Say Again? #39: ATC 205 - IFR Flight Plan II
Want another good reason to be careful how you file your flight plan? How about avoiding a midair collision? AVweb's Don Brown is back with another in his 'courses' on better ATC and pilot communication. This month he's trying to figure out why some pilot wants to go to Kentucky via Canada.
Welcome back class. I don't think there is any other subject that I've tried to cover that has created as much confusion as this subject. I know there isn't another that has been misconstrued as much. It's been a real eye-opener to see some of the interpretations springing from my articles. Let's take another whack at it shall we?
I don't know if you've been following along or not but I've been piecing together this puzzle ever since I started writing for AVweb. I'm still learning about it. The more I learn, the more complex -- yet clearer -- the subject becomes. Let's see if I can drag you through the learning curve with me.
It started with "The GPS Mess." That was the first time I delved into Section 5-1-7 of the AIM -- Flight Plan- IFR Flights. I found out it was long and complicated. Yet, the more problems I saw at work (with flight plans,) the more I kept going back to that section. The more problems we had (and there is an ever increasing number) the more I came to understand that section of the AIM.
Maybe that is the key that will help you understand this subject. Let's look at one of the problems. First, I want you to look at this from the perspective of a controller who is working the sector. We'll operate under the assumption that the controller actually took the time to look at the following flight plan (graphic below) before the pilot called for clearance. That is a big assumption. Trust me -- it doesn't happen nearly as often as it should.
The strip shows the plane will be departing from SVH (Statesville, N.C.) and then continuing on the following route:
The controller will obviously know where SVH is because that is the area he is working. SVH is about 30 nm north of Charlotte, N.C. (CLT), just outside of CLT Approach's airspace. BZM is Barretts Mountain, the VOR that serves the SVH airport. So far, so good.
Now then, where is 4743/08757? They are latitude and longitude coordinates, but I don't know where it is and you don't know. It doesn't really matter. Center controllers just tend to speed right past a Lat/Long when they're reading a route of flight. They're meaningless to us and we don't have the time, tools or inclination to look them up. Which leaves us with I05. Where's that? No idea. Assuming (once again) that this controller is on the ball it is now time to pull down the "red book" -- that is, the FAA Location Identifier book.
This is a very important part, so I want to make sure you visualize it. The controller is sitting at the sector (usually by himself) and he has to get up from the sector, reach up to the shelf above the D-side (data controller) desk (the assistant controller that he doesn't have) and pull out the red book. Then -- as airplanes are still moving through his airspace at 100+ miles an hour -- he has to thumb through several hundred pages until he finds I05: Sturgis, Ky. Where is the world (or Kentucky) is Sturgis? I have no idea. You probably don't know either.
As I hope you can see, the controller has had to take his eyes off the scope for up to 60 seconds to find out a virtually useless piece of information. Don't get me wrong, I'm a firm believer that controllers should clear pilots to a specific airport. I certainly don't believe in clearing a pilot to "your destination as filed." I don't even like saying "cleared to India zero five." I believe you should state the name of the airport. I could tell you some war stories about that process going wrong too.
The reason I say it is useless in this case is that the controller still can't visualize the route. He knows the route goes from SVH direct BZM and knows exactly what that looks like. But he has only the vaguest idea what happens after BZM. The airplane could wind up on any heading from 350 degrees to 300 degrees (the general direction from BZM to Kentucky).
This subject tends to upset a lot of people so let me take advantage of that and tell you what to be upset about. It's 2004 and we're still looking up identifiers in a three-inch thick book. It's ridiculous and there is absolutely no excuse for it. You and I can find out everything we need to know about Sturgis with one click of the mouse. Controllers have to look it up in a three-ring binder that really doesn't have the information that the controller needs anyway.
While you're there, take note of the Lat/Long. It doesn't match the one that is in the flight plan. That's the reason I wound up with the strip in my "inbox." The controller almost had a "deal" with this flight. That's what the handwritten remark says, in case you can't read it: "WRONG L/L" "ALMOST CAUSED SYSTEM DEVIATION."
There are about a dozen different insights to notice in what I've written so far, if you're paying close attention. For instance, most controllers don't like taking their eyes off the scope for anything, much less for what they perceive as useless information. That's the reason you hear "cleared to India zero five" or "cleared to your destination" so much these days instead of "cleared to Sturgis, Kentucky." That is also why pilots are so often asked, "What's your on-course heading?" It's also why so many airplanes are told to "fly runway heading" when there is absolutely no traffic that prevents them from turning on course. At least at the Centers.
What the controllers are doing is assigning a known route (runway heading) until the computer tracks up the target and can tell the controller which way the flight is supposed to be going. Of course, if the Lat/Long in the flight plan is wrong, the computer is (in effect) lying to the controller.
The pilot was cleared BZM direct I05. The computer shows him going BZM direct 4743/08757. It's two different things. (Sturgis is 3732/8757. I know some of you are going to look it up, so I'll save you the effort: That other Lat/Long is in the middle of Lake Superior.) Center controllers don't normally issue a Lat/Long to a pilot. We know the reason Lat/Longs are inserted into the flight plan and, as I said earlier, we tend to ignore them. The Towers are different. Let me see if I can explain the difference so you can understand it.
We'll stick with the same basic flight plan just to keep it simple.
As I said earlier, Center controllers are just going to ignore the Lat/Long. You'll be cleared to "Sturgis via direct BZM direct." The controller is making the assumption that the Lat/Long (4743/08757) is the airport. That should be a safe assumption because that is what the Lat/Long is supposed to represent: the next fix in the flight plan. Not to mention, the REMARKS section on the strip says "L/L I05," which is shorthand for "Latitude/Longitude is I05."
But if SVH had a Tower (or the flight departed an airport served by a Tower) the Tower controller might issue the clearance to include the Lat/Long. At least that is the consensus I got from my fellow controllers when I asked them how they would issue the clearance.
Let's make sure you understand this. It doesn't matter if you filed the Lat/Long or not. Either the FSS specialist or DUATS will have to put the Lat/Long in the computer to ensure the flight plan will process because the flight plan wasn't filed in accordance with the AIM. FSS or DUATS may also put in the REMARKS section "FRC." That means "Full Route Clearance." You'll be sitting in your cockpit -- fat, dumb and happy -- and the Tower will clear you via "Barretts Mountain direct forty seven forty three north eighty seven fifty seven west direct Sturgis" and you'll go "Huh?"
Notice that at no point in time have I said that the pilot shouldn't have filed a direct routing. If you want to file a direct routing then you need to file it in accordance with the AIM.
5-1-7. Flight Plan- IFR Flights
d. Area Navigation (RNAV)
2. Pilots of aircraft equipped with approved area navigation equipment may file for RNAV routes throughout the National Airspace System and may be filed for in accordance with the following procedures.
(c) Plan the random route portion of the flight plan to begin and end over appropriate arrival and departure transition fixes or appropriate navigation aids for the altitude stratum within which the flight will be conducted.
(d) File route structure transitions to and from the random route portion of the flight.
(e) Define the random route by waypoints. File route description waypoints by using degree-distance fixes based on navigational aids which are appropriate for the altitude stratum.
(f) File a minimum of one route description waypoint for each ARTCC through whose area the random route will be flown. These waypoints must be located within 200 NM of the preceding center's boundary.
I spent a total of about 15 minutes on the internet and this is what I came up with.
Keep in mind I don't hold an IFR ticket. I don't have a pilot certificate of any kind. Nor have I ever filed a flight plan. I don't even own a set of en route charts. I just "eyeballed" the route but it looks like a straight line to me.
There are (at least) two critical differences between this:
First, a controller can visualize the route with the radial fix distances (HMV180020) in it. He doesn't need a computer to do it. I know where SVH, BZM, HMV, LOZ and BWG are all located. It's not a problem to figure out where a point 20 miles due south of HMV is located.
Second is the inclusion of CCT in the route of flight prior to I05. I don't really know where CCT is but the controller that owns the airspace over I05 does. More importantly it provides a "route structure transition ... from the random route portion of the flight."
You see, I took the time to download the approach plate for I05. Have a look.
There are two published transitions for the NDB/GPS RWY 36 to Sturgis. One comes off of PXV (Pocket City) from the northeast and the other is from CCT (Central City) from the southeast. Some folks will want to cut out the VOR transitions and just go direct to the NDB, TWT (Tradewater.) And that's where you start getting in trouble.
Step back and think about it for a minute. The whole point of this exercise is so that everyone knows where you are going. At least while you're in a particular controller's airspace. The controller working the airspace around I05 probably doesn't know where SVH is any better than I know where I05 is. The guy working the airspace over BWG might not know where BZM is. He doesn't have to. Not if you file your flight plan correctly. He will know where CCT and LOZ are.
For controllers, airspace is like a jigsaw puzzle. We have to know our airspace very well and we have to know a certain amount of airspace beyond our borders. Beyond that, you might as well write in "Here Be Dragons" along the borders. We can't memorize the entire United States.
Guess how many controllers know where TWT is? That's right, the one controller working that approach. Nobody else knows it or cares to know it. Ditto for every other obscure NDB or Initial Approach Fix in the National Airspace System. If you filed SVH..BZM..TWT..I05 you wouldn't be any better off than if you had filed a Lat/Long. As a matter of fact, you'd be worse off. A Lat/Long would process through the computer. BZM..TWT wouldn't. But on second thought, maybe that wouldn't be a bad thing. At least the controller wouldn't think the Lat/Long was right and he'd know that he didn't know where you were going.
And TAPPA Too
In case that little tidbit didn't sink in let me give you another example. I bet I have a dozen guys a week file direct TAPPA intersection. They aren't landing anywhere close to TAPPA. They just know that is as far as they're going to get before whoever up there (Washington Center or Potomac Tracon?) puts them on a route. I don't know where TAPPA is. I don't know where 99% of the intersections in the NAS are. I do know a lot of VORs between me and TAPPA. I know GSO (Greensboro, N.C.) I know LYH (Lynchburg, V.) I know SBV, LVL, LIB, RDU, CVI, HPW, FAK and RIC. None of those are in my airspace but I know where they are. You can get on V16 and go to TAPPA. I know where V16 is. But I don't know TAPPA.
(ATC trivia. Did you know V16 runs from L.A. all the way to Boston? It's amazing what I learn writing for you.)
(e) Define the random route by waypoints. File route description waypoints by using degree-distance fixes based on navigational aids which are appropriate for the altitude stratum.
All of the above goes double for using GPS approach intersections as en route fixes. Unless that GPS intersection is on an approach you plan on flying, don't file it.
Exhibit A, B, C
Ever since I stumbled onto Section 5-1-7 in the AIM, it seems like I've been in a constant argument with some person or other about these issues. On the last midnight shift I spent half the shift arguing with another controller about it. We actually had the AIM pulled out and were going through it line by line.
I told him about this paragraph in the ATC Bible (FAA 7110.65).
4-4-3. DEGREE-DISTANCE ROUTE DEFINITION FOR MILITARY OPERATIONS
a. Do not accept a military flight plan whose route or route segments do not coincide with designated airways or jet routes or with a direct course between NAVAIDs unless it is authorized in subpara b and meets the following degree-distance route definition and procedural requirements:
1. The route or route segments shall be defined in the flight plan by degree-distance fixes composed of:
(a) A location identifier;
(b) Azimuth in degrees magnetic; and
(c) Distance in miles from the NAVAID used.
EXAMPLE- "MKE 030025."
On my break, I even pulled up the FARs off the internet to support my case.
PART 91--GENERAL OPERATING AND FLIGHT RULES
Subpart B--Flight Rules
Sec. 91.169 IFR flight plan: Information required.
(a) Information required. Unless otherwise authorized by ATC, each person filing an IFR flight plan must include in it the following information:
(1) Information required under Sec. 91.153 (a) of this part;
(Section 91.153 reads, in part ...)
Sec. 91.153 VFR flight plan: Information required.
(a) Information required. Unless otherwise authorized by ATC, each person filing a VFR flight plan shall include in it the following information:
(5) The proposed route ...
Just for fun, I showed him this one too.
Sec. 91.181 Course to be flown.
Unless otherwise authorized by ATC, no person may operate an aircraft within controlled airspace under IFR except as follows:
(a) On a Federal airway, along the centerline of that airway.
(b) On any other route, along the direct course between the navigational aids or fixes defining that route ...
Any of you who have been reading my columns for any length of time know I hate to "go legal." For most pilots and controllers the books we use on a daily basis are already confusing enough without getting into the legal mumbo-jumbo of the FARs. But for some folks, that is the only way to get their attention.
Still, some refuse to be convinced. Some fall into the reality denial mode. "My little hand-held PDA knows every fix in the world -- why doesn't the FAA's computers?" It's irrelevant. Your PDA doesn't run the NAS. Nor can it be hard-wired into the brains of every air traffic controller. It's important that controllers know which way you're going, whether our computer or your PDA is working at the moment or not.
In case I'm not tying these points together very neatly, let me summarize. I've got the FARs saying you must file a route of flight. I've got the AIM that tells you how to file a route of flight. I've got the 7110.65 that says I can't accept a flight plan from the military unless the random route is filed in the correct format. I can add in another dozen bits and pieces and it still adds up to the same thing: You're supposed to file a route of flight and it is supposed to be in a certain format.
Let me try one more thing and we'll wrap this up. Let's throw away all the books. Toss out the AIM and the 7110.65. Throw the FARs in the trash. Forget the limitations of the computers and the humans. No rules. Let's just do what feels good.
Let's see a show of hands class. How many want to fly direct to the airport?
That's what I thought. Most controllers are convinced that every pilot in the world wants to go direct to the airport, too. And any chance they get, they'll clear them direct. Does everybody feel good now?
Great. So explain this to me, class. Why don't you want to go to a point about three miles out on the final instead? If it's IFR, why don't you ask to go direct to the Initial Approach Fix instead of filing direct to the airport? Perhaps there is some confusion somewhere. Lately, about half the airplanes I see cleared direct to the airport turn themselves direct to one of those two points. (That can be very dangerous, by the way. )
Which is it? Do you want to go direct to the airport or do you want to go direct to the point where you commence the approach (either instrument or visual)? Why would a pilot ask for one and then do the other?
Why do airline dispatchers sometimes file their aircraft hundreds of miles out of the way from a direct line to the destination airport? Don't airline pilots want to go direct to the airport? Could it be because of the winds? Thunderstorms? "Stabilized approaches"? And why is it that I see so much discussion on the proper way to enter an airport traffic pattern? There's no air traffic controllers to get in the way at an uncontrolled airport. Surely that can't be blamed on the FAA's computers. Why doesn't everyone just go straight to the final?
Think about it and tell me what you come up with. You can send an email directly to me or you can post it for others to read (using the buttons below) -- I'll respond either way.
Have a safe flight.
Facility Safety Representative
National Air Traffic Controllers Association
Want to read more from Don Brown? Check out the rest of his columns.