFR departure procedures that remain wholly within CAS and permit direct connectivity with the en-route ATS system.”

Chapter 3 sections 1.1 & 1.2 go on to say “ICAO defines a SID as a designated IFR departure route linking an aerodrome, or a specified runway at an aerodrome, with a specified significant point, normally on a designated ATS route, at which the en-route phase of a flight commences. The UK additionally requires that all SIDs must be wholly contained within CAS.”

From memory: The initial climb segment is to 400’ above the ehhr, DER? Departure End of Runway, and after this a turn can be made?

If no SID or Omnidirectional, it is 400’ above DER.

The two places named are in Class G airspace and as far as I'm aware, you can't have a published SID in Class G.

Fly the instrument approach for your departure runway backwards. Check that OEI performance will allow you to do it even if, heavens forfend, one of the hamsters dies.

Just a suggestion.

Thanks for the pointer Aucky, I’ve had a look through CAP 778 and I see what you mean. I’m not surprised by the fact that it was last updated in 2012, talks about P-RNAV etc. but it does get bloody annoying when you put hours of work in trying to keep up to date with PANS-OPS and then have to wind your clock back ten years to find out how the CAA want you to do it!! :-)

Cheers
TeeS

or do not want you to do it… Don’t get me started on PinS (or lack thereof) :ugh:.

I think at least in FAA land, it's known as an "diverse departure assessment" - see the link below, usually in EASA (UK CAA?) land the rules follow in fairly similar format even if the naming etc. is different;

https://www.faa.gov/regulations_poli..._Chapter_1.pdf

Interesting, so “When an instrument approach is initially developed for an airport, the need for an ODP (Obstacle Departure Procedure) is assessed. If an aircraft may turn in any direction from a runway within the limits of the assessment area and remain clear of obstacles that runway passes what is called a diverse departure assessment, and no ODP is published. A diverse departure assessment ensures that a prescribed, expanding amount of required obstacle clearance (ROC) is achieved during the climb-out until the aircraft can obtain a minimum 1,000 feet ROC in non-mountainous areas or a minimum 2,000 feet ROC in mountainous areas. Unless specified otherwise, required obstacle clearance for all departures, including diverse, is
based on the pilot crossing the departure end of the runway (DER) at least 35 feet above the DER elevation, climbing to 400 feet above the DER elevation before making the initial turn, and maintaining a minimum climb gradient of 200 ft/ NM, unless required to level off by a crossing restriction, until the minimum IFR altitude is reached. Following ODP assessment, a SID may still be established for the purposes of ATC flow management, system enhancement, or noise abatement.”

So I guess my next question is as a pilot, how does one know if the runway passes a diverse departure assessment, unless they publish Omnidirectional departure criteria (call it what you will) in their AIP plate as this seems to be what is described procedurally in the FAA document (although the UK adopt 500ft climb on runway track superseding ICAOs 394ft, or the FAAs 400ft).

Sadly Aucky, I don't have the answer .... in absence of a SID or ODP, I would suggest that for an commercial operator - there would be a performance analysis done (in office) and brief to crew published - to require some form of departure procedure for said airfield, and ensuring obstacle clearance, gradients etc. are ensured. I stand to be corrected naturally.

I agree that this pragmatic approach would seem acceptable, but it would require some statement based on Obstacle data or OS analysis, and I can’t see the CAA accepting this done as an ‘in-house’ analysis, when essentially it is the same process which would be required to develop a SID or ODP, but that would require independent consultants approved by the CAA, and take 2 years with an ACP application.

It will if you have the performance to follow the profile.

The FAA TERPS answered is all airports with an instrument approach must be assessed under the diverse departure obstacle standard—ICA to 400’ above the DER, then 200’/nm to the airway structure. If neither a SID or and ODP is published, then the diverse procedure applies. Close-in obstacles, under 200’ IIRC, do not generate a climb gradient.

I’m aware it happens, and understand how it can be done safely, my question was more around the operational compliance of doing so without some form of notified departure, whether SID or ODP, when conducting CAT operations iaw CAT.OP.MPA.125

In which case, has any professional pilot here seen such a thing in their ops manual if it’s what everyone is doing? It would seem odd that after 26 posts no-one has given an example of this…

assuming the pilot on the day is concerned enough to to find a solution where there is no SID and no specific clearance (and no clues in the OM's), the best thing i read so far on this thread (from Apate) is:-

"Bottom line is that you are responsible for obstacle clearance. The easiest way to do this would be to follow any published missed approach procedure until MSA is reached for the sector you are departing in."

this seems eminently practical to me...especially if its a airfield where you have no experience.

The thing that strikes me most about this conversation is this: ATC procedures/rules are now at such a level of complexity that a competent person will struggle to understand them.

I count myself lucky - in 7500hrs rotary in the RAF, I was mostly operational or SAR. I never flew a SID…not once. I called ATC, told them what I needed to do, and the answer was invariably ‘yes’. When procedures become the subject of threads like this then I suggest they are unfit for purpose as their whole point is to ease the work burden.

This is why AI aircraft are absolutely in inevitable. A rule based system is, by definition, ripe for takeover by computers, and the days of the pilot are numbered.

I say that as a pilot.

From an immediate safety of life perspective yes, but working back from the smoking hole in the ground you should be the last line of defence in preventing the accident. The unfortunate R116 accident and report quite clearly highlight that whilst the pilots are ultimately responsible for obstacle clearance, the regulation, management systems, and operational procedures all have a significant role to play in ensuring earlier layers of defence. Very few things should be left to the pilot to come up with their own procedures on the day, or their own way of establishing compliance with the regulation. I’m asking how these should be done, as opposed to how they can be done.

It’s quite shocking to me that after everyone’s input thus far, and their combined experience, nobody seems to know the answer. If every IFR aerodrome had a straightforward omnidirectional departure published in the AIP we wouldn’t be having this conversation, but they don’t, and the fact no-one seems to know the gospel answer points to a significant failure of the regulation, it’s oversight, or implementation/knowledge of national procedure. I have looked through the AIP and as yet not found anything relevant. A relatively straightforward question shouldn’t have an ambiguous answer…

Thanks AM, do you recall what was considered acceptable to the authority as a method of analysing the local area for obstacles such that the required performance can be established? OS mapping/aeronautical charts/3rd party surveyor?

We seem to have lost AM!

You might be better worrying about how you can be in the procedural hold at Gloucester, and then get cleared for the procedure to the runway requiring a descent through class G airspace above the ATZ where anyone can just bimble through without even talking to ATC.

Much like the ILS at Gloucester on the Westerly runway where, although it is marked as an instrument approach zone on charts, someone could legally fly straight through it (and have) again without talking to ATC - very interesting on a marginal VFR day.

i don’t see your point. Regardless of VFR or IFR you are responsible for maintaining a collision-avoidance lookout. If the conditions are VMC then (allegedly) one is capable of “see and avoid”. I don’t understand why you see flying an IFR procedure in VFR is in some way worse than flying VFR in the same weather conditions? Maybe as a (ex) SAR pilot you habitually avoided flying VFR on a marginal VMC day? Seems unlikely!

I rather get the impression that you think that just because you are IFR you don’t need to look out. Hopefully I’m wrong.

Oh and having re-read your post, I very much doubt you would ever be “cleared” for a procedure in Class G. Clearances can only be given for flight in controlled airspace. You might have your proposed approach “approved” but that doesn’t include the magic word “cleared”.

I think it's reasonably clear what Crab is saying. TYPICALLY when flying an insrument approach you are in controlled airspace and can rely on a certain amount of comfort in knowing that other airspace users are on the same frequency and being separated from you. To be in the middle of an approach and have random aircraft, you are unaware of (because they are not required to broadcast their presence), appearing from nowhere is probably quite disconcerting. I see Gloucester is by no means alone - Cranfield, Oxford and Humberside to name a few. https://maps.openaip.net/?destinatio...et/node/162212

Thanks 212man - at least you were paying attention:):ok:

yes you are.

Typically when you are flying an offshore instrument approach, you are in Class G - although admittedly "unknown" traffic density tends to be miniscule. Onshore I agree the norm is inside controlled airspace, but it certainly doesn't have to be. Loads of instrument approaches in Scotland are outside CAS. Inverness, Dundee, Wick, Kirkwall and many others. So I don't really see it as a big deal, apart from the greater traffic densities in England.

My point was really to remind that just because one is IFR does not absolve one from keeping an adequate lookout. GM1 to SERA.3201 has this to say:
VIGILANCE ON BOARD AN AIRCRAFT
Regardless of the type of flight or the class of airspace in which the aircraft is operating, it is important that vigilance for the purpose of detecting potential collisions be exercised on board an aircraft. This vigilance is important at all times including while operating on the movement area of an aerodrome.

And there is of course radar at Gloucester, they will give you traffic information if necessary.

Of course, everyone would like to have their own private bit of airspace where no-one else is allowed to go, but with airspace being a scarce commodity, we have to share nicely.

The radar at Gloucester hasn’t worked for years.

Depending on the time of day/year, you might get a service from Brize. But not whilst on the approach itself.

Not sure how we drifted into Offshore approaches in Scotland when the OP clearly mentioned Cambridge and Gloucester HC - perhaps you have never flown at either airfield but felt you had to make a comment?

I have been 'cleared for the procedure' from the hold IMC at Gloucester and descended intermittent IMC/VMC through class G before getting to the IAF and flying the approach without (as Bravo 73 rightly says) radar service. It happens all the time because of the amount of IR training and testing that gets done there.

Alderney IFR
 

In a similar vein, how does one depart Alderney IFR….?There are commercial operators on CAT flights that land using an RNP LPV200 but how do they get airborne and join the airways structure?Odd,as it sits in a Class D CTR with radar control and atc.
i cannae see any SID or omni deps

Yes. I felt I had to make a comment because of the comment "Typically when flying an instrument approach you are in controlled airspace". Bearing in mind this is a helicopter forum, I suggest that when flying an instrument approach in a helcopter its quite likely not to be in controlled airspace - simply because of the amount of offshore IFR flying that goes on compared to that on land into airfields with CAS, and that therefore the quoted comment is misleading. The point being that a certain amount of woe and hysteria was being conjoured up for what is in fact a perfectly routine occurrence.

With regard to Gloucester (which I have flown into, though it was many years ago) if they can't even keep their radar serviceable how could they possibly manage controlled airspace - unless that airspace should exist just to allow a tiny minority to carry out intrument approaches without feeling the need to look out, at the expense of excluding or making life very difficult for many other classes of airspace users.

If ever there was an omen signaling the end of manned helicopter flight, it would definitely be whatever the hell you just said.

It may be a perfectly routine occurrence offshore but only those airfields not in CAS onshore will have an unprotected instrument approach. It is an issue, especially when the airfield doesn't have radar.

The MAP for Gloucester takes you to the edge of the ATZ but then climbs you and turns you back to the NDB hold at 2800' - ie outside the ATZ in class G (normal hold is at 4000') . You are possibly IMC with no radar service where anyone can just fly through.