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Old 01-15-2020, 07:41 AM
  #11  
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Originally Posted by dera View Post
What's the clean speed for MTOW 777, 275 or so? That's the max they can legally do.

They were "slowing down" to 280. I stand corrected if it's over 280.
Do you understand what emergency authority means? We had a minor bleed issue and the QRH directed us to avoid icing conditions. We declared an emergency in order to descend at 320 KIAS below 10,000 to minimize our time in the clouds.
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Old 01-15-2020, 08:48 AM
  #12  
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Originally Posted by 2StgTurbine View Post
Do you understand what emergency authority means? We had a minor bleed issue and the QRH directed us to avoid icing conditions. We declared an emergency in order to descend at 320 KIAS below 10,000 to minimize our time in the clouds.
I know. They were 250+ before they declared emergency.
Chief counsel disagrees with the comments here. But that's not relevant to the event, so let's discuss something else.
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Old 01-15-2020, 09:49 AM
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Originally Posted by dera View Post
I know. They were 250+ before they declared emergency.
Chief counsel disagrees with the comments here. But that's not relevant to the event, so let's discuss something else.
Let's say you are flying under Class B airspace and your clean maneuver speed is 215.
Would you extend flaps to be able to fly at 200, or would you keep the wing clean and fly at 215?
The same answer applies to the 250 below 10,000 rule.
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Old 01-15-2020, 10:03 AM
  #14  
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Originally Posted by Singlecoil View Post
Let's say you are flying under Class B airspace and your clean maneuver speed is 215.
Would you extend flaps to be able to fly at 200, or would you keep the wing clean and fly at 215?
The same answer applies to the 250 below 10,000 rule.
The Chief Counsel says yes, you do extend the flaps.
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Old 01-15-2020, 10:12 AM
  #15  
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Originally Posted by dera View Post
The Chief Counsel says yes, you do extend the flaps.
Not according to 91.117(d)
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Old 01-15-2020, 10:20 AM
  #16  
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Originally Posted by captjns View Post
Not according to 91.117(d)
If the airplane can be configured to that speed, you must fly that speed.
"Therefore, the pilot must operate the aircraft in the configuration to meet the requirements".

We are having pilot deviations from the topic so let's not ruin this thread any further.
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Old 01-15-2020, 11:43 AM
  #17  
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Originally Posted by dera View Post
The Chief Counsel says yes, you do extend the flaps.
Actually, Dera is correct here. According to the FAA Counsel's interpretation, we are required to configure in order to maintain 200/250 kts -- unless authorized by ATC.

As with a lot of things aviation, local tribal knowledge takes over and POI's interpret things their own way. This procedure has disappeared from manuals and the "min clean is fine" technique has become the norm.

The FAA is obviously fine with it, notwithstanding their assistant chief counsel.

"Section 91.117 does not distinguish requirements based on the aircraft's configuration during different portions of the operation. Under the scenario you describe, the aircraft can in fact be configured to operate in accordance with the speed restrictions of paragraph (b). Therefore, the pilot must operate the aircraft in the configuration to meet the requirements unless the minimum safe airspeed for that operation is greater than 200 knots. If so, then the aircraft can be operated at the minimum safe airspeed, in accordance with paragraph (d)."

https://www.faa.gov/about/office_org...rpretation.pdf
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Old 01-15-2020, 12:17 PM
  #18  
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Originally Posted by dera View Post
If the airplane can be configured to that speed, you must fly that speed.
"Therefore, the pilot must operate the aircraft in the configuration to meet the requirements".

We are having pilot deviations from the topic so let's not ruin this thread any further.
Never had an issue departing PHNL nor PANC... By the grace of the Sky Gods, and this has been my experience from the mid ‘90s to the present, both FAA and Expat Ops.
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Old 01-16-2020, 11:31 AM
  #19  
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Originally Posted by GogglesPisano View Post
Actually, Dera is correct here. According to the FAA Counsel's interpretation, we are required to configure in order to maintain 200/250 kts -- unless authorized by ATC.

As with a lot of things aviation, local tribal knowledge takes over and POI's interpret things their own way. This procedure has disappeared from manuals and the "min clean is fine" technique has become the norm.

The FAA is obviously fine with it, notwithstanding their assistant chief counsel.

"Section 91.117 does not distinguish requirements based on the aircraft's configuration during different portions of the operation. Under the scenario you describe, the aircraft can in fact be configured to operate in accordance with the speed restrictions of paragraph (b). Therefore, the pilot must operate the aircraft in the configuration to meet the requirements unless the minimum safe airspeed for that operation is greater than 200 knots. If so, then the aircraft can be operated at the minimum safe airspeed, in accordance with paragraph (d)."

https://www.faa.gov/about/office_org...rpretation.pdf
The "authorized by ATC" does not apply to 250/10000. ATC is not authorized to allow deviations from that, only Administrator is. There's another letter, Boll I believe, that clarifies that.

I know it is common practice, but at the same time, it's good to know what the Chief Counsel thinks about it.
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Old 01-16-2020, 11:33 AM
  #20  
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Originally Posted by captjns View Post
Never had an issue departing PHNL nor PANC... By the grace of the Sky Gods, and this has been my experience from the mid ‘90s to the present, both FAA and Expat Ops.
Chances of getting dinged for it are pretty small. But as the FAA has said, it is not allowed per the FARs. So I don't know if I would announce it on frequency.
Just call it "Southwest 250".
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