Thursday, January 21, 2010

Nothin' Special

I've never been a big fan of special VFR (or SVFR), a procedure that, simply put, allows pilots to operate without an instrument flight rules clearance in controlled airspace when the cloud ceiling and/or visibility are below basic visual flight rules minima. There are several reasons to be skeptical of special VFR and when the weather is poor, asking for this sort of clearance should not be the first solution you jump to, especially when other options might be available.

Attempting to fly VFR into deteriorating weather conditions and controlled flight into terrain continue to be two of the more popular ways to get into trouble in a small aircraft and these are exactly the kinds of risks that may be associated with SVFR. Besides these additional risks, pilots need to understand the regulations governing the use of special VFR, know when they can request and get a SVFR clearance, and then carefully and thoughtfully consider whether or not it might be appropriate to request such a clearance.

By the way, I'm not going to discuss SVFR requirements for helicopters since I'm not a qualified helicopter instructor. I will discuss some recent developments regarding SVFR at the airport I mostly call home, Oakland.

Location, Location, Location

Many pilots mistakenly think that if they are in controlled airspace, they can ask for SVFR. 14 CFR 91.157 describes the requirements and restrictions for SVFR. If you don't get anything else from reading this post, understand that a prerequisite for a SVFR clearance is that you must be below 10,000 feet MSL and within:
... airspace contained by the upward extension of the lateral boundaries of the controlled airspace designated to the surface for an airport.
If you're outside the upward extension of the lateral boundaries of an airport's surface airspace, you best have 3 miles of visibility and be 500 feet below, 1000 feet above, and 2000 feet laterally from the clouds. Another option during the day is to be in uncontrolled airspace with at least 1 mile visibility and clear of clouds, also known as some scary $#[+.

SVFR is not authorized in any of the Class Bravo surface airspace listed in 14 CFR 91 Appendix d, Section 3. In some cases, a Letter of Agreement may allow certain exceptions.

If you are transiting a Class B, C, D, or E airspace surface area to an airport that is reporting VFR conditions, you may still be granted a SVFR clearance if you tell the controller you cannot maintain regular VFR while transitioning. Think about this for a moment: If you are asking for a SVFR clearance to transition in Class B (assuming it's allowed), you must have less than 3 miles of visibility since you're normally only required to remain clear clouds in Class B under VFR. In classes C through E, you'd request a SVFR clearance to transition when you were unable to remain 1000 feet above, 500 feet below, and 2000 feet horizontally from the clouds and/or you expect to encounter less than 3 miles visibility.

Don't hang all your hopes on a SVFR clearance: Just because you think you're entitled to a SVFR clearance doesn't guarantee that a controller will give you such a clearance when you ask for it. Especially at Oakland. More on that later.

Pilot Requirements

Student pilots cannot request SVFR operations since 14 CFR 61.89(a)(6) clearly states they must have at least 3 miles visibility during the day. At night 5 miles visibility is required, assuming their instructor has given them an endorsement for night solo flights.

Any other pilot who yearns to operate SVFR can request it, but if the request occurs during the period between sunset and sunrise then the pilot must be instrument-rated and their aircraft must be equipped for IFR. In Alaska, these additional requirements apply when the sun is 6˚or more below the horizon.

SVFR Procedures
The minimum visibility for SVFR is 1 statute, reported at the departure or destination airport. If there is no weather reporting at the departure or destination airport, the pilot must report at least 1 statute mile of flight visibility to the controller. If the reported visibility by you or at the airport is less than a mile, the controller will deny the request from pilots of fixed-wing aircraft.

Adding to the arcane nature of SVFR, a controller cannot initiate a SVFR clearance: Pilots must specifically request it. A controller's official phraseology should sound something like:
Cessna 123, Moose Lips airport is reporting below basic VFR minimums, say intentions.
Sometimes a controller will be more informal, saying something like:
Mooney 345, Moose Lips Tower, the field is IFR, unable VFR departure, is there something special you wanted to request?
When a pilot wants a SVFR clearance, the request might sound something like:
Moose Lips Ground, Cessna 123, transient parking, VFR Redding, request special VFR departure, information xray.

Say Altitude

When a controller gives you a SVFR clearance, they don't specify an altitude to maintain since it's assumed that you, the pilot, must choose an altitude to remain clear of clouds. So the controller will say something like:
Bonanza 567, maintain special VFR conditions while in the surface portion of the Moose Lips airport class Delta airspace, runway 12, cleared for takeoff.
Or:
Cirrus 789, maintain special VFR conditions while inside the Moose Lips class Delta surface area, make a right base entry runway 30, report turning final.

Is it Safe?

Let's say you want to depart an airport where the visibility is being reported as 10 miles, but the ceiling is being reported as 900 feet. You see a hole in the clouds about 5 miles East of the airport. You reason that if you can get a SVFR clearance, you can depart, fly toward that hole in the clouds, and climb through the hole to VFR conditions. This is where you need to think carefully about your plan.

If you ask for and get a SVFR clearance, you'll end up being just under 900 feet above the ground. If your departure path is over a populated area, you won't be in compliance with 14 CFR 91.119, which says you must be 1000 feet above the highest obstacle within 2000 feet horizontally of your course. In addition, you must maintain an altitude that will permit you to make an emergency landing without undue hazard to persons or property on the ground should your engine fail.

I've seen many pilots do just these sorts of SVFR departures and arrivals. Controllers, for their part, seem to condone it. If nothing bad happens, well ... But if something does go wrong, the pilot will probably be called on the carpet for violating the minimum safe altitude rules as well as 14 CFR 91.13 - Careless and reckless operation - endangering the life and property of others. Assuming they survive, that is.

Separate and Unequal

Order 7110.65S - Air Traffic Control, the air traffic controller's "handbook," has some interesting things to say about priority of SVFR operations as well as separation of SVFR aircraft. The priority of SVFR is summed up simply:
SVFR flights may be approved only if arriving and departing IFR aircraft are not delayed.
Then later, there's this escape clause:
The priority afforded IFR aircraft over SVFR aircraft is not intended to be so rigidly applied that inefficient use of airspace results. The controller has the prerogative of permitting completion of a SVFR operation already in progress when an IFR aircraft becomes a factor if better overall efficiency will result.
Regarding separation, ATC is required to separate SVFR aircraft from each other and SVFR aircraft from IFR aircraft. The order goes on to reference separation standards from chapters 6 and 7 of that same document.

No SVFR at OAK

A few weeks ago, I was returning to Oakland at night with a student pilot in deteriorating weather. We discussed the visibility and concluded we had better than 3 miles of visibility and that we were approximately 500 feet below an overcast to broker cloud layer. After contacting NORCAL, my student was given the usual instructions for a straight-in VFR approach. A few minutes later, we were advised that Oakland was reporting below basic VFR minima and to "say intentions." Being only 7 miles from the airport, with good visibility, but in deteriorating weather conditions, I asked for special VFR. This seemed to be 1) a great teaching opportunity for my student and 2) the safest way for us to get on the ground quickly before the weather deteriorated further.

The controller approved the request, but less than a minute later instructed us to remain clear of the surface class C airspace. Oakland Tower was not allowing SVFR. Once again we were asked to say intentions, so I asked for an IFR clearance. We were given a Northeast heading, told to maintain VFR and to expect a delay for the clearance. This provided another excellent teaching situation: How things can go bad when you don't have a Plan B.

The weather began to deteriorate further, so I offered to maintain our own terrain and obstruction clearance if the controller could provide an IFR clearance immediately. The controller agreed, we turned East and then South as we climbed two thousand feet. We joined the localizer, descended, and lo and behold we were back in almost the same position we were just a few minutes earlier. "What the heck was that all about?" I wondered at the time.

A few weeks later, I was departing Oakland with another pilot to fly VFR to an airport in the Sierra Mountains for a mountain check out. It was one of those weird days where Oakland's South Field (runway 29) was reporting low visibility and ceilings while the North Field (runways 27 and 33) were scattered clouds and great visibility. The official story was that Oakland was IFR, so we called ground and asked for a SVFR departure. To our surprise, we were told that SVFR was no longer allowed at Oakland. What?

Choosing the path of least resistance, we called clearance delivery, explained we weren't pre-filed, and asked for an IFR clearance to VFR. A few minutes later, we had our IFR clearance and departed. As soon as we were handed off to approach (at about 1000'), we cancelled IFR. We actually could have cancelled IFR as soon as our wheels left the runway since we were already in VFR conditions.

I have yet to hear the official story, but gather that someone at the FAA decided to interpret the regulations to mean that no aircraft can be given SVFR in Oakland's Class C surface area when there is any IFR aircraft arriving or departing, regardless of how much separation is between those aircraft. And there's been no warning, no indication on the San Francisco VFR Terminal Area Chart, not even a NOTAM to inform the unsuspecting pilot who has studied all the above regulations and is religiously completing their preflight planning.

I guess this is just another reason to be extremely careful when your plans seem to depend on SVFR.


6 comments:

Jeff Tyler said...

"I've never been a big fan of special VFR..."

Don't come to Alaska, then, my friend.

I'll agree that there are other options in places like OAK. Quite the opposite is true in my neck of the woods. I'm an active CFI myself, and I work at Homer FSS. Here the center relinquishes the surface area to the FSS per letter of agreement and the FSS issues SVFR clearances to multiple aircraft at once. Yes, you read that right.

In this world of little to no radar coverage there just us no other way.

Anonymous said...

So how would you request a SVFR clearance at an airport without an operating control tower, but where Class E airspace extends to the surface?

FSS?

Anonymous said...

I tried once, unsuccessfully, to get a SVFR clearance for pattern work. The ceiling was 1300' and visibility was great. I wanted the SVFR so I could get to proper pattern altitude and just remain clear of clouds. When I asked tower for the clearance they responded, "Why? The field is VFR." Any thoughts on how to handle this?

John Ewing said...

Anon #1,

I can't speak to the procedures in the wild hinterlands of Alaska, but ...

My recommendation for requesting a SVFR clearance for an non-towered airport where class E extends to the surface in the lower 48 states would probably be to try the frequency published for approach and departure control for that airport found the Airport/Facility Directory. They may be unwilling to do so if there are IFR departures or arrivals that are planned at that airport.

Anon #2,

Reading between the lines, If the tower says you don't need a SVFR clearance for pattern work then perhaps they are saying they can't or don't want to give you SVFR but are willing to let you fly the pattern. You need to decide if you want to just go along with it and fly a slightly lower TPA to provide you with a comfortable cloud clearance or wait for a better day.

Ron said...

SVFR is very useful at my home airport (KSNA), because the wx is often such that there's just some remnants of the coastal stratus laying about, and by the time you get to the edge of the Class C surface area, you're in solid VFR conditions.

One strategy you might try if you ever run into that Oakland situation again is to request the IFR version of SVFR: the contact approach. I've done that before when the airport is reporting less than VFR weather, they don't want to give me SVFR, yet I know the area well. Down here, Socal is sometimes good about providing an instant pop-up IFR clearance to the airport and then issuing a contact approach.

--Ron

John Ewing said...

Ron,

Oakland is an interesting case since when the weather conditions get bad enough, runway 29 and runways 27 L & R are treated as simultaneous parallel approaches. That means the approach controller has to provide enough spacing between aircraft flying the ILS 29 and an aircraft flying any approach to 27 L or R. They usually do that by giving you delay vectors.

So asking for a contact approach could result in you being asked to loiter around until there was sufficient separation or, more likely, the controller would have denied the request.

I decided in the moment that there had been enough tooing-and-froing and I wanted a plan that was likely to work - namely and IFR clearance.