According to FAR 91.205(e) there must be DME or RNAV system when a pilot uses VOR navigation above FL240. However, why does the regulation say we need it from FL240, not from FL180 where class A begins?


The consensus of internet wisdom seems to be that no one knows for sure, but the most likely explanation is that before class A existed there was Positive Control Airspace (PCA) that started at FL240, and DME was a requirement in PCA. The main reasons for requiring DME were:

  • There's a limited number of high-altitude VORs so it isn't easy to use cross-radials from other VORs for fixes or position reporting; DME is a simple alternative
  • If there's no radar coverage then ATC can still manage lateral separation effectively using DME

That all seems plausible enough, but some sources out there say that PCA started at FL180, not FL240, e.g. this FAA history document:

[VFR on top] was a principle [sic] factor in the [Grand Canyon] crash and led to "Positive Control Airspace" (PCA) FL180 and above. Because of the speeds of the aircraft involved, non-radar procedures were unwieldy (standards called for ten minutes between aircraft; some 80 miles for a typical jet), even with the development of aircraft installed Distance Measuring Equipment (DME) and the reduced separation available between DME equipped aircraft (20 miles).

FL240 is also where ATC starts using Mach numbers instead of knots (ATC orders section 5-7-1(f)) and the separation minima change (section 8-4-4). I don't know if that's for historical reasons or physical/operational reasons, but it looks to me like FL240 is considered the general starting point for high-altitude operations (14 CFR 61.31 requires a high-altitude endorsement for aircraft that can operate above 25,000' MSL).

  • 1
    $\begingroup$ I would add that in a non-radar environment, having the precision of DME would allow better position reporting over lower precision cross-radials; this would be especially important at the higher speeds of aircraft most likely to be at those higher altitudes. $\endgroup$
    – J Walters
    Jan 28 '16 at 22:46

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