Quote:
Originally Posted by Fox Xray 
The 7110.65 states that 250 below 10K does not apply to offshore A/C (more then 12nm). There was a post on this forum a while back where the poster had a link to a letter from a FAA procedures office saying that at no time can A/C break 250 below 10K regardless of 12nm offshore. As long as it is still in the 7110.65 I consider it legal. The international flight crews (foreign and domestic) all seem to know about this rule, they will routinely break 250 below 10K until they reach the 12nm area.
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Fox Xray,
I was the person who posted the link about the 250/10,000 beyond 12nm from shore. Actually it wasn't from an FAA procedures office, but an interpretation of the regs from the FAA Chief Counsel's office. I realize you are required to operate from the 7110.65, but that isn't regulation and a legal interpretation essentially is. This (the offshore thing) is not a big issue for me, but I believe everyone should be aware that they are responsible for complying with the regulations even if a controller clears them otherwise. To quote the 7110.65 for those who are not controllers,
"
NOTE-
Pilots are required to abide by CFRs or other applicable regulations regardless of the application of any procedure or minima in this order."
The confusing part for most people I believe, is that not only does the 7110.65 allow for this type of operations beyond the 12nm limit, but so does the AIM and the Instrument Procedures Handbook. According to the letter, the statements in these manuals/Orders are under review and will be changed or the reg will be changed.
gary