WickedPenguin Junior Member Pensacola

# 1

I'm trying to get some second opinions on VFR-On-Top ops. This is a big grey area for me. I've gone over the 7110.65 and I feel like its wording leaves things unclear.

From my research, I've gathered the following:

• The pilot is on an IFR flight plan.
• The book says we clear a pilot as follows: "N123, climb to and report reaching VFR-On-Top. If not on top by [altitude], maintain [altitude] and advise."
• The book also says: "1. When an aircraft has been cleared to maintain 'VFR-on-top,' the pilot is responsible to fly at an appropriate VFR altitude, comply with VFR visibility and distance from cloud criteria, and to be vigilant so as to see and avoid other aircraft. The pilot is also responsible to comply with instrument flight rules applicable to the flight (e.g., adherence to ATC clearances)."
• Lastly, it states: "2. Although standard IFR separation is not applied, controllers shall continue to provide traffic advisories and safety alerts, and apply merging target procedures to aircraft operating VFR-on-top."

Reference: http://www.faa.gov/AIRPORTS_AIRTRAFF...7/atc0703.html

We do get a fair amount of VFR/OTP traffic here, but 99.999% of the time they're Navy trainers. We have our own specific procedures for them. I'm trying to understand how VFR/OTP is used in a normal civilian environment.

My questions:
1) In practice, I am to treat the airplane as a standard IFR aircraft until he reports on top, so 3 miles/1000 feet are required? That's what I do, but I just want to confirm that's the case.
2) Just so I'm clear, once the pilot reports reaching VFR/OTP, I'm not required to continue providing 3 miles/1000 feet - even if the pilot has not cancelled IFR? After all, that's what VFR is supposed to be and what I understand Paragraph 1 to mean.
3) Are pilots required to cancel their IFR clearance once they reach VFR/OTP?
4) If an aircraft is A) cleared only to a local fix, B) has reported VFR-On-Top, c) has not cancelled IFR, and D) wants to leave my airspace, can I simply terminate radar services as if he was a regular VFR flight following aircraft? I don't think I can, since he's technically an IFR flight plan, but just wanted to hear someone else's thoughts on this.
5) How do you guys handle VFR/OTP overflights, and what separation do you apply with them? I don't think I've ever seen one.

MikeATC Retired & Overseas Nashville TN

# 2

With VFR/OTP once the acft gets OTP and is VFR I ask them, "Report cancelling IFR", I want no confusion about whether the pilot is IFR or VFR once he reaches VFR on Top.

As for seperation, until the acft reports VFR/OTP I provide IFR seperation, once the acft reports VFR/OTP and has cancelled IFR, but wants flight following to someplace outside my airspace, I leave them on the discrete code so that I can hand them off, and I provide VFR seperation standards.

If the acft wants to stay within my airspace but wants to be VFR/OTP if the pilots wants VFR advisories I will leave them tagged up, if they don't want advisory services I will terminate VFR and tell them to squawk VFR, I've found that most pilots want to retain advisory services.

ATCinWI Senior Member Illinois

# 3

1) In practice, I am to treat the airplane as a standard IFR aircraft until he reports on top, so 3 miles/1000 feet are required? That's what I do, but I just want to confirm that's the case.

Whenever the pilot reports reaching VFR conditions on top, you can stop using IFR separation; you would provide it with traffic advisories like any other VFR aircraft.

2) Just so I'm clear, once the pilot reports reaching VFR/OTP, I'm not required to continue providing 3 miles/1000 feet - even if the pilot has not cancelled IFR? After all, that's what VFR is supposed to be and what I understand Paragraph 1 to mean.

Correct.

3) Are pilots required to cancel their IFR clearance once they reach VFR/OTP?

No, but like the poster above me said, I ask them to report cancelling IFR. Usually, a pilot intends to cancel IFR reaching VFR conditions, but may not understand that he has to say the magic words "cancel IFR", or might just not remember.

4) If an aircraft is A) cleared only to a local fix, B) has reported VFR-On-Top, c) has not cancelled IFR, and D) wants to leave my airspace, can I simply terminate radar services as if he was a regular VFR flight following aircraft? I don't think I can, since he's technically an IFR flight plan, but just wanted to hear someone else's thoughts on this.

Again, correct . . . he's still on an IFR flight plan. I would advise the pilot that he has to either cancel IFR, or you can try to work something out with the next facility. I have seen 2 different VFR-on-top situations. In the first one, the pilot just wants to get above a layer, then go VFR . . . that is the most common. In the other, the pilot is actually going somewhere on an IFR flight plan, so there will be a strip generated to the next facility. You will have to coordinate the VFR on top with them . . . if they say no, you will have to instruct the pilot to return to his flight planned route and assigned altitude.

5) How do you guys handle VFR/OTP overflights, and what separation do you apply with them? I don't think I've ever seen one.

They have to be IFR, say "N12345, climb and maintain 6000, report reaching VFR conditions on top (and canceling IFR (if you wish)). If not on top at 6000, maintain 6000 and advise." At that point, if he is not on top, you can keep trying different altitudes . . . but the pilot will have to hold upon reaching his clearance limit unless you vector him around or give him a new one. If he's enroute, it's the same thing, except his clearance limit is the destination airport, and again, if he's going to leave your airspace, you will have to coordinate it with the next facility.

WickedPenguin Junior Member Pensacola

# 4

That's the way I've been doing it. My initial transmission to a departing VFR/OTP aircraft is always, "N123, Departure, radar contact. Report On Top and cancellation of IFR." I don't want there to be any confusion as to what I'm expecting from them. That's how I was trained.

But in going through the 7110.65's section on it, there's absolutely no mention of IFR cancellation. Plus, that first paragraph says the pilot is responsible for his own separation. However, he's still technically an IFR airplane.

It just appears somewhat vague.

ATCinWI Senior Member Illinois

# 5

Yeah, it's not required that a pilot cancels IFR when reaching VFR conditions; I just do it as a hint that they *can* cancel. My (limited) experience has been that if you don't tell the pilot to report reaching VFR conditions on top AND report canceling IFR, then they won't cancel, even if they want to; they think that reporting that they're in VFR conditions IS their cancellation (it's not a common procedure for pilots, either . . . I'd say less know about VFR on top than, say, SVFR, which, I'm finding, is not as well-known as I thought).

He's on an IFR flight plan, but he's providing the separation . . . as long as their is some sort of separation, you're legal, right? We use visual separation all the time, right? Pilots in VFR conditions are still supposed to see-and-avoid, even on an IFR flight plan (although if at a hard altitude and route, ATC has the responsibility in controlled airspace). If they're flying VFR-on-top, it lets them climb and descend and maneuver as they need to to stay VFR and avoid other traffic, but retain their IFR clearance.

Kind of hand-in-hand with VFR on top is the VFR climb of an IFR aircraft. I have never seen this before, but I watched a CBI a while ago on it . . . "Climb VFR between 5000 and 14000" or something like that . . . it's pretty much the same thing.

joecoolinsc Rookie Spartanburg, SC

# 6

Sounds like two procedures are getting intermingled here.

7-5-6. CLIMB TO VFR is a Special VFR procedure. In this case a VFR aircraft just wants to get off an airport with less than 3 miles visibility to reach VFR conditions.

7-3-1. VFR-ON-TOP is only for aircraft on an IFR flight plan. The fact of the matter is, if he cancels IFR he is no longer "VFR-On-Top", he's just another VFR.

IFR aircraft can request a VFR-On-Top clearance anytime, even en route without a cloud in the sky. It just allows him to maintain VFR conditions, be treated as a VFR aircraft for separation purposes and retain his IFR clearance,

mklatval Rookie

# 7

I find that most pilots don't quite know what there are asking for. When someone here asks for OTP they are usually trying to get an IFR clearance to climb through the clouds and then cancel, which is not really OTP. OPT does not necessarily imply that the aircraft will be canceling.

joecoolinsc Rookie Spartanburg, SC

# 8

There is no special term or procedure for what mklatval describes. It is simply a short range IFR clearance with the knowledge the pilot intends to cancel.

zabnut Senior Member Albuquerque

# 9

Just because VFR/OTP has VFR there does not mean they are VFR, THEY ARE IFR plain and simple, don't over think this.

The book also says: "1. When an aircraft has been cleared to maintain 'VFR-on-top,' the pilot is responsible to fly at an appropriate VFR altitude, comply with VFR visibility and distance from cloud criteria, and to be vigilant so as to see and avoid other aircraft. <b>The pilot is also responsible to comply with instrument flight rules applicable to the flight (e.g., adherence to ATC clearances)." </B>
Lastly, it states: "2. Although standard IFR separation is not applied, controllers shall continue to provide traffic advisories and safety alerts, and apply merging target procedures to aircraft operating VFR-on-top."

You are soliciting cancelation on an IRF clearance, a big no no.

You allow a VFR/OTP to fly below MEAs or not follow other IFR procedures (clear of MOAs, ect) after that fact then you have had an ops error (Other than IFR separation FROM OTHER AIRCRAFT, after they say they are on top and you tell them to maintain VFR/OTP) .

Like I said don't over think this, This is a seldom used rule that can get you in big trouble. Misapplication can easily lead to an error. Force a cancelation on an AC then let them have an accident later that is totally unrelated and see if the NTSB won't want to talk to you about it later.

joecoolinsc Rookie Spartanburg, SC

# 10

Forcing or soliciting a cancellation is completely unnecessary and wrong. I say again... VFR-ON-TOP is a procedure for aircraft on an IFR flightplan. That is clearly stated. (agreeing with zabnut)