7 min read

Part 91 VFR pilots have an incredible amount of regulatory leeway, which is both good and bad. VFR pilots operate in the same airspace as commercial IFR jet aircraft without having to ever hit the push-to-talk button. Most of the time things go just fine and the two operate without running into each other.

Not having a requirement to talk to anyone doesn’t alleviate your responsibility as a small airplane driver to understand the airspace around you, though. As an airspace user you need to know who else needs the airspace and why. I was reminded of this recently.

ATC tower

Just because you don’t have to talk to ATC, doesn’t mean you shouldn’t.

The other week as I was on an approach in a regional turboprop airplane, I heard tower make a call in the blind to a small aircraft just outside his airspace.

He proceeded to get into a little tit for tat with a pilot. Tower thought the guy had entered his airspace without calling. He hadn’t, and the pilot wanted to make sure he was good (otherwise he would need to file an ASRS report).

I want to give kudos to the pilot. VFR pilots aren’t required to talk on the radio outside Class D airspace. Even though he wasn’t in the Class D airspace, he was monitoring tower’s frequency and was able to respond when tower called.

They also aren’t required to understand IFR traffic procedures. I get it: less regulation is helpful for our GA community. But I hope to raise your awareness of what goes on in and around Class D airspace. Hopefully, this knowledge will change your behavior.

You see, there are points outside Class D airspace that are potentially dangerous to VFR pilots due to arriving IFR traffic. Talking to tower, and avoiding certain areas will keep you clear of big aircraft coming in to land. And that is less stressful for all of us.

When I flew small planes and helicopters I didn’t understand what the big deal was when big, fast aircraft arrived. Why did we need to get out of the way? I have just as much of a right as big planes! Right?

Kind of. Let’s step into the shoes of an airline pilot for a minute. I want to explain from an airline pilot’s point of view why small GA traffic should pay attention to fast moving IFR traffic.

Three things to know

1. Large aircraft can’t maneuver as quickly or react to situations like small airplanes.

It’s a significant emotional event for an airplane weighing more than 50,000 pounds to do a go-around. The pilots don’t do it that often, and it completely interrupts the flow of the landing sequence. Add bad weather and you have a potentially hazardous situation.

The lack of maneuverability coupled with increased speed is the primary reason you, as a GA pilot, will be asked to get the hell out of the way by tower. Don’t take it personally; just get out of the way. They have paying passengers and are on a tight schedule. You don’t.

Also, a go-around or a quick 360 for you isn’t hard. Big jets need a lot of room and more time to do 360s.

United RJ

At 170 knots, it’s hard to pick out a smaller airplane.

2. It’s really hard to pick out small airplanes when you are going 170 knots and trying to set up the aircraft to land.

Yes, we have TCAS (traffic advisory system), but you still have to look outside to acquire the traffic. We are absolutely required, when we get a “resolution advisory” (RA), to do what the TCAS tells us (ie. climb, descend). We can legally ignore it if both pilots have the traffic and it is no factor, but on an approach that’s a hard thing to do.

I was recently on a commercial flight into Portland, and the 737 had to break off its approach due to a small airplane flying into Pearson Airfield. I suspect the jet got an RA, the pilots couldn’t acquire the traffic, and they had to do a go-around.

3. It gets really busy at the Final Approach Fix (FAF), which may or may not be in protected Class D airspace.

Let me explain for all you VFR-only pilots what these FAFs are and why you should avoid them.

On IFR approaches we have what are called “Final Approach Fixes.” The FAA tries to build them roughly the same way at every airport: 5 NM out and about 1500 ft AGL.

This means a small airplane legally flying 7 NM from a Class D airport at 2500 ft. AGL could seriously disrupt a large airplane’s approach.

Let me show you what I mean with these pictures.

I drew both of the FAFs for Salem, Oregon, and Eugene, Oregon with their corresponding altitudes.

5NM from Class D

Note they are right on the edge of Salem’s airspace.

Eugene is even worse. Neither point is inside Eugene’s airspace:

5NM Class D Eugene

So, a VFR pilot cruising around at 2500 ft. MSL about 6-7 miles north of Eugene’s airspace is completely legal not talking to tower, but can seriously disrupt any IFR traffic attempting to land.

 4 more things for VFR pilots to consider

1. Large jets typically “configure” the aircraft (put the flaps and gear down) around the FAF.

So, the cockpit is busy with button pushing and reading checklists. In other words, they probably aren’t focused outside.

2. Large airplanes typically capture the glidepath a little before the FAF.

So, the pilots may be distracted making sure the aircraft captures properly.

3. Usually the pilots are switching over to tower’s frequency slightly before but no later than the FAF.

This means if there is traffic they won’t get the call until late in the game. They are also busy switching frequencies.

Center can give the aircraft a traffic warning, but unless the VFR pilot is monitoring Center (which I also recommend you do), Center has no way of telling the VFR pilot they are getting in the way.

4. Large jets usually fly about 170 knots at the FAF.

This speed varies, but just know they are going fast! Everything moves a million times faster in big jets. That time you take for granted in a small airplane disappears above 120 knots.

What should you to do with this information?

1. Avoid FAFs.

Even on beautiful days, IFR pilots use these points. Because they are about 5 NMs out they are great reference points for turning final.

Don’t worry! You don’t need to know every FAF for every Class D airport.

You can do these two things to avoid FAFs:

  • Never fly 5 NM out from the main runways around 1500-2500 ft. AGL.
  • Fly higher (3500 ft. AGL) or go more than 8 NM at a lower altitude so you know the IFR traffic will be clear.
approach plate

Ask an instrument pilot to point out final approach fixes at your local airport.

2. Always monitor and preferably talk to tower within 10 NM of Class D airports.

Why 10 and not 6 or 7? Because sometimes these FAFs are 10 NM out, like Reno, Nevada.

I also recommend going a step farther and actually talking to tower and letting them know you are getting close to the airport (7-8 NM away).

This is especially true if you are traversing upwind or downwind of the major runways.

3. Know and avoid the FAFs at your local airport.

Have an IFR pilot point them out to you the next time you fly and add them to your GPS.

4. Always adhere to your cloud clearances in Class E airspace!

Flying 500 ft. below the clouds is a requirement precisely for this situation: IFR traffic descending out of the clouds.

If you inadvertently get close to a FAF and you are 500 feet below, you will have time to see and avoid that large beast barreling down on you.

I hope this gets you thinking about VFR flight planning a bit more.

Part 91 does give recreational VFR pilots a lot of leeway. That doesn’t always mean you should take it. Know the airspace around you!

Sarah Fritts
18 replies
  1. Javier Castro
    Javier Castro says:

    I would think flight following would remedy this issue unless of course ATC were to kick you off frequency due to high commercial work load. In fact, because I fly within the veil in SoCal, with so many class D and C airspace, LAX class B dominates the entire coastal area, I find it unsafe to fly VFR without flight following, until your East of KRIV.

  2. Ed
    Ed says:

    Good article. I was taught this by a fellow pilot many years a go and suggest all CFIs add this to a lesson plan for their Private Students.

    On the flip-side, I have a suggestion for IFR pilots flying approaches into uncontrolled fields. Don’t announce, “N12345, on the VOR/ILS/GPS XX approach”. No VFR pilot knows what the heck that means, and even if he/she did, it doesn’t really tell anyone WHERE you are.

    Instead, consider announcing, “N12345, five-mile final runway XX” or the like when at the FAF inbound and then, “N12345, 2-mile final runway XX” after you pop out of the clouds. It lets everyone know where you are without needing to use the “Secret IFR Decoder Ring”. :)

  3. Stephen Phoenix
    Stephen Phoenix says:

    Lot of good info here, the kind that should be brought up in a BFR. I will make it a point to include them next time I give a BFR.

  4. Charles West
    Charles West says:

    It even becomes more dangerous if the airspace is designed incorrectly!
    In the recent airspace change at KSLE used in your fine example, the back course to RWY 13 has been left unprotected. This can be seen in the picture below. An aircraft will be in class G airspace at 2200 feet after the PT. Check it out with Foreflight Pro!

  5. Duane
    Duane says:

    Very helpful post, Sarah! Thanks!

    Calling in to a Class D towered airport at 10 miles out would be the minimum in my book, unless your arrival is being dictated by ATC from an adjacent Class B or C airport, when they sometimes don’t let you go off frequency until you’re nearly on top of the Class D.

    I personally like to call in at around 20 miles out unless it’s a really busy Class D airport. It alerts the tower earlier, which can aid the controller in sequencing arrivals in the pattern, and also lets the tower have a better opportunity to guide your entry to a more advantageous point. And calling in sooner also gives you a better sound picture of the density of traffic in the pattern and how they’re being guided (straight ins, downwind entries, base entries, etc.).

  6. Jeff
    Jeff says:

    Let me second what Ed said. If you are using that super secret check point and calling inbound from there, Please, Please announce WHERE the heck you are! VFR pilots have no idea where all the points are around the area. If you tell me 10 miles out from the north at 2500 feet, I know.
    Also just because you are IFR don’t take advantage of the situation. If I’m on downwind and called my position, don’t expect me to get out of the way for some IFR flight 10 miles out. We need to share the sky. Can’t tell you how many times I have sat waiting for a IFR training flight that announced 5 miles out that didn’t show up for 10 minutes!
    Interestingly at non towered fields some charter operations require their pilots to fly the pattern, not just a 20 mile straight in. Good job there.
    Finally, particularly for those charter type flights, don’t tie up the frequency asking for Mrs. Browns car to be brought to the ramp, is your rental car ready and what’s on the lunch menu, or how much fuel you want in each tank. It can wait until you are on the ground.
    If I’m flying anywhere near a towered airport, particularly one with commercial traffic I always monitor the frequency, that’s just common sense. I also ask for flight following. If denied by ATC and outside their airspace I still monitor as they should be calling traffic out to you. If I’m in the way, I’ll move. So once again letting us know where you are, not just a fix is helpful.

  7. Andy K
    Andy K says:

    Thanks for the informative article. I am of the opinion that the more information about where you are in relation to visible landmarks the better.

  8. Jack
    Jack says:

    Would echo some of above comments re IFR lingo. My airport is a very busy non towered airport. On a beautiful VFR day, IFR rated pilots continue to announce their positions in IFR speak and 90% of the pilots approaching have no idea where they are. It is not a good idea.

  9. Chris
    Chris says:

    Thanks all! This article actually explains a ‘problem’ arose during an approach into KDCA that was on a Sporty’s flight video I viewed. On final, the twin was re-routed to runway 4 from 11-at the very last second! I suspect now that ATC gave clearance to the twin for 11, then ‘perhaps’ realized an IFR ATP behind it, had approached too fast and ultimately, re-routed the twin to 4 for safety’s sake. Yes? No? Sounds about correct, considering all the goings-on.

  10. Rolf Grandstaff
    Rolf Grandstaff says:

    This is very helpful and useful information and NOT something my CFIs ever even mentioned to me while I was learning to fly at a non towered airport years ago. I’ve since had 2 ‘close encounters’ with larger aircraft in the vicinity of a FAF before I finally figured it out on my own. It would be better to know this up front than have to learn it the hard way.

  11. Paul
    Paul says:

    Great article! I’m a student pilot and will be doing my check ride in about 2 weeks. Still wet behind the ears!

    I’ve often wondered about flying near or over our local (70 miles away) Class D airport and avoiding inbound commercial traffic. After talking to my instructor about it, he said that even though you may be passing close to or over the Class D airspace, with no legal requirement to talk to anyone, it would be a good idea to contact approach/tower and let them know you’re in the area and what your intentions are. Even though you’re not going to land at the Class D airport, they appreciate knowing you are in the area and can provide you with appropriate vectoring if needed.

    Thanks again for the article!


  12. Bill Rae
    Bill Rae says:

    I like your article very much. I have a question? What if the Class D airport with a tower, no radar, uses Opposite Direction Operations in a narrow valley, high terrain and you have IFR and VFR aircraft passing each other opposite directions 2 miles from the runnway. Arriving IFR aircraft are transitioned to VFR and accepting visual separation at a critical point during the landing sequence. VFR aircraft arriving or passing outside Class D don’t always communicate their position until just before entering. No cutoff points are used. Is this safe and why.

  13. Guido
    Guido says:

    Very good article, explains a lot to me.
    I too wish IFR practice would not say RNAV or GPS approach as I have no clue what either means at all airports. Finally figured them out at my field so I know where to look. Seems often to be just an excuse to make a straight in from miles out, which I like to do too. But I call it in as “10 miles south for straight in 36, traffic permitting” which seems to work…..

  14. Ed Conrad
    Ed Conrad says:

    Awesome artical ,well written and explained. Opens up conversation that can make the skys a safer place for all. Thank you for sharing your knowledge that is need by all that fly. I will never forget the words of my FAA Examiner in completing my private check ride. “ You now have a license to learn”

  15. John
    John says:

    I like Sarah and she always has good points as in most of this article, especially about the lack of maneuverability of the flying clouds.. However, I do take issue with two comments.
    First is the “They have paying passengers and are on a tight schedule. You don’t.” As a GA aircraft, I may have a paying passenger, or I may have to make an appointment. Sorry, but being big and a business doesn’t cut it for me and smacks of the “I’m important and you’re not.”
    The second is: “So, the cockpit is busy with button pushing and reading checklists. In other words, they probably aren’t focused outside.” I flew single seat fighter for 29 years and had to do it all by myself – pushing buttons and using checklists. My United Captain brother-in-law used to complain when his co-pilots weren’t up to snuff in doing things, to wit I said “what’s a co-pilot?” Oh, and most of the time I fly my little GA plane by myself. You have windows; look out them.

  16. Robert Alexander
    Robert Alexander says:

    Wow! This is great information to know and I will share with our flight school. I trained (and fly regularly) out of a Class D airport and think it would be great to know about this. I wonder why they don’t designate these areas similar to Class E Transition areas to help with separation for aircraft on instrument approaches? I am a new Private Pilot (less than 200 hours). Thanks for sharing this information. It will definitely become part of my flight planning and situational awareness.

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