Challenger 300
Flight Crew Air Transport Pilot (ATP)
Time Pressure; Communication Breakdown
ATC Issue All Types; Deviation / Discrepancy - Procedural FAR; Deviation / Discrepancy - Procedural Published Material / Policy
Air Traffic Control Issued Advisory / Alert; Flight Crew Requested ATC Assistance / Clarification
Procedure
Inbound to MDW; level at 4;000 feet ATC cleared us to intercept the localizer; and cleared us for the ILS 31C approach; maintain 210 knots until RUNTS. Knowing that on the glideslope we would descend to an altitude below Class B airspace prior to reaching RUNTS; Second In Command queried ATC 'so you are requiring us to maintain 210 knots below the Class Bravo airspace?' The immediate and terse answer was 'yes; maintain 210 knots' as instructed. A second voice came on the radio and said 'everyone on the frequency stand by'. We slowed to 200 knots prior to descending below 3;600 feet as required by FAR 91.117 (c). This has to stop! Unless there is an emergency; ATC cannot require us to violate this FAR. They are placing us in a very nasty position; where we are made to feel like criminals for obeying the law. Either change the Bravo airspace to include the Midway approaches; or change the ATC procedures! As a side note; the new controller did not say anything about our reduced speed; but I think I heard him start slowing other airplanes.
Crew of a Challenger 300 was cleared for ILS approach to 31C at MDW and to maintain 210 knots until RUNTS; a fix 6.7 miles from the localizer. The crew believed that flying the glideslope from their current position would require them to fly below the Class B airspace; which has a floor of 3600 feet in this area. Crew asked ATC about the clearance to violate the FAR restriction of airspeed below 200 knots below Class B airspace. ATC confirmed the 210-knot clearance; the crew elected to maintain 200 knots as required by FAR 91.117(c).