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convair880mfan
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For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Sun Aug 15, 2021 4:30 pm

I am especially interested in pilot's experiences of flying the older jetliners before the part of FAR 91:117 that imposed a 250 knot speed limit on aircraft operating below 10,000 feet MSL.

In an article by Paul W. Bennett [A Tribute to the 880] in Jon Proctor's excellent book "Convair 880"* are the words:

"What other aircraft in history entered the downwind leg at a major airport 'on the barber pole' (as fast as it could go), crossed the outer marker inbound at 250 knots airspeed, and made a perfectly normal landing -- with a horrified FAA inspector aboard?"*

*Proctor, John. Great Airliners Volume One: Convair 880 & 990. Miami, FL: World Transport Press, 1996 page 49.
 
Woodreau
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Sun Aug 15, 2021 7:20 pm

….. deleted …..
 
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zeke
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?ju

Sun Aug 15, 2021 10:07 pm

convair880mfan wrote:
I am especially interested in pilot's experiences of flying the older jetliners before the part of FAR 91:117 that imposed a 250 knot speed limit on aircraft operating below 10,000 feet MSL.

In an article by Paul W. Bennett [A Tribute to the 880] in Jon Proctor's excellent book "Convair 880"* are the words:

"What other aircraft in history entered the downwind leg at a major airport 'on the barber pole' (as fast as it could go), crossed the outer marker inbound at 250 knots airspeed, and made a perfectly normal landing -- with a horrified FAA inspector aboard?"*

*Proctor, John. Great Airliners Volume One: Convair 880 & 990. Miami, FL: World Transport Press, 1996 page 49.


Greater than 250/10k is very common even today. That rules is for US airspace, many US operators operate at higher speeds when outside the US.
 
Woodreau
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Sun Aug 15, 2021 10:26 pm

On the arrivals into Miami and Fort Lauderdale coming in from over the AR transitions we can be doing 320-330kts at 8000ft. We just slow to 250kts when we reach US airspace or when Miami approach tells us to slow earlier.

I have done 250kts to the marker. It’s just a matter of managing the energy of your aircraft on the approach.
 
r6russian
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Mon Aug 16, 2021 3:58 am

my last 4 flights in the US, only on arrival into MDW was there a resemblance of a 250 speed limit under 10,000. Other 3 going into either light trafficked airports or coming into busy airspace thru an empty corner, RSW, BWI and DTW, all on 737NGs, seemed like the only speed restriction was gear down/flaps 15 at glideslope capture. Do whatever you want up intil then. We crossed 10k anywhere between 280-320, on arrival into DTW we oversped every STAR speed limit and eventually around 7000ft engines went to idle, boards came out and stayed out til we turned final and started configuring for landing. Was kind of a fun arrival, all the speed, then silence, couple turns and final. Think it took longer to go from glideslope capture to touchdown than it did from overflying Fermi power plant, turning north, turning base almost over downtown Detroit and finally turning final. Ive flown the same exact approach in a PMDG NGx in fsx and following the STAR speed limits, youll fall asleep between Fermi and turning final, it was no more than 3-4 minutes IRL

This was watching the flights on my phone on fr24, and it made sense to slow down Midway 22L arrivals since theyre just a few feet south of the ORD west flow. But RSW and its airspace is dead, theres nothing going in in the SE corner of the BWI/DCA/IAD airspace, and DTW is way too light trafficked to need any kind of speed limits. Seems like the 250 under 10 speed limit is about as optional as the 65mph speed limit on the highways, or is only asked to be followed in busy airspace
 
GalaxyFlyer
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Mon Aug 16, 2021 3:14 pm

Not true, using FR24 as a source isn’t valid. 45 years and I’ve rarely seen, from the cockpit, long and willful violations of the 250 rule, military, airline, corporate. Yes, we might still be slowing from 280-ish below 10,000, but FOQA reports the violations and ATC will catch them. The FOQA Gatekeeper will bring up 250/10,000 violations to the crew.
 
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zeke
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Mon Aug 16, 2021 8:26 pm

r6russian wrote:
my last 4 flights in the US, only on arrival into MDW was there a resemblance of a 250 speed limit under 10,000. Other 3 going into either light trafficked airports or coming into busy airspace thru an empty corner, RSW, BWI and DTW, all on 737NGs, seemed like the only speed restriction was gear down/flaps 15 at glideslope capture. Do whatever you want up intil then. We crossed 10k anywhere between 280-320, on arrival into DTW we oversped every STAR speed limit and eventually around 7000ft engines went to idle, boards came out and stayed out til we turned final and started configuring for landing. Was kind of a fun arrival, all the speed, then silence, couple turns and final. Think it took longer to go from glideslope capture to touchdown than it did from overflying Fermi power plant, turning north, turning base almost over downtown Detroit and finally turning final. Ive flown the same exact approach in a PMDG NGx in fsx and following the STAR speed limits, youll fall asleep between Fermi and turning final, it was no more than 3-4 minutes IRL

This was watching the flights on my phone on fr24, and it made sense to slow down Midway 22L arrivals since theyre just a few feet south of the ORD west flow. But RSW and its airspace is dead, theres nothing going in in the SE corner of the BWI/DCA/IAD airspace, and DTW is way too light trafficked to need any kind of speed limits. Seems like the 250 under 10 speed limit is about as optional as the 65mph speed limit on the highways, or is only asked to be followed in busy airspace


Best of my knowledge controllers do not have the authority to lift the 250 below 10 in the US. I know some airlines have specific approvals in their OpsSpec (I.e approved by administrator), this is for heavy departures where the minimum clean speed is above 250 kts.

The expectation if cleared for example 300 kts on descent, and then descend down through 10,000 is to obey the 250 below 10.
 
GalaxyFlyer
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Mon Aug 16, 2021 9:11 pm

Also, the websites like FR24 use ground speed, not KIAS, for reporting. At 10,000’, 250 KIAS equals 288 KTAS in standard air plus or minus the wind.
 
bradyj23
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Mon Aug 16, 2021 9:21 pm

GalaxyFlyer wrote:
Also, the websites like FR24 use ground speed, not KIAS, for reporting. At 10,000’, 250 KIAS equals 288 KTAS in standard air plus or minus the wind.


Yeah they are seeing TAS or GS. Nobody is doing 300 IAS below 10k. I’ve done it during an emergency and it’s definitely different. Have to think about energy management a lot closer because it’s out of the norm.
 
N1120A
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 1:01 am

Almost no one in the US is intentionally violating 91.117(a). Certainly not any pilot at Southwest or any other major airline. Some corporate types might sometimes unintentionally violate 91.117(b) or (c), but I doubt any are similarly intentionally violating those sections.

zeke wrote:
r6russian wrote:
my last 4 flights in the US, only on arrival into MDW was there a resemblance of a 250 speed limit under 10,000. Other 3 going into either light trafficked airports or coming into busy airspace thru an empty corner, RSW, BWI and DTW, all on 737NGs, seemed like the only speed restriction was gear down/flaps 15 at glideslope capture. Do whatever you want up intil then. We crossed 10k anywhere between 280-320, on arrival into DTW we oversped every STAR speed limit and eventually around 7000ft engines went to idle, boards came out and stayed out til we turned final and started configuring for landing. Was kind of a fun arrival, all the speed, then silence, couple turns and final. Think it took longer to go from glideslope capture to touchdown than it did from overflying Fermi power plant, turning north, turning base almost over downtown Detroit and finally turning final. Ive flown the same exact approach in a PMDG NGx in fsx and following the STAR speed limits, youll fall asleep between Fermi and turning final, it was no more than 3-4 minutes IRL

This was watching the flights on my phone on fr24, and it made sense to slow down Midway 22L arrivals since theyre just a few feet south of the ORD west flow. But RSW and its airspace is dead, theres nothing going in in the SE corner of the BWI/DCA/IAD airspace, and DTW is way too light trafficked to need any kind of speed limits. Seems like the 250 under 10 speed limit is about as optional as the 65mph speed limit on the highways, or is only asked to be followed in busy airspace


Best of my knowledge controllers do not have the authority to lift the 250 below 10 in the US. I know some airlines have specific approvals in their OpsSpec (I.e approved by administrator), this is for heavy departures where the minimum clean speed is above 250 kts.

The expectation if cleared for example 300 kts on descent, and then descend down through 10,000 is to obey the 250 below 10.


It is not true that an approved Ops Spec is required to operate above 250 knots. 91.117(d) allows for the operation of any aircraft in excess of 250 KIAS under 10,000 feet if for that particular operation, the minimum safe airspeed is higher. In that situation, the aircraft may be operated at said minimum safe airspeed and may actually be done so without ATC approval, though an approval would be required to fly a published SID at higher than the published speed.
 
LH707330
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 3:23 am

zeke wrote:
r6russian wrote:
my last 4 flights in the US, only on arrival into MDW was there a resemblance of a 250 speed limit under 10,000. Other 3 going into either light trafficked airports or coming into busy airspace thru an empty corner, RSW, BWI and DTW, all on 737NGs, seemed like the only speed restriction was gear down/flaps 15 at glideslope capture. Do whatever you want up intil then. We crossed 10k anywhere between 280-320, on arrival into DTW we oversped every STAR speed limit and eventually around 7000ft engines went to idle, boards came out and stayed out til we turned final and started configuring for landing. Was kind of a fun arrival, all the speed, then silence, couple turns and final. Think it took longer to go from glideslope capture to touchdown than it did from overflying Fermi power plant, turning north, turning base almost over downtown Detroit and finally turning final. Ive flown the same exact approach in a PMDG NGx in fsx and following the STAR speed limits, youll fall asleep between Fermi and turning final, it was no more than 3-4 minutes IRL

This was watching the flights on my phone on fr24, and it made sense to slow down Midway 22L arrivals since theyre just a few feet south of the ORD west flow. But RSW and its airspace is dead, theres nothing going in in the SE corner of the BWI/DCA/IAD airspace, and DTW is way too light trafficked to need any kind of speed limits. Seems like the 250 under 10 speed limit is about as optional as the 65mph speed limit on the highways, or is only asked to be followed in busy airspace


Best of my knowledge controllers do not have the authority to lift the 250 below 10 in the US. I know some airlines have specific approvals in their OpsSpec (I.e approved by administrator), this is for heavy departures where the minimum clean speed is above 250 kts.

The expectation if cleared for example 300 kts on descent, and then descend down through 10,000 is to obey the 250 below 10.

This is correct, just because the controller says to do it, doesn't make it legal.... The only carve-out is 91.117 (d), which generally does not apply to arriving traffic that's lighter, unless it's some extenuating circumstance like engine-out heavy approach, but then you could also invoke 91.3 and say "I had to break the rule for safe ops."
 
saab2000
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 6:57 am

250/10,000 is adhered to at the 3 airlines I’ve worked for in the US. The data of non-compliance is electronically captured and habitual offenders will be called in to explain to the company what’s going on. Is not hard to comply with.

That said, where I work, in Chicago’s airspace, they expect a high speed above 10,000’ and 250 below until advised or unless required by a STAR or approach.

Any perceived variations from this are probably due to winds aloft, which can easily exceed 50 knots above 5000’. So any ground speed reading may exceed 300 knots even if the indicated speed up front is 250 or less.

250/10,000’ is not a huge burden except for certain types when heavy on departure.
 
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zeke
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 4:53 pm

N1120A wrote:
It is not true that an approved Ops Spec is required to operate above 250 knots. 91.117(d) allows for the operation of any aircraft in excess of 250 KIAS under 10,000 feet if for that particular operation, the minimum safe airspeed is higher. In that situation, the aircraft may be operated at said minimum safe airspeed and may actually be done so without ATC approval, though an approval would be required to fly a published SID at higher than the published speed.


I have a letter from Ms Rebecca B MacPherson, FAA Assistant Chief Council, Regulations Division, it is the FAA legal opinion that if an aircraft can be configured to meet a FAA speed limit, it shall be so.

The question asked of the FAA was if flying within 2500ft/4nm of Class C/D airspace with a 200 kt limit. The question related to a 737-900, it had a min clean of 215, when configured it can do 190. Can they use 91.117 (d) to fly the aircraft at min clean. The answer was no, the aircraft can be flown slower than the min clean speed by configuring with flaps/slats, it will need to be configured to meet the requirement.

There is an old wives tale about which says min clean is the same as min safe. If you have a document from the FAA Legal Council that says otherwise, I would be more than pleased to see it.
 
N1120A
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 5:30 pm

zeke wrote:
N1120A wrote:
It is not true that an approved Ops Spec is required to operate above 250 knots. 91.117(d) allows for the operation of any aircraft in excess of 250 KIAS under 10,000 feet if for that particular operation, the minimum safe airspeed is higher. In that situation, the aircraft may be operated at said minimum safe airspeed and may actually be done so without ATC approval, though an approval would be required to fly a published SID at higher than the published speed.


I have a letter from Ms Rebecca B MacPherson, FAA Assistant Chief Council, Regulations Division, it is the FAA legal opinion that if an aircraft can be configured to meet a FAA speed limit, it shall be so.

The question asked of the FAA was if flying within 2500ft/4nm of Class C/D airspace with a 200 kt limit. The question related to a 737-900, it had a min clean of 215, when configured it can do 190. Can they use 91.117 (d) to fly the aircraft at min clean. The answer was no, the aircraft can be flown slower than the min clean speed by configuring with flaps/slats, it will need to be configured to meet the requirement.

There is an old wives tale about which says min clean is the same as min safe. If you have a document from the FAA Legal Council that says otherwise, I would be more than pleased to see it.


You mean Shacknai 2007? That letter does not address 91.117(d), but instead complying with subpart (a) in international airspace 12 miles off shore. If you mean Seltzer 2010, that letter deals with configuring an aircraft to fly within the zone designated under 91.117(b) which deals with assigned speed restrictions on arrivals. On the other hand, Duncan 2015 specifically notes that subpart (d) applies to any specific operation where the aircraft must be operated in excess of the speeds in 91.117.

In short, you're wrong about the necessity for an Ops Spec to operate faster than the 91.117 speeds where that particularly operation dictates the need for a higher safe speed.
 
arcticcruiser
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 7:37 pm

The 250 below 10K is a US thing. Not so much elsewhere. Back in the day long before FDM (Flight Data Monitoring) we used to do 340 KIAS to 18DME final somewhere far away from the US. And everybody lived to tell about it. The 250/10.000 rule in the US was political, just like the 1500 hr rule.
 
GalaxyFlyer
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Tue Aug 17, 2021 8:12 pm

arcticcruiser wrote:
The 250 below 10K is a US thing. Not so much elsewhere. Back in the day long before FDM (Flight Data Monitoring) we used to do 340 KIAS to 18DME final somewhere far away from the US. And everybody lived to tell about it. The 250/10.000 rule in the US was political, just like the 1500 hr rule.


Actually, not, several mid-airs preceded the rule, blamed on high speed aircraft unable to “see and avoid”. Between 3/67 and 9/69; there were four midair collisions between airliners and civil GA planes, speed was partly causal.

https://en.wikipedia.org/wiki/TWA_Flight_553
 
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zeke
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Re: For older pilots: What was it like to fly commercial jetliners before FAR 91:117?

Wed Aug 18, 2021 2:30 am

N1120A wrote:
If you mean Seltzer 2010, that letter deals with configuring an aircraft to fly within the zone designated under 91.117(b) which deals with assigned speed restrictions on arrivals.


It actually deals with the entirety of 91.117, as they stated that effectively nothing changed since 1967, it used to be 250 below 10, within 30. The whole reason this was brought in was because of a mid air.

N1120A wrote:
On the other hand, Duncan 2015 specifically notes that subpart (d) applies to any specific operation where the aircraft must be operated in excess of the speeds in 91.117.


Duncan (Oct 2015) says is exactly as in 91.117, it does not say min safe is min clean. Flaps can be extended below 20,000.

N1120A wrote:
In short, you're wrong about the necessity for an Ops Spec to operate faster than the 91.117 speeds where that particularly operation dictates the need for a higher safe speed.


Demonstrate how 91.117(a) is complied with, i.e. "Unless otherwise authorized by the Administrator". There is no other FAA authorization around that says an aircraft can fly above 250 kts below 10 just to stay clean. The FAA has said the opposite, if an aircraft can be configured to meet a speed, then they shall then be in that configuration.

The OpsSpec approvals for above 250 kts below 10 I have seen are only valid for heavyweight departures, they are not applicable to arrivals at normal landing weights.

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