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Old 3rd Feb 2009, 13:15
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FAA Speed Limits

FAR 91.117 imposes a speed restriction of 25 below 10,000 for turbo jet aircraft.

It has been put to me that this is applicable only out to 5 miles offshore.

Try as I might I can find no reference to the area of application of the restriction.

It has always been my understanding that it applies to any designated US airspace regardless of proximity to the US coast.

If any one out there can point me in the right direction to find verifiable data on the application of this restriction, I would appreciate it

Maui
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Old 3rd Feb 2009, 14:35
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91.117 a)

"Unless otherwise authorized by the Administrator, no person may operate an aircraft below 10,000 feet MSL at an indicated airspeed of more than 250 knots (288 m.p.h)."

The US airspace extends to 12 NM from the coast, so my understanding is that this regulation applies as long as you are within that area.

Not sure if this answers your question, but I hope it helps.
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Old 3rd Feb 2009, 15:10
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In fact the FMC selects 240 below 10000 to be sure that 250 will be respected.
However there is a catch for departure, Clean if VRF +80 so when close to MAX TO Weight you will have at least 260, Normaly we call ATC and tell them about the speed for performance requirements, they always answer Approved
 
Old 3rd Feb 2009, 15:16
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The US airspace extends to 12 NM from the coast, so my understanding is that this regulation applies as long as you are within that area.
Discussions with several FAA inspectors have confirmed the above.
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Old 3rd Feb 2009, 15:29
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250 below 10,000

Despite that speed limit of 250, in the USA...
For a 747, we request "high speed" departure due to performance requirement.
Some guys simply say "Need 280 for performance".
ATCO confirms by clearing us for that speed.
Never had departure control denying us that speed.
xxx
You see, heavy (377 tonnes) our V2 flaps 20 is 180 KIAS.
To retract flaps, we need V2 180 + 80 = 260 KIAS.
To maneuver clean, we need V2 180 + 100 = 280 KIAS...
xxx

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Old 3rd Feb 2009, 15:32
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I find this very interesting.

However there is a catch for departure, Clean if VRF +80 so when close to MAX TO Weight you will have at least 260, Normaly we call ATC and tell them about the speed for performance requirements, they always answer Approved
My question now is: Who is the "Administrator"? Does ATC qualify as the "Administrator" in the case you just mentioned?

The way I have understood this after discussing with other pilots and also considering the way it is written in the regulations, ATC does not qualify as "the Administrator" they refer to in 91.117 a).

Therefore, at least the way I understand it, they can not give authorization for not complying with 91.117 a) in the case you mentioned.


Lets have a look at 91.117 (b):

"Unless otherwise authorized or required by ATC, no person may operate an aircraft at or below 2500 feet above the surface within 4 nautical miles of the primary airport of a Class C or Class D airspace area at an indicated airspeed of more than 200 knots (...)"

As you can see it is written differently from (a), as they here specifically state that ATC can authorize you to deviate from the regulation.

However, when it comes to the particular case you mentioned, it might still be legal under 91.117 (d) which says:

"If the minimum safe airspeed for any particular operation is greater than the maximum speed prescribed in this section, the aircraft may be operated at that minimum speed."


PS: in part 1 "Administrator" is defined as: "the Federal Aviation Administration or any person to whom he has delegated his authority in the matter concerned".


Someone please further enlighten me.
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Old 3rd Feb 2009, 15:48
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Speed limits FAA

The "Administrator" delegates his authority to FAA Inspectors, or ATC controllers, etc.
ATC has the authority to waive the 200/250 limits when aircraft requires higher speeds.
It implies that the aircraft requires higher speed as minimum speed.
We advise "departure control" on initial call of our speed requirements.
Funny is that when ATC knows we are 747, they clear us "speed at your discretion".
xxx

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Old 3rd Feb 2009, 15:52
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aha, I see.

But what if that speed requirement was not a necessity for your specific airplane, would ATC still be able to approve a speed above 250 below 10 000 ? (they probably wouldn't, but would they have the authority to do so?)

Thank you!
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Old 3rd Feb 2009, 15:54
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FAR 91.117 (d) says

d) If the minimum safe airspeed for any particular operation is greater than the maximum speed prescribed in this section, the aircraft may be operated at that minimum speed.
Please do not stop reading until the whole section ends. ATC does not grant the permission to operate above 200/250 kts, the FAR does.

GF
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Old 3rd Feb 2009, 15:59
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I am aware of this GF, but my thought was that if your speed requirement is in accordance with 91.117 (d) and you request permission from ATC (which in theory isn't even required) they will of course say "approved" as a confirmation ? What else would they say? They wouldn't go on babbling about how it isn't necessary for you to ask since it is in the regs etc...

Naturally the correct thing would just be to notify them as BelArgUSA said.
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Old 3rd Feb 2009, 17:35
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High speed below 10,000

Hola SeanGG -
xxx
To your question - If your airplane does not require to exceed 250 for above reasons... and you request high speed, a FAA ATC controller does NOT have the authority to waive the speed limits. They know which airplanes require higher speeds at heavy gross weight, knowledge of basic performance capability of airplanes is one thing controllers know well, and I assume is part of their training.
xxx
In other countries, regardless of their AIP speed limits, I used to request "high speed" below FL 100 for arrival, such as CDG, MAD, or FCO, they rarely said "negative, reduce to 250 speed"... well to the contrary, at these airports, they ask you to fly fast on arrival.
xxx
Being Belgian-born, I speak French. One evening, I was having a beer in a hotel bar, near CDG. A few gentlemen were there, talking airplanes. I realized that they were ATC controllers. I went to shake hands, and introduced myself as a pilot, etc...
xxx
We conversed for a while. Then they mentioned "you know, is very strange with USA carriers, we often ask them to fly faster than 250 to go with the flow of the traffic of other airplanes but they say NO...! - why is that you think"...? - I had to explain to them that all US air carriers have the 250 below 10,000 speed limit as company policy in their GOM.
xxx
Honestly, I can understand that while US pilots want to stick to their procedures, they do not realize that they upset approach control traffic management. Further, as these guys told me, "if an American does not want to fly fast, we will put him last for landing sequence"...
xxx
So, my USA friends, if you want to save fuel, proceed as cleared by ATC, if they tell you "speed at your discretion" - in aviation English they mean "FLY FAST". When ATC gave me "speed at my discretion", I did generally 280 KIAS until 10 NM from touch down, bearing in mind that my VFE for the first flaps extension is 275. I do not want to be nš 7 for landing sequence.
xxx

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Last edited by BelArgUSA; 3rd Feb 2009 at 18:52. Reason: spelling (I am a spelling bee at times)
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Old 3rd Feb 2009, 18:05
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Be careful!

Just a word of advice to readers of the forum, be careful of the opinions expressed here. US ATC is not authorised to grant deviations from FARs. The speed requirement in US airspace is statutory. There are several airports in the US where higher departure speeds have been specifically authorised by the Administrator for "evaluation purposes."

FAR 91.117 (d) says


Quote:
d) If the minimum safe airspeed for any particular operation is greater than the maximum speed prescribed in this section, the aircraft may be operated at that minimum speed.

Please do not stop reading until the whole section ends. ATC does not grant the permission to operate above 200/250 kts, the FAR does.

GF

I would point out that a minimum clean speed above 250 kts is not a "safety" issue but one of efficiency.

Then again, that's just my opinion. See sentence one.

Cheers
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Old 3rd Feb 2009, 18:11
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Thanks guys, and thank you for the great reply BelArgUSA. That clarifies a lot, and it also makes a lot of sense the way they have written it in the regs (which I pointed out in my second post in this thread).

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Old 3rd Feb 2009, 18:17
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As I see it, ATC was given the authority to waive the 200 KIAS rule regarding Class C and Class D airspace, but was NOT given that authority for the 250 below 10,000. The "Administrator" for these purposes is someone higher than the controller. For example, low altitude military airspace does not have a 250 knot restriction, but may not be "restricted' airspace prohibiting civil traffic i.e. MOAs.

So, fly 250 below 10,000, unless your aircraft specifically needs to maintain a higher minimum speed. (pretty much the Whale nowadays, but I don't know about the the French Whale), then do so silently. ATC knows what's up if your strip (actually not a strip anymore) shows B747 and you're doing 280 ground speed.

GF

Oh, and if you are operating underneath a Class B (a TCA to BelArgUSA and me) 200 KIAS, please. ATL Approach, among others, will scold ONCE, then send the Boys in Blue after you.

BelArgUSA: Last week we were operating out of ATL, actually PDK, and the chief pilot of the company we were demo'ing the plane to kept calling it Class B and I kept repeating it back as a "TCA". Boy, did I feel old!!
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Old 3rd Feb 2009, 18:24
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LanFranc

That is a good point, there is no restriction from operating the B744 at 250 knots, one would just have to have some Flaps 1 or Flaps 5, I suppose. Inefficient, but technically, it is not required to be clean below 10K.
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Old 3rd Feb 2009, 18:32
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LanFranc -
xxx
Flying a 747 at weight 377 tonnes at 249 KIAS clean will get it to STALL
Have you flown a 747...? I flew them from 1989 until 2008. In USA as well.
I would advise YOU to be careful with "opinions" expressed here.
I do not express opinions. I describe what are 747 procedures.
US ATC cannot waive 200/250 speed limits, but read post nš 11 above for exceptions.
xxx

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Old 3rd Feb 2009, 21:00
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The "Administrator" for these purposes is someone higher than the controller.
Negative, for the purposes of the minimum safe speed required.

Confirmed by the FAA on numerous occasions.
Speed required for normal ops...as required.

'Tis a fact.
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Old 3rd Feb 2009, 21:21
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BelArgUSA - LanFranc is saying that it is possible to safely operate a 747 at 250kts on climb, and he is of course correct. As you know, to do this, you'd need to have probably Flap 1, which isn't necessarily efficient but certainly possible.

I do agree with you, however, that +100 is what I call an operational requirement, and so tell ATC and fly that speed. London has been quite clever and granted a dispensation to 747's to fly at 280kts if required... less radio calls, less fuss. Some other airports state a speed restriction of 250kts or Min Clean Speed. Again, removes the fuss.

As to the US pilot thing... we were rather confused out of a major European airport when after takeoff, ATC would say "High Speed Approved", when we didn't think there was a speed limit! Further investigations got the answer that the phrase was used to remind US based airlines that they could go fast. Smart controllers!
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Old 3rd Feb 2009, 22:06
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Hola Comfy -
xxx
Agree with you about keeping Flaps 1 and 250 for a departure...
Honest, I cannot recall any instance of ever been required to do so.
Yet I have been just about everywhere with 747s on the planet.
No US controller, nor London ever gave us problems for approving 280.
Not even Frankfurt controllers who sit on regulation manuals...
xxx
Befehl ist befehl, they say - 280 bitte...? Jawohl, naturlich.
Even Lufty flies heavy 747s at 280 on departure.
I asked a buddy of mine, F/E 747 for many years on Lufthansa Cargo...
Ja ja ja...! Mein Kapitein always used 280 - is what he told me...!
They even do 280 on their autobahns with their BMW cars.
xxx

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Old 3rd Feb 2009, 22:23
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Thanks all for the discusion.

Sean GG post #2 came closest to what I am after, however I still haven't got what I need.

Can someone point me to the verification of the extent of US airspace and the applicability of the restriction.
Sean says it is 12 miles, someone else has told me it is 5 miles.
I have no doubt that if I was cracking along at VMO, 13 miles at 9000 feet off Long Beach I would be in a truckload of strife.

To my mind anywhere you are under the control or supervision of US controllers you should be bound by the restriction.

Maui
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