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This is a speed restriction found on the BNGOS 3 RNAV Departure Procedure out of KOPF:

KOPF BNGOS 3 DP Speed Restriction

SPEED: ACCELERATE TO 250 KT, IF UNABLE, ADVISE ATC

Opa Locka airport is Class D and is also below the Miami Class B airspace, so 14 CFR 91.117(b) & (c) would apply and we would be limited to 200 KIAS.

My questions are:

  1. When should we accelerate to 250 KT? I.e does the DP speed restriction override the 91.117 restrictions, and if not, do we need to advise ATC?
  2. Are we expected to maintain 250 KT or is this considered a minimum speed (above 10,000 ft.)?

It seems like ATC wants us to accelerate asap (in fact, the old procedure used to say to accelerate “as rapidly as feasible” or something similar), but I don’t believe that we can until we either enter the Class B or leave the lateral limits.

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  • $\begingroup$ That's been a long time, good to see you visiting. Welcome back! $\endgroup$
    – DeltaLima
    Commented Feb 29 at 21:50
  • $\begingroup$ @DeltaLima Yes, it has! I’ve always lurked some and never really completely left, but life kept me too busy for too long, lol. $\endgroup$
    – Lnafziger
    Commented Mar 1 at 0:34
  • $\begingroup$ CFR 91.117 part b) allows ATC leeway. c) seems pretty airtight. But d) seems to allow some discretion, especially if ATC is informed. Class D requires two-way communication anyways. $\endgroup$ Commented Mar 1 at 1:02

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You should remain below 200 knots while under class B. Accelerate to 250 knots once you leave the lateral boundaries of class B or enter the class B, whichever comes first.

The 91.117(b) restriction includes the language "Unless otherwise authorized or required by ATC," but the 91.117(c) restriction does not. You may not accelerate above 200 knots below class B airspace, regardless of what ATC says.

91.117(d) always applies- if the aircraft you are flying can't climb safely at 200 knots then you should fly at your minimum safe climb airspeed.

Based on the wording, I wouldn't necessarily interpret this as a maximum speed. But of course you need to maintain 250 until above 10000 feet.

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  • $\begingroup$ Opa Locka is described on the website as a "reliever to Miami International Airport". This would indicate that, under local rules, it might share speed limits for jets. Both airports share the same departure frequency 119.45. It would be understandable that ATC would want the same speed for departing jets for safer spacing. $\endgroup$ Commented Mar 1 at 15:36
  • $\begingroup$ @RobertDiGiovanni It's understandable but the regulation is clear that ATC doesn't have authority to waive 91.117(c) speed limits. $\endgroup$
    – Chris
    Commented Mar 1 at 16:23
  • $\begingroup$ I agree. But d) may apply for a local situation, especially since Opa Locka is essentially a satellite of Miami Int. Sort of where business jets can avoid some of the congestion of the main hub. Worth looking into, but if ATC (and the plate) says 250 knots, what is one to do? (In controlled airspace). $\endgroup$ Commented Mar 1 at 18:21
  • $\begingroup$ @RobertDiGiovanni Same thing as if a controller told you to maintain 300 knots below 10000 or gave you VFR vectors into class B without a clearance. "Unable." I'm not really convinced that 250 is the "minimum safe airspeed" per 91.117(d), particularly since it just says to notify ATC if you can't accelerate to 250. $\endgroup$
    – Chris
    Commented Mar 1 at 20:45
  • $\begingroup$ Generally, one follows orders and then reports it, unless the craft is in danger. I wonder if anyone reported it already, and what the response was. $\endgroup$ Commented Mar 1 at 21:53

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