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Takeoff minimums for part 91

Asked by: 2327 views General Aviation

"Aicraft operating under 14 CFR 91 are not required to comply with established takeoff minimums. Legally, a zero/zero departrue may be made, but it is never advisable. If commercial pilots who fly passengers on a daily basis must comply with takeoff minimums, then good judgment and common sense would tell all instrument pilots to floow the established minimums as well."

It's an excerpt from the Instrument Procedures Handbook. My question is: If it's the case that it's so dangerous for instrument pilots under part 91 to take off below the takeoff minimums required for part 121 and 135, why doesn't the FAA make a regulation about it and enforce it? Why do they legally permit part 91 pilots to depart under zero/zero conditions? It just doesn't make sense to me. Is there a good reason behind it?

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3 Answers



  1. Jim F. on Jan 26, 2017

    The ‘good reason’ IMO, is that we’re not in a dictatorship, so we as prudent individuals can make the decision for ourselves.

    In the airlines, I am approved for 600RVR departures. The way I see it, when you’re traveling at 100+ knots and factor in reaction time, even if you’re able to see a problem ahead, there’s not enough time to do a damn thing about it. My personal thought for pt.91 flights is that if 600RVR isn’t enough but legal, then why not 400? 200? 50? So for me, as long as the runway markings and lights are sufficient for me to maintain directional control, then I’m comfortable departing.

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  2. Lemontree on Jan 26, 2017

    I don’t know. If it’s not regulated because the FAA believes part 91 pilots would exercise their prudence for safe IFR departures, why they bother to make all those part 91 regulations in the first place? But I think your second explanation has a good point. The airplanes operated under part 91 are typically smaller and slower so the pilots mostly have a greater reaction time and thus don’t need as stricter minimums. Thank you for your answer.

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  3. Russ Roslewski on Jan 26, 2017

    As with many other regulations, the real reason it is the way it is, is because there has been neither the motivation nor the compelling reason to change it.

    The FAA, except in some “emergency”-type situations, doesn’t just make rules. They draft the rules. Those are then sent out for public comment via the Notice For Proposed Rulemaking process. There is some length of time for the public to submit comments. Then those comments are collected, combined, evaluated, and responded to. The rule is often changed based on the comments. Then there may be another review period, and eventually it becomes the final rule.

    In addition, the NPRM also often includes an analysis of the cost involved to implement, and the cost on the public to comply. Somebody has to figure those things out.

    Basically what I’m getting at is that changing a rule (or implementing a new one, like establishing Part 91 takeoff minimums) is a lengthy process that takes many man-hours and associated costs for the government. So, unless there’s a strong (often safety) reason to go down that road, there are other priorities which we as the taxpayers would rather the FAA spend its time and budget on (like 3rd class medical reform, to use a recent example).

    If airplanes start crashing all over the place due to the lack of visibility requirements, then you can bet it will get attention. But until then, there is no apparent need to do anything about it, and therefore no motivation to dedicate the resources to get it done.

    Further, I doubt a rule would make much difference. The pilot who recklessly takes off in 0/0 is likely not going to be stopped by a “200 – 1/2” requirement or something like that. Kind of a self-correcting problem.

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