Large transport aircraft captain reported the speed published on the tecky three (RNAV) SID at waypo...

Attributes
ACN	1653458
Time
Date	201906
Place
Locale Reference	SJC.Airport
State Reference	CA
Aircraft 1
Make Model Name	Large Transport
Operating Under FAR Part	Part 121
Flight Phase	Climb
Route In Use	SID TECKY THREE RNAV
Flight Plan	IFR
Person 1
Function	Captain
Qualification	Flight Crew Air Transport Pilot (ATP) Flight Crew Instrument Flight Crew Multiengine
Experience	Flight Crew Last 90 Days 240 Flight Crew Total 19000 Flight Crew Type 2000
Events
Anomaly	Deviation - Procedural FAR Deviation - Procedural Published Material / Policy Deviation - Speed All Types

Narrative:

I fly a lot of sjc trips. On the tecky 3 departure; there is a speed restriction of maximum 230 KT at both stclr and mlpts. Both of these fixes are beneath the sfo class B airspace. Far 91.117(c) states: no person may operate an aircraft in the airspace underlying a class B airspace area designated for an airport or in a VFR corridor designated through such a class B airspace area; at an indicated airspeed of more than 200 knots (230 mph). I am confused as to why jeppesen publishes the speed restriction of maximum 230 KT at those two fixes. It seems like an invitation for crews to violate far 91.117(c). I think there should be some note in the sjc 10-7 or jeppesen and FAA should remove the speed restriction notes.

Original NASA ASRS Text

Title: Large Transport aircraft Captain reported the speed published on the TECKY THREE (RNAV) SID at waypoints STCLR and MLPTS beneath SFO Class B airspace is greater than 200 knots; thus violating FAR 91.117.

Narrative: I fly a lot of SJC trips. On the TECKY 3 Departure; there is a speed restriction of MAX 230 KT at both STCLR and MLPTS. Both of these fixes are beneath the SFO Class B airspace. FAR 91.117(c) states: No person may operate an aircraft in the airspace underlying a Class B airspace area designated for an airport or in a VFR corridor designated through such a Class B airspace area; at an indicated airspeed of more than 200 knots (230 mph). I am confused as to why Jeppesen publishes the speed restriction of MAX 230 KT at those two fixes. It seems like an invitation for crews to violate FAR 91.117(c). I think there should be some note in the SJC 10-7 or Jeppesen and FAA should remove the speed restriction notes.

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.

Large transport aircraft captain reported the speed published on the tecky three (RNAV) SID at waypoints stclr and mlpts beneath sfo class B airspace is greater than 200 knots; thus violating far 91.117.