Oct 18 course reversal change

[[email protected]]

The FAA recognized that a mistake had been made in the recent revision
to the AIM concerning course reversals; that the wording was in conflict
with the 1994 legal interpretation on the issue.

At last week's FAA/Industry Aeronautical Charting Forum the following
language was adopted to replace the recent change in AIM language.
Because of the long lead time in amending the AIM, the following
language will soon appear in the NTAP (Notice to Airmen Publication)
portion of the FAA's web site:

"New: Revised October 18, 2005

5-4-9. Procedure Turn

A procedure turn is the maneuver prescribed when it is necessary to
reverse direction to establish the aircraft inbound on an intermediate
or final approach course. The procedure turn or hold-in-lieu-of-PT is a
required maneuver when it is depicted on the approach chart. However,
the procedure turn or hold-in-lieu-of-PT is not permitted when the
symbol "No PT" is depicted on the initial segment being used, when a
RADAR VECTOR to the final approach course is provided, or when
conducting a timed approach from a holding fix. The altitude
prescribed for the procedure turn is a minimum altitude until the
aircraft is established on the inbound course. The maneuver must be
completed within the distance specified in the profile view.
Note
The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
it is not required by the procedure, but must first receive an amended
clearance from ATC. When ATC is Radar vectoring to the final approach
course or to the Intermediate Fix, ATC may specify in the approach
clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
uncertain whether the ATC clearance intends for a procedure turn to be
conducted or to allow for a straight-in approach, the pilot shall
immediately request clarification from ATC (14 CFR Part 91.123). "

[Jose]

This still leaves open what to do if you are on a non-vector course
which is pretty close to straight in, at an appropriate altitude for
straight in (i.e. the same altitude you'd be at inbound from the PT),
but the controller doesn't clear you straight in, a PT is depicted, and
NoPT is not depicted. Presumably you do a U-turn, and then a procedure
turn. But that's what started this discussion. I forget - what was the
original AIM ambiguity that this fixes?

Jose

> The FAA recognized that a mistake had been made in the recent revision
> to the AIM concerning course reversals; that the wording was in conflict
> with the 1994 legal interpretation on the issue.
>
> At last week's FAA/Industry Aeronautical Charting Forum the following
> language was adopted to replace the recent change in AIM language.
> Because of the long lead time in amending the AIM, the following
> language will soon appear in the NTAP (Notice to Airmen Publication)
> portion of the FAA's web site:
>
> "New: Revised October 18, 2005
>
> 5-4-9. Procedure Turn
>
> A procedure turn is the maneuver prescribed when it is necessary to
> reverse direction to establish the aircraft inbound on an intermediate
> or final approach course. The procedure turn or hold-in-lieu-of-PT is a
> required maneuver when it is depicted on the approach chart. However,
> the procedure turn or hold-in-lieu-of-PT is not permitted when the
> symbol "No PT" is depicted on the initial segment being used, when a
> RADAR VECTOR to the final approach course is provided, or when
> conducting a timed approach from a holding fix. The altitude
> prescribed for the procedure turn is a minimum altitude until the
> aircraft is established on the inbound course. The maneuver must be
> completed within the distance specified in the profile view.
> Note
> The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
> it is not required by the procedure, but must first receive an amended
> clearance from ATC. When ATC is Radar vectoring to the final approach
> course or to the Intermediate Fix, ATC may specify in the approach
> clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
> turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
> uncertain whether the ATC clearance intends for a procedure turn to be
> conducted or to allow for a straight-in approach, the pilot shall
> immediately request clarification from ATC (14 CFR Part 91.123). "

--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

[Roger]

On Mon, 31 Oct 2005 10:29:53 -0800, wrote:

>The FAA recognized that a mistake had been made in the recent revision
>to the AIM concerning course reversals; that the wording was in conflict
>with the 1994 legal interpretation on the issue.
>
>At last week's FAA/Industry Aeronautical Charting Forum the following
>language was adopted to replace the recent change in AIM language.
>Because of the long lead time in amending the AIM, the following
>language will soon appear in the NTAP (Notice to Airmen Publication)
>portion of the FAA's web site:

Never paid any attention to it.
Under vectors they bring me around to an intercept on an inbound
heading. No reversal is needed.
I've never been "cleared for the approach" with vectors until I was
relatively close to the actual inbound approach course. If I were
outbound and cleared for the approach I'd do the whole thing or ask
*their* intentions/expectations.

I have been asked if I'd like vectors or would like to do the whole
approach when it was obvious I was out practicing having already done
at least 6 or so approaches over the past hour or two, or if it was a
beautiful VFR day and I'm doing approaches.

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com
>
>"New: Revised October 18, 2005
>
>5-4-9. Procedure Turn
>
>A procedure turn is the maneuver prescribed when it is necessary to
>reverse direction to establish the aircraft inbound on an intermediate
>or final approach course. The procedure turn or hold-in-lieu-of-PT is a
>required maneuver when it is depicted on the approach chart. However,
>the procedure turn or hold-in-lieu-of-PT is not permitted when the
>symbol "No PT" is depicted on the initial segment being used, when a
>RADAR VECTOR to the final approach course is provided, or when
>conducting a timed approach from a holding fix. The altitude
>prescribed for the procedure turn is a minimum altitude until the
>aircraft is established on the inbound course. The maneuver must be
>completed within the distance specified in the profile view.
>Note
>The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
>it is not required by the procedure, but must first receive an amended
>clearance from ATC. When ATC is Radar vectoring to the final approach
>course or to the Intermediate Fix, ATC may specify in the approach
>clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
>turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
>uncertain whether the ATC clearance intends for a procedure turn to be
>conducted or to allow for a straight-in approach, the pilot shall
>immediately request clarification from ATC (14 CFR Part 91.123). "
>

[Tim Auckland]

On Mon, 31 Oct 2005 22:55:54 GMT, Jose >
wrote:

>This still leaves open what to do if you are on a non-vector course
>which is pretty close to straight in, at an appropriate altitude for
>straight in (i.e. the same altitude you'd be at inbound from the PT),
>but the controller doesn't clear you straight in, a PT is depicted, and
>NoPT is not depicted. Presumably you do a U-turn, and then a procedure
>turn. But that's what started this discussion. I forget - what was the
>original AIM ambiguity that this fixes?

The ambiguity is still there.
The first sentence in the newly revised wording hints that a procedure
turn is not necessary unless "it is necessary to reverse
direction...".
However, the second sentence completely overrides the first sentence.
It states that the PT (or hold-in-lieu) is a required maneuver when it
is depicted on the approach chart.
The third sentence then goes on to say that the procedure turn is not
permitted in certain circumstances.
The note then goes on to say that the pilot may elect to use the
procedure turn when it is not permitted if she or he first receives an
amended clearance from ATC.

It'd be way clearer if the FAA just dropped the "when it is necessary
to reverse direction" wording completely, but this wording is also in
FAR 97.3(p).
It'd also be way clearer if the FAA just dropped the "is a required
maneuver when depicted on the approach plate" concept, but apparently
this is spelled out in some way by something referenced by FAR 97.20.

I'm not holding my breath.

TIm.




>
>Jose
>
>> The FAA recognized that a mistake had been made in the recent revision
>> to the AIM concerning course reversals; that the wording was in conflict
>> with the 1994 legal interpretation on the issue.
>>
>> At last week's FAA/Industry Aeronautical Charting Forum the following
>> language was adopted to replace the recent change in AIM language.
>> Because of the long lead time in amending the AIM, the following
>> language will soon appear in the NTAP (Notice to Airmen Publication)
>> portion of the FAA's web site:
>>
>> "New: Revised October 18, 2005
>>
>> 5-4-9. Procedure Turn
>>
>> A procedure turn is the maneuver prescribed when it is necessary to
>> reverse direction to establish the aircraft inbound on an intermediate
>> or final approach course. The procedure turn or hold-in-lieu-of-PT is a
>> required maneuver when it is depicted on the approach chart. However,
>> the procedure turn or hold-in-lieu-of-PT is not permitted when the
>> symbol "No PT" is depicted on the initial segment being used, when a
>> RADAR VECTOR to the final approach course is provided, or when
>> conducting a timed approach from a holding fix. The altitude
>> prescribed for the procedure turn is a minimum altitude until the
>> aircraft is established on the inbound course. The maneuver must be
>> completed within the distance specified in the profile view.
>> Note
>> The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
>> it is not required by the procedure, but must first receive an amended
>> clearance from ATC. When ATC is Radar vectoring to the final approach
>> course or to the Intermediate Fix, ATC may specify in the approach
>> clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
>> turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
>> uncertain whether the ATC clearance intends for a procedure turn to be
>> conducted or to allow for a straight-in approach, the pilot shall
>> immediately request clarification from ATC (14 CFR Part 91.123). "

[Ron Rosenfeld]

On Mon, 31 Oct 2005 10:29:53 -0800, wrote:

>The procedure turn or hold-in-lieu-of-PT is a
>required maneuver when it is depicted on the approach chart.

Finally.

"onward through the fog"


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

[Gary Drescher]

"Jose" > wrote in message
...
> This still leaves open what to do if you are on a non-vector course which
> is pretty close to straight in, at an appropriate altitude for straight in
> (i.e. the same altitude you'd be at inbound from the PT), but the
> controller doesn't clear you straight in, a PT is depicted, and NoPT is
> not depicted. Presumably you do a U-turn, and then a procedure turn.

Yes, nominally, although presumably there's a chart error in that case. So
there may be some residual doubt as to how to fly an approach when there's
an obvious chart error (about a PT or about anything else); but what's most
important in such a case, I think, is to email the FAA's chart-error address
). In my experience, they'll promptly issue a NOTAM
and then fix the chart in the next revision.

--Gary

[Gary Drescher]

"Tim Auckland" > wrote in message
...
> The ambiguity is still there.

No, I think it's cleared up now (finally!).

> The first sentence in the newly revised wording hints that a procedure
> turn is not necessary unless "it is necessary to reverse
> direction...".

The first sentence, taken by itself, is still slightly ambiguous (though
less so than before, since it now says that the procedure is "prescribed"
when a direction-reversal is necessary; in other words, when the FAA thinks
you need to reverse course, they prescribe a PT, by charting it).

> However, the second sentence completely overrides the first sentence.

I'd say it clarifies rather than overrides--the second sentence eliminates
the ambiguity that would otherwise have been present in the first sentence.

> It states that the PT (or hold-in-lieu) is a required maneuver when it
> is depicted on the approach chart.
> The third sentence then goes on to say that the procedure turn is not
> permitted in certain circumstances.
> The note then goes on to say that the pilot may elect to use the
> procedure turn when it is not permitted if she or he first receives an
> amended clearance from ATC.

Yup. That all seems unambiguous now.

> It'd also be way clearer if the FAA just dropped the "is a required
> maneuver when depicted on the approach plate" concept,

I think that concept is what clears up the previous ambiguity--the depicted
PT is required, apart from the specifically listed exceptions.

--Gary

>>> "New: Revised October 18, 2005
>>>
>>> 5-4-9. Procedure Turn
>>>
>>> A procedure turn is the maneuver prescribed when it is necessary to
>>> reverse direction to establish the aircraft inbound on an intermediate
>>> or final approach course. The procedure turn or hold-in-lieu-of-PT is a
>>> required maneuver when it is depicted on the approach chart. However,
>>> the procedure turn or hold-in-lieu-of-PT is not permitted when the
>>> symbol "No PT" is depicted on the initial segment being used, when a
>>> RADAR VECTOR to the final approach course is provided, or when
>>> conducting a timed approach from a holding fix. The altitude
>>> prescribed for the procedure turn is a minimum altitude until the
>>> aircraft is established on the inbound course. The maneuver must be
>>> completed within the distance specified in the profile view.
>>> Note
>>> The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
>>> it is not required by the procedure, but must first receive an amended
>>> clearance from ATC. When ATC is Radar vectoring to the final approach
>>> course or to the Intermediate Fix, ATC may specify in the approach
>>> clearance "CLEARED STRAIGHT-IN (type) APPROACH" to insure the procedure
>>> turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
>>> uncertain whether the ATC clearance intends for a procedure turn to be
>>> conducted or to allow for a straight-in approach, the pilot shall
>>> immediately request clarification from ATC (14 CFR Part 91.123). "

[Mark T. Dame]

Gary Drescher wrote:

> "Jose" > wrote in message
> ...
>
>>This still leaves open what to do if you are on a non-vector course which
>>is pretty close to straight in, at an appropriate altitude for straight in
>>(i.e. the same altitude you'd be at inbound from the PT), but the
>>controller doesn't clear you straight in, a PT is depicted, and NoPT is
>>not depicted. Presumably you do a U-turn, and then a procedure turn.
>
> Yes, nominally, although presumably there's a chart error in that case.

If that's the case, then there are a lot of charts with errors. I've
seen a lot of them (perhaps most?) that have this situation. Here's an
example:

http://204.108.4.16/d-tpp/0510/05949V24.PDF

If you are flying a heading of 235 10 miles NE of ICING. ATC clears you
direct ICING and then cleared VOR 24 approach. Your statement is that
you fly 10 miles, do a U-turn, fly the procedure turn, then the
approach. That just seems insane.

Yes, ATC will most likely vector you to the final approach course and
then clear you for the approach (turn left heading 235, join the final
approach course, cleared VOR 24 approach), but if they don't...


-m
--
## Mark T. Dame >
## VP, Product Development
## MFM Software, Inc. (http://www.mfm.com/)
"Sometimes it happens."
-- Forrest Gump

[Gary Drescher]

"Mark T. Dame" > wrote in message
...
> Gary Drescher wrote:
>
>> "Jose" > wrote in message
>> ...
>>
>>>This still leaves open what to do if you are on a non-vector course which
>>>is pretty close to straight in, at an appropriate altitude for straight
>>>in (i.e. the same altitude you'd be at inbound from the PT), but the
>>>controller doesn't clear you straight in, a PT is depicted, and NoPT is
>>>not depicted. Presumably you do a U-turn, and then a procedure turn.
>>
>> Yes, nominally, although presumably there's a chart error in that case.
>
> If that's the case, then there are a lot of charts with errors. I've seen
> a lot of them (perhaps most?) that have this situation. Here's an
> example:
>
> http://204.108.4.16/d-tpp/0510/05949V24.PDF
>
> If you are flying a heading of 235 10 miles NE of ICING. ATC clears you
> direct ICING and then cleared VOR 24 approach. Your statement is that you
> fly 10 miles, do a U-turn, fly the procedure turn, then the approach.
> That just seems insane.
>
> Yes, ATC will most likely vector you to the final approach course and then
> clear you for the approach (turn left heading 235, join the final approach
> course, cleared VOR 24 approach), but if they don't...

Hm, that's a good point. I was thinking more of charts where an IAF that's
distinct from the FAF is nonetheless aligned with the FAC, but not
designated NoPT. In cases like that, I've reported the chart to the FAA, and
have seen an immediate NOTAM issued to correct the chart.

But you're right that an FAF is often and IAF too, and there's usually
nothing on the chart that says NoPT if a direct course to the IAF/FAF is
already aligned with the FAC (and at the same altitude).

Oh well. I guess the situation is still more confused than I'd realized.

--Gary

[rps]

"A procedure turn is the maneuver prescribed <bold>when it is necessary
to reverse direction</bold> to establish the aircraft inbound on an
intermediate or final approach course."

FAA's explanation of the AIM change (August change, not this one)
implies that no PT is required "if the aircraft is aligned within 90
degrees of the inbound course."
(http://www.faa.gov/ATpubs/AIM/Exofchg/exchg3.html.) I couldn't find
the FAA's explanation for the October change, which has not made its
way into FAA's online version of the AIM.

[Ron Rosenfeld]

On 2 Nov 2005 10:05:34 -0800, "rps" > wrote:

>"A procedure turn is the maneuver prescribed <bold>when it is necessary
>to reverse direction</bold> to establish the aircraft inbound on an
>intermediate or final approach course."
>
>FAA's explanation of the AIM change (August change, not this one)
>implies that no PT is required "if the aircraft is aligned within 90
>degrees of the inbound course."
>(http://www.faa.gov/ATpubs/AIM/Exofchg/exchg3.html.) I couldn't find
>the FAA's explanation for the October change, which has not made its
>way into FAA's online version of the AIM.

Yes, but the discussion of a procedure turn in the AIM is merely a
definition. The point that most seem to miss is that the "prescribing" is
done by the procedure designer when applying the various TERPs
requirements; and not by the pilot while flying the approach.


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

[rps]

I agree, but the problem is this: suppose you are flying from an IAF on
a course that does not indicate NoPT but the chart depicts a PT, and
your course is mostly aligned with the FAC. Are you going to fly the
PT? You could confirm with ATC, but what if ATC is too busy to talk or
you have comm failure?

My guess is that ATC is not expecting you to fly the PT in this
circumstance even when a PT is depicted on the chart because it is not
"necessary to reverse direction."

[Gary Drescher]

"rps" > wrote in message
ps.com...
>I agree, but the problem is this: suppose you are flying from an IAF on
> a course that does not indicate NoPT but the chart depicts a PT, and
> your course is mostly aligned with the FAC. Are you going to fly the
> PT? You could confirm with ATC, but what if ATC is too busy to talk or
> you have comm failure?

Actually, according to what the AIM now says (with the October NOTAM), you'd
have to fly the PT regardless of what ATC tells you. There's a provision to
fly an otherwise prohibited PT if ATC approves; but there's no provision to
skip a required PT, even if ATC approves. In general, ATC can't approve a
deviation from the requirements of a charted approach; and according to the
AIM now, a charted PT is part of those requirements.

However, the last time a chart such as you just described was discussed
here, I emailed the FAA's chart-error address, and they replied that the
omission of NoPT was a charting error; they promptly issued a NOTAM to
correct it.

> My guess is that ATC is not expecting you to fly the PT in this
> circumstance even when a PT is depicted on the chart because it is not
> "necessary to reverse direction."

I'd hesitate to guess what ATC expects, but flying the PT in that case would
be contrary to what the AIM now says the pilot is required to do. The
revised phrasing does not say that the PT must only be flown when necessary
to reverse direction; it does say that the charted PT *must* be flown,
except if certain specified conditions obtain (and already being aligned
with the FAC is not one of those conditions).

--Gary

[Ron Rosenfeld]

On 2 Nov 2005 15:31:35 -0800, "rps" > wrote:

>I agree, but the problem is this: suppose you are flying from an IAF on
>a course that does not indicate NoPT but the chart depicts a PT, and
>your course is mostly aligned with the FAC. Are you going to fly the
>PT? You could confirm with ATC, but what if ATC is too busy to talk or
>you have comm failure?
>
>My guess is that ATC is not expecting you to fly the PT in this
>circumstance even when a PT is depicted on the chart because it is not
>"necessary to reverse direction."

It really depends on the specifics. I am assuming that in your
hypothetical example, not only is there not a NoPT notation, but you are
also NOT receiving radar vectors to the final approach course. Under
current guidance and regulations (and written legal opinion) as I
understand them, there is no authorization available for the pilot to
choose to "skip" a charted procedure turn absent one of the prohibited
circumstances in the regulations and in the AIM.

It may well be that there is an error in the charting, or errors in ATC
procedures. I've seen and heard of both. I think those issues should be
corrected on the ground. There have also been examples which "seem" like
there should be a NoPT notation, but closer examination reveals some TERPs
violation that would ensue, sometimes having to do with descent gradients;
sometimes having to do with hypotheticals that don't exist in the real
world.

Under the new AIM guidance posted by Tim, it seems that ATC may specify
"CLEARED STRAIGHT-IN (type) APPROACH" and this would tell you that they are
providing radar vectors and really, really don't want you to do a procedure
turn. The only thing new is this new verbiage, and also the implication
that ATC will be able to provide radar vectors to an intermediate fix. I
don't know if the ATC requirements for ATC to be able to do that have been
published yet.


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

[Tim Auckland]

Here's my current spin on all of this.

I think the AIM writers have an impossible job to do -- they're trying
to clarify two FARS which essentially contradict each other. Hence
the ambiguiity in the AIM.

The FARS in question are

97.3(p) which defines the Procedure Turn as "the maneuver prescribed
when it is necessary to reverse direction..."

and

97.20 which includes by reference the textual description of the
standard instrument procedures, which apparently state that the
Procedure Turn is mandatory (except in the well-known very specific
exceptions).


So, by definition (97.3(p)), Procedure Turns are only relevant when a
course reversal is required, but 97.20 states that a Procedure Turn is
mandatory even if a course reversal is not required.

To me, these two FARS are contradictory.

It's not surprising that the AIM is confusing when it tries to explain
them.

The 1994 legal opinion appears to have been based on 97.20, but I
don't see how it can be reconciled with 97.3(p).

Even within the FAA, there are apparently two schools of thought on
this: the August AIM revision writer clearly supported 97.3(p),
whereas the current proposed revision writers are backing 97.20.

I think the FAA should review 97.20 and the legal opinion in the light
of 97.3(p).

Personally, I hope 97.3(p) wins. To me it's safer, more efficent,
mostly in general use when circumstances highlighting the ambiguity
actually exist, and far more accessible to the piloting community.

Tim.



On Mon, 31 Oct 2005 10:29:53 -0800, wrote:

>The FAA recognized that a mistake had been made in the recent revision
>to the AIM concerning course reversals; that the wording was in conflict
>with the 1994 legal interpretation on the issue.
>
>At last week's FAA/Industry Aeronautical Charting Forum the following
>language was adopted to replace the recent change in AIM language.
>Because of the long lead time in amending the AIM, the following
>language will soon appear in the NTAP (Notice to Airmen Publication)
>portion of the FAA's web site:
>
>"New: Revised October 18, 2005
>
>5-4-9. Procedure Turn
>
>A procedure turn is the maneuver prescribed when it is necessary to
>reverse direction to establish the aircraft inbound on an intermediate
>or final approach course. The procedure turn or hold-in-lieu-of-PT is a
>required maneuver when it is depicted on the approach chart. However,
>the procedure turn or hold-in-lieu-of-PT is not permitted when the
>symbol "No PT" is depicted on the initial segment being used, when a
>RADAR VECTOR to the final approach course is provided, or when
>conducting a timed approach from a holding fix. The altitude
>prescribed for the procedure turn is a minimum altitude until the
>aircraft is established on the inbound course. The maneuver must be
>completed within the distance specified in the profile view.
>Note
>The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
>it is not required by the procedure, but must first receive an amended
>clearance from ATC. When ATC is Radar vectoring to the final approach
>course or to the Intermediate Fix, ATC may specify in the approach
>clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
>turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
>uncertain whether the ATC clearance intends for a procedure turn to be
>conducted or to allow for a straight-in approach, the pilot shall
>immediately request clarification from ATC (14 CFR Part 91.123). "
>

[Gary Drescher]

"Tim Auckland" > wrote in message
...
> Here's my current spin on all of this.
>
> I think the AIM writers have an impossible job to do -- they're trying
> to clarify two FARS which essentially contradict each other. Hence
> the ambiguiity in the AIM.
>
> The FARS in question are
>
> 97.3(p) which defines the Procedure Turn as "the maneuver prescribed
> when it is necessary to reverse direction..."
>
> and
>
> 97.20 which includes by reference the textual description of the
> standard instrument procedures, which apparently state that the
> Procedure Turn is mandatory (except in the well-known very specific
> exceptions).
>
>
> So, by definition (97.3(p)), Procedure Turns are only relevant when a
> course reversal is required, but 97.20 states that a Procedure Turn is
> mandatory even if a course reversal is not required.
>
> To me, these two FARS are contradictory.

I don't think so. The text in 97.3p merely explains what the FAA's rationale
is in prescribing a procedure turn. But once the FAA issues such a
prescription--by charting a PT on an approach plate--then the PT is
mandatory (as stated in the 1994 legal opinion and the newly revised AIM
wording).

I think you're reading 97.3p as though it said "We hereby prescribe that you
perform a PT when you think it is necessary to reverse direction..."; but it
was apparently intended to mean "When our TERPS designers think it is
necessary for you to reverse direction, they prescribe a PT (by charting it
on an approach plate)".

--Gary

[Tim Auckland]

On Thu, 3 Nov 2005 11:36:25 -0500, "Gary Drescher"
> wrote:

>"Tim Auckland" > wrote in message
...
>> Here's my current spin on all of this.
>>
>> I think the AIM writers have an impossible job to do -- they're trying
>> to clarify two FARS which essentially contradict each other. Hence
>> the ambiguiity in the AIM.
>>
>> The FARS in question are
>>
>> 97.3(p) which defines the Procedure Turn as "the maneuver prescribed
>> when it is necessary to reverse direction..."
>>
>> and
>>
>> 97.20 which includes by reference the textual description of the
>> standard instrument procedures, which apparently state that the
>> Procedure Turn is mandatory (except in the well-known very specific
>> exceptions).
>>
>>
>> So, by definition (97.3(p)), Procedure Turns are only relevant when a
>> course reversal is required, but 97.20 states that a Procedure Turn is
>> mandatory even if a course reversal is not required.
>>
>> To me, these two FARS are contradictory.
>
>I don't think so. The text in 97.3p merely explains what the FAA's rationale
>is in prescribing a procedure turn. But once the FAA issues such a
>prescription--by charting a PT on an approach plate--then the PT is
>mandatory (as stated in the 1994 legal opinion and the newly revised AIM
>wording).
>
>I think you're reading 97.3p as though it said "We hereby prescribe that you
>perform a PT when you think it is necessary to reverse direction..."; but it
>was apparently intended to mean "When our TERPS designers think it is
>necessary for you to reverse direction, they prescribe a PT (by charting it
>on an approach plate)".

I agree that is in line with the 1994 legal opinion, but I still
wonder if it's what the original drafters of 97.3(p) intended.

If the original drafters of 97.3(p) intended Procedure Turns to be
used in all cases, why did they include the words "reverse direction"
at all?

Wouldn't it have been far simpler just to say something along the
lines of: "the Procedure Turn (when charted, and when not prohibited
by 91.175(j) ) is the procedure used to establish the aircraft on an
intermediate or final approach course"?

(I'd still like the FAA to review the legal opinion.)

Tim.

[Jose]

> but it
> was apparently intended to mean "When our TERPS designers think it is
> necessary for you to reverse direction, they prescribe a PT (by charting it
> on an approach plate)".

Some charts come with a "noPT sector", which makes sense to me.
Otherwise, the TERPS designers don't really know where I'm coming from,
and whether or not I need to reverse direction.

Jose
--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

[Gary Drescher]

"Jose" > wrote in message
m...
>> but it was apparently intended to mean "When our TERPS designers think it
>> is necessary for you to reverse direction, they prescribe a PT (by
>> charting it on an approach plate)".
>
> Some charts come with a "noPT sector", which makes sense to me. Otherwise,
> the TERPS designers don't really know where I'm coming from, and whether
> or not I need to reverse direction.

Yup, the cleared-direct case is a problem (with most existing approach
charts) under the new AIM wording. On the other hand, controllers only clear
you direct to the FAF under circumstances that would permit them to vector
you, right? So if they just announce they're vectoring you sometime before
you arrive at the fix, then the PT is no longer required (or permitted) and
the problem doesn't arise.

--Gary

[Gary Drescher]

"Tim Auckland" > wrote in message
...
> On Thu, 3 Nov 2005 11:36:25 -0500, "Gary Drescher"
> > wrote:
>>I think you're reading 97.3p as though it said "We hereby prescribe that
>>you
>>perform a PT when you think it is necessary to reverse direction..."; but
>>it
>>was apparently intended to mean "When our TERPS designers think it is
>>necessary for you to reverse direction, they prescribe a PT (by charting
>>it
>>on an approach plate)".
>
> I agree that is in line with the 1994 legal opinion, but I still
> wonder if it's what the original drafters of 97.3(p) intended.
>
> If the original drafters of 97.3(p) intended Procedure Turns to be
> used in all cases, why did they include the words "reverse direction"
> at all?

I suspect they were simply being informative by mentioning the rationale for
the prescription when they stated the definition of a PT. It makes sense
that they'd want pilots to understand what PTs are supposed to be for (even
though, like any other feature of an approach chart, a PT might mistakenly
be prescribed when it's not supposed to be).

--Gary

[Tim Auckland]

Gary,

I think we're in danger in getting caught up in legaleze here.

Let's step back a moment, and consider what this means in the real
world.

I'm approaching my destination on an IFR flight plan. I'm in the
clouds, otherwise I'd be doing a visual approach. I'm quite possibly
being bumped around. I'm also quite possibly tired after a long and
stressful flight in IMC.

I'm nicely lined up with the final approach course, at an appropriate
airspeed and altitude. I'm cleared for the approach, but I haven't,
however, heard the magic words "vectors to final".

Does it really make sense that the regulations insist that I fly a
procedure turn to get back to exactly the same point, heading,
altitude and airspeed I'm at now?


(To get back to legaleze:)
I'm not denying that that's what the 1994 legal opinion says. I'm
just saying that it doesn't gel with my reading of 97.3(p) as it is
written, I'm also saying that I'd like to see the legal opinion
overturned, and whatever regulations there are in 97.20 changed so
that we don't have to fly a procedure turn in these circumstances.

Tim.

On Thu, 3 Nov 2005 13:25:51 -0500, "Gary Drescher"
> wrote:

>"Tim Auckland" > wrote in message
...
>> On Thu, 3 Nov 2005 11:36:25 -0500, "Gary Drescher"
>> > wrote:
>>>I think you're reading 97.3p as though it said "We hereby prescribe that
>>>you
>>>perform a PT when you think it is necessary to reverse direction..."; but
>>>it
>>>was apparently intended to mean "When our TERPS designers think it is
>>>necessary for you to reverse direction, they prescribe a PT (by charting
>>>it
>>>on an approach plate)".
>>
>> I agree that is in line with the 1994 legal opinion, but I still
>> wonder if it's what the original drafters of 97.3(p) intended.
>>
>> If the original drafters of 97.3(p) intended Procedure Turns to be
>> used in all cases, why did they include the words "reverse direction"
>> at all?
>
>I suspect they were simply being informative by mentioning the rationale for
>the prescription when they stated the definition of a PT. It makes sense
>that they'd want pilots to understand what PTs are supposed to be for (even
>though, like any other feature of an approach chart, a PT might mistakenly
>be prescribed when it's not supposed to be).
>
>--Gary
>

[Gary Drescher]

"Tim Auckland" > wrote in message
...
> I think we're in danger in getting caught up in legaleze here.
>
> Let's step back a moment, and consider what this means in the real
> world.
>
> I'm approaching my destination on an IFR flight plan. I'm in the
> clouds, otherwise I'd be doing a visual approach. I'm quite possibly
> being bumped around. I'm also quite possibly tired after a long and
> stressful flight in IMC.
>
> I'm nicely lined up with the final approach course, at an appropriate
> airspeed and altitude. I'm cleared for the approach, but I haven't,
> however, heard the magic words "vectors to final".
>
> Does it really make sense that the regulations insist that I fly a
> procedure turn to get back to exactly the same point, heading,
> altitude and airspeed I'm at now?

Fair enough--let's put aside the legalities for a moment and consider some
real-world scenarios. One scenario that's been discussed occurs when an IAF
is aligned with the FAC (and at the right altitude) but isn't marked NoPT.
The right thing to do in that case is to notify the FAA of a likely chart
error, and they'll promptly issue a NOTAM to fix it. (If pilots and
controllers notify the FAA each time an error like that is noticed on the
ground, few such errors, if any, will still be uncorrected by the time
someone flies the approach.) If I were flying such an approach and the chart
hadn't been corrected yet, I'd ask ATC about it as soon as I noticed the
anomaly. In a lost-comm situation, I suppose I'd just fly straight in, even
though it'd be nominally illegal (but I'd only do that if I were already at
the altitude at which I'd cross if I were to execute the PT).

The other scenario that's beed discussed occurs if you've been cleared
direct to the FAF (rather than via vectors or via a charted course from an
IAF) and you're closely aligned with the FAC (and at the right altitude).
I've never had that happen, but I don't usually fly with a GPS, so I don't
usually get direct clearances in general; I'm unclear, therefore, as to how
common a scenario that might be.

--Gary

[Tim Auckland]

On Thu, 3 Nov 2005 17:08:56 -0500, "Gary Drescher"
> wrote:

>"Tim Auckland" > wrote in message
...
>> I think we're in danger in getting caught up in legaleze here.
>>
>> Let's step back a moment, and consider what this means in the real
>> world.
>>
>> I'm approaching my destination on an IFR flight plan. I'm in the
>> clouds, otherwise I'd be doing a visual approach. I'm quite possibly
>> being bumped around. I'm also quite possibly tired after a long and
>> stressful flight in IMC.
>>
>> I'm nicely lined up with the final approach course, at an appropriate
>> airspeed and altitude. I'm cleared for the approach, but I haven't,
>> however, heard the magic words "vectors to final".
>>
>> Does it really make sense that the regulations insist that I fly a
>> procedure turn to get back to exactly the same point, heading,
>> altitude and airspeed I'm at now?
>
>Fair enough--let's put aside the legalities for a moment and consider some
>real-world scenarios. One scenario that's been discussed occurs when an IAF
>is aligned with the FAC (and at the right altitude) but isn't marked NoPT.
>The right thing to do in that case is to notify the FAA of a likely chart
>error, and they'll promptly issue a NOTAM to fix it. (If pilots and
>controllers notify the FAA each time an error like that is noticed on the
>ground, few such errors, if any, will still be uncorrected by the time
>someone flies the approach.) If I were flying such an approach and the chart
>hadn't been corrected yet, I'd ask ATC about it as soon as I noticed the
>anomaly. In a lost-comm situation, I suppose I'd just fly straight in, even
>though it'd be nominally illegal (but I'd only do that if I were already at
>the altitude at which I'd cross if I were to execute the PT).
No disagreements here.

>
>The other scenario that's beed discussed occurs if you've been cleared
>direct to the FAF (rather than via vectors or via a charted course from an
>IAF) and you're closely aligned with the FAC (and at the right altitude).
>I've never had that happen, but I don't usually fly with a GPS, so I don't
>usually get direct clearances in general; I'm unclear, therefore, as to how
>common a scenario that might be.
Doesn't have to be GPS. Just about any time you're on a course (VOR
radial, or airway, or NDB bearing, or direct, or vector) which crosses
the extension of a FAC (localiser, VOR, NDB or GPS) you could be
instructed by ATC to intercept the FAC course, assuming that you're
within operational range of the transmitter. Doesn't mean anything
about altitudes, doesn't mean that you're cleared for the approach,
doesn't mean that you've got "vectors to final", just means that you
have to fly that course.

99 times out of 100 youi'll also get "vectors to final", so you're
right, it's not very common in the real world.

Tim.

[[email protected]]

Tim Auckland wrote:

> Here's my current spin on all of this.
>
> I think the AIM writers have an impossible job to do -- they're trying
> to clarify two FARS which essentially contradict each other. Hence
> the ambiguiity in the AIM.
>
> The FARS in question are
>
> 97.3(p) which defines the Procedure Turn as "the maneuver prescribed
> when it is necessary to reverse direction..."
>
> and
>
> 97.20 which includes by reference the textual description of the
> standard instrument procedures, which apparently state that the
> Procedure Turn is mandatory (except in the well-known very specific
> exceptions).
>
> So, by definition (97.3(p)), Procedure Turns are only relevant when a
> course reversal is required, but 97.20 states that a Procedure Turn is
> mandatory even if a course reversal is not required.
>
> To me, these two FARS are contradictory.
>
> It's not surprising that the AIM is confusing when it tries to explain
> them.
>
> The 1994 legal opinion appears to have been based on 97.20, but I
> don't see how it can be reconciled with 97.3(p).
>
> Even within the FAA, there are apparently two schools of thought on
> this: the August AIM revision writer clearly supported 97.3(p),
> whereas the current proposed revision writers are backing 97.20.
>
> I think the FAA should review 97.20 and the legal opinion in the light
> of 97.3(p).
>
> Personally, I hope 97.3(p) wins. To me it's safer, more efficent,
> mostly in general use when circumstances highlighting the ambiguity
> actually exist, and far more accessible to the piloting community.
>

If a review were to be conducted the context of both would have to be
carefully considered. In my years of working with this stuff I don't see the
conflict.
97.3(p) is a general statement about procedure elements. What 97.3(p) is
impling when stating "when required" is that a procedure will have a charted
course reversal when it is required by the design circumstances. The toolbox
of TERPS design options include the option to not include a course reversal
where local topography, procedure track alignments, and ATC flow requirements
will permit exclusion of a course reversal in the design.

97.3 is defining symbols and terms, some of which may not appear on all
instrument approach procedures.

97.20 is the regulatory basis for incorporating specific TERPS instrument
approach procedures into Part 97 by reference in the federal register. Where
a course reversal is specified in any given procedure, then it is required
under the context of the definition in 97.3(p) unless one of the conditions
of 91.175(j) exists.

[[email protected]]

> If the original drafters of 97.3(p) intended Procedure Turns to be
> used in all cases, why did they include the words "reverse direction"
> at all?
>

Because they knew some procedure could be, and would be, designed without course
reversals. They also knew that some procedures designed with course reversal
would have some NoPT terminal routes.

[[email protected]]

Tim Auckland wrote:

> Doesn't have to be GPS. Just about any time you're on a course (VOR
> radial, or airway, or NDB bearing, or direct, or vector) which crosses
> the extension of a FAC (localiser, VOR, NDB or GPS) you could be
> instructed by ATC to intercept the FAC course, assuming that you're
> within operational range of the transmitter. Doesn't mean anything
> about altitudes, doesn't mean that you're cleared for the approach,
> doesn't mean that you've got "vectors to final", just means that you
> have to fly that course.
>
> 99 times out of 100 youi'll also get "vectors to final", so you're
> right, it's not very common in the real world.
>

If ATC has set you up to intercept the intermediate course, or an extension
thereof, they have provided "vectors to final." The ambiguity that occasionally
results is usually from vague ATC procedures rather than ambiguous procedure
design.

A new complexity will arrive early next year when the ATC procedure of clearing
pilots direct to the intermediate fix of an RNAV procedure will be finally
officially sanctioned. This will provide additional flexibility but will also
result in confustion.

Then, as the RNAV (RNP) procedures proliferate, this new ATC procedure will not
be permitted with those procedures, which is bound to create even more confusion.

[[email protected]]

Jose wrote:.

>
> Some charts come with a "noPT sector", which makes sense to me.
> Otherwise, the TERPS designers don't really know where I'm coming from,
> and whether or not I need to reverse direction.

When an NoPT sector is designated it states "via airways" within that sector
unless it is a TAA in an RNAV procedure (rather rare because most ATC facilities
don't know how to handle TAAs, thus they won't accept the design from AVN).

As to the second part of your statement, can you provide an example of an NoPT
route where the procedure designer wouldn't know where you would be coming from?

[Jose]

>> Some charts come with a "noPT sector", which makes sense to me.
>> Otherwise, the TERPS designers don't really know where I'm coming from,
>> and whether or not I need to reverse direction.
>
> When an NoPT sector is designated it states "via airways" within that sector
> unless it is a TAA in an RNAV procedure (rather rare because most ATC facilities
> don't know how to handle TAAs, thus they won't accept the design from AVN).

Ok. I didn't know that. It then makes less sense to me.

> As to the second part of your statement, can you provide an example of an NoPT
> route where the procedure designer wouldn't know where you would be coming from?

All of them. The procedures are designed before I get into the airplane.

Jose
--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

[[email protected]]

Jose wrote:

> >> Some charts come with a "noPT sector", which makes sense to me.
> >> Otherwise, the TERPS designers don't really know where I'm coming from,
> >> and whether or not I need to reverse direction.
> >
> > When an NoPT sector is designated it states "via airways" within that sector
> > unless it is a TAA in an RNAV procedure (rather rare because most ATC facilities
> > don't know how to handle TAAs, thus they won't accept the design from AVN).
>
> Ok. I didn't know that. It then makes less sense to me.

What made more sense with your previous understanding?

>
>
> > As to the second part of your statement, can you provide an example of an NoPT
> > route where the procedure designer wouldn't know where you would be coming from?
>
> All of them. The procedures are designed before I get into the airplane.
>

Hmmm...well, the procedure requires you to start at the fix that defines the NoPT
terminal route. Where is the mystery in that to the designer?

>

[Tim Auckland]

On Fri, 04 Nov 2005 04:54:26 -0800, wrote:

>
>
>Tim Auckland wrote:
>
>> Doesn't have to be GPS. Just about any time you're on a course (VOR
>> radial, or airway, or NDB bearing, or direct, or vector) which crosses
>> the extension of a FAC (localiser, VOR, NDB or GPS) you could be
>> instructed by ATC to intercept the FAC course, assuming that you're
>> within operational range of the transmitter. Doesn't mean anything
>> about altitudes, doesn't mean that you're cleared for the approach,
>> doesn't mean that you've got "vectors to final", just means that you
>> have to fly that course.
>>
>> 99 times out of 100 youi'll also get "vectors to final", so you're
>> right, it's not very common in the real world.
>>
>
>If ATC has set you up to intercept the intermediate course, or an extension
>thereof, they have provided "vectors to final." The ambiguity that occasionally
>results is usually from vague ATC procedures rather than ambiguous procedure
>design.
>
>A new complexity will arrive early next year when the ATC procedure of clearing
>pilots direct to the intermediate fix of an RNAV procedure will be finally
>officially sanctioned. This will provide additional flexibility but will also
>result in confustion.
>
>Then, as the RNAV (RNP) procedures proliferate, this new ATC procedure will not
>be permitted with those procedures, which is bound to create even more confusion.
Thanks for the heads-up.

[Jose]

> What made more sense with your previous understanding?

When I think of a "sector" I think of a block of airspace, not a set of
arrival points or routes.

> Hmmm...well, the procedure requires you to start at the fix that defines the NoPT
> terminal route. Where is the mystery in that to the designer?

I am cleared to a fix, and cleared for the approach. The fix I am
cleared to (especially in a GPS world) is not necessarily "the fix that
defines the NoPT terminal route" but may be a fix that is on the
approach. It's not on a NoPT terminal route, but it is aligned with the
FAC and I'm at an appropriate altitude.

I suppose the designer didn't design it for that, but sometimes it's
used that way.

Jose
--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

[[email protected]]

Jose wrote:

> > What made more sense with your previous understanding?
>
> I am cleared to a fix, and cleared for the approach. The fix I am
> cleared to (especially in a GPS world) is not necessarily "the fix that
> defines the NoPT terminal route" but may be a fix that is on the
> approach. It's not on a NoPT terminal route, but it is aligned with the
> FAC and I'm at an appropriate altitude.
>
> I suppose the designer didn't design it for that, but sometimes it's
> used that way.

That practice is different than arrival along an NoPT route. That is an "innovation,"
which is more akin to a vector to final. It is "bogus" but will be approved as a new
ATC procedure early next year. It is intended to be limited to RNAV IAPs (hopefully
;-). The clearance must be to the intermediate waypoint/fix (IF), must not exceed a
90-degree course change and at an altitude compatible with the procedure.