Narrative:

I am writing this report because I may or may not have violated far 135.219: 'IFR: destination airport WX minimums.' it is also my hope that if enough people write in, something might be done about the rather ambiguous wording of this far. The situation is involved with the go/no go decision before flight began. The to/no go decision required by far 135.219, which stated that 'no person may takeoff an aircraft under IFR or begin an IFR over the top unless the latest WX reports or forecasts, or any combination of them, indicate that the WX conditions at the estimated time of arrival at the next airport of intended landing will be at or above authority/authorized landing minimums.' because of the way this regulation is worded, this regulation can be interpreted in a # of ways. The WX at my destination was forecast to be 4000' overcast, 1 mi visibility in fog; ocl 200 overcast, 1/2 mi in fog--so if you relied strictly on the forecasts I could not depart. However I had 3 hours of reports for my destination reading as follows: first hour-1 1/2 mi in fog (I am omitting the ceilings because they are not controling). 2 specials were also issued in the first hour showing the visibility dropping to 3/4 and 1/2 mi, respectively. The second and third hours' reports showed the visibility holding at 1/2 mi. There are several different ways you can read 'or any combination of them.' since I was unsure, I looked in the aim and our company manual, but could find no guidance there. Next I talked to my dispatcher there. The dispatcher thought I could go and the capts available at that time were noncommittal. When the director of training walked in, I asked him. He thought that since I had 3 consecutive hours of reports that showed the WX holding at minimums, that I could go--so I did. Since I was still unsure about this regulation, I have continued to talk to my colleagues. I find that, after kicking this around for a few days, some feel I was legal to go and some feel I was not. At this point I am still not sure, so I write this in the hope that enough reports like this may someday generate a more clear regulation, or at least maybe a written explanation of this one.

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Original NASA ASRS Text

Title: PART 135 CAPT UNSURE OF INTERP OF FEDERAL AVIATION REG REGARDING DESTINATION WX MINIMUMS.

Narrative: I AM WRITING THIS RPT BECAUSE I MAY OR MAY NOT HAVE VIOLATED FAR 135.219: 'IFR: DEST ARPT WX MINIMUMS.' IT IS ALSO MY HOPE THAT IF ENOUGH PEOPLE WRITE IN, SOMETHING MIGHT BE DONE ABOUT THE RATHER AMBIGUOUS WORDING OF THIS FAR. THE SITUATION IS INVOLVED WITH THE GO/NO GO DECISION BEFORE FLT BEGAN. THE TO/NO GO DECISION REQUIRED BY FAR 135.219, WHICH STATED THAT 'NO PERSON MAY TKOF AN ACFT UNDER IFR OR BEGIN AN IFR OVER THE TOP UNLESS THE LATEST WX RPTS OR FORECASTS, OR ANY COMBINATION OF THEM, INDICATE THAT THE WX CONDITIONS AT THE ESTIMATED TIME OF ARR AT THE NEXT ARPT OF INTENDED LNDG WILL BE AT OR ABOVE AUTH LNDG MINIMUMS.' BECAUSE OF THE WAY THIS REG IS WORDED, THIS REG CAN BE INTERPRETED IN A # OF WAYS. THE WX AT MY DEST WAS FORECAST TO BE 4000' OVCST, 1 MI VISIBILITY IN FOG; OCL 200 OVCST, 1/2 MI IN FOG--SO IF YOU RELIED STRICTLY ON THE FORECASTS I COULD NOT DEPART. HOWEVER I HAD 3 HRS OF RPTS FOR MY DEST READING AS FOLLOWS: FIRST HR-1 1/2 MI IN FOG (I AM OMITTING THE CEILINGS BECAUSE THEY ARE NOT CTLING). 2 SPECIALS WERE ALSO ISSUED IN THE FIRST HR SHOWING THE VISIBILITY DROPPING TO 3/4 AND 1/2 MI, RESPECTIVELY. THE SECOND AND THIRD HRS' RPTS SHOWED THE VISIBILITY HOLDING AT 1/2 MI. THERE ARE SEVERAL DIFFERENT WAYS YOU CAN READ 'OR ANY COMBINATION OF THEM.' SINCE I WAS UNSURE, I LOOKED IN THE AIM AND OUR COMPANY MANUAL, BUT COULD FIND NO GUIDANCE THERE. NEXT I TALKED TO MY DISPATCHER THERE. THE DISPATCHER THOUGHT I COULD GO AND THE CAPTS AVAILABLE AT THAT TIME WERE NONCOMMITTAL. WHEN THE DIRECTOR OF TRNING WALKED IN, I ASKED HIM. HE THOUGHT THAT SINCE I HAD 3 CONSECUTIVE HRS OF RPTS THAT SHOWED THE WX HOLDING AT MINIMUMS, THAT I COULD GO--SO I DID. SINCE I WAS STILL UNSURE ABOUT THIS REG, I HAVE CONTINUED TO TALK TO MY COLLEAGUES. I FIND THAT, AFTER KICKING THIS AROUND FOR A FEW DAYS, SOME FEEL I WAS LEGAL TO GO AND SOME FEEL I WAS NOT. AT THIS POINT I AM STILL NOT SURE, SO I WRITE THIS IN THE HOPE THAT ENOUGH RPTS LIKE THIS MAY SOMEDAY GENERATE A MORE CLEAR REG, OR AT LEAST MAYBE A WRITTEN EXPLANATION OF THIS ONE.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.