In the past months, IFR pick-up for Z departures within Palma TMA , typically from LESB in our case, have changed vs the custom of prior times:
BEFORE
You filed an IFR change point at the edge of the TMA then request IFR enroute there which was typically granted as soon as clear of the islands or of traffic.
AFTER
You are to maintain VFR until the filed IFR change waypoint, and will only be granted an IFR clearance approaching such filed waypoint.
This causes all kinds of practical and safety problems, hence a group of local pilots want to call a meeting with local ATC to discuss and hopefully reach an agreement that works best for both GA and ATC. Currently it is more of a case of survival of the fittest, and there is no point in contesting who the fittest is.
Before such meeting, I am seeking guidance from the collective forum wisdom, both from experience as well as regulation.
BACKGROUND
The airspace in the Balearic islands is quite unique in that it is class A down to 1000ft AGL over the islands, class G or E underneath except for CTR’s. The class A floor over the sea is between 1000ft and 4000ft depending on sectors, with the exception of one sector at 6000ft.
This is a snip of the current chart with max VFR sector altitudes in blue: this matches the class A floor.
Minimum current ATC surveillance altitude in the whole TMA is at least 1000ft above the class A floor, as depicted in blue boxes in the below chart.
Now you can see WP’s over the sea closer to the islands in the chart above, but all except a couple are not on airways: they are RNAV WP’s. The ones which are on airways are rarely useful.
You could argue this is a bad design and that making it class C (vs A) would do away with most of the issues I am going to raise, but that point is moot: it is class A and changing that would be a major effort.
THE PROBLEM FOR Z FLIGHTS is, at least , twofold:
A) You cannot get an IFR clearance unless you are on a published instrument procedure, including at or above MEA on an airway, or above the minimum ATC surveillance altitude (used to be MVA but now they changed it, for practical purposes I will still call it MVA in this thread) . However in this TMA (with the exception of some portions of DEP and MAP procedures in class D CTR’s) you would need to fly VFR through class A in order to reach such MVA or MEA. Therefore unless you get a VFR clearance through class A you cannot be issued an IFR clearance. This is the first conflict
B) The second one is that the safety of routinely and otherwise unnecessarily sending SEP’s 30-60 NM out over the sea VFR at 1000ft (or 2500 or 3500 or whatever applies in the sector) with intermittent radio coverage is at least, questionable.
THE OLD SOLUTION
In the past, there were two ways:
1) once over the sea and while still VFR below class A floor ATC provided a clearance to climb to an altitude above MVA inbound your filed pickup point. Then upon climbing through MVA the clearance was changed to IFR.
2) once over the sea you were cleared VFR to an altitude above class A floor, then later were cleared IFR higher and inbound your filed pickup waypoint.
You can see problems with the legality of both options but, as far as I am aware, it has worked for the past 20 years in a very busy TMA with minimal problems. The reason is commercial traffic climb and descent profiles are much higher than the typical clearances provided per above.
THE NEW WAY
There has been an (official or unofficial) internal agreement at the ATC provider that IFR clearances for Z flights will no longer be granted unless at or near the filed IFR transition waypoint.
Although there are waypoints on the airways and on the islands that one could file for pick up, those are typically very populated at low altitudes with commercial traffic and although Eurocontrol will approve, in practice it is difficult to get an IFR clearance to change at those locations.
One could also try a pickup at a coordinate WP and then DCT to a published WP but the RAD restricts DCT to maximum length=0 in the whole FIR.
MY ASK
What proposals to resolve at least 2) above (and possibly 1 too) can we come up with in our meeting with ATC?
Go back to the old way?
I have not tried, but what if you put an IFR pickup coordinate waypoint on an airway: will Eurocontrol accept it?
What else?
I can’t really be useful to you Antonio (in terms of providing any guidance on how to fight your case before AESA/AENA), just wanted to say that this airspace is tremendously unfair and ridiculous. It just shows how small VFR GA flying is in Spain, there’s really NOBODY to oppose the bullying of the regulator who would be extremely happy and pleased if there were only A320s and heavier flying around.
The real way to solve this problem would be to turn the airspace into Class B. But this doesn’t exist in Spain (other than the Albacete CTR for some weird reason?) and as you said, changing the airspace category to a LOWER class is probably impossible to do in bureaucratic Spain.
The way this worked in the past was my experience also when cross-country flying in Spain. I can imagine a sequence of events similar to this:
Is IFR pickup at a WPT defined by coordinates possible? I know I sometimes use such WPTs to get IFR flight plans to validate in our FRA, but never thought to try picking IFR up at one of them.
Thanks Antonio for taking on this issue.
I have always thought that the way the airspace around the Balearic Islands is implemented is totally nonsensical (as showcased by the fact that the class A basically has to be ignored for any Z or Y flightplan to work). Case in point, when you arrive IFR relatively high from the sea crossing, Palma Approach asks anxiously when you are going to cancel IFR, but at that point you would have to sink below their MVA to be in airspace where VFR is legal…so you cancel in A, which is technically impossible.
That being said and to the actual question, when was this change implemented? Flying back from Menorca on October 22 I filed LESL SARGO IFR … and asked for a climb and pickup as soon as possible. The lady controller seemed a bit nonplussed because I was “so far away” from my waypoint, but cleared me first to 3000 and then to FL120 way before, so that I reached my cruising altitude around SARGO. Was I just lucky?
I will think about some arguments for your meeting with ATC and get back. If there’s anything else I can do to help, please let me know.
In what sensible world would you have Class ‘A’ TMA below an altitude that Radar coverage can be provided. And I don’t mean a little corner where Radar is sketchy, as can often happen.
As a point of reference, from my base strip, we call London on the phone with engine running and get an initial freq and sqwark. We call when airborne and providing they can ‘see us’ were usually cleared straight into class ‘A’ TMA, often on a heading. Job done. Very rarely are we lsft messing around OCAS or VFR
It requires the TMA base to a be workable altitude, and Radar coverage to start there, so they can clear you in. You’re legally allowed and entitled to be there. Operationally there will be issues but that’s how it should be.
VFR in class A is only ‘special VFR’ is it not?
I’m not highly experienced all over europe but I’m still surprised this airspace structure exists.
In many ways, Rome is the same.
On arrival, ATC will often ask you to cancel IFR when you are still in class A airspace. In some cases, they will simply cancel IFR on you! You then have to descend to get below the class A some way, but it‘s totally not regulated. For German readers, it has been discussed in PuF10/2023. And while the issue was probably blown up a bit, it raised a few very valid concerns, especially for commercial pilots relying on their license.
Same for departures: they do have to give you a VFR climb (too low for IFR) to get to IFR altitudes, but during that climb, you have to go through the Alpha.
Simply put, it‘s a structure where the flight rules change scenario has not been duly considered. Everything is set up to suit IFR-only CAT, whilst leaving a little bit of space for purely VFR flights.
In some cases, they will simply cancel IFR on you!
Never accept that, it is against flight safety and it is illegal.
Thanks.
Well, it is true that this “new ruling” is not applied 100%. You get exceptions, sometimes via an airwaves “fight”, sometimes seamlessly as in the case of @mri .
After a couple of bad cases, one famously reported herein re the @EuroGA meetup (which one you may ask? of course, as I said THE meetup: La Cerdanya) even in the commemorative video, I was starting to think I had become (in)famous at the ACC.
However I then started observing the same thing with other Z flights, even MEP’s, SET’s and jets. Usually the phraseology includes something to the effect of “expect to change IFR at the designated waypoint as filed” or something to that effect. I have been collating observations with ATC audio and ADS-B data (in case of traffic conflict) and it is clear this is a new policy which only rarely occurred in the prior 20 years I have been flying in this TMA.
speed wrote:
they will simply cancel IFR on you
Palma ACC used to do that on you years ago, but nowadays it rarely happens. “Negative, still IFR, will advise when ready to cancel” used to be my most used phraseology tool on arrival at Palma TMA
So on my next flight, I can either file SARGO again and risk being kept low over the water, or file LESL MHN IFR B16 CHELY G23 VERSO and fly a nice big dogleg, notwithstanding that joining at MHN is not very practicable.
Yeah, you’ll have trouble joining at MHN if there is any traffic. The other day they even refused me in the hold at MHN (at the end of the MAP) because they had IFR traffic inbound and outbound…I thought MAP holds were designed so they would not interfere with arriving or departing traffic? Worst case you could just stack me above the next traffic going missed…or maybe it had something to do with the final phrase in the ATIS: “ATC in training”
They have very little traffic in winter so this time of the year at Menorca it should work anyway
Anyway you get exactly the point: we could file ADX or MHN as IFR changeover waypoints at Mallorca or Menorca respectively, but then we would be at the same altitude as the biggies near such WP.
But if I use SARGO (as you did) or ESPOR or MEROS , all on the TMA border, by the time I get there at FL100-150, the biggies will be at FL250-350, so no conflict.