While posting changes in my Jepp book last night, I came across the
following change to the AIM.

Kris

Old text

5-4-9. Procedure Turn
a. A procedure turn is the maneuver prescribed when it is necessary to
perform a course reversal to establish the aircraft inbound on an
intermediate or final approach course. The procedure turn or hold in lieu of
procedure turn is a required maneuver. The procedure turn is not required
when the symbol "No PT" is shown, when RADAR VECTORING to the final approach
course is provided, when conducting a timed approach, or when the procedure
turn is not authorized.

New text

5-4-9. Procedure Turn
a. A procedure turn is the maneuver prescribed to perform a course reversal
to establish the aircraft inbound on an intermediate or final approach
course. The procedure turn or hold in lieu of procedure turn is a required
maneuver

(the following text is underlined in the AIM)
when it is necessary to perform a course reversal.

The procedure turn is not required when the symbol "No PT" is shown, when
RADAR VECTORING to the final approach course is provided, when conducting a
timed approach, or when the procedure turn is not authorized.

Doesn't the underlining just mean that the text was added?

I guess the FAA is just stating the obvious: you don't need to do a PT
when you're already inbound.

rps wrote:
> Doesn't the underlining just mean that the text was added?
>
> I guess the FAA is just stating the obvious: you don't need to do a PT
> when you're already inbound.
>
That's not what they are saying at all. You could be inbound yet not
have arrived via a vector to final, a timed approach, or a NoPT route.

Usually, that would mean that you're too high to go straight-in, at
least by the standards used in TERPS for descent gradients.

This was discussed on the AOPA's board. The FAA did not intend to
change the meaning--it was supposed to be a clarification. The
procedure turn remains required even if your course happenes to be
aligned with the inbound course unless the symbol "No PT" is shown,
when RADAR VECTORING to the final approach course is provided, when
conducting a timed approach, or when the procedure turn is not
authorized.

I'd ask the controller for permission to proceed inbound sans procedure
turn if that's what I wanted to do.

> I'd ask the controller for permission to proceed inbound sans procedure
> turn if that's what I wanted to do.

The controller's permission doesn't absolve you of the requirement to follow the
FARs. You could ask for a vector.

150flivver wrote:
/snip/

> I'd ask the controller for permission to proceed inbound sans procedure
> turn if that's what I wanted to do.
>

Just because a controller lets you do something, doesn't make it legal
or safe.

Happy Flying!
Scott Skylane

"rps" > wrote in message
oups.com...
> Doesn't the underlining just mean that the text was added?
>
Jeppesen places a vertical line at the side of the page to indicate
changed/added text.
The text was moved, not added. It was italicized in the Jeppesen edition
and underlined in the FAA online version.
My guess is that it is underlined for emphasis.

Kris

I see a change here. The procedure turn is NOW required IF a course
reversal is necessary. If you are straight in, or nearly so, but NOT on
radar vectors there is no longer any regulatory requirement to do a
procedure turn. I have never seen sense operationally to do one if I am
straight in and at the right altitude. Actually to clear this up, I
think they need to clarify how many degrees off constitutes a "course
reversal". I for one disagreed with having to do a proc turn when I am
straight in, on altitude and ready to continue, and under those
circumstances never would do one anyway, based on the safety of the
flight. If you aren't under radar vectors it's pretty much always one
in or one out at the airport at time, so it's not a matter of timing
seperation, ATC gives you the full area of the approach PT or no, so
that has never been an issue.

I agree. The online AIM also indicates the underlined text. See
http://www.faa.gov/ATpubs/AIM/Chap5/aim0504.html#5-4-9:

"a. A procedure turn is the maneuver prescribed to perform a course
reversal to establish the aircraft inbound on an intermediate or final
approach course. The procedure turn or hold in lieu of procedure turn
is a required maneuver when it is necessary to perform a course
reversal."

Thus, if you're already inbound on the final course (assuming you're at
the altitude the procedure requires), no PT is required.

"Kris Kortokrax" > wrote in message
...
> New text
>
> 5-4-9. Procedure Turn
> a. A procedure turn is the maneuver prescribed to perform a course
> reversal to establish the aircraft inbound on an intermediate or final
> approach course. The procedure turn or hold in lieu of procedure turn is a
> required maneuver
>
> (the following text is underlined in the AIM)
> when it is necessary to perform a course reversal.
>
> The procedure turn is not required when the symbol "No PT" is shown, when
> RADAR VECTORING to the final approach course is provided, when conducting
> a timed approach, or when the procedure turn is not authorized.

The new text strikes me as entirely ambiguous. It could mean:

"The procedure turn is a required maneuver, unless one of the following
conditions obtains, in which case a course reversal is unnecessary: 1) the
symbol 'NoPT' is shown; 2) radar vectoring to the final approach course is
provided; 3) you are conducting a timed approach; or 4) the procedure turn
is not authorized."

Or it could mean:

"The procedure turn is a required maneuver, unless: 1) the symbol 'NoPT' is
shown; 2) radar vectoring to the final approach course is provided; 3) you
are conducting a timed approach; or 4) the procedure turn is not authorized;
or 5) there is (for any reason) no necessity to perform a course reversal."

The two interpretations differ if conditions 1-4 don't obtain, but the pilot
(and/or controller) thinks there's no need for a course reversal. The first
interpretation says the procedure turn is still required in that case; the
second one says the opposite.

--Gary

On 29 Sep 2005 09:20:51 -0700, "Doug" > wrote:

>I see a change here. The procedure turn is NOW required IF a course
>reversal is necessary. If you are straight in, or nearly so, but NOT on
>radar vectors there is no longer any regulatory requirement to do a
>procedure turn.

What regulation was changed?

It seems to me that only the AIM was changed; I'm not aware of any
regulatory changes.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"150flivver" > wrote in message
ups.com...
>
> This was discussed on the AOPA's board. The FAA did not intend to
> change the meaning--it was supposed to be a clarification. The
> procedure turn remains required even if your course happenes to be
> aligned with the inbound course unless the symbol "No PT" is shown,
> when RADAR VECTORING to the final approach course is provided, when
> conducting a timed approach, or when the procedure turn is not
> authorized.
>

What makes the procedure turn required?


>
> I'd ask the controller for permission to proceed inbound sans procedure
> turn if that's what I wanted to do.
>

What difference would that make? It's either required or it isn't, the
controller can't override the FARs.

"Dave Butler" > wrote in message
news:1128008552.97305@sj-nntpcache-3...
>
> The controller's permission doesn't absolve you of the requirement to
> follow the FARs.
>

What FAR states when a procedure turn is required?


>
> You could ask for a vector.
>

A vector to where? The FAC? Aren't you already on it?

Steven P. McNicoll wrote:
> "Dave Butler" > wrote in message
> news:1128008552.97305@sj-nntpcache-3...
>
>>The controller's permission doesn't absolve you of the requirement to
>>follow the FARs.
>>
>
>
> What FAR states when a procedure turn is required?

Point taken, Mr. Socrates.

>
>
>
>>You could ask for a vector.
>>
>
>
> A vector to where? The FAC? Aren't you already on it?

A vector to the FAC. The poster to whom I responded didn't say whether he was
aligned on the FAC. He just suggested that one could ask the controller's
permission to skip the PT. I suggested that one could instead ask for a VTF, so
that the condition for skipping the PT would be met.

"Gary Drescher" > wrote in message
...
> "Kris Kortokrax" > wrote in message
> ...
>> New text
>>
>> 5-4-9. Procedure Turn
>> a. A procedure turn is the maneuver prescribed to perform a course
>> reversal to establish the aircraft inbound on an intermediate or final
>> approach course. The procedure turn or hold in lieu of procedure turn is
>> a required maneuver
>>
>> (the following text is underlined in the AIM)
>> when it is necessary to perform a course reversal.
>>
>> The procedure turn is not required when the symbol "No PT" is shown, when
>> RADAR VECTORING to the final approach course is provided, when conducting
>> a timed approach, or when the procedure turn is not authorized.
>
> The new text strikes me as entirely ambiguous. It could mean:
>
> "The procedure turn is a required maneuver, unless one of the following
> conditions obtains, in which case a course reversal is unnecessary: 1) the
> symbol 'NoPT' is shown; 2) radar vectoring to the final approach course is
> provided; 3) you are conducting a timed approach; or 4) the procedure turn
> is not authorized."
>
> Or it could mean:
>
> "The procedure turn is a required maneuver, unless: 1) the symbol 'NoPT'
> is shown; 2) radar vectoring to the final approach course is provided; 3)
> you are conducting a timed approach; or 4) the procedure turn is not
> authorized; or 5) there is (for any reason) no necessity to perform a
> course reversal."
>
> The two interpretations differ if conditions 1-4 don't obtain, but the
> pilot (and/or controller) thinks there's no need for a course reversal.
> The first interpretation says the procedure turn is still required in that
> case; the second one says the opposite.

As a previous poster noted, they need to define how many degrees of turn
constitutes a "course reversal". Then it would clear and unambiguous.
Otherwise it is still is open to interpretation depending on the
aircraft/speed etc.

On 9/29/2005 15:09, S Narayan wrote:

> "Gary Drescher" > wrote in message
> ...
>> "Kris Kortokrax" > wrote in message
>> ...
>>> New text
>>>
>>> 5-4-9. Procedure Turn
>>> a. A procedure turn is the maneuver prescribed to perform a course
>>> reversal to establish the aircraft inbound on an intermediate or final
>>> approach course. The procedure turn or hold in lieu of procedure turn is
>>> a required maneuver
>>>
>>> (the following text is underlined in the AIM)
>>> when it is necessary to perform a course reversal.
>>>
>>> The procedure turn is not required when the symbol "No PT" is shown, when
>>> RADAR VECTORING to the final approach course is provided, when conducting
>>> a timed approach, or when the procedure turn is not authorized.
>>
>> The new text strikes me as entirely ambiguous. It could mean:
>>
>> "The procedure turn is a required maneuver, unless one of the following
>> conditions obtains, in which case a course reversal is unnecessary: 1) the
>> symbol 'NoPT' is shown; 2) radar vectoring to the final approach course is
>> provided; 3) you are conducting a timed approach; or 4) the procedure turn
>> is not authorized."
>>
>> Or it could mean:
>>
>> "The procedure turn is a required maneuver, unless: 1) the symbol 'NoPT'
>> is shown; 2) radar vectoring to the final approach course is provided; 3)
>> you are conducting a timed approach; or 4) the procedure turn is not
>> authorized; or 5) there is (for any reason) no necessity to perform a
>> course reversal."
>>
>> The two interpretations differ if conditions 1-4 don't obtain, but the
>> pilot (and/or controller) thinks there's no need for a course reversal.
>> The first interpretation says the procedure turn is still required in that
>> case; the second one says the opposite.
>
> As a previous poster noted, they need to define how many degrees of turn
> constitutes a "course reversal".

This is defined; in the TERPS. More than 30 degrees or more than 300'
and a procedure turn is needed (IIRC).

However, this just gives the procedure designer what they need to design
the procedures. The pilot needs to use the published procedure.


> Then it would clear and unambiguous.
> Otherwise it is still is open to interpretation depending on the
> aircraft/speed etc.
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

"Dave Butler" > wrote in message
news:1128028113.655391@sj-nntpcache-3...
>
> A vector to the FAC. The poster to whom I responded didn't say whether he
> was aligned on the FAC. He just suggested that one could ask the
> controller's permission to skip the PT. I suggested that one could instead
> ask for a VTF, so that the condition for skipping the PT would be met.
>

The previous poster wrote, "the procedure turn remains required even if your
course happenes to be aligned with the inbound course..." That sounds to me
like he's already on the FAC. If he wasn't already on it, and if a vector
to it was an option, it'd probably be issued without his asking for it.

I'm a brand new instrument pilot, but I read this kind of thing for a
living, so my opinion may not be realistic, just legalistic, but here goes:

A procedure turn is the maneuver prescribed when it is necessary to
perform a course reversal to establish the aircraft inbound on an
intermediate or final approach course

means that if you need to perform a course reversal, you need to do a PT.
Otherwise, you don't. The following language:

The procedure turn is not required when the symbol "No PT" is shown,
when RADAR VECTORING to the final approach course is provided, when
conducting a timed approach, or when the procedure turn is not
authorized.

lists some exceptions, but doesn't change the first requirement which means
that even if you need to do a course reversal, you don't have to do a PT if
one of these exceptions applies.It doesn't mean that you need to do a PT
unless one of the exceptions applies, the original definition still applies,
no course reversal, no PT. I didn't look up the definition of course
reversal.

This makes sense to me at least in the following case, if you are inbound
from the opposite direction, and receiving radar vectors, you would normally
need to do a course reversal, so a PT would be required, but ATC will vector
you around to the final approach course usually sort of rectangularly. Since
this is a listed exception, you don't need to do a PT. If you weren't
getting vectors, or one of the other exceptions didn't apply, then a PT
would be required.

If you are inbound on a course that doesn't require a course reversal, no PT
is required even if none of the exceptions applies.

Brad




> wrote in message
nk.net...
> rps wrote:
> > Doesn't the underlining just mean that the text was added?
> >
> > I guess the FAA is just stating the obvious: you don't need to do a PT
> > when you're already inbound.
> >
> That's not what they are saying at all. You could be inbound yet not
> have arrived via a vector to final, a timed approach, or a NoPT route.
>
> Usually, that would mean that you're too high to go straight-in, at
> least by the standards used in TERPS for descent gradients.

"S Narayan" > wrote in message
news:1128031835.1bb41b72ab7f6a781ad35e5e7380cc8f@t eranews...
>
> "Gary Drescher" > wrote in message
> ...
>> "Kris Kortokrax" > wrote in message
>> ...
>>> New text
>>>
>>> 5-4-9. Procedure Turn
>>> a. A procedure turn is the maneuver prescribed to perform a course
>>> reversal to establish the aircraft inbound on an intermediate or final
>>> approach course. The procedure turn or hold in lieu of procedure turn is
>>> a required maneuver
>>>
>>> (the following text is underlined in the AIM)
>>> when it is necessary to perform a course reversal.
>>>
>>> The procedure turn is not required when the symbol "No PT" is shown,
>>> when RADAR VECTORING to the final approach course is provided, when
>>> conducting a timed approach, or when the procedure turn is not
>>> authorized.
>>
>> The new text strikes me as entirely ambiguous. It could mean:
>>
>> "The procedure turn is a required maneuver, unless one of the following
>> conditions obtains, in which case a course reversal is unnecessary: 1)
>> the symbol 'NoPT' is shown; 2) radar vectoring to the final approach
>> course is provided; 3) you are conducting a timed approach; or 4) the
>> procedure turn is not authorized."
>>
>> Or it could mean:
>>
>> "The procedure turn is a required maneuver, unless: 1) the symbol 'NoPT'
>> is shown; 2) radar vectoring to the final approach course is provided; 3)
>> you are conducting a timed approach; or 4) the procedure turn is not
>> authorized; or 5) there is (for any reason) no necessity to perform a
>> course reversal."
>>
>> The two interpretations differ if conditions 1-4 don't obtain, but the
>> pilot (and/or controller) thinks there's no need for a course reversal.
>> The first interpretation says the procedure turn is still required in
>> that case; the second one says the opposite.
>
> As a previous poster noted, they need to define how many degrees of turn
> constitutes a "course reversal". Then it would clear and unambiguous.
> Otherwise it is still is open to interpretation depending on the
> aircraft/speed etc.

No, the ambiguity I'm pointing out isn't just a matter of the vagueness of
"course reversal". The new AIM phrasing is ambiguous as to whether the
enumerated conditions are meant only as an *elaboration* of what it means
for a course reversal to be unnecessary (in which case a charted PT is
required unless the enumerated conditions are met), or whether a lack of
need for a course-reversal is meant as an *addition* to the enumerated
conditions (in which case the PT might not be required even if none of the
enumerated conditions are met).

A secondary point (mentioned earlier in the thread) is that the TERPS
standards can require a PT on the basis of altitude, even if you're already
aligned with the final approach course. Moreover, it would make little sense
for the AIM to recapitulate the TERPS criteria for PTs in order to specify
the required action by pilots. Instead, the procedure chart itself should be
designed according to the TERPS criteria, and should specify a PT
requirement (by omitting the 'NoPT' designation) whenever those criteria are
met. The first interpretation above would be consistent with that intent.

--Gary

On Fri, 30 Sep 2005 08:08:45 GMT, "Brad Salai" >
wrote:

>If you are inbound on a course that doesn't require a course reversal, no PT
>is required even if none of the exceptions applies.

I think what you are missing is that the determination as to whether or not
a course reversal is required has to do with the verbiage on the FAA forms
that define the SIAP (standard instrument approach procedure) and not on
what you as the pilot might determine at the time you are executing the
approach.

The FAA forms (8260 series) are (mostly) based on TERPs and those
approaches are incorporated by reference into 14 CFR 97.20(b), making the
procedures regulatory (refer back to 14 CFR 91.175(a)).


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On 9/30/2005 01:33, Peter wrote:

> Mark Hansen > wrote:
>
>>This is defined; in the TERPS. More than 30 degrees or more than 300'
>>and a procedure turn is needed (IIRC).
>
> I must be going thick, but how do I do a procedure turn to turn
> through just 30 degrees? Surely it is just a rate one turn?

What's a 'rate one turn'?

What I've read was that when the turn to the final approach course is
more than 30 degrees, the procedure designers want you to turn outbound
first, to give you a chance to get established on the final approach
course before the FAF.



--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

Suppose I'm on an approach in which the IAP leads me to the inbound
course at the correct altitude (no radar), am I supposed to execute a
PT? That doesn't make sense to me. ATC would not have authorized
anyone else to be in that airspace so aircraft separation isn't a
problem and there is no need to lose altitude or change course so
obstacle clearance shouldn't be an issue.

Maybe there are no such approaches, or perhaps all such courses are
marked NoPT.

"rps" > wrote in message
oups.com...
>
> Suppose I'm on an approach in which the IAP leads me to the inbound
> course at the correct altitude (no radar), am I supposed to execute a
> PT? That doesn't make sense to me. ATC would not have authorized
> anyone else to be in that airspace so aircraft separation isn't a
> problem and there is no need to lose altitude or change course so
> obstacle clearance shouldn't be an issue.
>
> Maybe there are no such approaches, or perhaps all such courses are
> marked NoPT.
>

I believe you just answered your question.

"Steven P. McNicoll" > wrote in message
nk.net...
>
> "rps" > wrote in message
> oups.com...
>>
>> Suppose I'm on an approach in which the IAP leads me to the inbound
>> course at the correct altitude (no radar), am I supposed to execute a
>> PT? That doesn't make sense to me. ATC would not have authorized
>> anyone else to be in that airspace so aircraft separation isn't a
>> problem and there is no need to lose altitude or change course so
>> obstacle clearance shouldn't be an issue.
>>
>> Maybe there are no such approaches, or perhaps all such courses are
>> marked NoPT.
>>
>
> I believe you just answered your question.

Even if the intention is to mark all such courses NoPT, there's always the
possibility that a NoPT gets omitted due to a charting error or a TERPS
design error. And the question arises in that case: is the PT required or
not? On one reasonable interpretation of the AIM's new wording, it's still
required; on the other reasonable interpretation, it's not.

--Gary

"Gary Drescher" > wrote in message
...
>
> Even if the intention is to mark all such courses NoPT, there's always the
> possibility that a NoPT gets omitted due to a charting error or a TERPS
> design error. And the question arises in that case: is the PT required or
> not?
>

Not.


>
> On one reasonable interpretation of the AIM's new wording, it's still
> required; on the other reasonable interpretation, it's not.
>

If it's required the requirement will be found in the FARs, and you will
find no FAR that requires it. The AIM is not regulatory.

In article t>,
Steven P. McNicoll > wrote:
>
>"rps" > wrote in message
oups.com...
>>
>> Suppose I'm on an approach in which the IAP leads me to the inbound
>> course at the correct altitude (no radar), am I supposed to execute a
>> PT? That doesn't make sense to me. ATC would not have authorized
>> anyone else to be in that airspace so aircraft separation isn't a
>> problem and there is no need to lose altitude or change course so
>> obstacle clearance shouldn't be an issue.
>>
>> Maybe there are no such approaches, or perhaps all such courses are
>> marked NoPT.
>>
>
>I believe you just answered your question.

The problem is not when you're on a published route which happens to
be properly aligned with the FAC and have a low enough altitude that
descent gradient is not a problem. Those are all already taken care
of by having NoPT on the plate.

The problem comes in when you're on a random route such as direct to
the IAF/FAF. You can be between two airways converging on the IAF,
both of which are marked NoPT (and at the same altitude marked for
those routes), and yet you're not on a NoPT segment yourself. I think
most people would agree that it's reasonable to assume that not doing
a PT in this case is perfectly safe. The question which leads to
endless debate is whether it's legal or not.

"Steven P. McNicoll" > wrote in message
ink.net...
>
> "Gary Drescher" > wrote in message
> ...
>>
>> Even if the intention is to mark all such courses NoPT, there's always
>> the possibility that a NoPT gets omitted due to a charting error or a
>> TERPS design error. And the question arises in that case: is the PT
>> required or not?
>>
>
> Not.
>>
>> On one reasonable interpretation of the AIM's new wording, it's still
>> required; on the other reasonable interpretation, it's not.
>>
>
> If it's required the requirement will be found in the FARs, and you will
> find no FAR that requires it.

You'll find no FAR that explicitly requires performing a charted PT
*regardless* of whether or not the PT meets the TERPS criteria. That doesn't
make all the PTs optional, does it?

> The AIM is not regulatory.

No, but in some cases it offers the only readily available definitive FAA
interpretation of key regulations. That's what it's trying to do in this
case, but the chosen wording is unfortunately ambiguous.

--Gary

On Fri, 30 Sep 2005 11:55:25 -0400, "Gary Drescher"
> wrote:

>You'll find no FAR that explicitly requires performing a charted PT
>*regardless* of whether or not the PT meets the TERPS criteria. That doesn't
>make all the PTs optional, does it?

If the approach plates constitute an appropriate display of the contents of
FAA forms 8260, and if they indicate that the PT is mandatory, then that
*IS* an FAR (incorporated by reference into 14 CFR 97)




Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
>
> If the approach plates constitute an appropriate display of the contents
> of
> FAA forms 8260, and if they indicate that the PT is mandatory, then that
> *IS* an FAR (incorporated by reference into 14 CFR 97)
>

Can you provide an example of an approach plate with the statement "PT
MANDATORY", or something similar?

Gary Drescher wrote:
> "Steven P. McNicoll" > wrote in message
> nk.net...
>
>>"rps" > wrote in message
oups.com...
>>
>>>Suppose I'm on an approach in which the IAP leads me to the inbound
>>>course at the correct altitude (no radar), am I supposed to execute a
>>>PT? That doesn't make sense to me. ATC would not have authorized
>>>anyone else to be in that airspace so aircraft separation isn't a
>>>problem and there is no need to lose altitude or change course so
>>>obstacle clearance shouldn't be an issue.
>>>
>>>Maybe there are no such approaches, or perhaps all such courses are
>>>marked NoPT.
>>>
>>
>>I believe you just answered your question.
>
>
> Even if the intention is to mark all such courses NoPT, there's always the
> possibility that a NoPT gets omitted due to a charting error or a TERPS
> design error. And the question arises in that case: is the PT required or
> not? On one reasonable interpretation of the AIM's new wording, it's still
> required; on the other reasonable interpretation, it's not.
>
> --Gary
>
>
The new AIM verbage is in error. The coordination was messed up, so
someone with a less than global view of it did some incorrect editing.
Following is part of an email sent yesterday by the person in the FAA
who understands this stuff and whose office should have issued any
change (no change was necessary, actually):

"We need to get AIM paragraph 5-4-9a fixed and clarify this in the IPG!
This is how the flying public is interpreting this and as you know, this
isn't the first time this has come up. The way it is written: 'The
procedure turn or hold in lieu of procedure turn is a required maneuver
when it is necessary to perform a course reversal' is way to open-ended
and leaves it up to the pilot to make this decision and the controller
to guess (or be surprised) what the pilot is doing."

Steven P. McNicoll wrote:

> "Ron Rosenfeld" > wrote in message
> ...
>
>>If the approach plates constitute an appropriate display of the contents
>>of
>>FAA forms 8260, and if they indicate that the PT is mandatory, then that
>>*IS* an FAR (incorporated by reference into 14 CFR 97)
>>
>
>
> Can you provide an example of an approach plate with the statement "PT
> MANDATORY", or something similar?
>
>
There is no provision for such wording because terminal routes that do
not have "NoPT" affixed to them on the 14 CFR 97 Form 8260-3/5 are, by
implication "PT Required" except when timed approaches are used or ATC
provides vectors in accordance with 7110.65, Para 5-9-1.

As you know the word "MANDATORY" on Part 97 procedures is used when
altitudes are not "at or above."

And, where a 8260-3/5 does not have a course reversal authorized on the
procedure, then all terminal routes, by implication, are "NoPT." In
that case, NACO charts "PT Not Authorized;" Jeppesen does not because
they feel it is obvious on such a procedure.

> wrote in message
nk.net...
> Gary Drescher wrote:
>> Even if the intention is to mark all such courses NoPT, there's always
>> the possibility that a NoPT gets omitted due to a charting error or a
>> TERPS design error. And the question arises in that case: is the PT
>> required or not? On one reasonable interpretation of the AIM's new
>> wording, it's still required; on the other reasonable interpretation,
>> it's not.
>>
> The new AIM verbage is in error. The coordination was messed up, so
> someone with a less than global view of it did some incorrect editing.
> Following is part of an email sent yesterday by the person in the FAA who
> understands this stuff and whose office should have issued any change (no
> change was necessary, actually):
>
> "We need to get AIM paragraph 5-4-9a fixed and clarify this in the IPG!
> This is how the flying public is interpreting this and as you know, this
> isn't the first time this has come up. The way it is written: 'The
> procedure turn or hold in lieu of procedure turn is a required maneuver
> when it is necessary to perform a course reversal' is way to open-ended
> and leaves it up to the pilot to make this decision and the controller to
> guess (or be surprised) what the pilot is doing."

Thanks for posting that! It's good to know that someone at the FAA
understands the problem and intends to fix it. (I emailed the FAA yesterday
about the AIM ambiguity, but I haven't gotten any reply yet.)

--Gary

On Fri, 30 Sep 2005 16:31:50 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> If the approach plates constitute an appropriate display of the contents
>> of
>> FAA forms 8260, and if they indicate that the PT is mandatory, then that
>> *IS* an FAR (incorporated by reference into 14 CFR 97)
>>
>
>Can you provide an example of an approach plate with the statement "PT
>MANDATORY", or something similar?
>

That phrase, to the best of my knowledge, appears on neither Jepp nor NACO
charts. However, that is not how Jepp indicates that a PT is mandatory on
their charts. (I'm not as familiar with NACO charts).

According to the Jepp charting conventions, if the PT is charted, and if
one of the previously discussed exceptions don't apply, then it is
required.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On 9/30/2005 14:26, Peter wrote:

> Mark Hansen > wrote
>
>>> I must be going thick, but how do I do a procedure turn to turn
>>> through just 30 degrees? Surely it is just a rate one turn?
>>
>>What's a 'rate one turn'?
>
> In the UK, it is the standard turn as indicated on the TC.
>
>>What I've read was that when the turn to the final approach course is
>>more than 30 degrees, the procedure designers want you to turn outbound
>>first, to give you a chance to get established on the final approach
>>course before the FAF.
>
> OK, thanks, I see that for the FAF.
>
> It also illuminates something else: if tracking towards an NDB or a
> VOR, which is part of an instrument approach, at which there is a
> significant track change, I've been told to do a procedure turn. The
> instructor could not quantify it. In this case the turn is necessary
> because one assumes there is no DME at the waypoint, so one has to
> track *over* the beacon.
>

More importantly, I was told that it is assumed you are on course
and ready for the approach when you cross the FAF. Even if you could
anticipate the turn using DME, you still would not be 'on course
and ready for the approach when crossing the FAF' ... it would happen
some time later (after you got your airplane established on the
final approach course).

Now ... I'm not saying that such a turn couldn't be made and the
approach safely flown - only that I was told this is the reason for
having the PT in the procedure for these cases.


--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

"Ron Rosenfeld" > wrote in message
...
>
> That phrase, to the best of my knowledge, appears on neither Jepp nor NACO
> charts. However, that is not how Jepp indicates that a PT is mandatory on
> their charts. (I'm not as familiar with NACO charts).
>
> According to the Jepp charting conventions, if the PT is charted, and if
> one of the previously discussed exceptions don't apply, then it is
> required.
>

The FAA does it the other way round.

Are you saying that if the form (approach plate?) says no PT, then no PT is
required, which I understand and agree with, or are you saying that if the
form is silent, then a PT is required in all cases, which I'm less sure of?

I looked at random at a bunch of NOCA forms, and there are lots of instances
of approaches from IAF's that clearly say no PT. These seem all to be
situations where I would say (based on pilot judgment) that a course
reversal is not required. There are also lots of examples, most, or all on
courses outbound on the final approach heading, that show a PT barb, which I
take as indicating that a PT is mandatory. on the new GPS approaches where
the heading into the fix is 90 degrees, there are indications that no PT is
required, other than that, I couldn't find any indication in ambiguous
situations (90 degrees or more), of whether a PT is required or not. It
looks to me as if, other than the pretty clear case where you are outbound
on the final approach heading, that they never indicate when a PT is
required, only when it is not. That means, I think, that you are going to
have to determine whether "a course reversal is required," to know whether
you need to make a PT.

Is there a definition somewhere of what a course reversal is, or even
better, when a course reversal is required?

If you happen to have it, or can get it, look at the VOR RWY 13 approach to
ACY (Atlantic City). A holding pattern is depicted at the IAF, but there is
no guidance as to when it should be used. Doesn't that mean that the pilot
needs to determine based on his heading into the IAF whether a course
reversal is required, and if it is, then he has to do a PT, either a
conventional PT, or a course reversal by way of the depicted hold? Or are
you saying that you need to enter the hold from all directions, go around at
least once, and then continue in, in which case, isn't the "when a course
reversal is required" language redundant?

Brad
"Ron Rosenfeld" > wrote in message
...
> On Fri, 30 Sep 2005 08:08:45 GMT, "Brad Salai" >
> wrote:
>
> >If you are inbound on a course that doesn't require a course reversal, no
PT
> >is required even if none of the exceptions applies.
>
> I think what you are missing is that the determination as to whether or
not
> a course reversal is required has to do with the verbiage on the FAA forms
> that define the SIAP (standard instrument approach procedure) and not on
> what you as the pilot might determine at the time you are executing the
> approach.
>
> The FAA forms (8260 series) are (mostly) based on TERPs and those
> approaches are incorporated by reference into 14 CFR 97.20(b), making the
> procedures regulatory (refer back to 14 CFR 91.175(a)).
>
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Gary Drescher" > wrote in message
...

>
> No, the ambiguity I'm pointing out isn't just a matter of the vagueness of
> "course reversal". The new AIM phrasing is ambiguous as to whether the
> enumerated conditions are meant only as an *elaboration* of what it means
> for a course reversal to be unnecessary (in which case a charted PT is
> required unless the enumerated conditions are met), or whether a lack of
> need for a course-reversal is meant as an *addition* to the enumerated
> conditions (in which case the PT might not be required even if none of
the
> enumerated conditions are met).
>
I think its the second case. Here is the language again:

The procedure turn or hold in lieu of procedure turn is a required
maneuver when it is necessary to perform a course reversal.
The procedure turn is not required when the symbol "No PT" is shown, when
RADAR VECTORING to the final approach course is provided, when
conducting a timed approach, or when the procedure turn is not
authorized.

The first sentence doesn't make any sense unless there are situations where
"it is necessary to perform a course reversal." If that's true, then the
second sentence must be exceptions to the first, that is, situations where
it would appear "necessary to perform a course reversal" but a PT is not
required.

If the intent were that a PT is required unless one of the four exceptions
applied, they would (or at least should) have said:

The procedure turn or hold in lieu of procedure turn is a required
maneuver unless the symbol "No PT" is shown, when
RADAR VECTORING to the final approach course is provided, when
conducting a timed approach, or when the procedure turn is not
authorized.

which would have been clear and unambiguous. General rules of construction
suggest that you should interpret the language so that the first sentence is
not redundant or meaningless, which leads to the second interpretation, what
G. Drescher calls *addition*. Maybe the rules of construction should be in
the POH?

Just my opinion, I could be wrong.

On Sat, 01 Oct 2005 03:59:14 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> That phrase, to the best of my knowledge, appears on neither Jepp nor NACO
>> charts. However, that is not how Jepp indicates that a PT is mandatory on
>> their charts. (I'm not as familiar with NACO charts).
>>
>> According to the Jepp charting conventions, if the PT is charted, and if
>> one of the previously discussed exceptions don't apply, then it is
>> required.
>>
>
>The FAA does it the other way round.
>

Could you expand on that statement? I'm not able to apply it to my
description of the Jepp charting conventions.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Sat, 01 Oct 2005 07:58:13 GMT, "Brad Salai" >
wrote:

>Are you saying that if the form (approach plate?) says no PT, then no PT is
>required, which I understand and agree with, or are you saying that if the
>form is silent, then a PT is required in all cases, which I'm less sure of?
>

I should only speak with regard to Jepp charting conventions as those are
the approach plates I use.

If a route or segment states NoPT, then no procedure turn is required OR
authorized. If you want to do a procedure turn, you must obtain ATC
permission.

If a procedure turn is charted, then it is required unless one of the
previously discussed exceptions apply (e.g. NoPT; vectors to final; timed
approaches).

If a procedure turn is NOT charted, then it is NOT authorized.



>I looked at random at a bunch of NOCA forms, and there are lots of instances
>of approaches from IAF's that clearly say no PT. These seem all to be
>situations where I would say (based on pilot judgment) that a course
>reversal is not required. There are also lots of examples, most, or all on
>courses outbound on the final approach heading, that show a PT barb, which I
>take as indicating that a PT is mandatory. on the new GPS approaches where
>the heading into the fix is 90 degrees, there are indications that no PT is
>required, other than that, I couldn't find any indication in ambiguous
>situations (90 degrees or more), of whether a PT is required or not. It
>looks to me as if, other than the pretty clear case where you are outbound
>on the final approach heading, that they never indicate when a PT is
>required, only when it is not. That means, I think, that you are going to
>have to determine whether "a course reversal is required," to know whether
>you need to make a PT.

I believe the determination of "course reversal required" is to be made by
the procedure designer, and not the pilot.


>
>Is there a definition somewhere of what a course reversal is, or even
>better, when a course reversal is required?

TERPS (I think it's 8260.3 and 8260.19 or something like that)

>
>If you happen to have it, or can get it, look at the VOR RWY 13 approach to
>ACY (Atlantic City). A holding pattern is depicted at the IAF, but there is
>no guidance as to when it should be used. Doesn't that mean that the pilot
>needs to determine based on his heading into the IAF whether a course
>reversal is required, and if it is, then he has to do a PT, either a
>conventional PT, or a course reversal by way of the depicted hold? Or are
>you saying that you need to enter the hold from all directions, go around at
>least once, and then continue in, in which case, isn't the "when a course
>reversal is required" language redundant?

Since the racetrack pattern is charted, the procedure turn must be flown as
charted (e.g. the type of turn and where to start it, in this instance, is
NOT pilot choice). Again, according to Jepp charting conventions, this PT
would have to be flown unless you were on radar vectors to the final
approach course (or if there were timed approaches going on). I'm not
familiar with that area, or how ATC works there, but I would expect that
radar coverage would be pretty good there and, unless there's some traffic
related reason off to the NW and not on the approach chart, that you would
be getting radar vectors to final if you were approaching from the NW (or
maybe even from other directions).

And there may be TERP's related reasons for that required course reversal,
also. The only charted course to the IAF is from ACY VOR with an MEA of
1900'; the MSA for that sector is 2100'. If you were to cross BURDK at
either of those altitudes, in order to execute a straight-in approach, you
would exceed the maximum TERPS allowed descent gradient of 400 ft/nm for a
straight-in approach. (1900-75)/4.5 = 405.6 ft/nm. So, the procedure
designer determined that a course reversal was required in order to publish
straight-in minimums.

I don't know what the MEA would be for a course from the NW because there's
nothing charted in that area. It would be no higher than 2100' (the MSA),
which doesn't help in this regard, though.

There used to be an approach into KLEB from the NW (I think the feeder was
from MPV). Even though the approach track appeared to be almost straight
in, a PT was charted, and required at the IAF (which was also the FAF for
the LOC). On the Jepp charts, it was apparent only because the feeder from
MPV was NOT marked NoPT. There were any number of pilots who decided to go
straight-in. But the reasons, which were not apparent to a cursory look at
the chart, had to do with exceeding allowable descent rates. This approach
was changed (I think they changed the feeder route course slightly and
lowered the MEA) and no longer has the required PT (the feeder route is now
marked NoPT).

In other instances, the lack of a NoPT notation where it seems as if it
should be there, on a particular course, may be an error, either on the
original FAA documentation, or on the NACO or Jepp chart. A call to the
chart maker usually resolves the problem fairly quickly, in those cases.

--Ron


>
>Brad
>"Ron Rosenfeld" > wrote in message
...
>> On Fri, 30 Sep 2005 08:08:45 GMT, "Brad Salai" >
>> wrote:
>>
>> >If you are inbound on a course that doesn't require a course reversal, no
>PT
>> >is required even if none of the exceptions applies.
>>
>> I think what you are missing is that the determination as to whether or
>not
>> a course reversal is required has to do with the verbiage on the FAA forms
>> that define the SIAP (standard instrument approach procedure) and not on
>> what you as the pilot might determine at the time you are executing the
>> approach.
>>
>> The FAA forms (8260 series) are (mostly) based on TERPs and those
>> approaches are incorporated by reference into 14 CFR 97.20(b), making the
>> procedures regulatory (refer back to 14 CFR 91.175(a)).
>>
>>
>> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
>

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Sat, 01 Oct 2005 08:21:52 GMT, "Brad Salai" >
wrote:


>
>If the intent were that a PT is required unless one of the four exceptions
>applied, they would (or at least should) have said:
>
> The procedure turn or hold in lieu of procedure turn is a required
> maneuver unless the symbol "No PT" is shown, when
> RADAR VECTORING to the final approach course is provided, when
> conducting a timed approach, or when the procedure turn is not
>authorized.
>
>which would have been clear and unambiguous. General rules of construction
>suggest that you should interpret the language so that the first sentence is
>not redundant or meaningless, which leads to the second interpretation, what
>G. Drescher calls *addition*. Maybe the rules of construction should be in
>the POH?
>
>Just my opinion, I could be wrong.
>
>

That's basically how Jepp defines it for their approach charts.

"It (the procedure turn) is a required maneuver, except under the following
conditions:
1. The symbol “NoPT” is shown.
2. Radar vectoring is provided.
3. A one-minute holding pattern is published in lieu of a procedure turn.
4. A teardrop course reversal is depicted.
5. The procedure turn is not authorized. "

The one-minute holding pattern and teardrop course reversal are also
mandatory in the same sense; Jepp means that you can't do a PT turn of the
type and starting point you wish if one of those is charted.

Also, Jepp's convention for the procedure turn not being authorized is that
they don't chart it.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
> On Sat, 01 Oct 2005 07:58:13 GMT, "Brad Salai" >
> wrote:
>
> >Are you saying that if the form (approach plate?) says no PT, then no PT
is
> >required, which I understand and agree with, or are you saying that if
the
> >form is silent, then a PT is required in all cases, which I'm less sure
of?
> >
>
> I should only speak with regard to Jepp charting conventions as those are
> the approach plates I use.
>
> If a route or segment states NoPT, then no procedure turn is required OR
> authorized. If you want to do a procedure turn, you must obtain ATC
> permission.
>
> If a procedure turn is charted, then it is required unless one of the
> previously discussed exceptions apply (e.g. NoPT; vectors to final; timed
> approaches).
>
> If a procedure turn is NOT charted, then it is NOT authorized.
>
>
>
> >I looked at random at a bunch of NOCA forms, and there are lots of
instances
> >of approaches from IAF's that clearly say no PT. These seem all to be
> >situations where I would say (based on pilot judgment) that a course
> >reversal is not required. There are also lots of examples, most, or all
on
> >courses outbound on the final approach heading, that show a PT barb,
which I
> >take as indicating that a PT is mandatory. on the new GPS approaches
where
> >the heading into the fix is 90 degrees, there are indications that no PT
is
> >required, other than that, I couldn't find any indication in ambiguous
> >situations (90 degrees or more), of whether a PT is required or not. It
> >looks to me as if, other than the pretty clear case where you are
outbound
> >on the final approach heading, that they never indicate when a PT is
> >required, only when it is not. That means, I think, that you are going to
> >have to determine whether "a course reversal is required," to know
whether
> >you need to make a PT.
>
> I believe the determination of "course reversal required" is to be made by
> the procedure designer, and not the pilot.
>
>
> >
> >Is there a definition somewhere of what a course reversal is, or even
> >better, when a course reversal is required?
>
> TERPS (I think it's 8260.3 and 8260.19 or something like that)
>
> >
> >If you happen to have it, or can get it, look at the VOR RWY 13 approach
to
> >ACY (Atlantic City). A holding pattern is depicted at the IAF, but there
is
> >no guidance as to when it should be used. Doesn't that mean that the
pilot
> >needs to determine based on his heading into the IAF whether a course
> >reversal is required, and if it is, then he has to do a PT, either a
> >conventional PT, or a course reversal by way of the depicted hold? Or are
> >you saying that you need to enter the hold from all directions, go around
at
> >least once, and then continue in, in which case, isn't the "when a course
> >reversal is required" language redundant?
>
> Since the racetrack pattern is charted, the procedure turn must be flown
as
> charted (e.g. the type of turn and where to start it, in this instance, is
> NOT pilot choice). Again, according to Jepp charting conventions, this PT
> would have to be flown unless you were on radar vectors to the final
> approach course (or if there were timed approaches going on). I'm not
> familiar with that area, or how ATC works there, but I would expect that
> radar coverage would be pretty good there and, unless there's some traffic
> related reason off to the NW and not on the approach chart, that you would
> be getting radar vectors to final if you were approaching from the NW (or
> maybe even from other directions).
>
> And there may be TERP's related reasons for that required course reversal,
> also. The only charted course to the IAF is from ACY VOR with an MEA of
> 1900'; the MSA for that sector is 2100'. If you were to cross BURDK at
> either of those altitudes, in order to execute a straight-in approach, you
> would exceed the maximum TERPS allowed descent gradient of 400 ft/nm for a
> straight-in approach. (1900-75)/4.5 = 405.6 ft/nm. So, the procedure
> designer determined that a course reversal was required in order to
publish
> straight-in minimums.
>
I wouldn't have guessed it from the language, but what you say makes a lot
of sense, and especially with the approach gradient issue, seems like the
safest way, so I at least will do it that way.

Just to be certain what you mean, coming in from the NW, straignt in, cross
BURDK, enter the hold and decend from 1900 to 1600 when established on the
inbound leg before reaching BURDK the second time? All this assumes no radar
vectors.

Thanks.

Brad

"Brad Salai" > wrote in message
...
>
> "Gary Drescher" > wrote in message
> ...
>>
>> No, the ambiguity I'm pointing out isn't just a matter of the vagueness
>> of
>> "course reversal". The new AIM phrasing is ambiguous as to whether the
>> enumerated conditions are meant only as an *elaboration* of what it means
>> for a course reversal to be unnecessary (in which case a charted PT is
>> required unless the enumerated conditions are met), or whether a lack of
>> need for a course-reversal is meant as an *addition* to the enumerated
>> conditions (in which case the PT might not be required even if none of
> the
>> enumerated conditions are met).
>>
> I think its the second case. Here is the language again:
>
> The procedure turn or hold in lieu of procedure turn is a required
> maneuver when it is necessary to perform a course reversal.
> The procedure turn is not required when the symbol "No PT" is shown,
> when
> RADAR VECTORING to the final approach course is provided, when
> conducting a timed approach, or when the procedure turn is not
> authorized.
>
> The first sentence doesn't make any sense unless there are situations
> where
> "it is necessary to perform a course reversal."

Sure.

> If that's true, then the
> second sentence must be exceptions to the first, that is, situations where
> it would appear "necessary to perform a course reversal" but a PT is not
> required.

Yes and no. Yes, the second sentence lists situations in which a charted PT
is not required (the PT does not necessarily "appear necessary" in those
situations, though, except to the extent that simply being charted might
make them appear necessary). But no, the second sentence doesn't list
exceptions to the if-then assertion made by the first sentence; that is, the
second sentence does not list situations in which there is a necessary
course reversal but not a required PT.

> If the intent were that a PT is required unless one of the four exceptions
> applied, they would (or at least should) have said:
>
> The procedure turn or hold in lieu of procedure turn is a required
> maneuver unless the symbol "No PT" is shown, when
> RADAR VECTORING to the final approach course is provided, when
> conducting a timed approach, or when the procedure turn is not
> authorized.
> which would have been clear and unambiguous.

Yes, if that was their intent, they should have used that wording, or else
they should have used the "elaboration" paraphrase I proposed earlier in the
thread. But if their intent was as you believe, then they should have used
the "addition" paraphrase I proposed, which would also have been clear and
unambiguous. In fact, though, they used neither, and their chosen phrasing
was not clear or unambiguous.

> General rules of construction
> suggest that you should interpret the language so that the first sentence
> is
> not redundant or meaningless,

Correct.

> which leads to the second interpretation, what G. Drescher calls
> *addition*.

No, because my "elaboration" interpretation *also* allows the first sentence
to be meaningful and not redundant. Here is the "elaboration" paraphrase
again:

"The procedure turn is a required maneuver, unless one of the following
conditions obtains, in which case a course reversal is unnecessary: 1) the
symbol 'NoPT' is shown; 2) radar vectoring to the final approach course is
provided; 3) you are conducting a timed approach; or 4) the procedure turn
is not authorized."

In this paraphrase, the sentence in question is construed to be explaining
the rationale for the exceptions--namely, that the reason the PT maneuver
isn't required in the exceptional cases is that a reversal of course is
deemed unnecessary in those cases. That explanation may not be profound, but
it is neither meaningless nor redundant.

So the AIM wording is ambiguous. But if we look beyond the wording to the
underlying logic, then the "elaboration" interpretation makes more sense
than the "addition" interpretation that you favor. That's because the
"addition" interpretation effectively expects the pilot to act as a
real-time approach designer, making her own decision as to the necessity for
a course reversal (presumably in compliance with the TERPS criteria, which
are not even part of the standard pilot curriculum). In contrast, the
"elaboration" interpretation expects the TERPS criteria to be used by the
approach-chart designer, and simply expects the pilot to comply with the
chart.

The FAA email that Tim posted earlier in the thread confirms that the FAA's
intent is indeed the "elaboration" interpretation (but of course that's not
authoritative until it appears in some official source).

--Gary

"Gary Drescher" > wrote in message
...
> "Brad Salai" > wrote in message
> ...
> >
> > "Gary Drescher" > wrote in message
> > ...
> >>
> >> No, the ambiguity I'm pointing out isn't just a matter of the vagueness
> >> of
> >> "course reversal". The new AIM phrasing is ambiguous as to whether the
> >> enumerated conditions are meant only as an *elaboration* of what it
means
> >> for a course reversal to be unnecessary (in which case a charted PT is
> >> required unless the enumerated conditions are met), or whether a lack
of
> >> need for a course-reversal is meant as an *addition* to the enumerated
> >> conditions (in which case the PT might not be required even if none of
> > the
> >> enumerated conditions are met).
> >>
> > I think its the second case. Here is the language again:
> >
> > The procedure turn or hold in lieu of procedure turn is a required
> > maneuver when it is necessary to perform a course reversal.
> > The procedure turn is not required when the symbol "No PT" is shown,
> > when
> > RADAR VECTORING to the final approach course is provided, when
> > conducting a timed approach, or when the procedure turn is not
> > authorized.
> >
> > The first sentence doesn't make any sense unless there are situations
> > where
> > "it is necessary to perform a course reversal."
>
> Sure.
>
> > If that's true, then the
> > second sentence must be exceptions to the first, that is, situations
where
> > it would appear "necessary to perform a course reversal" but a PT is not
> > required.
>
> Yes and no. Yes, the second sentence lists situations in which a charted
PT
> is not required (the PT does not necessarily "appear necessary" in those
> situations, though, except to the extent that simply being charted might
> make them appear necessary). But no, the second sentence doesn't list
> exceptions to the if-then assertion made by the first sentence; that is,
the
> second sentence does not list situations in which there is a necessary
> course reversal but not a required PT.
>
> > If the intent were that a PT is required unless one of the four
exceptions
> > applied, they would (or at least should) have said:
> >
> > The procedure turn or hold in lieu of procedure turn is a required
> > maneuver unless the symbol "No PT" is shown, when
> > RADAR VECTORING to the final approach course is provided, when
> > conducting a timed approach, or when the procedure turn is not
> > authorized.
> > which would have been clear and unambiguous.
>
> Yes, if that was their intent, they should have used that wording, or else
> they should have used the "elaboration" paraphrase I proposed earlier in
the
> thread. But if their intent was as you believe, then they should have used
> the "addition" paraphrase I proposed, which would also have been clear and
> unambiguous. In fact, though, they used neither, and their chosen phrasing
> was not clear or unambiguous.
>
> > General rules of construction
> > suggest that you should interpret the language so that the first
sentence
> > is
> > not redundant or meaningless,
>
> Correct.
>
> > which leads to the second interpretation, what G. Drescher calls
> > *addition*.
>
> No, because my "elaboration" interpretation *also* allows the first
sentence
> to be meaningful and not redundant. Here is the "elaboration" paraphrase
> again:
>
> "The procedure turn is a required maneuver, unless one of the following
> conditions obtains, in which case a course reversal is unnecessary: 1) the
> symbol 'NoPT' is shown; 2) radar vectoring to the final approach course is
> provided; 3) you are conducting a timed approach; or 4) the procedure turn
> is not authorized."
>
> In this paraphrase, the sentence in question is construed to be explaining
> the rationale for the exceptions--namely, that the reason the PT maneuver
> isn't required in the exceptional cases is that a reversal of course is
> deemed unnecessary in those cases. That explanation may not be profound,
but
> it is neither meaningless nor redundant.
>
> So the AIM wording is ambiguous. But if we look beyond the wording to the
> underlying logic, then the "elaboration" interpretation makes more sense
> than the "addition" interpretation that you favor. That's because the
> "addition" interpretation effectively expects the pilot to act as a
> real-time approach designer, making her own decision as to the necessity
for
> a course reversal (presumably in compliance with the TERPS criteria, which
> are not even part of the standard pilot curriculum). In contrast, the
> "elaboration" interpretation expects the TERPS criteria to be used by the
> approach-chart designer, and simply expects the pilot to comply with the
> chart.
>
> The FAA email that Tim posted earlier in the thread confirms that the
FAA's
> intent is indeed the "elaboration" interpretation (but of course that's
not
> authoritative until it appears in some official source).
>
> --Gary
>
I've either persuaded myself, or been persuaded that the "elaboration"
construction is the safest, and the email suggests that it is what was
intended, but it really doesn't follow from the original language. Your
paraphrase leaves out "when it is necessary to perform a course reversal"
from the first sentence where it actually appears, and puts in in the
second, where it actually says that a PT is not necessary so that it reads
"where a course reversal is not necessary" which it didn't say.
If they had had you available to help them out when they drafted this, it
would have saved us all a lot of time.
No matter what it says, as I said before, I'm going to fly by the
elaboration construction, but no way do I agree that the words say that.

On Sat, 01 Oct 2005 13:33:03 GMT, "Brad Salai" >
wrote:

>I wouldn't have guessed it from the language, but what you say makes a lot
>of sense, and especially with the approach gradient issue, seems like the
>safest way, so I at least will do it that way.
>
>Just to be certain what you mean, coming in from the NW, straignt in, cross
>BURDK, enter the hold and decend from 1900 to 1600 when established on the
>inbound leg before reaching BURDK the second time? All this assumes no radar
>vectors.
>

Well, coming from the NW there's no charted route until you get to BURDK of
which I am aware. So, unless ATC can clear you to a lower altitude, your
minimum IFR altitude would be controlled by 91.177 (ii) "In any other case,
an altitude of 1,000 feet above the highest obstacle within a horizontal
distance of 4 nautical miles from the course to be flown." 1900 would
probably be safe once you got to the area of the procedure turn, but that's
not precisely charted. If I were doing this from the NW, non-radar, I
would probably maintain at or above the MSA, which is a charted altitude,
until BURDK; then descend to 1900 outbound and 1600 inbound. (1900 might
be both safe and legal in the area to the NW that is not on the approach
plate, but I'd have to study sectionals to be sure).

Having said that, your clearance from ATC should give you the information.
Coming from the NW, it should go something like "Maintain at or above xxxx
ft until (some_fix); cleared for the VOR Rwy 13 approach". If you are
doing this non-radar, your clearance will likely be to ACY and not to
BURDK.



Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

I'm still confused. Assuming the following facts, how would you fly
the ILS RWY 28R at KSFO
(http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF), which has a holding
pattern depicted in lieu of PT, and no indication that radar is
required?

Assumptions:
1) Upon departure, you were cleared to SFO, as filed;
2) your filed route takes you through the MENLO IAF (I don't know if
there's an airway through MENLO, but assume you got there for the sake
of argument);
3) you lost radio contact before your arrival at MENLO; and
4) you arrive at MENLO at 4000 feet and at your filed ETA.

Here's how I'd fly the procedure - will I be in violation of any FARs,
even given the interpretation of the AIM change that is proposed here?
1) Cross MENLO at 4000, descend to 3200 and continue to CEPIN;
2) As I approach CEPIN and as the localizer comes alive and starts
moving toward center, begin turning left to intercept localizer - note
that I will initially have almost a 50 degree intercept - and begin
descent to 1800 feet; and
3) at AXMUL, intercept glideslope and continue descent.

Why would I turn right at CEPIN or even at MENLO to spend some time in
the hold at DUMBA, except perhaps if I arrived prior to my filed ETA?

My layman's interpretation of the language would be as follows:

1) "A procedure turn is the maneuver prescribed *when it is necessary
to
perform a course reversal*..."

2) [When it is necessary to perform a course reversal,] "The procedure
turn or hold in lieu of procedure turn is a required maneuver."

3) [Even when it is necessary to perform a course reversal,] "The
procedure turn is not required when the symbol "No PT" is shown, when
RADAR VECTORING to the final approach course is provided, when
conducting a timed approach, or when the procedure turn is not
authorized."

This begs the question, "when is it necessary to perform a course
reversal?" Someone mentioned a descent of 300 feet or a turn of more
than 30 degrees according to TERPS (not according to anything we
studied to get our IFR ticket, as far as I recall), though that doesn't
seem right to me. I think even a 90 degree intercept or 1000 feet (or
more) of descent may be okay if you're far enough from the FAF.

"Brad Salai" > wrote in message
...
>
> "Gary Drescher" > wrote in message
> Here is the "elaboration" paraphrase again:
>>
>> "The procedure turn is a required maneuver, unless one of the following
>> conditions obtains, in which case a course reversal is unnecessary: 1)
>> the
>> symbol 'NoPT' is shown; 2) radar vectoring to the final approach course
>> is
>> provided; 3) you are conducting a timed approach; or 4) the procedure
>> turn
>> is not authorized."
>>
> I've either persuaded myself, or been persuaded that the "elaboration"
> construction is the safest, and the email suggests that it is what was
> intended, but it really doesn't follow from the original language.

Not unambiguously, no. I claim only that it's one of two reasonable
interpretations.

> Your
> paraphrase leaves out "when it is necessary to perform a course reversal"
> from the first sentence where it actually appears, and puts in in the
> second, where it actually says that a PT is not necessary so that it reads
> "where a course reversal is not necessary" which it didn't say.

Right, and I think that's comaptible with the original phrasing. To put it
another way, I think the original sentences "The PT... is a required
maneuver when it is necessary to perform a course reversal. The PT is not
required when..." could be taken to mean "When we judge that it is necessary
for you to perform a course reversal, we require you to execute a PT. (We
convey this requirement by charting a PT on the approach plate.) However, a
charted PT is not required when..."

> No matter what it says, as I said before, I'm going to fly by the
> elaboration construction,

As will about half of all pilots, it seems. :) Now we just have to persuade
the other half.

--Gary

On 1 Oct 2005 18:13:06 -0700, "rps" > wrote:

>I'm still confused. Assuming the following facts, how would you fly
>the ILS RWY 28R at KSFO
>(http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF), which has a holding
>pattern depicted in lieu of PT, and no indication that radar is
>required?
>
>Assumptions:
>1) Upon departure, you were cleared to SFO, as filed;
>2) your filed route takes you through the MENLO IAF (I don't know if
>there's an airway through MENLO, but assume you got there for the sake
>of argument);
>3) you lost radio contact before your arrival at MENLO; and
>4) you arrive at MENLO at 4000 feet and at your filed ETA.
>
>Here's how I'd fly the procedure - will I be in violation of any FARs,
>even given the interpretation of the AIM change that is proposed here?
>1) Cross MENLO at 4000, descend to 3200 and continue to CEPIN;
>2) As I approach CEPIN and as the localizer comes alive and starts
>moving toward center, begin turning left to intercept localizer - note
>that I will initially have almost a 50 degree intercept - and begin
>descent to 1800 feet; and
>3) at AXMUL, intercept glideslope and continue descent.
>
>Why would I turn right at CEPIN or even at MENLO to spend some time in
>the hold at DUMBA, except perhaps if I arrived prior to my filed ETA?

I'm not as familiar with NACO charts as with Jepp charts (and I don't have
a Jepp chart for that approach) but I would not even consider turning right
at CEPIN or MENLO to go to DUMBA. It seems to me that the procedure track
from the MENLO IAF does not proceed via DUMBA. This seems apparent from
the charting; but also note that the MEA for the route from MENLO to CEPIN
is lower than the MEA in the hold at DUMBA.

So far as doing a hold if you arrived ahead of your ETA, in accord with the
regulations regarding radio failure, I believe you should be holding at
MENLO. Although, the situation may well be considered an emergency,
depending on what you are flying, and I might choose to skip this provision
of the regulations for safety reasons.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Roy Smith" > wrote in message
...
>
> The problem comes in when you're on a random route such as direct to
> the IAF/FAF. You can be between two airways converging on the IAF,
> both of which are marked NoPT (and at the same altitude marked for
> those routes), and yet you're not on a NoPT segment yourself. I think
> most people would agree that it's reasonable to assume that not doing
> a PT in this case is perfectly safe. The question which leads to
> endless debate is whether it's legal or not.
>

How did you come to be on that random route? You say you're not on an
airway, so you must be either within usable navaid limits or in radar
contact. If you're within usable navaid limits, why isn't the route also
published with a NoPT? If you're in radar contact, why weren't you vectored
for the approach, which would negate flying the PT?

"Gary Drescher" > wrote in message
...
>
> You'll find no FAR that explicitly requires performing a charted PT
> *regardless* of whether or not the PT meets the TERPS criteria. That
> doesn't make all the PTs optional, does it?
>

Of course not.


>
> No, but in some cases it offers the only readily available definitive FAA
> interpretation of key regulations. That's what it's trying to do in this
> case, but the chosen wording is unfortunately ambiguous.
>

The regulation seems pretty clear to me in this case.

"Brad Salai" > wrote in message
...
>
> If you happen to have it, or can get it, look at the VOR RWY 13 approach
> to ACY (Atlantic City). A holding pattern is depicted at the IAF, but
> there
> is no guidance as to when it should be used. Doesn't that mean that the
> pilot
> needs to determine based on his heading into the IAF whether a course
> reversal is required, and if it is, then he has to do a PT, either a
> conventional PT, or a course reversal by way of the depicted hold? Or are
> you saying that you need to enter the hold from all directions, go around
> at least once, and then continue in, in which case, isn't the "when a
> course
> reversal is required" language redundant?
>

I don't think you're going to be cleared to ACY via "direct BURDK direct".
You're virtually certain to be vectored to the FAC, which would then
prohibit the course reversal. If you're on your own navigation for this
approach you're probably going to be cleared via the ACY VORTAC, which
requires a course reversal of 180 degrees.

"Ron Rosenfeld" > wrote in message
...
>
> Could you expand on that statement? I'm not able to apply it to my
> description of the Jepp charting conventions.
>

The FARs prohibit the PT under specific conditions, they say nothing about
when a PT is required.

"Steven P. McNicoll" > wrote in message
ink.net...
>
> "Gary Drescher" > wrote in message
> ...
>>
>> You'll find no FAR that explicitly requires performing a charted PT
>> *regardless* of whether or not the PT meets the TERPS criteria. That
>> doesn't make all the PTs optional, does it?
>
> Of course not.

So then when is a PT mandatory, and by virtue of which regulation?

--Gary

"Ron Rosenfeld" > wrote in message
...
>
> If a procedure turn is charted, then it is required unless one of the
> previously discussed exceptions apply (e.g. NoPT; vectors to final; timed
> approaches).
>

Where in the FARs did you find that requirement?


>
> I believe the determination of "course reversal required" is to be made by
> the procedure designer, and not the pilot.
>

Why?

"Brad Salai" > wrote in message
...
>
> Just to be certain what you mean, coming in from the NW, straignt in,
> cross BURDK, enter the hold and decend from 1900 to 1600 when established
> on
> the inbound leg before reaching BURDK the second time? All this assumes no
> radar vectors.
>

What ATC clearance are you following when you're coming in to BURDK from the
northwest?

"Gary Drescher" > wrote in message
...
>
> So then when is a PT mandatory, and by virtue of which regulation?
>

It's never mandatory by virtue of regulation.

"rps" > wrote in message
oups.com...
>
> I'm still confused. Assuming the following facts, how would you fly
> the ILS RWY 28R at KSFO
> (http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF), which has a holding
> pattern depicted in lieu of PT, and no indication that radar is
> required?
>
> Assumptions:
> 1) Upon departure, you were cleared to SFO, as filed;
> 2) your filed route takes you through the MENLO IAF (I don't know if
> there's an airway through MENLO, but assume you got there for the sake
> of argument);
>

MENLO is on the BIG SUR TWO arrival.


>
> 3) you lost radio contact before your arrival at MENLO; and
> 4) you arrive at MENLO at 4000 feet and at your filed ETA.
>
> Here's how I'd fly the procedure - will I be in violation of any FARs,
> even given the interpretation of the AIM change that is proposed here?
> 1) Cross MENLO at 4000, descend to 3200 and continue to CEPIN;
> 2) As I approach CEPIN and as the localizer comes alive and starts
> moving toward center, begin turning left to intercept localizer - note
> that I will initially have almost a 50 degree intercept - and begin
> descent to 1800 feet; and
> 3) at AXMUL, intercept glideslope and continue descent.
>
> Why would I turn right at CEPIN or even at MENLO to spend some time in
> the hold at DUMBA, except perhaps if I arrived prior to my filed ETA?
>

I wouldn't turn right at CEPIN even if I was ahead of my filed ETA. There's
no way to turn at MENLO, the procedure goes only to CEPIN from MENLO.

On Sun, 02 Oct 2005 22:35:25 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> Could you expand on that statement? I'm not able to apply it to my
>> description of the Jepp charting conventions.
>>
>
>The FARs prohibit the PT under specific conditions, they say nothing about
>when a PT is required.
>

So you are saying that Jeppesen's charting conventions, in which they
interpret the applicaple FAA forms 8260 are incorrect?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Sun, 02 Oct 2005 22:41:08 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> If a procedure turn is charted, then it is required unless one of the
>> previously discussed exceptions apply (e.g. NoPT; vectors to final; timed
>> approaches).
>>
>
>Where in the FARs did you find that requirement?
>
>

14 CFR Part 97
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Sun, 02 Oct 2005 22:41:08 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> If a procedure turn is charted, then it is required unless one of the
>> previously discussed exceptions apply (e.g. NoPT; vectors to final; timed
>> approaches).
>>
>
>Where in the FARs did you find that requirement?

To elaborate, it is in the Jepp interpretation of the FAA published
approach procedure. These procedures are regulatory by virtue of 14 CFR 97
and must be followed by virtue of 14 CFR 91

>
>
>>
>> I believe the determination of "course reversal required" is to be made by
>> the procedure designer, and not the pilot.
>>
>
>Why?
>

Because the requirement is noted in TERPS which is used to design the
approach.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
>
> So you are saying that Jeppesen's charting conventions, in which they
> interpret the applicaple FAA forms 8260 are incorrect?
>

No, I'm saying the FARs prohibit the PT under specific conditions, they say
nothing about
when a PT is required. I'm not familiar with Jeppesen's charting
conventions, I'm not in a position to say anything about them.

"Ron Rosenfeld" > wrote in message
...
>
> 14 CFR Part 97
>

What section?

"Ron Rosenfeld" > wrote in message
...
>
> To elaborate, it is in the Jepp interpretation of the FAA published
> approach procedure. These procedures are regulatory by virtue of 14 CFR
> 97
> and must be followed by virtue of 14 CFR 91
>

Then it appears that Jepp misinterpreted.


>
> Because the requirement is noted in TERPS which is used to design the
> approach.
>

The TERPs requirements apply only to the design of the procedure.

"Steven P. McNicoll" > wrote in message
ink.net...
>"Gary Drescher" > wrote in message
...
>> "Steven P. McNicoll" > wrote in message
>> ink.net...
>>>
>>> "Gary Drescher" > wrote in message
>>> ...
>>>>
>>>> You'll find no FAR that explicitly requires performing a charted PT
>>>> *regardless* of whether or not the PT meets the TERPS criteria. That
>>>> doesn't make all the PTs optional, does it?
>>>
>>> Of course not.
>>
>> So then when is a PT mandatory, and by virtue of which regulation?
>
> It's never mandatory by virtue of regulation.

Then when is a PT mandatory, and by virtue of what if not regulation?

--Gary

On Mon, 03 Oct 2005 00:35:29 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> To elaborate, it is in the Jepp interpretation of the FAA published
>> approach procedure. These procedures are regulatory by virtue of 14 CFR
>> 97
>> and must be followed by virtue of 14 CFR 91
>>
>
>Then it appears that Jepp misinterpreted.

Since 14 CFR 97 states that the SIAP's are included by reference, it would
seem that the regulatory nature of these SIAP's is pretty clear.


>
>
>>
>> Because the requirement is noted in TERPS which is used to design the
>> approach.
>>
>
>The TERPs requirements apply only to the design of the procedure.

And the procedures based on TERPs are regulatory.

>

Steve,

Myself, Jepp, as well as FAA published legal opinion all agree that a PT
must be flown if the pilot is cleared for a SIAP which includes a PT, and
for which one of the 91.175 exceptions is not present.

SIAP's ARE regulatory. They are included, by reference, in 14 CFR 97.

It is certainly your right to disagree with Jeppesen's interpretation, and
with the FAA Assistant Chief Counsel Regulatory Division's interpretation.

Myself, I will choose to rely on their opinions, and encourage others to do
the same.

==========================================
Nov. 28, 1994
Mr. Tom Young, Chairman
Charting and Instrument Procedures Committee
Air Line Pilots Association
535 Herndon Parkway
Herndon, VA 22070

Dear Mr. Young,

.... A SIAP may or may not prescribe a procedure turn based on the
application of certain criteria contained in the TERPs. However, if a SIAP
does contain a procedure turn and ATC has cleared a pilot to execute the
SIAP, the pilot must make the procedure turn when one of the conditions of
Section 91.175(j) is not present.

If you have any questions regarding this matter, please contact Patricia
R. Lane, Manager, Airspace and Air Traffic Law Branch, at (202) 267-3491.

Sincerely,

/s/
Patricia R. Lane
for Donald P. Byrne
Assistant Chief Counsel
Regulations Division
===========================================

Title 14: Aeronautics and Space
PART 97—STANDARD INSTRUMENT APPROACH PROCEDURES
Subpart C—TERPS Procedures

§ 97.20 General.

(a) This subpart prescribes standard instrument procedures and weather
takeoff minimums based on the criteria contained in FAA Order 8260.3, U.S.
Standard for Terminal Instrument Procedures (TERPs), and other related
Orders in the 8260 series that also address instrument procedure design
criteria.

(b) Standard instrument procedures and associated supporting data adopted
by the FAA are documented on FAA Forms 8260–3, 8260–4, 8260–5. Weather
takeoff minimums are documented on FAA Form 8260–15A. These forms are
incorporated by reference. The Director of the Federal Register approved
this incorporation by reference pursuant to 5 U.S.C. 552(a) and 1 CFR part
51...
==================================

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Gary Drescher" > wrote in message
...
>
> Then when is a PT mandatory, and by virtue of what if not regulation?
>

It's mandatory when it is necessary to reverse direction to establish the
aircraft on an intermediate or final approach course, by virtue of the need
to reverse direction to establish the aircraft on an intermediate or final
approach course. This really isn't that hard.

On Sun, 2 Oct 2005 21:15:13 -0400, "Gary Drescher" >
wrote:

>"Steven P. McNicoll" > wrote in message
ink.net...
>>"Gary Drescher" > wrote in message
...
>>> "Steven P. McNicoll" > wrote in message
>>> ink.net...
>>>>
>>>> "Gary Drescher" > wrote in message
>>>> ...
>>>>>
>>>>> You'll find no FAR that explicitly requires performing a charted PT
>>>>> *regardless* of whether or not the PT meets the TERPS criteria. That
>>>>> doesn't make all the PTs optional, does it?
>>>>
>>>> Of course not.
>>>
>>> So then when is a PT mandatory, and by virtue of which regulation?
>>
>> It's never mandatory by virtue of regulation.
>
>Then when is a PT mandatory, and by virtue of what if not regulation?
>
>--Gary
>

According to both Jepp, and the FAA (regulatory division counsel), a PT is
mandatory if the pilot is cleared for a SIAP that includes one, and one of
the 91.175 exceptions does not apply.

SIAP's are regulatory, incorporated (by reference) into 14 CFR 97


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

In article et>,
"Steven P. McNicoll" > wrote:

> "rps" > wrote in message
> oups.com...
> >
> > I'm still confused. Assuming the following facts, how would you fly
> > the ILS RWY 28R at KSFO
....
> I wouldn't turn right at CEPIN even if I was ahead of my filed ETA. There's
> no way to turn at MENLO, the procedure goes only to CEPIN from MENLO.

Turning left at CEPIN certainly makes intuitive sense, but if that's the
right thing to do then why is MENLO->CEPIN not marked NoPT?
There are three (and only three) possibilities:

1. You are required to turn right at CEPIN and hold at DUMBA.
2. The absence of a NoPT designation is meaningless.
3. MENLO->CEPIN should be marked NoPT; the fact that it isn't is a
mistake.

Given that the ILS 28L approach has an almost identical segment
(MENLO->HEMAN) that IS marked NoPT my money is on #3.

rg

"Ron Garret" > wrote in message
...
>
> Turning left at CEPIN certainly makes intuitive sense, but if that's the
> right thing to do then why is MENLO->CEPIN not marked NoPT?
> There are three (and only three) possibilities:
>
> 1. You are required to turn right at CEPIN and hold at DUMBA.
> 2. The absence of a NoPT designation is meaningless.
> 3. MENLO->CEPIN should be marked NoPT; the fact that it isn't is a
> mistake.
>
> Given that the ILS 28L approach has an almost identical segment
> (MENLO->HEMAN) that IS marked NoPT my money is on #3.
>

I don't see why MENLO..HEMAN should be marked NoPT. If you're beginning the
ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.

"Ron Rosenfeld" > wrote in message
...
>
> Since 14 CFR 97 states that the SIAP's are included by reference, it would
> seem that the regulatory nature of these SIAP's is pretty clear.
>

It is to me.


>
> And the procedures based on TERPs are regulatory.
>

Please cite the FAR that requires a charted PT to be flown whenever one of
the prohibitions of FAR 91.175(j) is not applicable.


>
> Steve,
>
> Myself, Jepp, as well as FAA published legal opinion all agree that a PT
> must be flown if the pilot is cleared for a SIAP which includes a PT, and
> for which one of the 91.175 exceptions is not present.
>
> SIAP's ARE regulatory. They are included, by reference, in 14 CFR 97.
>
> It is certainly your right to disagree with Jeppesen's interpretation, and
> with the FAA Assistant Chief Counsel Regulatory Division's interpretation.
>
> Myself, I will choose to rely on their opinions, and encourage others to
> do
> the same.
>
> ==========================================
> Nov. 28, 1994
> Mr. Tom Young, Chairman
> Charting and Instrument Procedures Committee
> Air Line Pilots Association
> 535 Herndon Parkway
> Herndon, VA 22070
>
> Dear Mr. Young,
>
> ... A SIAP may or may not prescribe a procedure turn based on the
> application of certain criteria contained in the TERPs. However, if a SIAP
> does contain a procedure turn and ATC has cleared a pilot to execute the
> SIAP, the pilot must make the procedure turn when one of the conditions of
> Section 91.175(j) is not present.
>
> If you have any questions regarding this matter, please contact Patricia
> R. Lane, Manager, Airspace and Air Traffic Law Branch, at (202) 267-3491.
>
> Sincerely,
>
> /s/
> Patricia R. Lane
> for Donald P. Byrne
> Assistant Chief Counsel
> Regulations Division
> ===========================================
>
> Title 14: Aeronautics and Space
> PART 97-STANDARD INSTRUMENT APPROACH PROCEDURES
> Subpart C-TERPS Procedures
>
> § 97.20 General.
>
> (a) This subpart prescribes standard instrument procedures and weather
> takeoff minimums based on the criteria contained in FAA Order 8260.3, U.S.
> Standard for Terminal Instrument Procedures (TERPs), and other related
> Orders in the 8260 series that also address instrument procedure design
> criteria.
>
> (b) Standard instrument procedures and associated supporting data adopted
> by the FAA are documented on FAA Forms 8260-3, 8260-4, 8260-5. Weather
> takeoff minimums are documented on FAA Form 8260-15A. These forms are
> incorporated by reference. The Director of the Federal Register approved
> this incorporation by reference pursuant to 5 U.S.C. 552(a) and 1 CFR part
> 51...
> ==================================
>

I am aware of that interpretation, I am also aware that is NOT an
interpretation supported by the FARs.

"Ron Rosenfeld" > wrote in message
...
>
> According to both Jepp, and the FAA (regulatory division counsel), a PT is
> mandatory if the pilot is cleared for a SIAP that includes one, and one of
> the 91.175 exceptions does not apply.
>

But not according to the FARs.

Another example from the same plate:

http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF

You've not been given "vectors to final".
You're established on the approach from the IAF FAITH.
You're at 4100 feet.
You fly over DUMBA.
The leg from FAITH to DUMBA is NOT marked NoPT.

I'm in the camp which thinks (hopes?) that a turn in the hold at DUMBA
is not logical nor required.

Three questions:

a) does anyone think a turn in the hold at DUMBA is required? If so,
why?

b) should the leg from FAITH to DUMBA be marked "NoPT"?

Tim.

PS. I think Chip Jones posted a very similar example a while back when
he got a surprise when the pilot did do a turn. I'll see if I can
find the reference.


On Mon, 03 Oct 2005 09:16:54 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Garret" > wrote in message
...
>>
>> Turning left at CEPIN certainly makes intuitive sense, but if that's the
>> right thing to do then why is MENLO->CEPIN not marked NoPT?
>> There are three (and only three) possibilities:
>>
>> 1. You are required to turn right at CEPIN and hold at DUMBA.
>> 2. The absence of a NoPT designation is meaningless.
>> 3. MENLO->CEPIN should be marked NoPT; the fact that it isn't is a
>> mistake.
>>
>> Given that the ILS 28L approach has an almost identical segment
>> (MENLO->HEMAN) that IS marked NoPT my money is on #3.
>>
>
>I don't see why MENLO..HEMAN should be marked NoPT. If you're beginning the
>ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.
>

In article et>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > Turning left at CEPIN certainly makes intuitive sense, but if that's the
> > right thing to do then why is MENLO->CEPIN not marked NoPT?
> > There are three (and only three) possibilities:
> >
> > 1. You are required to turn right at CEPIN and hold at DUMBA.
> > 2. The absence of a NoPT designation is meaningless.
> > 3. MENLO->CEPIN should be marked NoPT; the fact that it isn't is a
> > mistake.
> >
> > Given that the ILS 28L approach has an almost identical segment
> > (MENLO->HEMAN) that IS marked NoPT my money is on #3.
> >
>
> I don't see why MENLO..HEMAN should be marked NoPT.

It's marked NoPT to make it clear that you should turn left at HEMAN
instead of right. (Isn't that obvious?)

> If you're beginning the
> ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.

You will if you turn right at HEMAN.

rg

Another example from the same plate:

http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF

You've not been given "vectors to final".
You're established on the approach from the IAF FAITH.
You're at 4100 feet.
You fly over DUMBA.
The leg from FAITH to DUMBA is NOT marked NoPT.

I'm in the camp which thinks (hopes?) that a turn in the hold at DUMBA
is not logical nor required.

Three questions:

a) does anyone think a turn in the hold at DUMBA is required? If so,
why?

b) should the leg from FAITH to DUMBA be marked "NoPT"?

Tim.

PS. I think Chip Jones posted a very similar example a while back when
he got a surprise when the pilot did do a turn. I'll see if I can
find the reference.

=========================================
FYI:

The Chip Jones reference is:
"VOR/DME Approach Question"
posted on 8/22/2004 6:15pm.

The approach referred to is RKW: VOR/DME or GPS RWY 22

http://www.naco.faa.gov/d-tpp/0510/05408VDG22.PDF

with a /G airplane

approaching MINES on about a 270 heading.

Is a turn round the holding pattern mandatory for this plane?
My impression is most responders thought it was.

Google groups reference is:

<http://groups.google.com/group/rec.aviation.ifr/browse_thread/thread/64ed91b8309cb921/c285893e7e0a84c2?q=chip+jones+group:rec.aviation.i fr&hl=en&>


>On Mon, 03 Oct 2005 09:16:54 GMT, "Steven P. McNicoll"
> wrote:
>
>>
>>"Ron Garret" > wrote in message
...
>>>
>>> Turning left at CEPIN certainly makes intuitive sense, but if that's the
>>> right thing to do then why is MENLO->CEPIN not marked NoPT?
>>> There are three (and only three) possibilities:
>>>
>>> 1. You are required to turn right at CEPIN and hold at DUMBA.
>>> 2. The absence of a NoPT designation is meaningless.
>>> 3. MENLO->CEPIN should be marked NoPT; the fact that it isn't is a
>>> mistake.
>>>
>>> Given that the ILS 28L approach has an almost identical segment
>>> (MENLO->HEMAN) that IS marked NoPT my money is on #3.
>>>
>>
>>I don't see why MENLO..HEMAN should be marked NoPT. If you're beginning the
>>ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.
>>

So this just occurred to me in the debate on procedure turns.

The AIM famously says "The procedure turn is a required maneuver..."
But the AIM is not regulatory. Is there anything in the FARs that
requires a PT? I'm pretty sure there isn't anything in Part 91.
Someone in another thread said that there was something in Part 97, but
I can't find it.

If nothing in the FARs requires a PT then a reasonable interpretation of
the AIM is: "WHEN it is necessary to reverse course (which is determined
at the pilot's discretion I suppose) you must do so by executing a PT
(or a hold in lieu of)..." as opposed to, say, doing an Immelman or half
a lazy eight.

rg

I finally got around to opening my 2004 FAR/AIM (the only one I have
here in the office), and found:

97.3 "Symbols and terms used in procedures."
97.3 (p) "Procedure term means the maneuver prescribed when it is
necessary to reverse direction to establish the aircraft on an
intermediate or final approach course. ..."

To me, this means that any discussion of procedure turns is irrlevant
unless "it is necessary to reverse direction to establish the aircraft
on an intermediate or final approach course.".

So, we have to define two more items:

a) "to reverse direction".
I would argue strongly that any turn less than 90 degrees is NOT
reversing direction. I can't think of any field (except perhaps
politics :-) where say a 30 degree change of direction is considered
reversing direction.

b) "to establish the aircraft on an intermediate or final approach
course."
This is where I consider pilot's discretion comes in. However, if
you're already aligned with the required course (or close to it), then
there's no way I consider it necessary to reverse direction to
establish myself on the course.

As 97.3 (p) is regulatory, I think there's a strong case for saying
procedure turns are not mandatory.

--------

The second part of 97.3 (p) addresses your issue about how you do the
turn:

"The outbound course, direction, distance within which the turn must
be completed, and minimum altititude are specified in the procedure.
However, the point at which the turn may be commenced, and the type
and rate of turn, is left to the discretion of the pilot".

So, yes, you can do an Immelman if you can keep it within the
parameters mentioned above.

Tim.



On Mon, 03 Oct 2005 18:33:31 -0700, Ron Garret >
wrote:

>So this just occurred to me in the debate on procedure turns.
>
>The AIM famously says "The procedure turn is a required maneuver..."
>But the AIM is not regulatory. Is there anything in the FARs that
>requires a PT? I'm pretty sure there isn't anything in Part 91.
>Someone in another thread said that there was something in Part 97, but
>I can't find it.
>
>If nothing in the FARs requires a PT then a reasonable interpretation of
>the AIM is: "WHEN it is necessary to reverse course (which is determined
>at the pilot's discretion I suppose) you must do so by executing a PT
>(or a hold in lieu of)..." as opposed to, say, doing an Immelman or half
>a lazy eight.
>
>rg

In article >,
Tim Auckland > wrote:

> So, yes, you can do an Immelman if you can keep it within the
> parameters mentioned above.

Cool! I've always wanted to try one of those in IMC! ;-)

rg

"Tim Auckland" > wrote in message
...
>
> Another example from the same plate:
>
> http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF
>
> You've not been given "vectors to final".
> You're established on the approach from the IAF FAITH.
> You're at 4100 feet.
> You fly over DUMBA.
> The leg from FAITH to DUMBA is NOT marked NoPT.
>
> I'm in the camp which thinks (hopes?) that a turn in the hold at DUMBA
> is not logical nor required.
>
> Three questions:
>
> a) does anyone think a turn in the hold at DUMBA is required? If so,
> why?
>
> b) should the leg from FAITH to DUMBA be marked "NoPT"?
>

Yes. Interesting that the segments from MENLO and FAITH are marked NoPT on
the ILS RWY 28L but neither is so marked on the ILS RWY 28R.

"Ron Garret" > wrote in message
...
> In article et>,
> "Steven P. McNicoll" > wrote:
>
>>
>> I don't see why MENLO..HEMAN should be marked NoPT.
>>
>
> It's marked NoPT to make it clear that you should turn left at HEMAN
> instead of right. (Isn't that obvious?)
>
>>
>> If you're beginning the
>> ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.
>>
>
> You will if you turn right at HEMAN.
>

I can't tell if you're joking or not. Only an idiot would turn right at
HEMAN.

"Tim Auckland" > wrote in message
...
>
> =========================================
> FYI:
>
> The Chip Jones reference is:
> "VOR/DME Approach Question"
> posted on 8/22/2004 6:15pm.
>
> The approach referred to is RKW: VOR/DME or GPS RWY 22
>
> http://www.naco.faa.gov/d-tpp/0510/05408VDG22.PDF
>
> with a /G airplane
>
> approaching MINES on about a 270 heading.
>
> Is a turn round the holding pattern mandatory for this plane?
> My impression is most responders thought it was.
>
> Google groups reference is:
>
> <http://groups.google.com/group/rec.aviation.ifr/browse_thread/thread/64ed91b8309cb921/c285893e7e0a84c2?q=chip+jones+group:rec.aviation.i fr&hl=en&>
>

The request was, "Center, Army 569 would like to shoot the full VOR/DME 22
into Rockwood, followed by a missed approach and a ten minute hold at MINES
and then on to Campbell." They requested the FULL approach. I wouldn't
have cleared them direct MINES, I'd have cleared them direct HCH.

On Tue, 04 Oct 2005 08:49:34 -0700, Ron Garret >
wrote:

>In article >,
> Tim Auckland > wrote:
>
>> So, yes, you can do an Immelman if you can keep it within the
>> parameters mentioned above.
>
>Cool! I've always wanted to try one of those in IMC! ;-)
>
>rg

Don't do it with passengers unless you've got parachutes.

In article et>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> > In article et>,
> > "Steven P. McNicoll" > wrote:
> >
> >>
> >> I don't see why MENLO..HEMAN should be marked NoPT.
> >>
> >
> > It's marked NoPT to make it clear that you should turn left at HEMAN
> > instead of right. (Isn't that obvious?)
> >
> >>
> >> If you're beginning the
> >> ILS RWY 28R at MENLO you're not going to cross the holding fix DUMBA.
> >>
> >
> > You will if you turn right at HEMAN.
> >
>
> I can't tell if you're joking or not.

I'm not.

> Only an idiot would turn right at HEMAN.

Someone might turn right at HEMAN if they thought that 1) the absence of
a "NoPT" designation on the MENLO->HEMAN leg was both correct and
meaningful, and 2) that the AIM's description of the PT as a "required
maneuver" except under specific circumstances was meaningful.

Now, I think that the fact of the matter is that the absence of the NoPT
designation is a mistake, and that that the AIM's use of the phrase
"required maneuver" is meaningless (and no, I'm not joking about that
either). But I don't think that failing to come to those conclusions
makes someone an idiot.

rg

"Ron Garret" > wrote in message
...
>
>> Only an idiot would turn right at HEMAN.
>
> Someone might turn right at HEMAN if they thought that 1) the absence of
> a "NoPT" designation on the MENLO->HEMAN leg was both correct and
> meaningful, and 2) that the AIM's description of the PT as a "required
> maneuver" except under specific circumstances was meaningful.
>

Someone that thinks that is an idiot.

>I wouldn't
>have cleared them direct MINES, I'd have cleared them direct HCH.

Why?

"John Clonts" > wrote in message
oups.com...
>
> Why?
>

Because they asked for the "full VOR/DME 22" approach. Pilots request a
"full" approach when they want to do it on their own navigation, almost
always for training purposes. You can't navigate direct to MINES using VOR,
you've got to go to HCH and fly the feeder route.

>Because they asked for the "full VOR/DME 22" approach. Pilots request a
>"full" approach when they want to do it on their own navigation, almost
always for training purposes. You can't navigate direct to MINES using
VOR,
>you've got to go to HCH and fly the feeder route.

But the aircraft in question was /G, so he could fly direct MINES. And
MINES is an IAF, so an approach beginning there would be a "full
approach" ???

Thanks,
John

Steve,

You might have got an intersting response from the army. Chip's
original post implied they were approaching MINES from the east. HCH
is 27 miles southwet of MINES.

Tim.

On Tue, 04 Oct 2005 18:59:33 GMT, "Steven P. McNicoll"
> wrote:

>
>"John Clonts" > wrote in message
oups.com...
>>
>> Why?
>>
>
>Because they asked for the "full VOR/DME 22" approach. Pilots request a
>"full" approach when they want to do it on their own navigation, almost
>always for training purposes. You can't navigate direct to MINES using VOR,
>you've got to go to HCH and fly the feeder route.
>

"John Clonts" > wrote in message
oups.com...
> >Because they asked for the "full VOR/DME 22" approach. Pilots request a
>>"full" approach when they want to do it on their own navigation, almost
> always for training purposes. You can't navigate direct to MINES using
> VOR,
>>you've got to go to HCH and fly the feeder route.
>
> But the aircraft in question was /G, so he could fly direct MINES. And
> MINES is an IAF, so an approach beginning there would be a "full
> approach" ???
>

Yes, he could use GPS to fly direct to MINES. But if he wanted to use GPS
why did he ask for the "full VOR/DME 22" approach? Check the plate, there's
a GPS overlay, he could have used GPS exclusively to fly the approach.
Requesting the "full VOR/DME 22" approach suggests the objective of their
navigational exercise was VOR/DME approaches, not GPS approaches.

"Tim Auckland" > wrote in message
...
>
> You might have got an intersting response from the army. Chip's
> original post implied they were approaching MINES from the east. HCH
> is 27 miles southwet of MINES.
>

I know that. They also requested to hold at MINES for ten minutes. That
tells me they're not in a hurry. It was clearly a training flight and the
training was to be on VOR approach procedures. They requested the full
VOR/DME approach so I'd give them every bit of it.

In article t>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> >> Only an idiot would turn right at HEMAN.
> >
> > Someone might turn right at HEMAN if they thought that 1) the absence of
> > a "NoPT" designation on the MENLO->HEMAN leg was both correct and
> > meaningful, and 2) that the AIM's description of the PT as a "required
> > maneuver" except under specific circumstances was meaningful.
> >
>
> Someone that thinks that is an idiot.

OK, if you say so.

rg

Fair enough.

On Tue, 04 Oct 2005 19:48:05 GMT, "Steven P. McNicoll"
> wrote:

>
>"Tim Auckland" > wrote in message
...
>>
>> You might have got an intersting response from the army. Chip's
>> original post implied they were approaching MINES from the east. HCH
>> is 27 miles southwet of MINES.
>>
>
>I know that. They also requested to hold at MINES for ten minutes. That
>tells me they're not in a hurry. It was clearly a training flight and the
>training was to be on VOR approach procedures. They requested the full
>VOR/DME approach so I'd give them every bit of it.
>

>> But the aircraft in question was /G, so he could fly direct MINES. And
>> MINES is an IAF, so an approach beginning there would be a "full
>> approach" ???
>>
>
> Yes, he could use GPS to fly direct to MINES. But if he wanted to use GPS why did he ask for the "full
> VOR/DME 22" approach? Check the plate, there's a GPS overlay, he could have used GPS exclusively to fly the
> approach. Requesting the "full VOR/DME 22" approach suggests the objective of their navigational exercise was
> VOR/DME approaches, not GPS approaches.

I see what you mean, thanks!

John

On Mon, 03 Oct 2005 09:32:39 GMT, "Steven P. McNicoll"
> wrote:

>I am aware of that interpretation, I am also aware that is NOT an
>interpretation supported by the FARs.

No, that's your interpretation. I assume it is based on YOUR reading of
14 CFR 91, 14 CFR 97, 8260.3 as well as the textual description of the
various SIAP's published by the FAA.

My reading of those parts, along with other documents, leads me to disagree
with your interpretation.

In instances where it is clear, unambigous, and supported by others whose
business it is to intepret these things correctly (i.e. Jepp), I choose to
rely on the interpretation of the FAA regulatory division counsel, in
deciding what is required by regulations. And I would recommend others do
so, too.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Mon, 03 Oct 2005 18:33:31 -0700, Ron Garret >
wrote:

>So this just occurred to me in the debate on procedure turns.
>
>The AIM famously says "The procedure turn is a required maneuver..."
>But the AIM is not regulatory. Is there anything in the FARs that
>requires a PT? I'm pretty sure there isn't anything in Part 91.
>Someone in another thread said that there was something in Part 97, but
>I can't find it.
>
>If nothing in the FARs requires a PT then a reasonable interpretation of
>the AIM is: "WHEN it is necessary to reverse course (which is determined
>at the pilot's discretion I suppose) you must do so by executing a PT
>(or a hold in lieu of)..." as opposed to, say, doing an Immelman or half
>a lazy eight.
>
>rg

Where does it state that the determination as to when a course reversal is
necessary is to be made by the pilot?

The procedure turn is described in the textual description of a SIAP as
published by the FAA and interpreted graphically by the chart makers (Jepp
and NACO, for the most part).

By regulation and legal intepretation, we are required to start a SIAP at
an IAF, unless receiving radar vectors to the FAC.

By regulation we are required to fly a SIAP as published when it is
necessary, and the SIAP is regulatory by inclusion by reference into 14 CFR
97.

If the SIAP includes a procedure turn, without qualification as to how one
is approaching that point (i.e. NoPT routings), then it becomes regulatory
by virtue of the above.

Having said that, it does happen from time to time that the chart makers
get it wrong, or the FAA forgets to add NoPT to certain routings. If you
find a route that you think should be marked NoPT and it is not, call and
they will correct it pretty quickly.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

In article >,
Ron Rosenfeld > wrote:

> On Mon, 03 Oct 2005 18:33:31 -0700, Ron Garret >
> wrote:
>
> >So this just occurred to me in the debate on procedure turns.
> >
> >The AIM famously says "The procedure turn is a required maneuver..."
> >But the AIM is not regulatory. Is there anything in the FARs that
> >requires a PT? I'm pretty sure there isn't anything in Part 91.
> >Someone in another thread said that there was something in Part 97, but
> >I can't find it.
> >
> >If nothing in the FARs requires a PT then a reasonable interpretation of
> >the AIM is: "WHEN it is necessary to reverse course (which is determined
> >at the pilot's discretion I suppose) you must do so by executing a PT
> >(or a hold in lieu of)..." as opposed to, say, doing an Immelman or half
> >a lazy eight.
> >
> >rg
>
> Where does it state that the determination as to when a course reversal is
> necessary is to be made by the pilot?

91.3(a)?

> The procedure turn is described in the textual description of a SIAP as
> published by the FAA and interpreted graphically by the chart makers (Jepp
> and NACO, for the most part).

I didn't know there were textual descriptions. Where can I find those?

> By regulation and legal intepretation, we are required to start a SIAP at
> an IAF, unless receiving radar vectors to the FAC.
>
> By regulation we are required to fly a SIAP as published when it is
> necessary, and the SIAP is regulatory by inclusion by reference into 14 CFR
> 97.
>
> If the SIAP includes a procedure turn, without qualification as to how one
> is approaching that point (i.e. NoPT routings), then it becomes regulatory
> by virtue of the above.
>
> Having said that, it does happen from time to time that the chart makers
> get it wrong, or the FAA forgets to add NoPT to certain routings. If you
> find a route that you think should be marked NoPT and it is not, call and
> they will correct it pretty quickly.

OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
is in use. Then you lose comm. What would you do and why?

rg

On Thu, 06 Oct 2005 00:12:01 -0700, Ron Garret >
wrote:

>In article >,
> Ron Rosenfeld > wrote:
>
>> On Mon, 03 Oct 2005 18:33:31 -0700, Ron Garret >
>> wrote:
>>

>>
>> Where does it state that the determination as to when a course reversal is
>> necessary is to be made by the pilot?
>
>91.3(a)?
>

But you need to be in an emergency situation to deviate from the other
rules of Part 91. I try to not allow my SIAP's deteriorate to that point
:-))


>> The procedure turn is described in the textual description of a SIAP as
>> published by the FAA and interpreted graphically by the chart makers (Jepp
>> and NACO, for the most part).
>
>I didn't know there were textual descriptions. Where can I find those?
>

I don't know of any web source for these. So far as I know, they are
available for inspection at FAA Headquarters Building, 800 Independence
Avenue, SW., Washington, DC 20591; the FAA Regional Office of the region in
which the affected airport is located; or the Flight Inspection Area Office
which originated the SIAP.

They are also available for purchase at the FAA Public Inquiry Center
(APA-200), FAA Headquarters Building, 800 Independence Avenue, SW.,
Washington, DC 20591; or the FAA Regional Office of the region in which the
affected airport is located.


>OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
>is in use. Then you lose comm. What would you do and why?
>

Being more familiar with Jepp charts, and having to rely on NACO charts for
that approach, perhaps I am missing some subtlety.

But assuming a non-emergency situation, not getting into the discussion of
what to do at SLI if you're ahead of your ETA, and also assuming IMC, I
would maintain the V21 MEA of 4000' until reaching SLI. At SLI I would
execute a racetrack type procedure turn on the SE side of the final
approach course, descending to 2600'. Passing SLI inbound I would cross
BWALT at or above 1500' and then continue my descent to the MDA and land if
I met the requirements of 91.175 and the runway were clear.

As to why? I would do that because that's how that SIAP is charted, and I
am obliged to follow the rules absent an emergency situation.

There is no provision I see for descending to the MEA prior to SLI absent
an emergency. (And the descent gradient from SLI-->KFUL far exceeds the
acceptable TERPs standards).

If it were an *emergency* situation, and I had to get on the ground ASAP,
it would be both appropriate and safe to use the MSA altitude of 2800' when
within 25 NM of SLI. At one mile or so from SLI, I would descend so as to
cross SLI at 2600' and then continue straight in.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

In article >,
Ron Rosenfeld > wrote:

> >OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
> >is in use. Then you lose comm. What would you do and why?
> >
>
> Being more familiar with Jepp charts, and having to rely on NACO charts for
> that approach, perhaps I am missing some subtlety.
>
> But assuming a non-emergency situation, not getting into the discussion of
> what to do at SLI if you're ahead of your ETA, and also assuming IMC, I
> would maintain the V21 MEA of 4000' until reaching SLI. At SLI I would
> execute a racetrack type procedure turn on the SE side of the final
> approach course, descending to 2600'. Passing SLI inbound I would cross
> BWALT at or above 1500' and then continue my descent to the MDA and land if
> I met the requirements of 91.175 and the runway were clear.
>
> As to why? I would do that because that's how that SIAP is charted

No, it isn't. There is no "racetrack type procedure turn" on the chart.
There is a hold that is part of the missed approach. And if you fly
that hold so as to end up at SLI inbound then you've flown it in the
wrong direction.

> There is no provision I see for descending to the MEA prior to SLI absent
> an emergency.

Huh? The MEA is 4000. I think you meant that you see no provision for
descending to 2600 on V21 prior to SLI. And you're right. There isn't
any.

So, once again, what do you do and why?

rg

On 10/6/2005 08:23, Ron Garret wrote:

> In article >,
> Ron Rosenfeld > wrote:
>
>> >OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
>> >is in use. Then you lose comm. What would you do and why?
>> >
>>
>> Being more familiar with Jepp charts, and having to rely on NACO charts for
>> that approach, perhaps I am missing some subtlety.
>>
>> But assuming a non-emergency situation, not getting into the discussion of
>> what to do at SLI if you're ahead of your ETA, and also assuming IMC, I
>> would maintain the V21 MEA of 4000' until reaching SLI. At SLI I would
>> execute a racetrack type procedure turn on the SE side of the final
>> approach course, descending to 2600'. Passing SLI inbound I would cross
>> BWALT at or above 1500' and then continue my descent to the MDA and land if
>> I met the requirements of 91.175 and the runway were clear.
>>
>> As to why? I would do that because that's how that SIAP is charted
>
> No, it isn't. There is no "racetrack type procedure turn" on the chart.
> There is a hold that is part of the missed approach. And if you fly
> that hold so as to end up at SLI inbound then you've flown it in the
> wrong direction.

I think Ron said he wasn't as familiar with the government charts.
However, if you look at the chart, the procedure turn is indicated
with the Barb, pointing 155 degrees. You can see, also, that if you
use AIBAS IAF, no procedure turn is necessary.

>
>> There is no provision I see for descending to the MEA prior to SLI absent
>> an emergency.
>
> Huh? The MEA is 4000. I think you meant that you see no provision for
> descending to 2600 on V21 prior to SLI. And you're right. There isn't
> any.
>
> So, once again, what do you do and why?

When you hit the VOR, you turn outbound for the procedure turn, 200
degrees. During the outbound leg (and the procedure turn) you can
begin your descent to 2600'. You should time it such that you are
at 2600' before you get back to the VOR.

Note that you need to remain within 10NM of the VOR during the turn,
so you can go outbound quite a log way (to aid in the descent) before
actually beginning the physical turn.

>
> rg


--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

"Ron Rosenfeld" > wrote in message
...
>
> No, that's your interpretation. I assume it is based on YOUR reading of
> 14 CFR 91, 14 CFR 97, 8260.3 as well as the textual description of the
> various SIAP's published by the FAA.
>
> My reading of those parts, along with other documents, leads me to
> disagree with your interpretation.
>

So make your case. Fill in the steps between "In the case of a radar vector
to a final approach course or fix, a timed approach from a holding fix, or
an approach for which the procedure specifies 'No PT,' no pilot may make a
procedure turn unless cleared to do so by ATC.[FAR 91.175(j)]", "Procedure
turn means the maneuver prescribed when it is necessary to reverse direction
to establish the aircraft on an intermediate or final approach course. The
outbound course, direction of turn, distance within which the turn must be
completed, and minimum altitude are specified in the procedure. However, the
point at which the turn may be commenced, and the type and rate of turn, is
left to the discretion of the pilot. [FAR 97.3(p)]", and, "If a SIAP does
contain a procedure turn and ATC has cleared a pilot to execute the SIAP,
the pilot must make the procedure turn when one of the conditions of Section
91.175(j) is not present.", [statement of Patricia R. Lane].


>
> In instances where it is clear, unambigous, and supported by others whose
> business it is to intepret these things correctly (i.e. Jepp), I choose to
> rely on the interpretation of the FAA regulatory division counsel, in
> deciding what is required by regulations. And I would recommend others do
> so, too.
>

I prefer logic. If it was clear and unambiguous this issue would never be
discussed here.

In article >,
Mark Hansen > wrote:

> On 10/6/2005 08:23, Ron Garret wrote:
>
> > In article >,
> > Ron Rosenfeld > wrote:
> >
> >> >OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
> >> >is in use. Then you lose comm. What would you do and why?
> >> >
> >>
> >> Being more familiar with Jepp charts, and having to rely on NACO charts for
> >> that approach, perhaps I am missing some subtlety.
> >>
> >> But assuming a non-emergency situation, not getting into the discussion of
> >> what to do at SLI if you're ahead of your ETA, and also assuming IMC, I
> >> would maintain the V21 MEA of 4000' until reaching SLI. At SLI I would
> >> execute a racetrack type procedure turn on the SE side of the final
> >> approach course, descending to 2600'. Passing SLI inbound I would cross
> >> BWALT at or above 1500' and then continue my descent to the MDA and land if
> >> I met the requirements of 91.175 and the runway were clear.
> >>
> >> As to why? I would do that because that's how that SIAP is charted
> >
> > No, it isn't. There is no "racetrack type procedure turn" on the chart.
> > There is a hold that is part of the missed approach. And if you fly
> > that hold so as to end up at SLI inbound then you've flown it in the
> > wrong direction.
>
> I think Ron said he wasn't as familiar with the government charts.

There are two Rons in play here :-) Ron G. (that's me) is looking at a
government chart.

> However, if you look at the chart, the procedure turn is indicated
> with the Barb, pointing 155 degrees. You can see, also, that if you
> use AIBAS IAF, no procedure turn is necessary.

True, but you're not coming from ALBAS. You're coming in on V21. (As
an aside, doesn't it make intuitive sense that, from a TERPS point of
view, if no procedure turn is required from ALBAS that none should be
required coming from V21?)

> When you hit the VOR, you turn outbound for the procedure turn, 200
> degrees. During the outbound leg (and the procedure turn) you can
> begin your descent to 2600'. You should time it such that you are
> at 2600' before you get back to the VOR.
>
> Note that you need to remain within 10NM of the VOR during the turn,
> so you can go outbound quite a log way (to aid in the descent) before
> actually beginning the physical turn.

I presume you mean turn to a 200 heading, not turn 200 degrees. V21 is
on a 202 heading. You would be turning 178 degrees or 182 degrees
depending on which way you made the turn. Now...

Do you really turn to a 200 heading, or do you turn to intercept the SLI
200 radial? Those are not the same maneuver.

Do you turn left or right and why?

At what point are you "established on the outbound leg", when you reach
a 200 heading, or when you are established on the SLI 200 radial?

Finally, suppose you flew this Byzantine procedure... by the time you
got to the actual procedure turn (which, I note in passing, would be
your SECOND course reversal) you would be in almost exactly the same
spot as you were just minutes ago when you were on V21. Why is it safe
to descend now but not then?

rg

"Ron Rosenfeld" > wrote in message
...
>
> Where does it state that the determination as to when a course reversal is
> necessary is to be made by the pilot?
>

Where does it state when a course reversal is necessary at all?


>
> By regulation we are required to fly a SIAP as published when it is
> necessary, and the SIAP is regulatory by inclusion by reference into 14
> CFR 97.
>

I don't think anybody disputes that, but you're saying we are also required
by regulation to fly a SIAP as published when it is NOT necessary. Yet you
can't cite any regulation that says that.


>
> If the SIAP includes a procedure turn, without qualification as to how one
> is approaching that point (i.e. NoPT routings), then it becomes regulatory
> by virtue of the above.
>

Alright, here's a real world example for you. You're flying AWI123 from
KORD to KGRB, Chicago departure puts you in the east departure track on a
360 heading and hands you off to Chicago Center. Around the Kenosha, WI,
area Chicago Center tells you to proceed direct to GRB VORTAC. Down the
road a piece you're handed off to Green Bay approach. At GRB the ILS RWY 36
approach is in use, and the approach controller notices you're present track
will intercept the localizer about fifteen miles from DEPRE, the LOM/IAF.
On initial contact you're told "descend and maintain 3,000 join the runway
36 localizer". About three minutes later you hear the same instruction
issued to EGF456. When you're about five miles from DEPRE the approach
controller says "AWI123 cleared ILS runway three six contact tower one one
eight point seven." When you reach DEPRE will you continue towards the
runway or will you start a procedure turn?

http://www.myairplane.com/databases/approach/pdfs/00873I36.PDF

"Ron Garret" > wrote in message
...
>
> 91.3(a)?
>

Works for me.


>
> OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
> is in use. Then you lose comm. What would you do and why?
>

It's IMC. I'd track the 020 radial out of SLI, fly the approach and land
because doing anything else is nutty.

"Ron Rosenfeld" > wrote in message
...
>>
>>91.3(a)?
>>
>
> But you need to be in an emergency situation to deviate from the other
> rules of Part 91. I try to not allow my SIAP's deteriorate to that point
> :-))
>

FAR 91.3(a) says nothing about an emergency situation.

In response to Steven McNicoll's scenario:

It wasn't clear to me from the scenario you wrote whether I'd be
arriving from the north or elsewhere. If from the north, I'd have to
fly the published PT because a course reversal is necessary. So, upon
arriving DEPRE, I'd continue south on the localizer for about 1.5
minutes, and fly any type of PT to the west of the localizer. Upon
returning to the localizer, I'd follow the glideslope down.

If I'm approaching from the south (which is probably what you meant)
and hadn't already arrived at GRB VORTAC before being cleared for the
ILS, I'd join the localizer and:
1) when I'm within 10 nm of DEPRE, descend to 2700 and inform approach
that I'm "leaving 3000 for 2700"; and
2) capture and follow the glide slope.

In my opinion, the PT is unnecessary because there is no course
reversal. Some would probably argue that you've been given radar
vectors because your prior instruction was direct GRB VORTAC.

In this northbound scenario, let's say you weren't cleared to 3000, and
were still at an en route altitude, suppose 6000, when approach clears
you for the ILS. You'd have to lose altitude fast. I still wouldn't
do the PT. I'd instead opt to descend in a holding pattern at DEPRE
(which is an IAF) down to 2200 (or capture glideslope northbound when
south of DEPRE on an inbound leg of the hold). Of course, I'd let
approach (or tower, as appropriate) know what I'm doing so that ATC is
not surprised. If they need the airspace for someone else, they'd let
me know. Doing so also keeps me closer to the airport in case
something goes wrong when I'm descending. I think you could opt to do
a PT instead, but how would you know when to begin the PT if you're
approaching from the south and don't have a GPS?

In article et>,
"Steven P. McNicoll" > wrote:

> "Ron Rosenfeld" > wrote in message
> ...
> >
> > Where does it state that the determination as to when a course reversal is
> > necessary is to be made by the pilot?
> >
>
> Where does it state when a course reversal is necessary at all?
>
>
> >
> > By regulation we are required to fly a SIAP as published when it is
> > necessary, and the SIAP is regulatory by inclusion by reference into 14
> > CFR 97.
> >
>
> I don't think anybody disputes that, but you're saying we are also required
> by regulation to fly a SIAP as published when it is NOT necessary. Yet you
> can't cite any regulation that says that.
>
>
> >
> > If the SIAP includes a procedure turn, without qualification as to how one
> > is approaching that point (i.e. NoPT routings), then it becomes regulatory
> > by virtue of the above.
> >
>
> Alright, here's a real world example for you. You're flying AWI123 from
> KORD to KGRB, Chicago departure puts you in the east departure track on a
> 360 heading and hands you off to Chicago Center. Around the Kenosha, WI,
> area Chicago Center tells you to proceed direct to GRB VORTAC. Down the
> road a piece you're handed off to Green Bay approach. At GRB the ILS RWY 36
> approach is in use, and the approach controller notices you're present track
> will intercept the localizer about fifteen miles from DEPRE, the LOM/IAF.
> On initial contact you're told "descend and maintain 3,000 join the runway
> 36 localizer". About three minutes later you hear the same instruction
> issued to EGF456. When you're about five miles from DEPRE the approach
> controller says "AWI123 cleared ILS runway three six contact tower one one
> eight point seven." When you reach DEPRE will you continue towards the
> runway or will you start a procedure turn?
>
> http://www.myairplane.com/databases/approach/pdfs/00873I36.PDF

I don't think that's a very good example because (one could argue)
you're being radar vectored to the approach, which is specifically cited
in the AIM as one of the situations where a PT is not needed.

rg

On 10/6/2005 10:51, Ron Garret wrote:

> In article >,
> Mark Hansen > wrote:
>
>> On 10/6/2005 08:23, Ron Garret wrote:
>>
>> > In article >,
>> > Ron Rosenfeld > wrote:
>> >
>> >> >OK, so say you're flying AVX V21 SLI FUL. Fullerton ATIS says the VOR-A
>> >> >is in use. Then you lose comm. What would you do and why?
>> >> >
>> >>
>> >> Being more familiar with Jepp charts, and having to rely on NACO charts for
>> >> that approach, perhaps I am missing some subtlety.
>> >>
>> >> But assuming a non-emergency situation, not getting into the discussion of
>> >> what to do at SLI if you're ahead of your ETA, and also assuming IMC, I
>> >> would maintain the V21 MEA of 4000' until reaching SLI. At SLI I would
>> >> execute a racetrack type procedure turn on the SE side of the final
>> >> approach course, descending to 2600'. Passing SLI inbound I would cross
>> >> BWALT at or above 1500' and then continue my descent to the MDA and land if
>> >> I met the requirements of 91.175 and the runway were clear.
>> >>
>> >> As to why? I would do that because that's how that SIAP is charted
>> >
>> > No, it isn't. There is no "racetrack type procedure turn" on the chart.
>> > There is a hold that is part of the missed approach. And if you fly
>> > that hold so as to end up at SLI inbound then you've flown it in the
>> > wrong direction.
>>
>> I think Ron said he wasn't as familiar with the government charts.
>
> There are two Rons in play here :-) Ron G. (that's me) is looking at a
> government chart.

Thanks, but I wasn't confused about that. ;-)

>
>> However, if you look at the chart, the procedure turn is indicated
>> with the Barb, pointing 155 degrees. You can see, also, that if you
>> use AIBAS IAF, no procedure turn is necessary.
>
> True, but you're not coming from ALBAS. You're coming in on V21.

My point was that *if you were using ALBAS*, you would not need the
procedure turn. According to the SIAP, if you're using the VOR as
the IAF, you would need to use the procedure turn.

> (As
> an aside, doesn't it make intuitive sense that, from a TERPS point of
> view, if no procedure turn is required from ALBAS that none should be
> required coming from V21?)

Victor 21 is not a feeder route for the approach. If it was, it would
be charted as such. So you may be able to argue your point with the
procedure designers...

>
>> When you hit the VOR, you turn outbound for the procedure turn, 200
>> degrees. During the outbound leg (and the procedure turn) you can
>> begin your descent to 2600'. You should time it such that you are
>> at 2600' before you get back to the VOR.
>>
>> Note that you need to remain within 10NM of the VOR during the turn,
>> so you can go outbound quite a log way (to aid in the descent) before
>> actually beginning the physical turn.
>
> I presume you mean turn to a 200 heading, not turn 200 degrees.

Yes, you can because I said "Turn, 200 degrees" instead of "turn 200 degrees",
which wouldn't make any sense anyway...

Sorry it wasn't clear.

> V21 is
> on a 202 heading. You would be turning 178 degrees or 182 degrees
> depending on which way you made the turn. Now...

Right, because V21 is not a feeder route...

>
> Do you really turn to a 200 heading, or do you turn to intercept the SLI
> 200 radial? Those are not the same maneuver.

You intercept the radial, of course...

>
> Do you turn left or right and why?

You turn toward the protected side of the procedure area, which is to
the southeast.

>
> At what point are you "established on the outbound leg", when you reach
> a 200 heading, or when you are established on the SLI 200 radial?

I'll bet you can answer that one yourself ;-)


>
> Finally, suppose you flew this Byzantine procedure... by the time you
> got to the actual procedure turn (which, I note in passing, would be
> your SECOND course reversal) you would be in almost exactly the same
> spot as you were just minutes ago when you were on V21. Why is it safe
> to descend now but not then?


What is the MEA on the victor airway (I don't have it here...) Something
like 4000'? They aren't going to change the MEA of the airway just to
satisfy an approach (or at least they didn't in this case). So, you'll
be approaching the VOR at 4000' ... much to high to begin the approach.

Now if you look at the feeder route from AIBAS, it has a minimum
altitude of 2600'. This is exactly what you want. If you don't want
to do the PT, use this IAF rather than the VOR.

Note that WILMA requires a PT because it is not aligned within 30
degrees of the FAC...

Now, if they created a fix somewhere out on V21, and wrote a feeder
route from that fix, then you could. Effectively, you've be flying
V21 to the fix, then initiating the SIAP from there. However, they
didn't, so you can't ;-)

That gets in to why the designers set up the approach this way, which
I don't know. As a pilot using the procedure, I need only to interpret
the chart. I don't really have to understand the "whys" behind it.

>
> rg


--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

I forgot to mentiond that I'd hold south of DEPRE, left turns.

On Thu, 06 Oct 2005 16:37:34 GMT, "Steven P. McNicoll"
> wrote:

>So make your case

I've already made my case. You may reread it and the references until you
understand it, or choose to disagree.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Thu, 06 Oct 2005 08:23:29 -0700, Ron Garret >
wrote:

>No, it isn't. There is no "racetrack type procedure turn" on the chart.
>There is a hold that is part of the missed approach. And if you fly
>that hold so as to end up at SLI inbound then you've flown it in the
>wrong direction.

Huh? On the NACO chart I am looking at there is a barb on R-200 from SLI
with 155°/335° on it. To the best of my knowledge, that indicates that the
type of procedure turn is up to the pilot.

Perhaps you are not aware that a racetrack pattern is one of the allowable
types of procedure turns. Review your IFR materials and you will discover
that it is.

To be more precise, I would turn right at SLI to a heading that will allow
me to track parallel to the inbound 020° course so that, with wind
correction, when I turn inbound I will be established on the FAC INBOUND to
SLI.

Other methods are acceptable, but you asked what *I* would do. You could
also, (and I probably would in mountainous terrain without GPS), continue
the right turn at SLI until intercepting R-200, and then do a 45° PT on the
SE side. But the choice of PT type is up to the pilot, in this instance.

And your correct about the MEA statement. I meant to type "descend *from*
the MEA" and not "*to* the MEA".


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"rps" > wrote in message
ups.com...
>
> In response to Steven McNicoll's scenario:
>
> It wasn't clear to me from the scenario you wrote whether I'd be
> arriving from the north or elsewhere.
>

KGRB is about 150 miles north of KORD.


>
> If from the north, I'd have to
> fly the published PT because a course reversal is necessary. So, upon
> arriving DEPRE, I'd continue south on the localizer for about 1.5
> minutes, and fly any type of PT to the west of the localizer. Upon
> returning to the localizer, I'd follow the glideslope down.
>
> If I'm approaching from the south (which is probably what you meant)
> and hadn't already arrived at GRB VORTAC
>

I included a link to the approach plate, it shows the VORTAC to be about
five miles NNW of the field.


>
> before being cleared for the
> ILS, I'd join the localizer and:
> 1) when I'm within 10 nm of DEPRE, descend to 2700 and inform approach
> that I'm "leaving 3000 for 2700"; and
> 2) capture and follow the glide slope.
>

If you begin descent when ten miles from DEPRE you've busted your altitude.
The last instruction was "descend and maintain 3,000, join the runway 36
localizer", approach clearance was issued at five miles from DEPRE.


>
> In my opinion, the PT is unnecessary because there is no course
> reversal. Some would probably argue that you've been given radar
> vectors because your prior instruction was direct GRB VORTAC.
>

Those making that argument would be wrong. If you're on your own navigation
direct to a fix you're not being vectored, you're being vectored when you're
on an assigned heading.

"Ron Garret" > wrote in message
...
>
> I don't think that's a very good example because (one could argue)
> you're being radar vectored to the approach, which is specifically cited
> in the AIM as one of the situations where a PT is not needed.
>

You're not being radar vectored to the approach in this example. The last
vector was issued by Chicago departure, Chicago Center then issued direct to
GRB VORTAC. That's the route clearance you're operating on when Green Bay
approach instructs you to join the runway 36 localizer.

"Ron Rosenfeld" > wrote in message
...
>
> I've already made my case. You may reread it and the references until you
> understand it, or choose to disagree.
>

I missed the message in which you did that, didn't make it through my
provider. Could you copy and paste it in reply to this message?

"rps" > wrote in message
oups.com...
>
> I forgot to mentiond that I'd hold south of DEPRE, left turns.
>

Any concern about EGF456?

Steven P. McNicoll said:

"If you begin descent when ten miles from DEPRE you've busted your
altitude.
The last instruction was 'descend and maintain 3,000, join the runway
36
localizer', approach clearance was issued at five miles from DEPRE."

I thought the last instruction was "AWI123 cleared ILS runway three six
contact tower one one eight point seven." You may not be able to
intercept the glideslope from 3000 (e.g., if the signal is weak there),
which is why I suggest descending.

According to the plate, if you were flying the PT, upon crossing DEPRE
southbound, you can descend to 2700 and track outbound on the PT and
then descend to 2200 once you've begun turning inbound on the PT. The
PT area includes the entire area south of DEPRE and west of the
localizer for a radius of 10 nm. So, if you're on the localizer, I
believe you can safely descend to 2700 so that you have a chance of
capturing the glideslope from below. I suggested to let ATC know so
that ATC can correct you if that's not what they want you to do.

Good point - I forgot about the other craft. I'd hope that my
communication with ATC about my plan to enter the hold and descend
would alert ATC that there may be a conflict.

On Thu, 06 Oct 2005 18:06:34 GMT, "Steven P. McNicoll"
> wrote:


>Alright, here's a real world example for you. You're flying AWI123 from
>KORD to KGRB, Chicago departure puts you in the east departure track on a
>360 heading and hands you off to Chicago Center. Around the Kenosha, WI,
>area Chicago Center tells you to proceed direct to GRB VORTAC. Down the
>road a piece you're handed off to Green Bay approach. At GRB the ILS RWY 36
>approach is in use, and the approach controller notices you're present track
>will intercept the localizer about fifteen miles from DEPRE, the LOM/IAF.
>On initial contact you're told "descend and maintain 3,000 join the runway
>36 localizer". About three minutes later you hear the same instruction
>issued to EGF456. When you're about five miles from DEPRE the approach
>controller says "AWI123 cleared ILS runway three six contact tower one one
>eight point seven." When you reach DEPRE will you continue towards the
>runway or will you start a procedure turn?
>
>http://www.myairplane.com/databases/approach/pdfs/00873I36.PDF
>

If I understand your scenario properly, I have intercepted the FAC about 15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

In article . net>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > I don't think that's a very good example because (one could argue)
> > you're being radar vectored to the approach, which is specifically cited
> > in the AIM as one of the situations where a PT is not needed.
> >
>
> You're not being radar vectored to the approach in this example. The last
> vector was issued by Chicago departure, Chicago Center then issued direct to
> GRB VORTAC. That's the route clearance you're operating on when Green Bay
> approach instructs you to join the runway 36 localizer.

Yes, but I would think that the instruction to join the localizer
constitutes a radar vector, notwithstanding the fact that the controller
may or may not have actually voiced the word "vector".

rg

On Thu, 06 Oct 2005 17:12:16 -0400, Ron Rosenfeld
> wrote:
>
>If I understand your scenario properly, I have intercepted the FAC about 15
>miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
>am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
>be below the GP at that point so I would just continue along until
>intercepting the GP, and then descend into the airport.
>
>The presence of an aircraft behind me is irrelevant.
>
>What is your point?

Ron,

You've lsot me a bit here. I thought your earlier posts and
references to 97.20 were arguing that a procedure turn is mandatory by
regulation in all cases when it's charted and the standard exceptions
(NoPT, vectors to final, etc.) don't apply.

The standard exceptions don't apply in this scenario proposed by
Steven.

If I misunderstood your earlier posts about 97.20, then perhaps we've
had a similar point of view all along.

I'm intrigued.

Tim.

Correction - instead of "then descend to 2200 once you've begun turning
inbound on the PT" I should have written "then descend to 2200 once
you've begun turning inbound onto the FAC."

"rps" > wrote in message
oups.com...
>
> Steven P. McNicoll said:
>
> "If you begin descent when ten miles from DEPRE you've busted your
> altitude. The last instruction was 'descend and maintain 3,000, join the
> runway 36 localizer', approach clearance was issued at five miles from
> DEPRE."
>
> I thought the last instruction was "AWI123 cleared ILS runway three six
> contact tower one one eight point seven." You may not be able to
> intercept the glideslope from 3000 (e.g., if the signal is weak there),
> which is why I suggest descending.
>

You might want to read the scenario again. The approach clearance was
issued when the aircraft was five miles from DEPRE, so when you're ten miles
from DEPRE that hasn't happened yet. When ten miles from DEPRE the last
instruction was indeed "descend and maintain 3,000, join the runway 36
localizer". When you're five miles from DEPRE you're about 700' below the
glideslope and less than tem miles from the GS transmitter. The signal is
fine.

"rps" > wrote in message
ups.com...
>
> Good point - I forgot about the other craft. I'd hope that my
> communication with ATC about my plan to enter the hold and descend
> would alert ATC that there may be a conflict.
>

Yeah, they'll probably break you out and put you behind him.

"Ron Rosenfeld" > wrote in message
...
>
> If I understand your scenario properly, I have intercepted the FAC about
> 15
> miles South of DEPRE and then turned inbound (to the N, towards DEPRE).
> I
> am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I
> should
> be below the GP at that point so I would just continue along until
> intercepting the GP, and then descend into the airport.
>
> The presence of an aircraft behind me is irrelevant.
>
> What is your point?
>

Why did you not execute the procedure turn? You've not been vectored to a
final approach course or fix, you're not an a segment marked NoPT, and
you've not been cleared for a timed approach from a holding fix. Is it not
your position that if the procedure has a PT charted it must be flown unless
one of those applies?

"Ron Garret" > wrote in message
...
>
> Yes, but I would think that the instruction to join the localizer
> constitutes a radar vector, notwithstanding the fact that the controller
> may or may not have actually voiced the word "vector".
>

The instruction to join the localizer does not constitute a radar vector.
If you're being vectored the controller will either assign a magnetic
heading to be flown or tell you to turn some number of degrees left or
right.

On Fri, 07 Oct 2005 00:46:46 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> If I understand your scenario properly, I have intercepted the FAC about
>> 15
>> miles South of DEPRE and then turned inbound (to the N, towards DEPRE).
>> I
>> am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I
>> should
>> be below the GP at that point so I would just continue along until
>> intercepting the GP, and then descend into the airport.
>>
>> The presence of an aircraft behind me is irrelevant.
>>
>> What is your point?
>>
>
>Why did you not execute the procedure turn? You've not been vectored to a
>final approach course or fix, you're not an a segment marked NoPT, and
>you've not been cleared for a timed approach from a holding fix. Is it not
>your position that if the procedure has a PT charted it must be flown unless
>one of those applies?
>

I would have assumed this was a "radar vectors to final" situation and
queried ATC to verify, since they didn't use the magic words that I
understand to be necessary for me to assume radar vectors. But ATC has had
me lined up with the FAC for quite some distance; I've been in radar
contact; I've been assigned an appropriate altitude to intercept the GP
from below; I've not crossed any IAF prior to DEPRE.

If that confirmation is not forthcoming, then I would inform ATC that I am
obliged to execute a procedure turn at DEPRE. I would maintain my last
assigned altitude of 3000' until crossing DEPRE.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Thu, 06 Oct 2005 16:18:46 -0600, Tim Auckland > wrote:

>On Thu, 06 Oct 2005 17:12:16 -0400, Ron Rosenfeld
> wrote:
>>
>>If I understand your scenario properly, I have intercepted the FAC about 15
>>miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
>>am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
>>be below the GP at that point so I would just continue along until
>>intercepting the GP, and then descend into the airport.
>>
>>The presence of an aircraft behind me is irrelevant.
>>
>>What is your point?
>
>Ron,
>
>You've lsot me a bit here. I thought your earlier posts and
>references to 97.20 were arguing that a procedure turn is mandatory by
>regulation in all cases when it's charted and the standard exceptions
>(NoPT, vectors to final, etc.) don't apply.
>
>The standard exceptions don't apply in this scenario proposed by
>Steven.
>
>If I misunderstood your earlier posts about 97.20, then perhaps we've
>had a similar point of view all along.
>
>I'm intrigued.
>
>Tim.

As I just wrote to Steve, I would have assumed that ATC was setting this up
as a "radar vectors to final situation" and queried them to ensure there
was no misunderstanding since they did not use the standard verbiage. But
the way I was set up was identical to that used for radar vectors to final.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
>
> I would have assumed this was a "radar vectors to final" situation and
> queried ATC to verify, since they didn't use the magic words that I
> understand to be necessary for me to assume radar vectors.
>

Why would you have assumed it was a "radar vectors to final" situation if
they didn't use the magic words that you understand to be necessary to
assume radar vectors? You're not being vectored in this situation, that
should be clear.


>
> But ATC has had
> me lined up with the FAC for quite some distance; I've been in radar
> contact; I've been assigned an appropriate altitude to intercept the GP
> from below; I've not crossed any IAF prior to DEPRE.
>

The approach controller did nothing to line you up with the FAC. He simply
told you to intercept the FAC as your previous clearance of direct GRB
VORTAC crossed it some fifteen miles from the LOM at a shallow angle.


>
> If that confirmation is not forthcoming, then I would inform ATC that I am
> obliged to execute a procedure turn at DEPRE. I would maintain my last
> assigned altitude of 3000' until crossing DEPRE.
>

And when they informed you that you weren't being vectored you'd proceed to
fly the PT turn, which upon completion you'd be in the exact same position.

Of course, that wouldn't happen. Upon informing ATC you felt obligated to
fly the PT they'd vector you out of the way of the following traffic. Then
they'd either vector you back to the FAC, which would prohibit flying the
PT, or send you direct to the IAF so you could happily fly your PT without
endangering anyone else.

> ... On initial contact you're told "descend and maintain 3,000 join the runway
> 36 localizer"...


As I understand things, the PT is what you do when a course reversal is
required. So, is a course reversal required here? I think not.
Therefore I would not do a PT - I'd just fly the localizer when cleared
for the approach.

When doing a PT, the manner of turn is up to the pilot (90-270,
45-180-45, racetrack, immelman). So what is special about a PT? It's
just a U-turn (within the protected area), and not even a special kind
of U-turn.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" > wrote in message
. ..
>
> As I understand things, the PT is what you do when a course reversal is
> required. So, is a course reversal required here? I think not. Therefore
> I would not do a PT - I'd just fly the localizer when cleared for the
> approach.
>

Then you'd be in agreement with the thousands that have actually flown this
example. I've never heard of anyone that decided to fly the PT, and never
heard of anyone violated for not flying the PT.

In article >,
Mark Hansen > wrote:

> Now, if they created a fix somewhere out on V21, and wrote a feeder
> route from that fix, then you could. Effectively, you've be flying
> V21 to the fix, then initiating the SIAP from there. However, they
> didn't, so you can't ;-)

OK, I'll buy that.

I wonder if Steven P. McNicoll buys it too.

And I wonder what Socal Approach would have to say about it. (I think
I'll go find out. What a great excuse to fly to Catalina!)

rg

On Fri, 07 Oct 2005 03:40:31 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> I would have assumed this was a "radar vectors to final" situation and
>> queried ATC to verify, since they didn't use the magic words that I
>> understand to be necessary for me to assume radar vectors.
>>
>
>Why would you have assumed it was a "radar vectors to final" situation if
>they didn't use the magic words that you understand to be necessary to
>assume radar vectors? You're not being vectored in this situation, that
>should be clear.
>
>
>>
>> But ATC has had
>> me lined up with the FAC for quite some distance; I've been in radar
>> contact; I've been assigned an appropriate altitude to intercept the GP
>> from below; I've not crossed any IAF prior to DEPRE.
>>
>
>The approach controller did nothing to line you up with the FAC. He simply
>told you to intercept the FAC as your previous clearance of direct GRB
>VORTAC crossed it some fifteen miles from the LOM at a shallow angle.
>
>
>>
>> If that confirmation is not forthcoming, then I would inform ATC that I am
>> obliged to execute a procedure turn at DEPRE. I would maintain my last
>> assigned altitude of 3000' until crossing DEPRE.
>>
>
>And when they informed you that you weren't being vectored you'd proceed to
>fly the PT turn, which upon completion you'd be in the exact same position.
>
>Of course, that wouldn't happen. Upon informing ATC you felt obligated to
>fly the PT they'd vector you out of the way of the following traffic. Then
>they'd either vector you back to the FAC, which would prohibit flying the
>PT, or send you direct to the IAF so you could happily fly your PT without
>endangering anyone else.
>
Well, there are FAA facilities that do not follow the same rules as they
are published and interpreted by Washington. SoCal is another. There has
been a push to standardize these kinds of things.

There was an old (1977) legal opinion indicating that pilots could get
authorization from ATC to eliminate PT's when they were sort of lined up
with the FAC and at an appropriate altitude. This supposedly was
eliminated by the 1994 opinion; however, that 1994 opinion (which I quoted
before) referred specifically to non-radar environments and was mute on
radar environments.

There is no question in my mind that it would be safe to fly straight in
from the position you set up. Perhaps the simplest way of getting that ATC
facilities practice in line with the regulations would be to designate
SENNA as an IAF. The route from OSH, which includes the route from SENNA
to DEPRE, is a NoPT route, and ATC has placed me on that route crossing
SENNA.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

> Then you'd be in agreement with the thousands that have actually flown this
> example.

Ok, now let's change the example a bit.

This time, on initial contact you're told "maintain 5,000 join the
runway 36 localizer" Then, five miles from DEPRE the approach
controller says "AWI123 cleared ILS runway three six contact tower one
one eight point seven."

You acknowledge, then lose coms. Dive? PT? Racetrack?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

My closing thoughts:

If I do ever find myself in the scenario described, I think I'd let
ATC know what I'm planning to do and fly straight on in.

In the apparently highly unikely case that I did get challenged by a
FAA inspector, I'd base my defense on 97.3(p), arguing that a
procedure turn is by definition only relevant "when it is necessary to
reverse direction to establish the aircarft on an intermediate or
final approach course."

It seems to me that the 1994 opinion doesn't gel with 97.3(p). I
think it promotes unnecessary maneuvering in IMC, and I think it would
be a good thing if it were revisited.

I'm not a lawyer and I don't fully understand all the legal
ramifications of the 1994 opinion, but wouldn't it be great if common
sense were allowed to prevail every now and then.

(Just my $0.02 worth.)

Tim.

On Fri, 07 Oct 2005 08:40:07 -0400, Ron Rosenfeld
> wrote:

>On Fri, 07 Oct 2005 03:40:31 GMT, "Steven P. McNicoll"
> wrote:
>
>>
>>"Ron Rosenfeld" > wrote in message
...
>>>
>>> I would have assumed this was a "radar vectors to final" situation and
>>> queried ATC to verify, since they didn't use the magic words that I
>>> understand to be necessary for me to assume radar vectors.
>>>
>>
>>Why would you have assumed it was a "radar vectors to final" situation if
>>they didn't use the magic words that you understand to be necessary to
>>assume radar vectors? You're not being vectored in this situation, that
>>should be clear.
>>
>>
>>>
>>> But ATC has had
>>> me lined up with the FAC for quite some distance; I've been in radar
>>> contact; I've been assigned an appropriate altitude to intercept the GP
>>> from below; I've not crossed any IAF prior to DEPRE.
>>>
>>
>>The approach controller did nothing to line you up with the FAC. He simply
>>told you to intercept the FAC as your previous clearance of direct GRB
>>VORTAC crossed it some fifteen miles from the LOM at a shallow angle.
>>
>>
>>>
>>> If that confirmation is not forthcoming, then I would inform ATC that I am
>>> obliged to execute a procedure turn at DEPRE. I would maintain my last
>>> assigned altitude of 3000' until crossing DEPRE.
>>>
>>
>>And when they informed you that you weren't being vectored you'd proceed to
>>fly the PT turn, which upon completion you'd be in the exact same position.
>>
>>Of course, that wouldn't happen. Upon informing ATC you felt obligated to
>>fly the PT they'd vector you out of the way of the following traffic. Then
>>they'd either vector you back to the FAC, which would prohibit flying the
>>PT, or send you direct to the IAF so you could happily fly your PT without
>>endangering anyone else.
>>
>Well, there are FAA facilities that do not follow the same rules as they
>are published and interpreted by Washington. SoCal is another. There has
>been a push to standardize these kinds of things.
>
>There was an old (1977) legal opinion indicating that pilots could get
>authorization from ATC to eliminate PT's when they were sort of lined up
>with the FAC and at an appropriate altitude. This supposedly was
>eliminated by the 1994 opinion; however, that 1994 opinion (which I quoted
>before) referred specifically to non-radar environments and was mute on
>radar environments.
>
>There is no question in my mind that it would be safe to fly straight in
>from the position you set up. Perhaps the simplest way of getting that ATC
>facilities practice in line with the regulations would be to designate
>SENNA as an IAF. The route from OSH, which includes the route from SENNA
>to DEPRE, is a NoPT route, and ATC has placed me on that route crossing
>SENNA.
>Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

I agree, though telling ATC may not even be required but may keep you
safe. Moreover, I think the FAA meant as much based on their
explanation of changes that added the additional language to the AIM
that confused us:

"This [change to the AIM] is for those folks that think a procedure
turn is required unless it meets one of the exceptions which does not
include 'if the aircraft is aligned within 90 degrees of the inbound
course.'"

See http://www.faa.gov/ATPUBS/AIM/Exofchg/exchg3.html, and scroll down
to entry w.

So, the FAA added this language to satisfy people who thought a
procedure turn is required even when no course reversal is required
(e.g., when intercepting the FAC at 89 degrees) at the correct altitude.

On 7 Oct 2005 11:22:03 -0700, "rps" > wrote:

>I agree, though telling ATC may not even be required but may keep you
>safe. Moreover, I think the FAA meant as much based on their
>explanation of changes that added the additional language to the AIM
>that confused us:
>
>"This [change to the AIM] is for those folks that think a procedure
>turn is required unless it meets one of the exceptions which does not
>include 'if the aircraft is aligned within 90 degrees of the inbound
>course.'"
>
>See http://www.faa.gov/ATPUBS/AIM/Exofchg/exchg3.html, and scroll down
>to entry w.
>
>So, the FAA added this language to satisfy people who thought a
>procedure turn is required even when no course reversal is required
>(e.g., when intercepting the FAC at 89 degrees) at the correct altitude.


Thank you for posting that link.

That explanation of intent seems to be a lot more clear than previous
discussions of the change on this and other groups would lead one to
believe. It makes sense and it lends some authority to not executing a PT
in the type of instance Steve posed (even though the AIM is not
regulatory).
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Mark Hansen" > wrote in message
...
>
> Victor 21 is not a feeder route for the approach. If it was, it would
> be charted as such. So you may be able to argue your point with the
> procedure designers...
>

Feeder routes are depicted on SIAPs to designate routes for aircraft to
proceed from the en route structure to the IAF. Charting V21 as a feeder
route would be superfluous as the airway already performs that function.

Note that they did superfluously chart a feeder route from WILMA, that route
is also known as V8. Go figure.


>
> What is the MEA on the victor airway (I don't have it here...) Something
> like 4000'? They aren't going to change the MEA of the airway just to
> satisfy an approach (or at least they didn't in this case). So, you'll
> be approaching the VOR at 4000' ... much to high to begin the approach.
>

The MEA on V21 southwest of SLI is 4000. One has to wonder why it's that
high near the VOR. It's certainly not required by terrain or obstruction
and the A/FD shows no navaid restrictions that would affect it. V21 crosses
V25 about nine miles southwest of SLI, it seems there could easily be a
named intersection at that point with an MEA change. A MOCA would seem to
be appropriate as well.


>
> Note that WILMA requires a PT because it is not aligned within 30
> degrees of the FAC...
>

There are many examples of routes marked NoPT that are offset by more than
thirty degrees.

On 7 Oct 2005 11:22:03 -0700, "rps" > wrote:


>See http://www.faa.gov/ATPUBS/AIM/Exofchg/exchg3.html, and scroll down
>to entry w.
>

Thanks also from me. I hadn't found that resource.

Tim.

In article . net>,
"Steven P. McNicoll" > wrote:

> "Mark Hansen" > wrote in message
> ...
> >
> > Victor 21 is not a feeder route for the approach. If it was, it would
> > be charted as such. So you may be able to argue your point with the
> > procedure designers...
> >
>
> Feeder routes are depicted on SIAPs to designate routes for aircraft to
> proceed from the en route structure to the IAF. Charting V21 as a feeder
> route would be superfluous as the airway already performs that function.
>
> Note that they did superfluously chart a feeder route from WILMA, that route
> is also known as V8. Go figure.
>
>
> >
> > What is the MEA on the victor airway (I don't have it here...) Something
> > like 4000'? They aren't going to change the MEA of the airway just to
> > satisfy an approach (or at least they didn't in this case). So, you'll
> > be approaching the VOR at 4000' ... much to high to begin the approach.
> >
>
> The MEA on V21 southwest of SLI is 4000. One has to wonder why it's that
> high near the VOR. It's certainly not required by terrain or obstruction
> and the A/FD shows no navaid restrictions that would affect it. V21 crosses
> V25 about nine miles southwest of SLI, it seems there could easily be a
> named intersection at that point with an MEA change. A MOCA would seem to
> be appropriate as well.
>
>
> >
> > Note that WILMA requires a PT because it is not aligned within 30
> > degrees of the FAC...
> >
>
> There are many examples of routes marked NoPT that are offset by more than
> thirty degrees.

So what would you do in the situation I described? You're at 4000 feet
on V21 going to FUL. You have not been cleared for the approach or told
to descend when you lose comm. If you go straight in you'll get to FUL
right at your filed ETA.

rg

"Ron Garret" > wrote in message
...
> In article >,
> Mark Hansen > wrote:
>
>> Now, if they created a fix somewhere out on V21, and wrote a feeder
>> route from that fix, then you could. Effectively, you've be flying
>> V21 to the fix, then initiating the SIAP from there. However, they
>> didn't, so you can't ;-)
>>
>
> OK, I'll buy that.
>
> I wonder if Steven P. McNicoll buys it too.
>

I'd create a fix on V21 where it crosses V25, I'd call it MCNIC. I'd make
the MEA on V21 between MCNIC and SLI 2600'. I wouldn't show it as a feeder
route, I'd make MCNIC an IAF just like ALBAS.

"Ron Rosenfeld" > wrote in message
...
>
> Well, there are FAA facilities that do not follow the same rules as they
> are published and interpreted by Washington. SoCal is another. There has
> been a push to standardize these kinds of things.
>

Are you saying a rule was violated in this scenario? If so, what rule was
violated?


>
> There was an old (1977) legal opinion indicating that pilots could get
> authorization from ATC to eliminate PT's when they were sort of lined up
> with the FAC and at an appropriate altitude. This supposedly was
> eliminated by the 1994 opinion; however, that 1994 opinion (which I quoted
> before) referred specifically to non-radar environments and was mute on
> radar environments.
>

The 1994 opinion you posted does not differentiate between nonradar and
radar environments.


>
> There is no question in my mind that it would be safe to fly straight in
> from the position you set up. Perhaps the simplest way of getting that
> ATC facilities practice in line with the regulations would be to designate
> SENNA as an IAF. The route from OSH, which includes the route from SENNA
> to DEPRE, is a NoPT route, and ATC has placed me on that route crossing
> SENNA.
>

That ATC facility's practice is already in line with the regulations.

"Jose" > wrote in message
. ..
>
> Ok, now let's change the example a bit.
>
> This time, on initial contact you're told "maintain 5,000 join the runway
> 36 localizer" Then, five miles from DEPRE the approach controller says
> "AWI123 cleared ILS runway three six contact tower one one eight point
> seven."
>
> You acknowledge, then lose coms. Dive? PT? Racetrack?
>

I don't get in that position. When I'm about nine miles from DEPRE, as I'm
about to intercept the GS at 5,000', I ask the controller if I'm cleared for
the approach. He responds, "AWI123 cleared ILS runway 36 approach", and I
start down on the GS. When my comm radios mysteriously fail four miles down
the road while all my other avionics continue operating flawlessly I just
continue on a normal ILS approach and land.

> I don't get in that position. When I'm about nine miles from DEPRE, as I'm
> about to intercept the GS at 5,000', I ask the controller if I'm cleared for
> the approach. He responds, "AWI123 cleared ILS runway 36 approach", and I
> start down on the GS. When my comm radios mysteriously fail four miles down
> the road while all my other avionics continue operating flawlessly I just
> continue on a normal ILS approach and land.

Well, it might not happen that way. When you ask if you're cleared for
the approach, the controller responds "negative, maintain five thousand,
I'll have clearance for you shortly." Then he gets busy. Controllers
get busy sometimes, don't they? :)

Two minutes later you are at five thousand and five miles from DEPRE,
and get the approach clearance.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Ron Garret" > wrote in message
...
>
> So what would you do in the situation I described? You're at 4000 feet
> on V21 going to FUL. You have not been cleared for the approach or told
> to descend when you lose comm. If you go straight in you'll get to FUL
> right at your filed ETA.
>

I answered that the first time you asked. I'd go straight in on the 020
radial.

"Jose" > wrote in message
.. .
>
> Well, it might not happen that way. When you ask if you're cleared for
> the approach, the controller responds "negative, maintain five thousand,
> I'll have clearance for you shortly."
>

Then I'd have to tell him we either start down now or we'll need vectors for
another shot at it. Why can't he clear me now?


>
> Then he gets busy. Controllers get busy sometimes, don't they? :)
>

At GRB? Rarely.


>
> Two minutes later you are at five thousand and five miles from DEPRE, and
> get the approach clearance.
>

No I'm not. I'm either being vectored for another shot at the approach or
I've been cleared for it and have started down on the GS.

You'll have to remind the controller if it looks like he or she is so
busy so that you're going to get a slam dunk approach. I think you can
descend in a hold, south of DEPRE, left turns (see earlier posts in
this thread from me) until you intercept the GS. However, I wouldn't
try this if the frequency is busy and you can't tell the controller
what you're up to. If the frequency is so busy, I'd descend no lower
than MSA, follow the LOC and then declare missed above the airport.

"rps" > wrote in message
oups.com...
>
> You'll have to remind the controller if it looks like he or she is so
> busy so that you're going to get a slam dunk approach. I think you can
> descend in a hold, south of DEPRE, left turns (see earlier posts in
> this thread from me) until you intercept the GS.
>

With EGF456 three minutes behind me? No freakin' way!

>> Well, it might not happen that way. When you ask if you're cleared for
>> the approach, the controller responds "negative, maintain five thousand,
>> I'll have clearance for you shortly."
>
> Then I'd have to tell him we either start down now or we'll need vectors for
> another shot at it. Why can't he clear me now?

Ok, I'll buy that. (I know... generous of me. :)

I don't know why he can't clear you now. Perhaps there's a departure, a
traffic conflict, a handoff issue, a staffing shortage, or the
controller's pencil rolled behind the console. Whatever it is, it's not
something I'd be questioning him about on the radio.

And despite the relative calmness at GRB, there are places where one
can't get a word in edgewise. I fly in the Northeast, and it is not at
all uncommon, especially at a handoff.

> No I'm not [at five thousand and five miles from DEPRE, when you
> get the approach clearance]. I'm either being vectored for another shot at
> the approach or I've been cleared for it and have started down on the GS.

Suppose, for whatever reason, the controller does not respond when you
tell him "we either start down now or we'll need vectors for another
shot at it". For example, the airplane behind you has a
misunderstanding and goes the wrong way, and needs to be coddled back
into place, and a third aircraft comes into the picture. It's well and
good that you can change the scenario on Usenet, but you can't change it
in the air. It is whatever it is.

In any case, I would conclude (synthesize) from what you have said so
far, that in this case, when you are given the approach clearance at
five thousand feet, five miles from DEPRE, you would refuse the
clearance and request vectors (or perhaps a hold at DEPRE to lose altitude).

But, upon lost com (which could be a problem with ground transmitters,
as well as a hardware issue with the volume control or PTT, I expect
you'd want to get down most expiditiously. (you've been cleared for the
approach)

What I would do is probably enter a descending hold at DEPRE and proceed
inbound from there. One turn ought to get me down to approach altitude.
I suspect you'd do something similar.

Am I right?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" > wrote in message
. ..
>
> I don't know why he can't clear you now. Perhaps there's a departure,

There may very well be, but they don't point the departures at the arrivals.


>
> a traffic conflict,
>

That would mean he let somebody cross the FAC just outside the LOM. Why did
he do that?


>
> a handoff issue,
>

There's nobody to handoff to, only one approach controller between the
Center and the tower.


>
> a staffing shortage,
>

How can that be? Again, there's only one approach controller between the
Center and the tower and he's already working me.


>
> or the controller's pencil rolled behind the console.
>

Why does he need a pencil to speak the clearance?


>
> Whatever it is, it's not something I'd be questioning him about on the
> radio.
>

I'm not questioning him, I'm questioning you. It's your scenario.


>
> And despite the relative calmness at GRB, there are places where one can't
> get a word in edgewise. I fly in the Northeast, and it is not at all
> uncommon, especially at a handoff.
>

Yeah, but we're not in the northeast, we're at GRB.


>
> Suppose, for whatever reason, the controller does not respond when you
> tell him "we either start down now or we'll need vectors for another shot
> at it". For example, the airplane behind you has a misunderstanding and
> goes the wrong way, and needs to be coddled back into place, and a third
> aircraft comes into the picture. It's well and good that you can change
> the scenario on Usenet, but you can't change it in the air. It is
> whatever it is.
>

You don't work a stream of traffic from the rear forward, you have to take
care of the guys in front first. If you screw something up in front it's
transmitted and magnified throughout the string.


>
> In any case, I would conclude (synthesize) from what you have said so far,
> that in this case, when you are given the approach clearance at five
> thousand feet, five miles from DEPRE, you would refuse the clearance and
> request vectors (or perhaps a hold at DEPRE to lose altitude).
>
> But, upon lost com (which could be a problem with ground transmitters, as
> well as a hardware issue with the volume control or PTT, I expect you'd
> want to get down most expiditiously. (you've been cleared for the
> approach)
>
> What I would do is probably enter a descending hold at DEPRE and proceed
> inbound from there. One turn ought to get me down to approach altitude. I
> suspect you'd do something similar.
>
> Am I right?
>

No. There's traffic following me. I'm not turning around.

> With EGF456 three minutes behind me? No freakin' way!

EGF456 got the clearance three minutes after you, but you don't know
where he is.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

> I'm not questioning him, I'm questioning you. It's your scenario.

Ok. He's a new controller and he's nervous. He dropped his pencil
behind the console after wondering if he accidentally may have let
somebody cross the FAC outside the LOM, and he won't issue the clearance
until he knows it's ok. As he reaches down to pick up the pencil he hit
his head just as his boss came in. He really wants to be a lot less
polite to you, but he limits himself to telling you to wait a moment
(while he gets his **** together).

It's my scenario, you can't say "it wouldn't happen" as a response. :)

In any case, it doesn't matter -why- it happens this way this time - as
the pilot you deal with it or get sent to the back of the line (which
may be the smartest thing to do at this point).

> There's traffic following me. I'm not turning around.

There's always traffic following you. In this case EGF456 is also
cleared for the approach, but he may well be at 2500 feet coming from
the west, or 9000 feet coming from the North. You don't know. He may
well not be "following" you.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" > wrote in message
. ..
>
> EGF456 got the clearance three minutes after you, but you don't know where
> he is.
>

Sure I do. He's three minutes behind me. He's been three minutes behind me
since we left ORD. We filed the same route and the same altitude. Every
step of the way I heard ATC issue him the same instruction I was issued,
just three minutes later. I heard him report out of the same altitudes I
did, just three minutes later.

>> EGF456 got the clearance three minutes after you, but you don't know where
>> he is.
>
> Sure I do. He's three minutes behind me. He's been three minutes behind me
> since we left ORD. We filed the same route and the same altitude. Every
> step of the way I heard ATC issue him the same instruction I was issued,
> just three minutes later. I heard him report out of the same altitudes I
> did, just three minutes later.

That wasn't part of the original scenario, but I'll bite. He will be at
5000 while I am descending in the hold to 3000. At 500 feet per minute
I'll have 1500 feet of vertical clearance when he goes whizzing by overhead.

But this is the crux of the matter. I've already said that if I were at
the right altitude and reasonably on track, I'd go right in (no PT).
You've indicated the same, and also that if you were not at the right
altitude (say, 5000 feet), you'd get a new vector (and likely be sent to
the back of the line) if you couldn't get an earlier clearance. This is
also reasonable and I'd do the same.

If you are dealt an inappropriate slam dunk (5000 on a 3000 approach),
do you go missed or make it work? If you make it work, how would you
lose the altitude?

I suppose it's a bit off track of the PT question, though hold in lieu
is one way to lose altitude, and is permitted most places a PT is.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

In article . net>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > So what would you do in the situation I described? You're at 4000 feet
> > on V21 going to FUL. You have not been cleared for the approach or told
> > to descend when you lose comm. If you go straight in you'll get to FUL
> > right at your filed ETA.
> >
>
> I answered that the first time you asked. I'd go straight in on the 020
> radial.

My news server seems to have some lag. I presume this is your answer:

> I'd create a fix on V21 where it crosses V25, I'd call it MCNIC. I'd make
> the MEA on V21 between MCNIC and SLI 2600'. I wouldn't show it as a feeder
> route, I'd make MCNIC an IAF just like ALBAS.

I can't tell if you're being serious or not. As far as I know pilots
can't create fixes, and certainly not while they're in the air.

So let me be clear: if you were actually flying this route and lost comm
you'd start a descent at MCNIC. I think I'd do the same thing. But I
also think I'd technically be in violation of the FARs. Do you agree?

rg

It's clear that whoever drafted the language in the explanation needs
to brush up on his or her written English skills.

Pilots often create fixes in the air and use them.

Often it eases the route to intercept a radial of a VOR, since FMS boxes are
inherently fix to fix. It makes navigating much easier and is done
routinely.

Karl
"Curator" N185KG

"Ron Garret" > wrote in message
...
>
> My news server seems to have some lag. I presume this is your answer:
>
>> I'd create a fix on V21 where it crosses V25, I'd call it MCNIC. I'd
>> make
>> the MEA on V21 between MCNIC and SLI 2600'. I wouldn't show it as a
>> feeder
>> route, I'd make MCNIC an IAF just like ALBAS.
>

No, my answer was, "It's IMC. I'd track the 020 radial out of SLI, fly the
approach and land because doing anything else is nutty."


>
> I can't tell if you're being serious or not. As far as I know pilots
> can't create fixes, and certainly not while they're in the air.
>

If my response isn't funny, I'm being serious.


>
> So let me be clear: if you were actually flying this route and lost comm
> you'd start a descent at MCNIC. I think I'd do the same thing. But I
> also think I'd technically be in violation of the FARs. Do you agree?
>

It appears you're losing context. Mark Hansen mentioned creating a fix
somewhere on V21 and initiating the approach from that point. My message
was written along those lines, what I would do if I was designing the
approach.

Steven P. McNicoll wrote:
>
> Alright, here's a real world example for you. You're flying AWI123 from
> KORD to KGRB, Chicago departure puts you in the east departure track on a
> 360 heading and hands you off to Chicago Center. Around the Kenosha, WI,
> area Chicago Center tells you to proceed direct to GRB VORTAC. Down the
> road a piece you're handed off to Green Bay approach. At GRB the ILS RWY 36
> approach is in use, and the approach controller notices you're present track
> will intercept the localizer about fifteen miles from DEPRE, the LOM/IAF.
> On initial contact you're told "descend and maintain 3,000 join the runway
> 36 localizer". About three minutes later you hear the same instruction
> issued to EGF456. When you're about five miles from DEPRE the approach
> controller says "AWI123 cleared ILS runway three six contact tower one one
> eight point seven." When you reach DEPRE will you continue towards the
> runway or will you start a procedure turn?

As someone who knows a couple of AWI pilots, I can tell you what they
would do. They'd point her one or two LRCH's to the left of DEPRE, peg
it a 250 kts to stay ahead of Eagle, a couple of miles from DEPRE chop
the power, deploy the airbrake, flaps, gear, some more flaps, stable at
1000', make the first turn-off, and be at the gate drinking Starbucks
while the rest of you try to make up your minds about flying a
proceedure turn or not.

In article et>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > My news server seems to have some lag. I presume this is your answer:
> >
> >> I'd create a fix on V21 where it crosses V25, I'd call it MCNIC. I'd
> >> make
> >> the MEA on V21 between MCNIC and SLI 2600'. I wouldn't show it as a
> >> feeder
> >> route, I'd make MCNIC an IAF just like ALBAS.
> >
>
> No, my answer was, "It's IMC. I'd track the 020 radial out of SLI, fly the
> approach and land because doing anything else is nutty."
>
>
> >
> > I can't tell if you're being serious or not. As far as I know pilots
> > can't create fixes, and certainly not while they're in the air.
> >
>
> If my response isn't funny, I'm being serious.
>
>
> >
> > So let me be clear: if you were actually flying this route and lost comm
> > you'd start a descent at MCNIC. I think I'd do the same thing. But I
> > also think I'd technically be in violation of the FARs. Do you agree?
> >
>
> It appears you're losing context. Mark Hansen mentioned creating a fix
> somewhere on V21 and initiating the approach from that point. My message
> was written along those lines, what I would do if I was designing the
> approach.

But I'm the one who posed the original question, and my question is what
you would do if you were *flying* the approach (as it currently exists)
and lost comm.

rg

In article >,
"kgruber" > wrote:

> Pilots often create fixes in the air and use them.

Not as part of an instrument approach they don't.

rg

On Fri, 07 Oct 2005 20:39:54 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> Well, there are FAA facilities that do not follow the same rules as they
>> are published and interpreted by Washington. SoCal is another. There has
>> been a push to standardize these kinds of things.
>>
>
>Are you saying a rule was violated in this scenario? If so, what rule was
>violated?
>
>
>>
>> There was an old (1977) legal opinion indicating that pilots could get
>> authorization from ATC to eliminate PT's when they were sort of lined up
>> with the FAC and at an appropriate altitude. This supposedly was
>> eliminated by the 1994 opinion; however, that 1994 opinion (which I quoted
>> before) referred specifically to non-radar environments and was mute on
>> radar environments.
>>
>
>The 1994 opinion you posted does not differentiate between nonradar and
>radar environments.

The full text, which has been posted previously by others, makes it clear
that the opinion refers to a non-radar environment. Here is the relevant
portion.

"This is a clarification of our response to your letter of
August 23, 1993. In that letter you requested an
interpretation of Section 91.175 of the Federal Aviation
Regulation (FAR) (14 C.F.R. Section 91.175). You address
the necessity of executing a complete Standard Instrument
Approach Procedure (SIAP) in a non-radar environment while
operating under Instrument Flight Rules (IFR). Our response
assumes that each of the specific scenarios you pose speaks
to a flight conducted under IFR in a non-radar environment."


>
>
>>
>> There is no question in my mind that it would be safe to fly straight in
>> from the position you set up. Perhaps the simplest way of getting that
>> ATC facilities practice in line with the regulations would be to designate
>> SENNA as an IAF. The route from OSH, which includes the route from SENNA
>> to DEPRE, is a NoPT route, and ATC has placed me on that route crossing
>> SENNA.
>>
>
>That ATC facility's practice is already in line with the regulations.
>

No, it seems to me that you've set up a situation which is quite similar
to, and understood by most, to be functionally equivalent to radar vectors
to the final approach course.

It also happens to include a segment prior to the FAF which is part of a
NoPT routing from a different IAF.

However, you claim this procedure is NOT equivalent to RV to FAC.

So you've effectively ignored the ATC requirement to start an approach at
an IAF. That is a requirement for ATC unless giving radar vectors IAW
7110.65 5-9-1. You may say that DEPRE is an IAF (which it is) but it is not
being used as one in this scenario.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On 7 Oct 2005 17:05:28 -0700, "rps" > wrote:

>It's clear that whoever drafted the language in the explanation needs
>to brush up on his or her written English skills.


It is also unclear whether the drafter even checked with the TERP's people
who design the procedures, to see if such language meets with their
approval. Or if he checked with the regulatory office to resolve the
conflict with their 1994 opinion.

Gee, if PT execution is now pilot choice, and "course reversal" is not
further defined, that opens up a whole bunch of ways to get into trouble!


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Garret" > wrote in message
...
>
> But I'm the one who posed the original question, and my question is what
> you would do if you were *flying* the approach (as it currently exists)
> and lost comm.
>

Which I have twice answered.

In article . net>,
"Steven P. McNicoll" > wrote:

> "Ron Garret" > wrote in message
> ...
> >
> > But I'm the one who posed the original question, and my question is what
> > you would do if you were *flying* the approach (as it currently exists)
> > and lost comm.
> >
>
> Which I have twice answered.

Ah, so you have.

You said you'd go straight in.

So my followup question (if you'll indulge me) is: do you acknowledge
that this would be a technical violation of the FARS? (You'd have to
start descending below the MEA on V21 before passing an IAF for the
approach.)

rg

"Ron Garret" > wrote in message
...
>
> Ah, so you have.
>
> You said you'd go straight in.
>
> So my followup question (if you'll indulge me) is: do you acknowledge
> that this would be a technical violation of the FARS? (You'd have to
> start descending below the MEA on V21 before passing an IAF for the
> approach.)
>

I wouldn't have to stay on V21, I could move over two degrees to the 200
radial used for the approach. As for a possible technical violation of the
FARs, I've had a complete communications failure for unknown reasons, and
while my navigational radios are functioning, I'm not sure how long they
will continue to do so. To avoid a possible loss of navigational capability
in IMC I'm using the emergency authority granted me by
FAR 91.3 to deviate from any rule of Part 91.

> As for a possible technical violation of the
> FARs, I've had a complete communications failure for unknown reasons, and
> while my navigational radios are functioning, I'm not sure how long they
> will continue to do so. To avoid a possible loss of navigational capability
> in IMC I'm using the emergency authority granted me by
> FAR 91.3 to deviate from any rule of Part 91.

Good enough. But suppose your radios are all working fine, but you just
can't get a word in edgewise. I won't speculate as to how that might be
possible at this particular (middle of nowhere) facility, I'll just note
that it happens where I fly.

You go straight in, as you said you would.

Would =that= be a technical violation of the FARs, since you don't have
91.3 to rely upon?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" > wrote in message
. ..
>
> Ok. He's a new controller and he's nervous.
>

What's he nervous about?


>
> He dropped his pencil behind the console after wondering if he
> accidentally
> may have let somebody cross the FAC outside the LOM, and he won't issue
> the clearance until he knows it's ok.
>

Wouldn't a quick look at the radar scope tell him if it's ok?


>
> As he reaches down to pick up the pencil he hit his head just as
> his boss came in.
>

Why didn't he just take another pencil? Why did he hit his head? What does
his boss have to do with any of this?


>
> He really wants to be a lot less polite to you, but he
> limits himself to telling you to wait a moment (while he gets his ****
> together).
>

Why does he want to be less polite to me? Is he just antisocial by nature?


>
> It's my scenario, you can't say "it wouldn't happen" as a response. :)
>

Okay, but then my response can be just as unrealistic as your scenario.


>
> In any case, it doesn't matter -why- it happens this way this time - as
> the pilot you deal with it or get sent to the back of the line (which may
> be the smartest thing to do at this point).
>
>> There's traffic following me. I'm not turning around.
>
> There's always traffic following you. In this case EGF456 is also cleared
> for the approach, but he may well be at 2500 feet coming from the west, or
> 9000 feet coming from the North. You don't know. He may well not be
> "following" you.
>

But he's been following me all the way from ORD. How can he now be coming
from the west or the north if we departed ORD just three minutes apart? If
he's now coming from the west, how was the GRB controller able to descend
him below the 4000' traffic that's keeping me up at 5,000? If he's coming
from the north, how was the GRB tower controller able to launch that
departure?

"Jose" > wrote in message
. ..
>
> That wasn't part of the original scenario, but I'll bite.
>

Yes it was. If you reread the original scenario you'll find; "On initial
contact you're told 'descend and maintain 3,000, join the runway 36
localizer'. About three minutes later you hear the same instruction issued
to EGF456." Then you modified the original scenario with the following:

"This time, on initial contact you're told 'maintain 5,000 join the runway
36 localizer' Then, five miles from DEPRE the approach controller says
'AWI123 cleared ILS runway three six contact tower one one eight point
seven'."

"You acknowledge, then lose coms. Dive? PT? Racetrack?"

You said nothing about deleting the EGF456 flight.


>
> He will be at
> 5000 while I am descending in the hold to 3000. At 500 feet per minute
> I'll have 1500 feet of vertical clearance when he goes whizzing by
> overhead.
>

How do I know that? I've lost comms, I can't hear transmissions to other
aircraft any better than I can hear those directed at me. The controller
let 4000' traffic cross the localizer near the LOM when he had two aircraft
inbound for the approach, so I know I'm not being worked by the sharpest
spoon in the drawer. I'm not turning towards traffic following me.


>
> But this is the crux of the matter. I've already said that if I were at
> the right altitude and reasonably on track, I'd go right in (no PT).
> You've indicated the same, and also that if you were not at the right
> altitude (say, 5000 feet), you'd get a new vector (and likely be sent to
> the back of the line) if you couldn't get an earlier clearance. This is
> also reasonable and I'd do the same.
>
> If you are dealt an inappropriate slam dunk (5000 on a 3000 approach), do
> you go missed or make it work? If you make it work, how would you lose
> the altitude?
>

I'd go missed.

>> That wasn't part of the original scenario, but I'll bite.
>>
> Yes it was. If you reread the original scenario you'll find; "On initial
> contact you're told 'descend and maintain 3,000, join the runway 36
> localizer'. About three minutes later you hear the same instruction issued
> to EGF456."

That EGF456 was following you since the beginning of your flight was not
part of the scenario, at least not as presented. I took it as another
aircraft that could be coming from anywhere, which is now also cleared
for the same approach you are on and presumably will be following you.

>> If you are dealt an inappropriate slam dunk (5000 on a 3000 approach), do
>> you go missed or make it work? If you make it work, how would you lose
>> the altitude?
>
> I'd go missed.

Good enough. Thanks.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

Jose wrote:
>> As for a possible technical violation of the FARs, I've had a complete
>> communications failure for unknown reasons, and while my navigational
>> radios are functioning, I'm not sure how long they will continue to do
>> so. To avoid a possible loss of navigational capability in IMC I'm
>> using the emergency authority granted me by
>> FAR 91.3 to deviate from any rule of Part 91.
>
>
> Good enough. But suppose your radios are all working fine, but you just
> can't get a word in edgewise. I won't speculate as to how that might be
> possible at this particular (middle of nowhere) facility, I'll just note
> that it happens where I fly.
>
> You go straight in, as you said you would.
>
> Would =that= be a technical violation of the FARs, since you don't have
> 91.3 to rely upon?

Sure, if you can't communicate, either for reasons of congestion or
hardware failure, the end result is the same and use can use 91.3 as needed.

Matt

"Ron Rosenfeld" > wrote in message
...
>
> The full text, which has been posted previously by others, makes it clear
> that the opinion refers to a non-radar environment. Here is the relevant
> portion.
>
> "This is a clarification of our response to your letter of
> August 23, 1993. In that letter you requested an
> interpretation of Section 91.175 of the Federal Aviation
> Regulation (FAR) (14 C.F.R. Section 91.175). You address
> the necessity of executing a complete Standard Instrument
> Approach Procedure (SIAP) in a non-radar environment while
> operating under Instrument Flight Rules (IFR). Our response
> assumes that each of the specific scenarios you pose speaks
> to a flight conducted under IFR in a non-radar environment."
>

So, Ron, did you delete that portion for brevity, or because including it
weakened your argument?

So how does the 1994 legal opinion supposedly eliminate the 1977 legal
opinion in all cases if the 1994 opinion is expressly limited to non-radar
environments?


>
> No, it seems to me that you've set up a situation which is quite similar
> to, and understood by most, to be functionally equivalent to radar vectors
> to the final approach course.
>

I didn't set this situation up, this situation was set up by geography,
runway alignment, navaid placement, and departure procedures for MKE and
ORD. This is not a hypothetical, it's a real world example, it happens
regularly and has been for probably three decades or so.

What do you mean by "functionally equivalent to radar vectors to the final
approach course"? Is AWI123 being vectored or is it on it's own navigation?


>
> It also happens to include a segment prior to the FAF which is part of a
> NoPT routing from a different IAF.
>

So what? AWI123 didn't join the segment to which NoPT applies.


>
> However, you claim this procedure is NOT equivalent to RV to FAC.
>

Well, given the absence of any radar vector to the final approach course,
I'd be a fool to claim anything else.


>
> So you've effectively ignored the ATC requirement to start an approach at
> an IAF. That is a requirement for ATC unless giving radar vectors IAW
> 7110.65 5-9-1. You may say that DEPRE is an IAF (which it is) but it is
> not being used as one in this scenario.
>

Cite that requirement. Why doesn't DEPRE count as an IAF in this scenario?

"Ron Rosenfeld" > wrote in message
...
>
> It is also unclear whether the drafter even checked with the TERP's people
> who design the procedures, to see if such language meets with their
> approval.
>

Why is their approval required?


>
> Or if he checked with the regulatory office to resolve the
> conflict with their 1994 opinion.
>

What's the conflict there?

"Jose" > wrote in message
m...
>
> Good enough. But suppose your radios are all working fine, but you just
> can't get a word in edgewise. I won't speculate as to how that might be
> possible at this particular (middle of nowhere) facility, I'll just note
> that it happens where I fly.
>
> You go straight in, as you said you would.
>
> Would =that= be a technical violation of the FARs, since you don't have
> 91.3 to rely upon?
>

In that case I don't make a straight-in approach, I don't make an approach
at all. I continue to my clearance limit and enter a standard hold at
whatever altitude I was last cleared to maintain.

"Jose" > wrote in message
...
>
> That EGF456 was following you since the beginning of your flight was not
> part of the scenario, at least not as presented. I took it as another
> aircraft that could be coming from anywhere, which is now also cleared for
> the same approach you are on and presumably will be following you.
>

Even if I hadn't heard any of the previous exchanges between EGF456 and ATC,
the exchange on initial contact with GRB approach was enough to tell me he's
three minutes behind me. He's my direct competition, we fly the same route
just a few minutes apart every day. The fact that he contacted GRB three
minutes after I did and reported out of an altitude above mine tells me he's
behind me.

"Steven P. McNicoll" > wrote in message
link.net...
>
> "Ron Rosenfeld" > wrote in message
> ...
>>
>> I've already made my case. You may reread it and the references until
>> you
>> understand it, or choose to disagree.
>>
>
> I missed the message in which you did that, didn't make it through my
> provider. Could you copy and paste it in reply to this message?

Your case didn't show up on Google Groups either. Could you repost it? I'd
really like to read it.

On Sun, 09 Oct 2005 00:00:02 GMT, "Steven P. McNicoll"
> wrote:

>>
>> So you've effectively ignored the ATC requirement to start an approach at
>> an IAF. That is a requirement for ATC unless giving radar vectors IAW
>> 7110.65 5-9-1. You may say that DEPRE is an IAF (which it is) but it is
>> not being used as one in this scenario.
>>
>
>Cite that requirement.

7110.65 4-8-1. APPROACH CLEARANCE
a. ... Standard Instrument Approach Procedures shall commence at an Initial
Approach Fix or an Intermediate Approach Fix if there is not an
Initial Approach Fix.

>Why doesn't DEPRE count as an IAF in this scenario?

What is the minimum altitude at DEPRE when it is being used as an IAF?

How is the initial segment defined?

How will you navigate from DEPRE to the FAF for the ILS approach?

---------------------------------------


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
>
> 7110.65 4-8-1. APPROACH CLEARANCE
> a. ... Standard Instrument Approach Procedures shall commence at an
> Initial
> Approach Fix or an Intermediate Approach Fix if there is not an
> Initial Approach Fix.
>

That requirement is not violated. AWI123 intercepts the localizer fifteen
miles south of DEPRE. DEPRE is an IAF.


>
> What is the minimum altitude at DEPRE when it is being used as an IAF?
>

AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
approach. He follows the localizer down and crosses DEPRE at 2141 MSL.


>
> How is the initial segment defined?
>

The segment between the intial approach fix and the intermediate fix or the
point where the aircraft is established on the intermediate course or final
approach course.


>
> How will you navigate from DEPRE to the FAF for the ILS approach?
>

Lateral guidance is provided by the localizer, if I've passed DEPRE I've
passed the FAF.

> AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
> approach. He follows the localizer down and crosses DEPRE at 2141 MSL.

Wasn't there an accident recently caused by a misunderstanding like what
is suggested here? If you are (umpty ump) miles south of the IAF, but
above the initial approach altitude, and get cleared for the approach,
when can you descend? I recall (perhaps imperfectly) that some airliner
descended inappropriately and ran into terrain, while still above the
altitude for the IAF. A clearance for the approach is not (AFAIK) a
clearance to -descend- to the approach altitude from an otherwise
assigned higher one.

If I'm missing something here, what is it?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" > wrote in message
t...
>>
>> AWI123 is level at 3000 and five miles south of DEPRE when cleared for
>> the approach. He follows the localizer down and crosses DEPRE at 2141
>> MSL.
>>
>
> Wasn't there an accident recently caused by a misunderstanding like what
> is suggested here?
>

What misunderstanding do you believe is suggested here?


>
> If you are (umpty ump) miles south of the IAF, but
> above the initial approach altitude, and get cleared for the approach,
> when can you descend?
>

Immediately. If the aircraft is not yet established on a segment of a
published route or instrument approach procedure ATC must assign an altitude
to maintain until it is. Sometimes in the situation I described here
aircraft report on the localizer on initial contact with GRB approach, when
they are 30 miles or so from the field. They can be cleared for the
approach at that time, "cross SENNA at or above 3000, cleared ILS runway
three six approach."


>
> I recall (perhaps imperfectly) that some airliner
> descended inappropriately and ran into terrain, while still above the
> altitude for the IAF. A clearance for the approach is not (AFAIK) a
> clearance to -descend- to the approach altitude from an otherwise assigned
> higher one.
>
> If I'm missing something here, what is it?
>

Doesn't sound like a recent accident to me, sounds like TWA514, but that was
over thirty years ago.

> Doesn't sound like a recent accident to me, sounds like TWA514, but that was
> over thirty years ago.

To some of us that's recent. :)

>> If you are (umpty ump) miles south of the IAF, but
>> above the initial approach altitude, and get cleared for the approach,
>> when can you descend?
>
> Immediately. If the aircraft is not yet established on a segment of a
> published route or instrument approach procedure ATC must assign an altitude
> to maintain until it is. Sometimes in the situation I described here
> aircraft report on the localizer on initial contact with GRB approach, when
> they are 30 miles or so from the field. They can be cleared for the
> approach at that time, "cross SENNA at or above 3000, cleared ILS runway
> three six approach."
>

IF the controller fails to assign an altitude to maintain when giving
the approach clearance umpty ump miles out, I presume the existing
altitude assignment remains valid until the aircraft is established, in
this case until SENNA, the start of the heavy black line. Yes?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

Jose wrote:

>>
>
> IF the controller fails to assign an altitude to maintain when giving
> the approach clearance umpty ump miles out, I presume the existing
> altitude assignment remains valid until the aircraft is established, in
> this case until SENNA, the start of the heavy black line. Yes?

No. That's why the controller is required to state the altitude. Once
cleared for the approach the pilot may descend to the initial approach
altitude.

Newps wrote:
>
>
> Jose wrote:
>
>>>
>>
>> IF the controller fails to assign an altitude to maintain when giving
>> the approach clearance umpty ump miles out, I presume the existing
>> altitude assignment remains valid until the aircraft is established,
>> in this case until SENNA, the start of the heavy black line. Yes?
>
>
> No. That's why the controller is required to state the altitude. Once
> cleared for the approach the pilot may descend to the initial approach
> altitude.

I didn't see the initial question here, but I think you are wrong. the
controllers are required to say it because in may cases (as it appears
here) pilots make mistakes and think they can descend when in fact they
are not on any segment. You cannot descend until established on a
segment.

An airliner crashed several years ago when the crew mistakenly
descended to the initial approach altitude when cleared for the
approach several miles out. The CVR recorded the conversation between
the two pilots discussing whether or not that meant they could go down
to the IAF altitude (they had been cleared direct to the IAF not via a
feeder fix). The captain won the discussion and the aircraft hit a
ridgeline before the IAF. Unless established on a published segment of
the approach, the aircraft is not automatically cleared to descend.
Feeder fixes depicted on the approach plate are considered published
segments of the approach and when approach clearance is received, the
aircraft may descend to the MEA published for that feeder fix without
specific clearance.

* 150flivver >:
> An airliner crashed several years ago when the crew mistakenly
> descended to the initial approach altitude when cleared for the
> approach several miles out. The CVR recorded the conversation between
> the two pilots discussing whether or not that meant they could go down
> to the IAF altitude (they had been cleared direct to the IAF not via a
> feeder fix). The captain won the discussion and the aircraft hit a
> ridgeline before the IAF.

Did they sink thru MSA?

Can you remember what airport and approach that was? Would like to look
at the approach plate...

> Unless established on a published segment of
> the approach, the aircraft is not automatically cleared to descend.

So their approach clearance would have meant to fly to the IAF at level,
then "somehow" descend there, and then follow the approach? Or was ATC's
behaviour just wrong and they should have asked for clarification?


Best regards,
Daniel (not a real pilot, so please bear with me if I'm talking/asking
nonsense)

"Jose" > wrote in message
...
>
> IF the controller fails to assign an altitude to maintain when giving the
> approach clearance umpty ump miles out, I presume the existing altitude
> assignment remains valid until the aircraft is established, in this case
> until SENNA, the start of the heavy black line. Yes?
>

§ 91.175 Takeoff and landing under IFR.

(i) Operations on unpublished routes and use of radar in instrument approach
procedures. When radar is approved at certain locations for ATC purposes, it
may be used not only for surveillance and precision radar approaches, as
applicable, but also may be used in conjunction with instrument approach
procedures predicated on other types of radio navigational aids. Radar
vectors may be authorized to provide course guidance through the segments of
an approach to the final course or fix. When operating on an unpublished
route or while being radar vectored, the pilot, when an approach clearance
is received, shall, in addition to complying with §91.177, maintain the last
altitude assigned to that pilot until the aircraft is established on a
segment of a published route or instrument approach procedure unless a
different altitude is assigned by ATC. After the aircraft is so established,
published altitudes apply to descent within each succeeding route or
approach segment unless a different altitude is assigned by ATC. Upon
reaching the final approach course or fix, the pilot may either complete the
instrument approach in accordance with a procedure approved for the facility
or continue a surveillance or precision radar approach to a landing.

* Steven P. McNicoll >:
> When operating on an unpublished route or while being radar vectored,
> the pilot, when an approach clearance is received, shall, in addition
> to complying with §91.177, maintain the last altitude assigned to that
> pilot until the aircraft is established on a segment of a published
> route or instrument approach procedure unless a different altitude is
> assigned by ATC.

Let's say I've been vectored on heading 090 at 4000ft, 5NM from LLZ
rwy 18. This track is not part of a published IAF-to-FAF track. Published
GS intercept altitude is 3000ft. ATC instructs "turn right heading 150,
cleared ILS 18". My interpretation of your quote would be that I'm _not_
allowed to start descending to 3000ft while I'm turning to 150 but would
have to stay on 4000ft until LLZ capture, and then descend (either with
the glide, or to 3000ft in order to wait there for GS capture) - or
declare unable if the GS is already below me at LLZ capture. Is that
correct?


Best regards,
Daniel (not a real pilot, just trying to learn)

"Daniel Roesen" > wrote in message
...
>
> Did they sink thru MSA?
>

Elevation at the crash site was about 1,670 feet, MSA in that quadrant was
3300.


>
> Can you remember what airport and approach that was? Would like to look
> at the approach plate...
>

VOR/DME RWY 12 at Dulles International, you can see it at
alt.binaries.pictures.aviation, the subject is "Dulles VOR/DME RWY 12".


>
> So their approach clearance would have meant to fly to the IAF at level,
> then "somehow" descend there, and then follow the approach?
>

Not to the IAF, until on a published segment of the approach. They were
already on the Armel 300 radial, they would have been on a published segment
of the approach when they reached ROUND HILL, 11.6 miles from the IAF.

>
> Or was ATC's behaviour just wrong and they should have asked for
> clarification?
>

There was no ATC error, and asking for clarification certainly wouldn't have
hurt them. The CVR indicated uncertainty of the proper altitude, the
captain said the approach plate indicated the minimum altitude until ROUND
HILL was 3400, but decided that clearance for the approach was clearance to
the initial approach altitude.

* Steven P. McNicoll >:
>> Can you remember what airport and approach that was? Would like to look
>> at the approach plate...
>
> VOR/DME RWY 12 at Dulles International, you can see it at
> alt.binaries.pictures.aviation, the subject is "Dulles VOR/DME RWY 12".

Thank you, got it.

>> So their approach clearance would have meant to fly to the IAF at level,
>> then "somehow" descend there, and then follow the approach?
>
> Not to the IAF, until on a published segment of the approach.

Timothy Witt wrote: "they had been cleared direct to the IAF", e.g.
"turn X heading Y direct ROUND HILL, cleared VOR/DME 12".

> They were already on the Armel 300 radial, they would have been on a
> published segment of the approach when they reached ROUND HILL, 11.6
> miles from the IAF.

If I'm not totally mistaken, ROUND HILL is 11.6 DME from the FAF (which
is in turn 6 DME from AML), not the IAF. I guess ROUND HILL is the
actual IAF?!

>> Or was ATC's behaviour just wrong and they should have asked for
>> clarification?
>
> There was no ATC error, and asking for clarification certainly wouldn't
> have hurt them. The CVR indicated uncertainty of the proper altitude,
> the captain said the approach plate indicated the minimum altitude until
> ROUND HILL was 3400, but decided that clearance for the approach was
> clearance to the initial approach altitude.

Hm. My reading of the old approach plate would be to stay at or above
3300 (which MSA radius was used back then?) until ROUND HILL, then
descend to 1800, and at 6 DME AML (FAF) start descending to MDA.

Where did this captain get the idea to descend below the MEA of 1800ft
before the FAF? You said "but decided that clearance for the approach
was clearance to the initial approach altitude" - which would be 1800ft.
Did they overshoot this descend (you mentioned 1670ft), or did he
actually thought he could descend to MDA?


Best regards,
Daniel

On Sun, 09 Oct 2005 03:34:29 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> 7110.65 4-8-1. APPROACH CLEARANCE
>> a. ... Standard Instrument Approach Procedures shall commence at an
>> Initial
>> Approach Fix or an Intermediate Approach Fix if there is not an
>> Initial Approach Fix.
>>
>
>That requirement is not violated. AWI123 intercepts the localizer fifteen
>miles south of DEPRE. DEPRE is an IAF.
>
>
>>
>> What is the minimum altitude at DEPRE when it is being used as an IAF?
>>
>
>AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
>approach. He follows the localizer down and crosses DEPRE at 2141 MSL.
>
>
>>
>> How is the initial segment defined?
>>
>
>The segment between the intial approach fix and the intermediate fix or the
>point where the aircraft is established on the intermediate course or final
>approach course.
>
>
>>
>> How will you navigate from DEPRE to the FAF for the ILS approach?
>>
>
>Lateral guidance is provided by the localizer, if I've passed DEPRE I've
>passed the FAF.
>

Just so I understand exactly what you are saying, is it your position that,
when using DEPRE as the IAF for the purpose of starting this SIAP, if one
is inbound, the legal minimum altitude at DEPRE is 2141'?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Sun, 09 Oct 2005 03:34:29 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> 7110.65 4-8-1. APPROACH CLEARANCE
>> a. ... Standard Instrument Approach Procedures shall commence at an
>> Initial
>> Approach Fix or an Intermediate Approach Fix if there is not an
>> Initial Approach Fix.
>>
>
>That requirement is not violated. AWI123 intercepts the localizer fifteen
>miles south of DEPRE. DEPRE is an IAF.
>
>
>>
>> What is the minimum altitude at DEPRE when it is being used as an IAF?
>>
>
>AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
>approach. He follows the localizer down and crosses DEPRE at 2141 MSL.
>
>
>>
>> How is the initial segment defined?
>>
>
>The segment between the intial approach fix and the intermediate fix or the
>point where the aircraft is established on the intermediate course or final
>approach course.
>
>
>>
>> How will you navigate from DEPRE to the FAF for the ILS approach?
>>
>
>Lateral guidance is provided by the localizer, if I've passed DEPRE I've
>passed the FAF.
>

One other question which I keep forgetting to ask:

Does the TRACON have appropriate radar coverage and setup to use Radar
Vectors to Final in this area?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" > wrote in message
...
>
> Just so I understand exactly what you are saying, is it your position
> that,
> when using DEPRE as the IAF for the purpose of starting this SIAP, if one
> is inbound, the legal minimum altitude at DEPRE is 2141'?
>

There is no Minimum Descent Altitude on an ILS approach, there is instead a
Decision Height. AWI123 is level at 3000 and five miles south of DEPRE, on
the localizer, when cleared for the approach. The aircraft leaves 3000
about 2.7 miles south of DEPRE, where it intercepts the glideslope. It
follows the glideslope down, crossing DEPRE at 2141 MSL, to the decision
height of 882 MSL. From that point it will either complete the approach
visually or execute the missed approach procedure.

"Ron Rosenfeld" > wrote in message
...
>
> One other question which I keep forgetting to ask:
>
> Does the TRACON have appropriate radar coverage and setup to use Radar
> Vectors to Final in this area?
>

Yes.

* Steven P. McNicoll >:
> follows the glideslope down, crossing DEPRE at 2141 MSL, to the decision
> height of 882 MSL.

The decision height is 200ft for straight-in ILS 36. What you mean is
the decision altitude. Unless I've misunderstood something completely.


Best regards,
Daniel

"Daniel Roesen" > wrote in message
...
>
> Let's say I've been vectored on heading 090 at 4000ft, 5NM from LLZ
> rwy 18. This track is not part of a published IAF-to-FAF track. Published
> GS intercept altitude is 3000ft. ATC instructs "turn right heading 150,
> cleared ILS 18". My interpretation of your quote would be that I'm _not_
> allowed to start descending to 3000ft while I'm turning to 150 but would
> have to stay on 4000ft until LLZ capture, and then descend (either with
> the glide, or to 3000ft in order to wait there for GS capture) - or
> declare unable if the GS is already below me at LLZ capture. Is that
> correct?
>

Where's LLZ? Sounds like the heading will intercept inside the LOM.

On Mon, 10 Oct 2005 20:35:42 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> Just so I understand exactly what you are saying, is it your position
>> that,
>> when using DEPRE as the IAF for the purpose of starting this SIAP, if one
>> is inbound, the legal minimum altitude at DEPRE is 2141'?
>>
>
>There is no Minimum Descent Altitude on an ILS approach, there is instead a
>Decision Height. AWI123 is level at 3000 and five miles south of DEPRE, on
>the localizer, when cleared for the approach. The aircraft leaves 3000
>about 2.7 miles south of DEPRE, where it intercepts the glideslope. It
>follows the glideslope down, crossing DEPRE at 2141 MSL, to the decision
>height of 882 MSL. From that point it will either complete the approach
>visually or execute the missed approach procedure.
>

Your answer is not responsive to my question, but perhaps I did not write
clearly. So I will try to be more clear:

I did not mean to ask you about an MDA for this ILS approach. Nor am I
concerned about how the approach is flown from the FAF to DH.

I ask how your procedure without radar vectors satisfies the requirement
that this approach begin at an IAF.

I thought you indicated that DEPRE was the applicable IAF to satisfy this
requirement. Was that an incorrect assumption?

If DEPRE is the applicable IAF, it must have a minimum crossing altitude.
Since traffic is passing DEPRE at 2141', I would have expected that you
would think that is legal when DEPRE is being used as the IAF from which
this approach begins. Is that your position?

If DEPRE is not the applicable IAF, then I don't see how your procedure
meets the requirements of the 7110.65 that a non-vectored approach begin at
an IAF.

--------------------------------------

Out of curiousity, does the Green Bay TRACON have the appropriate radar
equipment and screen markings to legally issue radar vectors to final for
this approach?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Mon, 10 Oct 2005 20:36:51 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> One other question which I keep forgetting to ask:
>>
>> Does the TRACON have appropriate radar coverage and setup to use Radar
>> Vectors to Final in this area?
>>
>
>Yes.
>

Please ignore this question in my last post. I had not seen this response
of yours.

Although it does make your original scenario seem even more odd to me; but
I'll reserve comments until after considering your response to my other
questions and gathering some more information.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Daniel Roesen" > wrote in message
...
>
> Timothy Witt wrote: "they had been cleared direct to the IAF", e.g.
> "turn X heading Y direct ROUND HILL, cleared VOR/DME 12".
>

Who's Timothy Witt?

"At 10:51 the [Washington] center controller gave the flight a heading of
090 to intercept the 300-degree radial of the Armel VOR, to cross a point 25
miles west of Armel at 8,000, and '...the three-zero-zero radial will be for
the VOR approach to Runway One-Two at Dulles, altimeter
two-niner-point-seven-four.' The crew acknowledged. Cockpit voice recordings
(CVR) showed that the VOR was tuned and altimeters properly set."

"At 10:57 the crew again discussed the approach, including Round Hill
intersection, the final approach fix, VASI, runway lights, and the airport
diagram."

"At 11:01 the flight was cleared to 7,000 feet and handed off to Dulles
Approach Control. Dulles cleared it to proceed inbound to Armel VOR and to
expect the VOR/DME approach to Runway 12. At 11:04 the flight reported level
at 7,000, and five seconds later the controller said, 'TWA Five-Fourteen,
you're cleared for a VOR/DME approach to Runway One-Two.' The captain
acknowledged this."

http://www.aopa.org/asf/asfarticles/sp9806.html


>
> If I'm not totally mistaken, ROUND HILL is 11.6 DME from the FAF (which
> is in turn 6 DME from AML), not the IAF. I guess ROUND HILL is the
> actual IAF?!
>

Oops. I should have written, "...when they reached ROUND HILL, 11.6 miles
from the FAF. There is no designated IAF on this plate.


>
> Hm. My reading of the old approach plate would be to stay at or above
> 3300 (which MSA radius was used back then?) until ROUND HILL, then
> descend to 1800, and at 6 DME AML (FAF) start descending to MDA.
>

According to the regulation in effect today, given the clearance TWA514
received, you'd stay at 7,000 until ROUND HILL.


>
> Where did this captain get the idea to descend below the MEA of 1800ft
> before the FAF? You said "but decided that clearance for the approach
> was clearance to the initial approach altitude" - which would be 1800ft.
> Did they overshoot this descend (you mentioned 1670ft), or did he
> actually thought he could descend to MDA?
>

They were descending to 1,800. The weather was bad, the CVR mentions a
downdraft and a bumpy ride. Why the captain chose 1,800 is a mystery. If
you extend the 300 radial beyond ROUND HILL, you can see they'd be flying
almost directly over a 1764' obstruction. The MSA for the quadrant they
were in is 3300'. The MEA for the route from Front Royal VOR, which was
just 14 degrees off of their track, was 3400'. How anyone could examine
that plate and conclude 1800 MSL was a good altitude west of ROUND HILL is a
mystery to me.

On Mon, 10 Oct 2005 18:50:51 +0000 (UTC), Daniel Roesen > wrote:

>Where did this captain get the idea to descend below the MEA of 1800ft
>before the FAF? You said "but decided that clearance for the approach
>was clearance to the initial approach altitude" - which would be 1800ft.
>Did they overshoot this descend (you mentioned 1670ft), or did he
>actually thought he could descend to MDA?

According to what I was told by people who were in a position to know, that
idea that "clearance for the approach was also clearance to immediately
descend to the initial approach altitude" was part of the airline training
(at the particular airline) at that time.

I, too, was surpised as my IFR training, occurring a few years earlier,
would have led me to NOT descend until I was on a charted portion of the
approach.

Needless to say, that accident led to changes both in ATC procedures as
well as airline training.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

* Steven P. McNicoll >:
>
> "Daniel Roesen" > wrote in message
> ...
>>
>> Let's say I've been vectored on heading 090 at 4000ft, 5NM from LLZ
>> rwy 18. This track is not part of a published IAF-to-FAF track. Published
>> GS intercept altitude is 3000ft. ATC instructs "turn right heading 150,
>> cleared ILS 18". My interpretation of your quote would be that I'm _not_
>> allowed to start descending to 3000ft while I'm turning to 150 but would
>> have to stay on 4000ft until LLZ capture, and then descend (either with
>> the glide, or to 3000ft in order to wait there for GS capture) - or
>> declare unable if the GS is already below me at LLZ capture. Is that
>> correct?
>
> Where's LLZ?

It's the localizer, not a fix.

> Sounds like the heading will intercept inside the LOM.

Probably. Does that matter? Point being that I'm on hdg 150 towards
intercepting the localizer on 4000ft when being cleared for ILS. As
this is radar vectoring and my position not on a published procedure
track until I did capture the localizer and am established on FAC,
I understand that I'm not allowed to descend on my own. In my scenary
I would have the glideslope falling thru while I'm still heading for
localizer, so I may not descend. Ergo I can descend only at a time
when the GS is already below me.


Best regards,
Daniel

* Steven P. McNicoll >:
>> Timothy Witt wrote: "they had been cleared direct to the IAF", e.g.
>> "turn X heading Y direct ROUND HILL, cleared VOR/DME 12".
>
> Who's Timothy Witt?

The person who posted . com>
as deducted from his email address.

> "At 10:51 the [Washington] center controller gave the flight a heading of
> 090 to intercept the 300-degree radial of the Armel VOR, to cross a point 25
> miles west of Armel at 8,000, and '...the three-zero-zero radial will be for
> the VOR approach to Runway One-Two at Dulles, altimeter
> two-niner-point-seven-four.' The crew acknowledged. Cockpit voice recordings
> (CVR) showed that the VOR was tuned and altimeters properly set."
>
> "At 10:57 the crew again discussed the approach, including Round Hill
> intersection, the final approach fix, VASI, runway lights, and the airport
> diagram."
>
> "At 11:01 the flight was cleared to 7,000 feet and handed off to Dulles
> Approach Control. Dulles cleared it to proceed inbound to Armel VOR and to
> expect the VOR/DME approach to Runway 12. At 11:04 the flight reported level
> at 7,000, and five seconds later the controller said, 'TWA Five-Fourteen,
> you're cleared for a VOR/DME approach to Runway One-Two.' The captain
> acknowledged this."
>
> http://www.aopa.org/asf/asfarticles/sp9806.html

Thanks. I can see no clearance "direct to the IAF" there. Only vector
to intercept the FAC for the VOR/DME 12.

>> If I'm not totally mistaken, ROUND HILL is 11.6 DME from the FAF (which
>> is in turn 6 DME from AML), not the IAF. I guess ROUND HILL is the
>> actual IAF?!
>
> Oops. I should have written, "...when they reached ROUND HILL, 11.6 miles
> from the FAF. There is no designated IAF on this plate.

OK. Wasn't sure wether IAFs were explicitly marked as such almost 30
years ago. I'm only familiar with today's charts. :-)

>> Hm. My reading of the old approach plate would be to stay at or above
>> 3300 (which MSA radius was used back then?) until ROUND HILL, then
>> descend to 1800, and at 6 DME AML (FAF) start descending to MDA.
>
> According to the regulation in effect today, given the clearance TWA514
> received, you'd stay at 7,000 until ROUND HILL.

Yep, fully agree. Good to see that I actually understood one thing and
another. :-)

>> Where did this captain get the idea to descend below the MEA of 1800ft
>> before the FAF? You said "but decided that clearance for the approach
>> was clearance to the initial approach altitude" - which would be 1800ft.
>> Did they overshoot this descend (you mentioned 1670ft), or did he
>> actually thought he could descend to MDA?
>
> They were descending to 1,800. The weather was bad, the CVR mentions a
> downdraft and a bumpy ride. Why the captain chose 1,800 is a mystery.

Indeed.

> The MSA for the quadrant they were in is 3300'. The MEA for the route
> from Front Royal VOR, which was just 14 degrees off of their track,
> was 3400'.

Yeah, that's why I asked what MSA radius was used back then, as it's not
stated on the approach plate. The enroute segment with the 3400ft MEA
is (IIRC) about 18nm long, so it's certainly longer than the MSA radius.

> How anyone could examine that plate and conclude 1800 MSL was a good
> altitude west of ROUND HILL is a mystery to me.

Indeed.

Best regards,
Daniel

"Tim Auckland" > wrote in message
...
> Another example from the same plate:
>
> http://www.naco.faa.gov/d-tpp/0510/00375I28R.PDF
>
> You've not been given "vectors to final".
> You're established on the approach from the IAF FAITH.
> You're at 4100 feet.
> You fly over DUMBA.
> The leg from FAITH to DUMBA is NOT marked NoPT.
>
> I'm in the camp which thinks (hopes?) that a turn in the hold at DUMBA
> is not logical nor required.
>
> Three questions:
>
> a) does anyone think a turn in the hold at DUMBA is required? If so,
> why?
>
> b) should the leg from FAITH to DUMBA be marked "NoPT"?

I emailed the FAA at their chart-error address ),
and just received a reply:

"Thanks for your e-mail. You have brought up a very interesting question.
The arrival over FAITH INT should have a 'NoPT' associated with it, and a
T-NOTAM (see below) is being issued to cover the procedure until amended.
Coincidentally, this chart was already being amended, and the amendment will
be published in the Oct 27,2005 edition of the chart. The amendment will now
replace FAITH INT with MEHTA INT, located 0.6 NM southeast of the current
location of FAITH. The transition from MEHTA will have an associated 'NoPT'.
!FDC 5/9250 SFO FI/T SAN FRANCISCO INTL, SAN FRANCISCO, CA. ILS RWY 28R (CAT
I, II, III), AMDT 10A. TERMINAL ROUTE FROM FAITH INT TO DUMBA INT NOPT."

--Gary

"Daniel Roesen" > wrote in message
...
>
> The decision height is 200ft for straight-in ILS 36. What you mean is
> the decision altitude. Unless I've misunderstood something completely.
>

No, I mean decision height. The decision height for the S-ILS 36 is 882
MSL, the height above touchdown is 200 feet.

On 10/11/2005 09:31, Steven P. McNicoll wrote:

> "Daniel Roesen" > wrote in message
> ...
>>
>> The decision height is 200ft for straight-in ILS 36. What you mean is
>> the decision altitude. Unless I've misunderstood something completely.
>>
>
> No, I mean decision height. The decision height for the S-ILS 36 is 882
> MSL, the height above touchdown is 200 feet.
>
>

No...

Decision Height is the height above the touchdown zone elevation.

Decision Altitude is the MSL altitude of the Decision Height.

From the Pilot/Controller Glossary:

DECISION ALTITUDE/DECISION HEIGHT [ICAO]- A specified altitude or height (A/H)
in the precision approach at which a missed approach must be initiated if the
required visual reference to continue the approach has not been established.

Note 1: Decision altitude [DA] is referenced to mean sea level [MSL] and
decision height [DH] is referenced to the threshold elevation.

Note 2: The required visual reference means that section of the visual aids
or of the approach area which should have been in view for sufficient time
for the pilot to have made an assessment of the aircraft position and rate
of change of position, in relation to the desired flight path.

--
Mark Hansen, PP-ASEL, Instrument Airplane
Sacramento, CA

"Mark Hansen" > wrote in message
...[i]
>>
>> No, I mean decision height. The decision height for the S-ILS 36 is 882
>> MSL, the height above touchdown is 200 feet.
>>
>
> No...
>
> Decision Height is the height above the touchdown zone elevation.
>
> Decision Altitude is the MSL altitude of the Decision Height.
>
> From the Pilot/Controller Glossary:
>
> DECISION ALTITUDE/DECISION HEIGHT - A specified altitude
> or height (A/H) in the precision approach at which a missed approach must
> be
> initiated if the required visual reference to continue the approach has
> not been
> established.
>
> Note 1: Decision altitude [DA] is referenced to mean sea level [MSL] and
> decision height [DH] is referenced to the threshold elevation.
>
> Note 2: The required visual reference means that section of the visual
> aids or of the approach area which should have been in view for sufficient
> time for the pilot to have made an assessment of the aircraft position and
> rate of change of position, in relation to the desired flight path.
>

That's an ICAO definition, we're talking about a US IAP. See NACO TPP pages
A1 and F2.

* Steven P. McNicoll >:
> That's an ICAO definition, we're talking about a US IAP. See NACO TPP pages
> A1 and F2.

http://www.naco.faa.gov/d-tpp/frntmatter.pdf (page 2, bottom)

Hm indeed. What ICAO calls DA is called DH there. By mistake?

Do you have an URL for the TPP pages you referenced? I couldn't find
them.


Best regards,
Daniel

"Daniel Roesen" > wrote in message
...
>
> It's the localizer, not a fix.
>

Localizer identifiers are in the book, LLZ is not. You seem reluctant to
identify this airport. Why?


>
> Probably. Does that matter? Point being that I'm on hdg 150 towards
> intercepting the localizer on 4000ft when being cleared for ILS. As
> this is radar vectoring and my position not on a published procedure
> track until I did capture the localizer and am established on FAC,
> I understand that I'm not allowed to descend on my own. In my scenary
> I would have the glideslope falling thru while I'm still heading for
> localizer, so I may not descend. Ergo I can descend only at a time
> when the GS is already below me.
>

Yes, the point of interception does matter. Aircraft are to be vectored to
intercept the localizer at a point no closer than three miles outside the
FAF and at an altitude not above the glideslope or below the minimum
glideslope intercept altitude specified on the IAP. At 4000 you seem a bit
too high.

* Steven P. McNicoll >:
>> It's the localizer, not a fix.
>
> Localizer identifiers are in the book, LLZ is not. You seem reluctant
> to identify this airport. Why?

Because I had no specific airport in mind, really. It was a completely
synthetic example.

> Yes, the point of interception does matter. Aircraft are to be vectored to
> intercept the localizer at a point no closer than three miles outside the
> FAF and at an altitude not above the glideslope or below the minimum
> glideslope intercept altitude specified on the IAP. At 4000 you seem a bit
> too high.

Absolutely. But sometimes things don't go the way they should go, and
my question was what to do then.


Best regards,
Daniel

"Daniel Roesen" > wrote in message
...
>
> The person who posted
> . com>
> as deducted from his email address.
>

He seems to prefer the handle "150flivver". He was incorrect about the
clearance issued.


>
> OK. Wasn't sure wether IAFs were explicitly marked as such almost 30
> years ago. I'm only familiar with today's charts. :-)
>

They were designated by "(IAF)". LINDEN VOR, FRONT ROYAL VOR, and MRB VOR
are all designated as IAFs, but none of them are actually on the plate.


>
>> The MSA for the quadrant they were in is 3300'. The MEA for the route
>> from Front Royal VOR, which was just 14 degrees off of their track,
>> was 3400'.
>
> Yeah, that's why I asked what MSA radius was used back then, as it's not
> stated on the approach plate. The enroute segment with the 3400ft MEA
> is (IIRC) about 18nm long, so it's certainly longer than the MSA radius.
>

I have a Jeppesen approach chart legend dated October 10, 1975. The MSA
radius is 25 miles unless otherwise noted.

On Mon, 10 Oct 2005 20:35:42 GMT, "Steven P. McNicoll"
> wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>>
>> Just so I understand exactly what you are saying, is it your position
>> that,
>> when using DEPRE as the IAF for the purpose of starting this SIAP, if one
>> is inbound, the legal minimum altitude at DEPRE is 2141'?
>>
>
>There is no Minimum Descent Altitude on an ILS approach, there is instead a
>Decision Height. AWI123 is level at 3000 and five miles south of DEPRE, on
>the localizer, when cleared for the approach. The aircraft leaves 3000
>about 2.7 miles south of DEPRE, where it intercepts the glideslope. It
>follows the glideslope down, crossing DEPRE at 2141 MSL, to the decision
>height of 882 MSL. From that point it will either complete the approach
>visually or execute the missed approach procedure.
>

I didn't see your response of mine to this post of yours. Perhaps you
missed it, or I missed your response. In any event, here it is again:

=======================================

Your answer is not responsive to my question, but perhaps I did not write
clearly. So I will try to be more clear:

I did not mean to ask you about an MDA for this ILS approach. Nor am I
concerned about how the approach is flown from the FAF to DH.

I ask how your procedure without radar vectors satisfies the requirement
that this approach begin at an IAF.

I thought you indicated that DEPRE was the applicable IAF to satisfy this
requirement. Was that an incorrect assumption?

If DEPRE is the applicable IAF, it must have a minimum crossing altitude.
Since traffic is passing DEPRE at 2141', I would have expected that you
would think that is legal when DEPRE is being used as the IAF from which
this approach begins. Is that your position?

If DEPRE is not the applicable IAF, then I don't see how your procedure
meets the requirements of the 7110.65 that a non-vectored approach begin at
an IAF.
========================


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Daniel Roesen" > wrote in message
...
>
> http://www.naco.faa.gov/d-tpp/frntmatter.pdf (page 2, bottom)
>
> Hm indeed. What ICAO calls DA is called DH there. By mistake?
>

No.


>
> Do you have an URL for the TPP pages you referenced? I couldn't find
> them.
>

You just posted a URL for the TPP pages I referenced. TPP page A1 is page 2
of the above .pdf file, and TPP page F2 is page 6.

In article >,
Ron Garret > wrote:

> In article >,
> Mark Hansen > wrote:
>
> > Now, if they created a fix somewhere out on V21, and wrote a feeder
> > route from that fix, then you could. Effectively, you've be flying
> > V21 to the fix, then initiating the SIAP from there. However, they
> > didn't, so you can't ;-)
>
> OK, I'll buy that.
>
> I wonder if Steven P. McNicoll buys it too.
>
> And I wonder what Socal Approach would have to say about it. (I think
> I'll go find out. What a great excuse to fly to Catalina!)

Well, I did this experiment today. Flew VNY->AVX->FUL->VNY. It was a
gorgeous day, though I didn't get to do as much sightseeing as I would
have liked. All those approaches keep you busy!

So coming out of AVX I was cleared V21 SLI Direct, but coming out of AVX
I was immediately put on a 050 vector, which is not actually a vector to
SLI but takes you about 15nm east. So I asked Socal if I lost comm just
then what would he expect me to do? The controller seemed a little
taken aback, as if lost comm. was not something that he ever thought
about, but then improvised that he'd expect me to fly the vector until
abeam SLI, then turn towards SLI. But he added that "no one ever flies
their clearance around here. We always just give out vectors."

So I guess the bottom line is that as a practical matter no one ever
flies a PT in southern california because we always get vectors to final.

rg