Narrative:

This report pertains to the 'VFR-to-IFR flights' section of the 7110.65; section 4-2-8.I was instructing a student in VFR conditions at ZZZ. Forecast overcast conditions were moving into the area; and our home base of ZZZ1 was reporting OVC010. I filed an IFR flight plan while at ZZZ; departed VFR; and requested an IFR clearance from D10 TRACON. The controller asked me if I could maintain my own terrain and obstruction clearance from my present altitude through 2;500 ft MSL. I accepted; noting that a large antenna complex with tops at 2;500 ft MSL was approximately 2 miles north. The controller advised me that upon reaching 2;500 to fly heading 250.when I reached 2;500; I flew heading 250. The controller then asked me if I could maintain my own terrain and obstruction clearance for 3 more miles. Because I was local to the area and was familiar with the relevant obstructions; I accepted; however; this is still a misuse of section 4-2-8 in the 7110.65. The 250 heading I was assigned was actually not sufficient to prevent the wind from drifting me into the antenna complex. As a result; when I accepted (for a second time) terrain and obstruction clearance; I made a left turn to about a 210 heading; which put me on a track that diverged from the antennas.had this procedure been applied to a non-local pilot; the controller would have essentially allowed a pilot to climb from VFR into IMC conditions near an antenna complex; with the false expectation that upon reaching the 2;500 ft altitude specified that he would no longer have responsibility for terrain and obstruction clearance. The problem is that by the time 2;500 ft was reached; we were much closer to the antenna complex than when we started the climb. Factoring in any delays in notifying a pilot that he needs to take back terrain and obstruction clearance responsibility when he is that close to the antennas; or any other factors; and this could cause a CFIT accident.the simple solution is to follow the procedures already in the 7110.65. When asking pilots who are requesting an IFR clearance to maintain terrain and obstruction clearance from our present altitude through X altitude; 'X' should be the minimum IFR altitude so that when we reach it; we know terrain and obstruction clearance responsibility goes back to and is retained by the controller. The idea that we can reach the altitude requested (in my case 2;500) and then be asked to again take back this responsibility; after flying an assigned heading no less; is not congruent with the procedures in the 7110.65 and is not addressed anywhere in the aim.if what I propose means I get vectored across the localizer for the ILS 34 at gky while climbing to the MVA/mia; then so be it. I'd rather be vectored across a localizer for a few miles than not be at a sufficient altitude and have a CFIT.

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Original NASA ASRS Text

Title: A C150 pilot reported a TRACON Controller improperly applied JO7110.65; 4-2-8(d); procedure. This misapplication caused aircraft to not be provided terrain and obstacle clearance.

Narrative: This report pertains to the 'VFR-to-IFR Flights' section of the 7110.65; Section 4-2-8.I was instructing a student in VFR conditions at ZZZ. Forecast overcast conditions were moving into the area; and our home base of ZZZ1 was reporting OVC010. I filed an IFR flight plan while at ZZZ; departed VFR; and requested an IFR clearance from D10 TRACON. The controller asked me if I could maintain my own terrain and obstruction clearance from my present altitude through 2;500 ft MSL. I accepted; noting that a large antenna complex with tops at 2;500 ft MSL was approximately 2 miles north. The controller advised me that upon reaching 2;500 to fly heading 250.When I reached 2;500; I flew heading 250. The controller then asked me if I could maintain my own terrain and obstruction clearance for 3 more miles. Because I was local to the area and was familiar with the relevant obstructions; I accepted; however; this is still a misuse of Section 4-2-8 in the 7110.65. The 250 heading I was assigned was actually not sufficient to prevent the wind from drifting me into the antenna complex. As a result; when I accepted (for a second time) terrain and obstruction clearance; I made a left turn to about a 210 heading; which put me on a track that diverged from the antennas.Had this procedure been applied to a non-local pilot; the controller would have essentially allowed a pilot to climb from VFR into IMC conditions near an antenna complex; with the false expectation that upon reaching the 2;500 ft altitude specified that he would no longer have responsibility for terrain and obstruction clearance. The problem is that by the time 2;500 ft was reached; we were much closer to the antenna complex than when we started the climb. Factoring in any delays in notifying a pilot that he needs to take back terrain and obstruction clearance responsibility when he is that close to the antennas; or any other factors; and this could cause a CFIT accident.The simple solution is to follow the procedures already in the 7110.65. When asking pilots who are requesting an IFR clearance to maintain terrain and obstruction clearance from our present altitude through X altitude; 'X' should be the minimum IFR altitude so that when we reach it; we know terrain and obstruction clearance responsibility goes back to and is retained by the controller. The idea that we can reach the altitude requested (in my case 2;500) and then be asked to again take back this responsibility; after flying an assigned heading no less; is not congruent with the procedures in the 7110.65 and is not addressed anywhere in the AIM.If what I propose means I get vectored across the localizer for the ILS 34 at GKY while climbing to the MVA/MIA; then so be it. I'd rather be vectored across a localizer for a few miles than not be at a sufficient altitude and have a CFIT.

Data retrieved from NASA's ASRS site and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.