IFR Alternate Question

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FL_CH
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IFR Alternate Question

#1 Post by FL_CH » Tue Aug 29, 2017 6:12 am

I have an aircraft with a GNS430 (non-WAAS) and an additional VOR/ILS receiver, and NO DME/ADF.

I'm planning an IFR flight from Toronto to London, ON. I'm planning on the ILS15 at London. Even though this is not a satellite-based approach, I need to be able to identify the FAF - XU NDB. Since I have neither DME nor ADF, the only way for me to identify passing XU is using the GPS.

Assuming no VFR weather in the region, and all other conventional approaches having to rely on the GPS in a similar fashion, does this mean that my alternate has to be 100nm away?
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Re: IFR Alternate Question

#2 Post by Black_Tusk » Tue Aug 29, 2017 9:49 am

It's been a while but from my understanding on this 100nm requirement it only comes into play when your destination and alternate are both GPS based approaches.

Since your destinations main navaid is ground based, even though you need to use your GPS to identify the FAF the 100nm requirement shouldn't apply.
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Re: IFR Alternate Question

#3 Post by photofly » Tue Aug 29, 2017 10:23 am

I believe you are correct. Since you require GPS to complete the approach, your alternate needs to meet the no gps rule, as amended recently by the 100nm rule.

Also bear in mind the overarching IFR requirement safely to complete the flight, somewhere, with one piece of equipment u/s. What are you going to do if your GPS is that piece of equipment?
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Re: IFR Alternate Question

#4 Post by jg24 » Tue Aug 29, 2017 10:37 am

Black_Tusk wrote:It's been a while but from my understanding on this 100nm requirement it only comes into play when your destination and alternate are both GPS based approaches.

Since your destinations main navaid is ground based, even though you need to use your GPS to identify the FAF the 100nm requirement shouldn't apply.

Agree with Black_Tusk. They mean when RNAV approaches are planned for both primary destination and alternate.

From current CAPGEN:

"Where a satellite-based approach is planned at both the destination and alternate, the aerodromes are separated by a minimum of 100NM."
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Re: IFR Alternate Question

#5 Post by photofly » Tue Aug 29, 2017 10:42 am

The intent of the original rule was to force you to give yourself an option in the event of a system-wide GPS failure. The 100nm rule softens that to cover only local GPS failures (or jamming). I don't see that weaselling out because an ILS approach in which you need to use GPS to identify the FAF isn't strictly "satellite-based" is wise or meets the rule.

In any event, nobody is checking up on you and nobody is going to care what you do in a piston single for training purposes, and you can ask for vectors to final.
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Re: IFR Alternate Question

#6 Post by Black_Tusk » Tue Aug 29, 2017 10:45 am

jg24 wrote:
Black_Tusk wrote:It's been a while but from my understanding on this 100nm requirement it only comes into play when your destination and alternate are both GPS based approaches.

Since your destinations main navaid is ground based, even though you need to use your GPS to identify the FAF the 100nm requirement shouldn't apply.

Agree with Black_Tusk. They mean when RNAV approaches are planned for both primary destination and alternate.

From current CAPGEN:

"Where a satellite-based approach is planned at both the destination and alternate, the aerodromes are separated by a minimum of 100NM."
This is my interpretation as well. Let's be honest, how many people are keeping working ADF's in their aircraft anymore? I don't believe this new regulation was designed to for situation like this. If it was, it needs to be readdressed.
photofly wrote:
Also bear in mind the overarching IFR requirement safely to complete the flight, somewhere, with one piece of equipment u/s. What are you going to do if your GPS is that piece of equipment?
I see no issue with using the GPS to identify the FAF, and at the end of the day if you really needed to you can still safely fly an ILS without identifying the fix if it really required it in an emergency or failure of your GPS receiver.
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Re: IFR Alternate Question

#7 Post by photofly » Tue Aug 29, 2017 10:48 am

Black_Tusk wrote:
jg24 wrote:
Black_Tusk wrote:It's been a while but from my understanding on this 100nm requirement it only comes into play when your destination and alternate are both GPS based approaches.

Since your destinations main navaid is ground based, even though you need to use your GPS to identify the FAF the 100nm requirement shouldn't apply.

Agree with Black_Tusk. They mean when RNAV approaches are planned for both primary destination and alternate.

From current CAPGEN:

"Where a satellite-based approach is planned at both the destination and alternate, the aerodromes are separated by a minimum of 100NM."
This is my interpretation as well. Let's be honest, how many people are keeping working ADF's in their aircraft anymore? I see no issue with using the GPS to identify the FAF, and at the end of the day if you really needed to you can still safely fly an ILS without identifying the fix if it really required it in an emergency or failure of your GPS receiver.
What's the big deal about meeting the rule by planning an alternate 100nm away? It's not like you actually have to *go* there unless you have a total comm failure, merely maintain the ability to do so. Are you so tight on fuel?
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Re: IFR Alternate Question

#8 Post by Black_Tusk » Tue Aug 29, 2017 10:55 am

photofly wrote:
Black_Tusk wrote:
jg24 wrote:

Agree with Black_Tusk. They mean when RNAV approaches are planned for both primary destination and alternate.

From current CAPGEN:

"Where a satellite-based approach is planned at both the destination and alternate, the aerodromes are separated by a minimum of 100NM."
This is my interpretation as well. Let's be honest, how many people are keeping working ADF's in their aircraft anymore? I see no issue with using the GPS to identify the FAF, and at the end of the day if you really needed to you can still safely fly an ILS without identifying the fix if it really required it in an emergency or failure of your GPS receiver.
What's the big deal about meeting the rule by planning an alternate 100nm away? It's not like you actually have to *go* there unless you have a total comm failure, merely maintain the ability to do so. Are you so tight on fuel?
It didn't work for me a lot of the time flying up north. Often we did not have enough range, and I imagine someone flogging around IFR in a single engine may not have enough fuel to fly 100NM to an alternate. Now, if that alternate is required due to weather then I would agree... perhaps delay the flight, but if it's just to tick an arbitrary box when it's not even required...

I look at it this way. OP is flying to London to shoot the ILS. Your alternate is 25NM away and is an LNAV approach. Enroute your GPS goes haywire or there is an outage. You can still safely fly the ILS in London and land without identifying the FAF. The other scenario is you shoot the approach in London, go missed... maybe there is an issue and the runway is closed. You now fly to your alternate and shoot the LNAV with your working GPS. The chances of your GPS going haywaire/outage and an issue at your destination is very slim and in reality it's one of the risks we take on a daily basis even without this new requirement.

Not to mention there are a number of airports close to London with ILS approaches CYKF being one.
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Re: IFR Alternate Question

#9 Post by photofly » Tue Aug 29, 2017 1:03 pm

I look at it this way. OP is flying to London to shoot the ILS. Your alternate is 25NM away and is an LNAV approach. Enroute your GPS goes haywire or there is an outage. You can still safely fly the ILS in London and land without identifying the FAF.
And when the tower tells you the radar is down, and report the beacon outbound, what do you reply?

I paid for and installed an ADF to solve just this problem: before the 100nm rule was introduced, without it it was extremely difficult to find a legal alternate that didn't depend on GPS. Even near Toronto. So there are solutions; I'm sorry if you find them inconvenient or expensive, and if you're going to flout the rules that's fine, I don't imagine any harm will come to the OP, just be honest with yourself.
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Re: IFR Alternate Question

#10 Post by Black_Tusk » Tue Aug 29, 2017 1:18 pm

photofly wrote: Also bear in mind the overarching IFR requirement safely to complete the flight, somewhere, with one piece of equipment u/s. What are you going to do if your GPS is that piece of equipment?
You said "safely complete a flight if one item is u/s." I'm merely stating that *IF* your GPS happened to fail you can safely fly an ILS. You tell tower what you situation is, and they will clear any traffic around you and not have anyone follow close in behind.

Any regulation/CAR can be deviated from in the interest of immediate safety. In this case, you need to get on the ground because your GPS failed. If you were flying an approach at your alternate, with no more fuel to go around and you hit minimums... What would you do?

To answer the question for the OP since that's what we're talking about. Not what if's... No, based on the wording of the regulation you do not require an alternate 100NM away.
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Re: IFR Alternate Question

#11 Post by photofly » Tue Aug 29, 2017 1:54 pm

Any regulation/CAR can be deviated from in the interest of immediate safety. In this case, you need to get on the ground because your GPS failed. If you were flying an approach at your alternate, with no more fuel to go around and you hit minimums... What would you do?
It's true that in the moment, any regulation can be deviated from. But the regulator is entitled to ask, after the fact, if your emergency deviation would have been avoided if you'd complied with the regulations in the first place. If yes, they may feel free to screw you to the wall for your failure to comply.

In your example, if I'd legally filed an alternate and hit minimums with no fuel to go around, then whatever I did at the time would be excused by my having complied with all the relevant regulations.

We will politely disagree over the answer to the OP's question!

(And by the way, I imagine if you asked a variety of TC inspectors what the answer is they'd not all agree.)
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Re: IFR Alternate Question

#12 Post by Black_Tusk » Tue Aug 29, 2017 1:56 pm

photofly wrote:
Any regulation/CAR can be deviated from in the interest of immediate safety. In this case, you need to get on the ground because your GPS failed. If you were flying an approach at your alternate, with no more fuel to go around and you hit minimums... What would you do?
It's true that in the moment, any regulation can be deviated from. But the regulator is entitled to ask, after the fact, if your emergency deviation would have been avoided if you'd complied with the regulations in the first place. If yes, they may feel free to screw you to the wall for your failure to comply.

In your example, if I'd legally filed an alternate and hit minimums with no fuel to go around, then whatever I did at the time would be excused by my having complied with all the relevant regulations.

We will politely disagree over the answer to the OP's question!
I agree with you. I think the part where we disagree is weather you were or were not complying with the regulations in regards to the GNSS requirements.
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Re: IFR Alternate Question

#13 Post by photofly » Tue Aug 29, 2017 2:29 pm

Another reason why the ILS RWY15 at YXU requires GPS in the absence of an ADF: the missed approach is a climb to and hold at ZXU. So without an ADF or working GPS, even if you could fly the ILS without identifying the FAF you had better give some thought to where you're going if you need to overshoot.
605.18 No person shall conduct a take-off in a power-driven aircraft for the purpose of IFR flight unless it is equipped with
...
(ii) where the aircraft is operated in IMC, to complete an instrument approach and, if necessary, conduct a missed approach procedure.
So if you're dead set on legally flying IFR with one GPS and a VOR/ILS, you had better start considering aerodromes where the missed approach can be carried out entirely with a VOR. Are there any? And what with NavCanada withdrawing almost all VORs in southern Ontario, if you don't want an ADF or a DME, you had better get used to the 100nm+ alternate every time. And/or be ready to install a second GPS.
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Re: IFR Alternate Question

#14 Post by ahramin » Tue Aug 29, 2017 4:24 pm

Photofly I don't see how 605.18 applies to a failure case. You need to comply with all the equipment rules for IFR, but the only rules that apply to equipment failures are the ones that apply to equipment failure. You don't recursively go back after that failure and make sure you still meet all the rules (unless you aren't airborne yet of course). If you have a GPS failure enroute, you're going to change your plans accordingly. Lost your GPS and can't identify the FAF anymore? Ask ATC to do it for you. "Pan Pan Pan, Toronto Center FABC loss of RNAV capability" "Pan Pan FABC proceeding direct YYY VOR, request vectors for ILS XX, I will require you to tell me when I am over the FAF". Can't do the missed approach? Suggest or ask for a different one. "Toronto Center, Pan Pan FABC, in the event of a missed approach request runway heading to 3000'". In no case do you just keep trucking along hoping that nothing else goes wrong and then game over when ATC tells you to do a full procedure or you go missed. If the airport environment and infrastructure at destination is such that you're just not going to be able to get in without the GPS, then I would suggest having an alternate with a traditional approach you can use regardless of distance or rules.
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Re: IFR Alternate Question

#15 Post by photofly » Tue Aug 29, 2017 4:40 pm

I'm sorry - I omitted the relevant part of the regulation:
605.18 No person shall conduct a take-off in a power-driven aircraft for the purpose of IFR flight unless it is equipped with
...
(j) sufficient radio navigation equipment to permit the pilot, in the event of the failure at any stage of the flight of any item of that equipment, including any associated flight instrument display,

(i) to proceed to the destination aerodrome or proceed to another aerodrome that is suitable for landing, and

(ii) where the aircraft is operated in IMC, to complete an instrument approach and, if necessary, conduct a missed approach procedure.
Read it again - it's very clear.

Your suggestions are great in radar airspace, but most of Canada doesn't have radar and nobody can give you vectors anywhere.
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Re: IFR Alternate Question

#16 Post by AuxBatOn » Tue Aug 29, 2017 6:34 pm

There is technically no FAF on an ILS and there is no need to identify it. The GP checkpoint is a mean to ensure you are on an appropriate descent angle. If you can verify that by other means, like a HUD with a velocity vector or by ensuring your rate of decent matches what the glidepath angle should give you then this satisfy this requirement.

Before people jump on me, here's the Canadian definition of FAF:
final approach fix
(1) Canada: The fix of a non-precision instrument approach procedure (IAP) where the final approach segment commences.
From
https://www.tc.gc.ca/eng/civilaviation/ ... .html#s4_7

You can substitute DME by GNSS anytime, even on approach.

As far as "GPS" based approach, read AIC 08/16 for clarification. It defines GPS-based approach as approaches named "RNAV".
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Re: IFR Alternate Question

#17 Post by ahramin » Tue Aug 29, 2017 7:08 pm

Whoops, my bad photo. I'm on my frikken phone and couldn't look it up myself. If a GNSS failure meant there was no approach at destination or alternates for which you could follow the missed approach, I'd agree that it's not looking good with 605.18, even taking into account the definition in AIC 08/16.
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Re: IFR Alternate Question

#18 Post by photofly » Tue Aug 29, 2017 7:18 pm

@auxbaton - you're absolutely right it's not called a FAF for an ILS - good catch - but (other than a few RADAR or RNAV only approaches) there's always some navaid from which the ILS approach starts, often an NDB, or a VOR for a DME arc approach) and being equipped to fly the appproach means having the gear to find your way there, unaided.

And then there's the missed approach procedure that is typically based on that or another traditional navaid, to which you need to be able to navigate on your own.

The HUD with a velocity vector sounds cool though - I wonder if the OP has one :D
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Re: IFR Alternate Question

#19 Post by AuxBatOn » Tue Aug 29, 2017 7:20 pm

Is the missed approach part of terminal operations or approach operations? I believe this is ambiguous in the regulation. I consider it part of terminal operations, which allows me to conduct an ILS approach with an NDB for a missed approach termination point, even if I don't have an ADF in my aircraft (as long as I have a GPS).

Before you tell me that anything on the plate is part of the approach operations, know that the approach segment doesn't start until the FAF on a non-precision approach or glidepath intercept on a precision approach..

Even if an NDB is depicted on the plate, it doesn't have to be identified. It is on most precision approach plates for identifying the FAF on the backup non-precision approach (like a LOC in this case).
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Re: IFR Alternate Question

#20 Post by photofly » Tue Aug 29, 2017 7:24 pm

Does it matter what it's called? 605.18 is clear you need to be able to fly an approach and the missed approach, somewhere, with one system u/s.
Even if an NDB is depicted on the plate, it doesn't have to be identified
For a typical ILS, beginning 50 miles out, how are you going to navigate to intercept the localizer without identifying and flying to the navaid, and then completing the course reversal?
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Re: IFR Alternate Question

#21 Post by AuxBatOn » Tue Aug 29, 2017 7:28 pm

Approach operations is defined in the TERPS manual as from FAF to MAP. Before that point and after, you are conducting Terminal Operations, which allows you to use a GPS in lieu of an NDB, VOR or DME. All you have to identify with traditional Navaids are the FAF, if there is one, the MAP and any fixes in between. On an ILS, there is no FAF and MAP is based on an altitude. Anything before the FAF or after the MAP can be identified using GPS.
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Re: IFR Alternate Question

#22 Post by photofly » Tue Aug 29, 2017 7:30 pm

I think we're arguing different points, then. There's no disagreement from me that you can use GPS in lieu, as you describe. But the OP has only GPS and VOR/ILS, and needs to satisfy 605.18 to be able to fly an approach and the missed, in the situation that his GPS become u/s. I don't think there are many airports even in southern Ontario he can do that with only the remaining VOR/ILS.
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Re: IFR Alternate Question

#23 Post by AuxBatOn » Tue Aug 29, 2017 7:31 pm

I could also ask you, if you file to an airport serve by a VOR, with no GPS, and your VOR fails, how do you navigate to your destination?

FYI, 50 nm out is definately in enroute operations which also allows using GPS in lieu of VOR, DME and NDB..
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Re: IFR Alternate Question

#24 Post by photofly » Tue Aug 29, 2017 7:33 pm

AuxBatOn wrote:I could also ask you, if you file to an airport serve by a VOR, with no GPS, and your VOR fails, how do you navigate to your destination?
I don't need to go to my destination - 605.18 requires only that I can go somewhere. There are plenty of places I can still go with my remaining operational GPS.

But where can you go with only a VOR/ILS? Perhaps Cold Lake, AB for the one remaining PAR approach in Canada, but I don't think the OP has the range from London, ON.
FYI, 50 nm out is definately in enroute operations which also allows using GPS in lieu of VOR, DME and NDB..
Agreed. But not the point in question.

I hate to say it, but if you want to do legal GPS or ILS approaches IFR you really do also need one of an ADF, a DME (which will do for a very limited number of places) or a second GPS.
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Re: IFR Alternate Question

#25 Post by AuxBatOn » Tue Aug 29, 2017 7:41 pm

Plenty of airports with VORs. If you can make it to you alternate with your second means of navigation, you are good. Read here: https://www.tc.gc.ca/eng/civilaviation/ ... 2-3388.htm

Talks about interpretation of 605.18.
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