OLV GPS 36 approach question

[A Lieberma]

Went out seeking some IMC time today. Severe clear at my home airport,
so took a trip from KMBO (Madison MS) to KOLV (Olive Branch MS)

Early morning clouds at OLV was 500 overcast, so I figured by the time I
got there, it would at least be broken. It wasn't the clouds that was
restricting the visibility so much as the haze. 2 mile forward viz at
best on my final approach.

Memphis Approach asked what approach I wanted and I elected GPS RWY 36
approach. I was at 4000 feet and about 10 miles out I was cleared to the
NOCAP initial approach fix, My instructions were descend and maintain
2,100, cleared for the GPS36 approach. My heading was 006 to the fix so
it was as easy as it gets to to intercepting the final approach course.

When I was looking at the profile part, before NOCAP I was to maintain
2800. So rather then descend to 2100, I maintained 2800 til I got to
NOCAP.

I didn't say anything / question the approach controller since the
frequency was wall to wall traffic, but I didn't want to hit anything
poking out of the ground either.

What is the overriding factor in this case (besides my PIC decision of
maintaining 2800)?

I can see where the controller got the 2100 figure which was the final
approach fix step down altitude, but I also didn't want to cause a
traffic conflict by maintaining 2800. So, I figured I'd have a better
chance at 2800 then 2100 as things poking out of the ground won't move
out of my way.

Was I correct in maintaining 2800 before the IAF or is the controller
allowed to clear me below a minimum dictated by an approach chart?

Is a ASR in order or did I mess up somewhere?

Allen

[Sam Spade]

A Lieberma wrote:

> Went out seeking some IMC time today. Severe clear at my home airport,
> so took a trip from KMBO (Madison MS) to KOLV (Olive Branch MS)
>
> Early morning clouds at OLV was 500 overcast, so I figured by the time I
> got there, it would at least be broken. It wasn't the clouds that was
> restricting the visibility so much as the haze. 2 mile forward viz at
> best on my final approach.
>
> Memphis Approach asked what approach I wanted and I elected GPS RWY 36
> approach. I was at 4000 feet and about 10 miles out I was cleared to the
> NOCAP initial approach fix, My instructions were descend and maintain
> 2,100, cleared for the GPS36 approach. My heading was 006 to the fix so
> it was as easy as it gets to to intercepting the final approach course.
>
> When I was looking at the profile part, before NOCAP I was to maintain
> 2800. So rather then descend to 2100, I maintained 2800 til I got to
> NOCAP.
>
> I didn't say anything / question the approach controller since the
> frequency was wall to wall traffic, but I didn't want to hit anything
> poking out of the ground either.
>
> What is the overriding factor in this case (besides my PIC decision of
> maintaining 2800)?
>
> I can see where the controller got the 2100 figure which was the final
> approach fix step down altitude, but I also didn't want to cause a
> traffic conflict by maintaining 2800. So, I figured I'd have a better
> chance at 2800 then 2100 as things poking out of the ground won't move
> out of my way.
>
> Was I correct in maintaining 2800 before the IAF or is the controller
> allowed to clear me below a minimum dictated by an approach chart?
>
> Is a ASR in order or did I mess up somewhere?
>
> Allen

Chances are about 100% that the controller could vector you at 2,100.

There is an abundance of regulatory and training information about
vectors to an approach.

[Ron Rosenfeld]

On Sat, 05 Aug 2006 22:15:07 GMT, A Lieberma > wrote:

>Went out seeking some IMC time today. Severe clear at my home airport,
>so took a trip from KMBO (Madison MS) to KOLV (Olive Branch MS)
>
>Early morning clouds at OLV was 500 overcast, so I figured by the time I
>got there, it would at least be broken. It wasn't the clouds that was
>restricting the visibility so much as the haze. 2 mile forward viz at
>best on my final approach.
>
>Memphis Approach asked what approach I wanted and I elected GPS RWY 36
>approach. I was at 4000 feet and about 10 miles out I was cleared to the
>NOCAP initial approach fix, My instructions were descend and maintain
>2,100, cleared for the GPS36 approach. My heading was 006 to the fix so
>it was as easy as it gets to to intercepting the final approach course.
>
>When I was looking at the profile part, before NOCAP I was to maintain
>2800. So rather then descend to 2100, I maintained 2800 til I got to
>NOCAP.
>
>I didn't say anything / question the approach controller since the
>frequency was wall to wall traffic, but I didn't want to hit anything
>poking out of the ground either.
>
>What is the overriding factor in this case (besides my PIC decision of
>maintaining 2800)?
>
>I can see where the controller got the 2100 figure which was the final
>approach fix step down altitude, but I also didn't want to cause a
>traffic conflict by maintaining 2800. So, I figured I'd have a better
>chance at 2800 then 2100 as things poking out of the ground won't move
>out of my way.
>
>Was I correct in maintaining 2800 before the IAF or is the controller
>allowed to clear me below a minimum dictated by an approach chart?
>
>Is a ASR in order or did I mess up somewhere?
>
>Allen

From what you describe, I think you should file an ASRS report. You wrote
that the controller instructed you to descend and maintain 2100', yet you
did not do so, nor did you question him. You could write in the ASRS
report that you did not question him because it of radio frequency
congestion.

On the other hand, since you started at 4000', you could also state that
you were just making a "gradual" descent :-).

Your impression as to where the controller got the 2100 figure from may be
wrong. He might have been looking at an MVA chart, which we as pilots do
not have access to.

Unless I were familiar with the area, I probably would have done what you
did.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

[A Lieberma]

Sam Spade > wrote in news:iBbBg.520$0F5.397@fed1read04:

> Chances are about 100% that the controller could vector you at 2,100.
>
> There is an abundance of regulatory and training information about
> vectors to an approach.

Help me a little Sam on your reply as I am not quite sure I understand. :-)

I was cleared for the approach, not vectored so the navigation was put on
me. Based on the approach plate, from where I was coming from, within 30
miles I am to maintain 2800 unless I am misunderstanding something?

Allen

[Dan Luke]

"A Lieberma" wrote:

> I can see where the controller got the 2100 figure which was the final
> approach fix step down altitude

I'll bet it was the local MVA. Controllers do not usually have much
information handy about outlying airports' approaches.

> Was I correct in maintaining 2800 before the IAF or is the controller
> allowed to clear me below a minimum dictated by an approach chart?

Are you sure the controller didn't say "maintain *at or above* 2100..."?

The controller probably had no clue about the altitudes on the approach
plate, but did know the MVA in that area, and so included it in the
clearance.

http://tinyurl.com/jul8f

> Is a ASR in order or did I mess up somewhere?

No to both.

--
Dan
C172RG at BFM

[Greg Esres]

<<Was I correct in maintaining 2800 before the IAF or is the
controller allowed to clear me below a minimum dictated by an approach
chart?>>


I often fly this same approach. On occasion, a controller will give
me a lower altitude than published, but when I say, "Skyhawk 1234X
requests 2800 to comply with the procedure", they always give it to
me.

Your controller made a mistake and you should have corrected it. His
instruction to descend and maintain 2,100 was an order, and
technically you were wrong to ignore it.

BTW, MVA in that area is probably 2,000 feet, so you were safe at
2,100, but not in compliance with the procedure.

Controllers make mistakes like this *all the time*, and you should be
spring-loaded to deal with it in a polite way.

[Greg Esres]

<<Controllers do not usually have much information handy about
outlying airports' approaches.>>

This airport is only 10 miles from the Memphis Class B Airport, even
though it's in MS. At one time, this was the busiest airport in all
of Mississippi, due to flight training activities. The controllers
are intimately familiar with the approaches into this airport and most
of them know that the initial segments require 2,800.

[A Lieberma]

Greg Esres > wrote in
:

> Your controller made a mistake and you should have corrected it. His
> instruction to descend and maintain 2,100 was an order, and
> technically you were wrong to ignore it.

Appreciate your feedback Dan,

I kinda knew that I was not in the right by not complying, but not being
spring loaded as you said I should have been, I didn't want to cause any
commotion on the airwaves, as my goal was to fly the plane with the hopes I
could have gotten a clarification, but the frequency was really congested.

Even though I have had my IFR ticket for 2 years, every flight feels like
my first :-)

I didn't have the airport in sight due to forward viz being so low so I had
to stick with the numbers in front of me.

Allen

[A Lieberma]

Greg Esres > wrote in
:

> This airport is only 10 miles from the Memphis Class B Airport, even
> though it's in MS. At one time, this was the busiest airport in all
> of Mississippi, due to flight training activities.

Unfortunately the flight school no longer operates out of OLV per airport
personel, so traffic has been reduced substantially!

Sure was a pleasure not to fight merging into the pattern though, as I was
up here before the tower was built and I was told it's not unusual to have
4 to 6 planes in the pattern!

Allen

[Greg Esres]

<<Even though I have had my IFR ticket for 2 years, every flight feels
like my first :-)>>

Perfectly understandable. Unless you fly profesionally, it takes
quite a long time years-wise to have encountered and digested most
types of situations.

I fly the approaches in this area over and over again with students,
so these approaches are more mine than the controller's. I'm used to
telling them how I want to fly them.

I doubt the controller even noticed that you didn't descend to the
altitude he gave you, or he would have said something.

[Greg Esres]

<<Unfortunately the flight school no longer operates out of OLV per
airport personel, so traffic has been reduced substantially! >>

The owner screwed up the business royally. But, the lease for the
building was taken over by the smaller flight school next door.
However, they did not aquire the leasebacks for the newer Cessna
Aircraft, or the complex aircraft. Downtown Aviation at the Dewitt
Spain Airport just north of Memphis' downtown area got those, along
with a large number of the instructors (including moi) and students.

So, there is indeed still a flight school at Olive Branch, but it's
operating at a far reduced capability than it had 3 or 4 years ago.
The new owners have big plans, but so far their execution has been
poor, IMO.

[john smith]

In article >,
Greg Esres > wrote:

> BTW, MVA in that area is probably 2,000 feet, so you were safe at
> 2,100, but not in compliance with the procedure.

What is the MSA on the approach chart?

[Greg Esres]

<<What is the MSA on the approach chart?>>

No MSA on TAA RNAV approaches.

On the ILS, I think it's 2,500, due to a very tall tower north of the
airport.

[BillJ]

Greg Esres wrote:
> <<What is the MSA on the approach chart?>>
>
> No MSA on TAA RNAV approaches.
>
> On the ILS, I think it's 2,500, due to a very tall tower north of the
> airport.
>
>
MVA trumps MSA, and that is what was issued. Published 2800 would be
required if no radar.

[A Lieberma]

BillJ > wrote in news:pk5Cg.15$H84.900
@eagle.america.net:

> MVA trumps MSA, and that is what was issued. Published 2800 would be
> required if no radar.

Once I am cleared for an approach, am I no longer under "vectors" but own
navigation?

In other words, MVA no longer is applicable since I am responsible for
executing the approach without vector instructions?

Allen

[Greg Esres]

<<MVA trumps MSA, and that is what was issued. Published 2800 would be
required if no radar.>>

MSA is irrelevant, except in an emergency. And MVA only trumps the
2800 if being RADAR VECTORED to the final approach course. In this
case, the pilot was flying a non-radar procedure in a radar
environment. ATC should have given him no altitude below 2800.

[Sam Spade]

[Sam Spade]

Greg Esres wrote:

> <<MVA trumps MSA, and that is what was issued. Published 2800 would be
> required if no radar.>>
>
> MSA is irrelevant, except in an emergency. And MVA only trumps the
> 2800 if being RADAR VECTORED to the final approach course. In this
> case, the pilot was flying a non-radar procedure in a radar
> environment. ATC should have given him no altitude below 2800.
>

Not so with this past February's AIM and ATC procedure change:

"AIM 5-4-7

i. ATC may clear aircraft that have filed an Advanced RNAV equipment
suffix to the intermediate fix when clearing aircraft for an instrument
approach procedure. ATC will take the following actions when clearing
Advanced RNAV aircraft to the intermediate fix:
1. Provide radar monitoring to the intermediate fix.
2. Advise the pilot to expect clearance direct to the intermediate fix
at least 5 miles from the fix.
NOTE-
This is to allow the pilot to program the RNAV equipment to allow the
aircraft to fly to the intermediate fix when cleared by ATC.
3. Assign an altitude to maintain until the intermediate fix.
4. Insure the aircraft is on a course that will intercept the
intermediate segment at an angle not greater than 90 degrees and is at
an altitude that will permit normal descent from the intermediate fix to
the final approach fix."

Item 1 "Radar Monitor" is the functional equivalent to a radar vector
for purposes of this provision. That was all explained in the preamble
to the change, which appeared in this news group a while back.

[[email protected]]

<<Not so with this past February's AIM and ATC procedure change: >>

You informed me of this change a month or two ago, but that doesn't
change the fact that published altitudes apply after arriving at the
IF. An assigned altitutde below an intermediate segment altitude would
be an error, as I think you'd agree.

However, as I reviewed the original post, he said he was cleared to
DOCAP. In my mind, I pictured the right base entry, which is the one
that I usually make, but DOCAP is the IF/IAF and which makes it a
straight-in. The first published altitude IS (I think) 2,100, so the
controller didn't make an error after all. The 2,800 that the OP
mentioned was probably the straight in sector altitude, which becomes
irrelevant when cleared to the IF.

[[email protected]]

Allen:

When I orginally read your post, I pictured you making a right base
entry to the procedure, even though you mentioned DOCAP. Anyway, my
reply was based on this incorrect mental image.

The published intermediate segment after DOCAP has a published altitude
of 2,100, so the controller's instruction was appropriate. The
published altitude prior to that fix is for the holding pattern course
reversal, which you were not required to perform coming from the
straight-in area.

Sorry for the confusion.

[Sam Spade]

wrote:
> <<Not so with this past February's AIM and ATC procedure change: >>
>
> You informed me of this change a month or two ago, but that doesn't
> change the fact that published altitudes apply after arriving at the
> IF. An assigned altitutde below an intermediate segment altitude would
> be an error, as I think you'd agree.

I would agree, and if there were a step-down altitude in the
intermediate higher than 2,100, then the assignment would have been in
error.

But, in the circstances with this IAP, it was functionally no different
than "vectors to final" (i.e., the intermediate segment), which wouldn't
be any surprise to have done at 2,100 feet.

Having said that, because of the nuance of this new procedure, an
assignment to cross DOCAP at 2,800 would be better human-factors.
>
> However, as I reviewed the original post, he said he was cleared to
> DOCAP. In my mind, I pictured the right base entry, which is the one
> that I usually make, but DOCAP is the IF/IAF and which makes it a
> straight-in. The first published altitude IS (I think) 2,100, so the
> controller didn't make an error after all. The 2,800 that the OP
> mentioned was probably the straight in sector altitude, which becomes
> irrelevant when cleared to the IF.
>

[A Lieberma]

wrote in news:1155147361.341080.40380
@p79g2000cwp.googlegroups.com:

> The published intermediate segment after DOCAP has a published altitude
> of 2,100, so the controller's instruction was appropriate. The
> published altitude prior to that fix is for the holding pattern course
> reversal, which you were not required to perform coming from the
> straight-in area.

Hi Greg,

Bear with me as I am really trying to understand this....

Looking at the FAA version of the approach plate, profile section, it has
2800 to DOCAP, then descend to 2100 at CICAL for the final approach into
OLV.

Based on what you are saying, since I am pretty much a straight in approach
that it's allowable to be cleared by ATC below the profile altitude of 2800
10 miles BEFORE DOCAPS?

10 miles outside DOCAPS, my instructions were descend and maintain 2100,
cleared for the GPS 36.

Allen

[Sam Spade]

A Lieberma wrote:
>
>
> Bear with me as I am really trying to understand this....
>
> Looking at the FAA version of the approach plate, profile section, it has
> 2800 to DOCAP, then descend to 2100 at CICAL for the final approach into
> OLV.
>
> Based on what you are saying, since I am pretty much a straight in approach
> that it's allowable to be cleared by ATC below the profile altitude of 2800
> 10 miles BEFORE DOCAPS?
>
> 10 miles outside DOCAPS, my instructions were descend and maintain 2100,
> cleared for the GPS 36.
>
> Allen

Think in terms of being vectored to the final approach course on an ILS.
When done correctly, the controller will vector you at an altitude
below the G/S.

If this approach were an ILS and the controller was setting you up to
intercept the "final" perhaps 3 miles prior to CICAL on a 30 degree
intercept angle. The controller would almost certainly descend you to
2,100 to intercept. He might have you at 2,100 10 miles prior to intercept.

Do you see any difference with your handling, albeit with a new ATC/AIM
procedure?

[[email protected]]

<<Looking at the FAA version of the approach plate, profile section, it
has
2800 to DOCAP, then descend to 2100 at CICAL for the final approach
into
OLV.>>

The 2,800 ft segment you see is the Hold-in-Lieu. A HIL is part of the
initial segment, which doesn't begin until the IAF. From your
direction of flight, the HIL wasn't required for you, so its altitude
didn't apply.

Regardless, ATC has a right to assign you an altitude to maintain until
you arrive at a certain fix; only AFTER you arrive there do published
altitudes apply. Until then, you're relying on their MVA to keep you
safe.

If they had cleared you to ECILE, and told you to maintain 2,100, then
there would have been a problem. You're fine until you get to ECILE,
but the moment you pass that fix, you're in violation of 91.177.

Same thing if you had come from the north direction to DOCAP. You'd be
fine at 2,100 until the fix, but the HIL is required from this
direction and you'd be in violation of 91.177 once you started the hold
entry.


Sam: The fix DOCAP is labeld IF/IAF. Does the segment from DOCAP to
CICAL use initial or intermediate ROC ?

[John Clonts]

wrote:
> <<Looking at the FAA version of the approach plate, profile section, it
> has
> 2800 to DOCAP, then descend to 2100 at CICAL for the final approach
> into
> OLV.>>
>
> The 2,800 ft segment you see is the Hold-in-Lieu. A HIL is part of the
> initial segment, which doesn't begin until the IAF. From your
> direction of flight, the HIL wasn't required for you, so its altitude
> didn't apply.
>
> Regardless, ATC has a right to assign you an altitude to maintain until
> you arrive at a certain fix; only AFTER you arrive there do published
> altitudes apply. Until then, you're relying on their MVA to keep you
> safe.
>
> If they had cleared you to ECILE, and told you to maintain 2,100, then
> there would have been a problem. You're fine until you get to ECILE,
> but the moment you pass that fix, you're in violation of 91.177.
>
> Same thing if you had come from the north direction to DOCAP. You'd be
> fine at 2,100 until the fix, but the HIL is required from this
> direction and you'd be in violation of 91.177 once you started the hold
> entry.
>

It seems to me you are ignoring the depiction of the southern sector on
the map view that shows 2800. This applies to aircraft inbound to
DOCAP from anywhere southern. Why are you saying that it does not
apply? (I.e. why is the controller allowed to clear the a/c to DOCAP
and descend to 2100?).
--
Thanks,
John Clonts
Temple, Texas

[Sam Spade]

wrote:
> <<Looking at the FAA version of the approach plate, profile section, it
> has
> 2800 to DOCAP, then descend to 2100 at CICAL for the final approach
> into
> OLV.>>
>
> The 2,800 ft segment you see is the Hold-in-Lieu. A HIL is part of the
> initial segment, which doesn't begin until the IAF. From your
> direction of flight, the HIL wasn't required for you, so its altitude
> didn't apply.
>
> Regardless, ATC has a right to assign you an altitude to maintain until
> you arrive at a certain fix; only AFTER you arrive there do published
> altitudes apply. Until then, you're relying on their MVA to keep you
> safe.

ATC has an obligation to assign an offroute altitude. If they don't
then the pilot has a regulatory obligation to challenge the lack of an
altitude assignment (one of the many changes provided by TWA 514
crashing into Mt. Weather on Dec 1, 1974.)

In this instance it would have been reasonable for the pilot to
challenge the 2,100-foot assignment since 2,800 is shown at DOCAP.

When this change to the AIM and ATC Order was discussed, I think
everyone envisioned 2,800 being assigned for a direct-to DOCAP. But,
once the real-world takes over...

The controllers really have to know the IAP to assign any altitude less
than that shown in the profile at the IF. I am not sure that is the
conservative way to go, but it is certainly legal so long as there isn't
a step-down in the intermediate somewhere that is missed.

>
> If they had cleared you to ECILE, and told you to maintain 2,100, then
> there would have been a problem. You're fine until you get to ECILE,
> but the moment you pass that fix, you're in violation of 91.177.
>
> Same thing if you had come from the north direction to DOCAP. You'd be
> fine at 2,100 until the fix, but the HIL is required from this
> direction and you'd be in violation of 91.177 once you started the hold
> entry.
>
>
> Sam: The fix DOCAP is labeld IF/IAF. Does the segment from DOCAP to
> CICAL use initial or intermediate ROC ?
>
That is the intermediate segment with 500-foot ROC requirements. But,
at a location like this, airspace and descent gradient requirements are
limiting, not ROC. There is probably at least 1,200 feet or more, of
ROC in this particular intermediate segment. The MVA overlying this
intermediate segment is 2,000 feet.

[Sam Spade]

John Clonts wrote:

> wrote:
>

> It seems to me you are ignoring the depiction of the southern sector on
> the map view that shows 2800. This applies to aircraft inbound to
> DOCAP from anywhere southern. Why are you saying that it does not
> apply? (I.e. why is the controller allowed to clear the a/c to DOCAP
> and descend to 2100?).

2,100 applies at DOCAP per the IAP. The MVA is 2,000 to the west of
DOCAP and 2,100 to the east.

Again, a more consistent handling with the IAP profile and human-factors
would have been for ATC to assign 2,800 to DOCAP.

[John Clonts]

Sam Spade wrote:
> John Clonts wrote:
>
> > wrote:
> >
>
> > It seems to me you are ignoring the depiction of the southern sector on
> > the map view that shows 2800. This applies to aircraft inbound to
> > DOCAP from anywhere southern. Why are you saying that it does not
> > apply? (I.e. why is the controller allowed to clear the a/c to DOCAP
> > and descend to 2100?).
>
> 2,100 applies at DOCAP per the IAP. The MVA is 2,000 to the west of
> DOCAP and 2,100 to the east.
>
Yes but I am talking about *prior to* DOCAP. 2800 applies prior to
DOCAP per the IAP. If ATC clears an a/c to 2100 prior to DOCAP is it
(1) a controller error which should be refused by the pilot, or (2) ok
because somehow "mva trumps iap arrival sector altitude"?

> Again, a more consistent handling with the IAP profile and human-factors
> would have been for ATC to assign 2,800 to DOCAP.

[[email protected]]

<<It seems to me you are ignoring the depiction of the southern sector
on
the map view that shows 2800. This applies to aircraft inbound to
DOCAP from anywhere southern. >>

That sector is essentially a feeder route. If cleared for the approach
within that area, you could descend down to 2,800 if you were above it,
absent any other altitude assignment by ATC.

Many approaches have feeder routes, but you're not obligated to fly
them to the IAF if ATC clears you direct to the IAF and assigns an
altitude.

[[email protected]]

<<If they don't then the pilot has a regulatory obligation to challenge
the lack of an
altitude assignment >>

Unless they've changed 91.175, it merely says that if an altitude isn't
assigned when an approach clearance is received, the pilot is to
maintain the last altitude assigned. Where is the regulatory
requirement to challenge the lack of assignment?

<<When this change to the AIM and ATC Order was discussed, I think
everyone envisioned 2,800 being assigned for a direct-to DOCAP. But,
once the real-world takes over... >>

I'm not clear on how this clearance relates to the new change to ATC
procedures. That pertains to direct to IF's, but this fix is a
combined IAF/IF and has been for years, most likely prior to the AIM
change, and a clearance direct to an IAF has long (forever?) been ok.

[Sam Spade]

John Clonts wrote:
> Sam Spade wrote:
>
>>John Clonts wrote:
>>
>>
wrote:
>>>
>>
>>>It seems to me you are ignoring the depiction of the southern sector on
>>>the map view that shows 2800. This applies to aircraft inbound to
>>>DOCAP from anywhere southern. Why are you saying that it does not
>>>apply? (I.e. why is the controller allowed to clear the a/c to DOCAP
>>>and descend to 2100?).
>>
>>2,100 applies at DOCAP per the IAP. The MVA is 2,000 to the west of
>>DOCAP and 2,100 to the east.
>>
>
> Yes but I am talking about *prior to* DOCAP. 2800 applies prior to
> DOCAP per the IAP. If ATC clears an a/c to 2100 prior to DOCAP is it
> (1) a controller error which should be refused by the pilot, or (2) ok
> because somehow "mva trumps iap arrival sector altitude"?
>
>
>>Again, a more consistent handling with the IAP profile and human-factors
>>would have been for ATC to assign 2,800 to DOCAP.
>
>
Under the present wording in the ATC Handbook MVA trumps the
direct-entry sector's altitude.

Another way to look at it is the IAP begins at the IF based on the
clearance.

An anology would be a "true" vector to final, say a 30 degree cut to the
approach course 2 miles inside DOCAP. 2,100 would be an acceptable
controller assignment in that case.

The new application might work better with a restriction to not assign
an altitude below the IF crossing altitude. But, that is not how it
reads at present.

[Sam Spade]

wrote:

> <<If they don't then the pilot has a regulatory obligation to challenge
> the lack of an
> altitude assignment >>
>
> Unless they've changed 91.175, it merely says that if an altitude isn't
> assigned when an approach clearance is received, the pilot is to
> maintain the last altitude assigned. Where is the regulatory
> requirement to challenge the lack of assignment?

It is implicit in 91.175 to challenge an assigned off-route altitude if
it appears to the pilot to be incorrct.
>
> <<When this change to the AIM and ATC Order was discussed, I think
> everyone envisioned 2,800 being assigned for a direct-to DOCAP. But,
> once the real-world takes over... >>
>
> I'm not clear on how this clearance relates to the new change to ATC
> procedures. That pertains to direct to IF's, but this fix is a
> combined IAF/IF and has been for years, most likely prior to the AIM
> change, and a clearance direct to an IAF has long (forever?) been ok.
>

Prior to the new change a clearance direct to DOCAP would have required
a course reversal. No one was doing that, though, thus the pressure for
the change.

Before the change it would have been a clearance to DOCAP, the IAF.
Now, it's a clearance to DOCAP, the IF.

[[email protected]]

<<Prior to the new change a clearance direct to DOCAP would have
required
a course reversal. No one was doing that, though, thus the pressure
for
the change. >>

But the TAA has had a NoPT sector for a straight-in ever since its
inception.

As far as I can tell, this new rule only affects Non-TAA RNav
approaches.

[Sam Spade]

wrote:

> <<Prior to the new change a clearance direct to DOCAP would have
> required
> a course reversal. No one was doing that, though, thus the pressure
> for
> the change. >>
>
> But the TAA has had a NoPT sector for a straight-in ever since its
> inception.
>
> As far as I can tell, this new rule only affects Non-TAA RNav
> approaches.
>

The new procedure does not exclude RNAV IAPs with TAAs.

You are correct, though, that prior to the new procedure with a TAA I
could have gone straight-in if cleared direct to DOCAP anywhere within
the straight-in TAA sector. I could not have accepted an altitude of
less than 2,800 in that case, though.

Then, there are TAA straight-in sectors at other locations with
subsectors that must be satisfied before "NoPT" is authorized.

Seems like some unintended consequences at play here.

[Sam Spade]

A Lieberma wrote:

>
> Too new and green to know any difference *smile*.
>
> Been in the IA world for two years, and everytime I launch, it's a new
> experience!
>
> Allen

For future reference, if in doubt about an altitude assignment,
especially when it is below what seems reasonable, just request the
higher altitude.

It's important to keep the controller's expectations in sync with your's.

[[email protected]]

<<The new procedure does not exclude RNAV IAPs with TAAs. >>

I know, but it appears it is irrelevant for TAA's.

<<I could have gone straight-in if cleared direct to DOCAP anywhere
within
the straight-in TAA sector. I could not have accepted an altitude of
less than 2,800 in that case, though. >>

And why is that? "Skyhawk 1234X, cleared direct to DOCAP, maintain
2,100 until established, cleared RNAV 18 Olive Branch."

Since DOCAP is and has always been labeled as an IAF, how is this any
different from being given MVA direct to any other IAF on non-RNAV
approaches, something that is done a thousand times every day?

[Sam Spade]

wrote:
> <<The new procedure does not exclude RNAV IAPs with TAAs. >>
>
> I know, but it appears it is irrelevant for TAA's.
>
> <<I could have gone straight-in if cleared direct to DOCAP anywhere
> within
> the straight-in TAA sector. I could not have accepted an altitude of
> less than 2,800 in that case, though. >>
>
> And why is that? "Skyhawk 1234X, cleared direct to DOCAP, maintain
> 2,100 until established, cleared RNAV 18 Olive Branch."
>
> Since DOCAP is and has always been labeled as an IAF, how is this any
> different from being given MVA direct to any other IAF on non-RNAV
> approaches, something that is done a thousand times every day?
>

Yes, but on thoese thousands of other IAPs, you are not in a published
segment of the approach. In the case of the OLV RNAV 36 you are within
a giant initial approach "segment" (the right and left base TAA sectors
are feeder "routes"), thus once cleared for the approach you are
operating below the minimum segment altitude while on a published IAP
segment. You don't do that on the thousands of other IAPs.

[[email protected]]

<<thus once cleared for the approach you are operating below the
minimum segment altitude while on a published IAP segment. You don't
do that on the thousands of other IAPs. >>

In the example cited, the clearance didn't start until DOCAP. Prior to
that, he was on a "direct clearance". If you hold that that is
invalid, then it seems that the same logic applies to any direct
clearance that happens to either cross or coincide with an airway or
feeder route.

1) If I cross an airway at MVA that is lower than MEA on a direct
clearance, then am I in violation of 91.177?

2) If I am tracking a radial that happens to coincide with a feeder
route, then am I in violation of 91.177 when I'm below the published
altitude, even though I've never been cleared for the feeder route?

[Tim Auckland]

To me, the issue hinges on whether the controller thought he was
issuing a clearance based on the traditional method of clearing the
plane to the IAF.
In this case, it's my belief that the controller made a mistake, and
should have assigned 2800 as the altititude.

If, on the hand, the controller was intending to follow the new
procedure of "direct clearance to an intermediate fix", then 2100 is
appropriate, but the controller should have advised the pilot to
"expect clearance direct to the Intermediate Fix" while the plane was
at least 5 miles from the fix.
The OP didn't indicate whether or not he was advised of this.

The controller's instructions for the new procedure can be found at:

http://www.faa.gov/ATPUBS/ATC/Chp4/atc0408.html#4-8-1

Tim.


On 10 Aug 2006 09:27:39 -0700, wrote:

><<Prior to the new change a clearance direct to DOCAP would have
>required
>a course reversal. No one was doing that, though, thus the pressure
>for
>the change. >>
>
>But the TAA has had a NoPT sector for a straight-in ever since its
>inception.
>
>As far as I can tell, this new rule only affects Non-TAA RNav
>approaches.

[Sam Spade]

wrote:
> <<thus once cleared for the approach you are operating below the
> minimum segment altitude while on a published IAP segment. You don't
> do that on the thousands of other IAPs. >>
>
> In the example cited, the clearance didn't start until DOCAP. Prior to
> that, he was on a "direct clearance". If you hold that that is
> invalid, then it seems that the same logic applies to any direct
> clearance that happens to either cross or coincide with an airway or
> feeder route.
>
> 1) If I cross an airway at MVA that is lower than MEA on a direct
> clearance, then am I in violation of 91.177?
>
> 2) If I am tracking a radial that happens to coincide with a feeder
> route, then am I in violation of 91.177 when I'm below the published
> altitude, even though I've never been cleared for the feeder route?
>
The issue isn't 91.177, rather it is the minimum altitude set forth
under Part 97.

Before the advent of the direct-to-the-IF procedure, I would not have
accepted 2,100 at this location because of the TAA's minimum altitude.

Your example #1 is irrelevant because the airway is not part of your
clearance.

Your example #2 is difficult to envision happening.

[Sam Spade]

Tim Auckland wrote:

> To me, the issue hinges on whether the controller thought he was
> issuing a clearance based on the traditional method of clearing the
> plane to the IAF.
> In this case, it's my belief that the controller made a mistake, and
> should have assigned 2800 as the altititude.
>
> If, on the hand, the controller was intending to follow the new
> procedure of "direct clearance to an intermediate fix", then 2100 is
> appropriate, but the controller should have advised the pilot to
> "expect clearance direct to the Intermediate Fix" while the plane was
> at least 5 miles from the fix.
> The OP didn't indicate whether or not he was advised of this.

Good points.

[Sam Spade]

wrote:
> <<Your example #1 is irrelevant because the airway is not part of your
> clearance. >>
>
> Neither was the feeder route (arrival sector) with the OP. He was
> cleared direct to an IAF, not via the arrival sector (feeder route).
>
> Would your opinion change if the OP had been cleared direct to the IAF
> at 2,100, yet approach clearance were withheld until he arrived there?
>
> <<Your example #2 is difficult to envision happening>>
>
> Happened to me quite a few times practicing local approaches.
>

We all have different experiences. ;-)

I just hate seeing any of this stuff causing pilots to have to sort
through complexities than can result in tripping situational awareness
or minimum safe altitudes.

[[email protected]]

<<We all have different experiences.>>

That's why we share on this newsgroup.

However, I'm still trying to pin down your thoughts on this issue, so
I'll ask again:

"Would your opinion change if the OP had been cleared direct to the IAF

at 2,100, yet approach clearance were withheld until he arrived there?"

I predict that either "yes" or "no" will undermine your evaluation of
the situation. ;-)

[Sam Spade]

wrote:
> <<We all have different experiences.>>
>
> That's why we share on this newsgroup.
>
> However, I'm still trying to pin down your thoughts on this issue, so
> I'll ask again:
>
> "Would your opinion change if the OP had been cleared direct to the IAF
>
> at 2,100, yet approach clearance were withheld until he arrived there?"
>
> I predict that either "yes" or "no" will undermine your evaluation of
> the situation. ;-)
>

Under the new procedure ATC was required to tell him he was being
cleared directly to the IF for a straight-in, at least 5 miles before
the IF. Had I received that clearance I would set my navigator for
direct to the IF, cleared the hold-in-lieu if it were in the approach
flight plan, tracked the intermediate segment until the FAF, then
descended in accordance with the procedure.

Under the old procedures I would have not accepted lower than 2,800,
then done as above, except descending to 2,100 crossing the IF, and so
forth.

Under the old procedures, had this not been a TAA procedure I would have
accepted no lower than 2,800 and done the course reversal, making it
clear to ATC that I would do the course reversal.

What is inconsistent about any of that?

[[email protected]]

<<Under the old procedures, had this not been a TAA procedure I would
have
accepted no lower than 2,800 and done the course reversal, making it
clear to ATC that I would do the course reversal.

What is inconsistent about any of that? >>

As stated, sounds good to me. ;-) But the key phrase is "had this not
been a TAA procedure". Your earlier statements seemed to indicate you
were not drawing a distinction between a TAA and a random RNAV
approach.

Here's what I infer from your above paragraph:

With a TAA approach (such as the one under discussion), even under the
old procedure, it is ok to be cleared direct to the straight-in IAF at
an altitude below the sector altitude, as long as the altitude is
compatible with the minimum intermediate altitude and at or above MVA.

If you disagree with that, then I'd like to explore further why this
might be so,

[Sam Spade]

wrote:
> <<Under the old procedures, had this not been a TAA procedure I would
> have
> accepted no lower than 2,800 and done the course reversal, making it
> clear to ATC that I would do the course reversal.
>
> What is inconsistent about any of that? >>
>
> As stated, sounds good to me. ;-) But the key phrase is "had this not
> been a TAA procedure". Your earlier statements seemed to indicate you
> were not drawing a distinction between a TAA and a random RNAV
> approach.

I may have not drawn the distinction earlier until the TAA aspects sunk
in.

I am surprised that an RNAV IAP with TAAs even exists in a major metro
TRACON area. The decision to accept TAAs has been on a center/TACON and
sometimes regional basis. Some regions have rejected the concept
entirely. Most major TRACONS have rejected them. They have little
value where radar coverage and MVAs exist. All Memphis probably uses is
the T configuration, which is much more common than a T with TAAs.
>
> Here's what I infer from your above paragraph:
>
> With a TAA approach (such as the one under discussion), even under the
> old procedure, it is ok to be cleared direct to the straight-in IAF at
> an altitude below the sector altitude, as long as the altitude is
> compatible with the minimum intermediate altitude and at or above MVA.
>
> If you disagree with that, then I'd like to explore further why this
> might be so,
>
If I said that earlier. I think you might have said something like
that. ;-) But, I am not going to go back and figure it out. Suffice it
to say that a clearance prior to the new procedure does not negate the
TAA sectors, unless it were a vector to within the intermediate segment.

I suspect Memphis doesn't concern themselves at all with the TAAs, but
that is supposition on my part based on how badly the TAA program is
going nationally.

[Troy]

The controller, as others have stated, has an MVA (minimum vectoring
altitude) chart. He wouldn't (shouldn't) clear you down to 2100'
outside DOCAP if you'd be hitting something.

Here's the plate: http://204.108.4.16/d-tpp/0608/05883R36.PDF

Nobody can fault you for being cautious and aware... I think
congratulations are in order for being "in the game" with your head and
not just BLINDLY following altitude and heading clearances. CFIT
results from that course of action.

That said, I think you should have just verified with the controller.
Congestion on the radio might have made that difficult.

Without that, I would have gone down to 2100, for two reasons:

1) That was your last clearance;
2) A look at the approach plate shows that the tallest obstruction is
just off to the east, ESE of Holly Springs, at 1049' MSL. The plates
always put the highest obstruction in a bolder / larger font.

Troy

[Greg Esres]

<<Suffice it to say that a clearance prior to the new procedure does
not negate the TAA sectors, unless it were a vector to within the
intermediate segment.>>

Ok, this backs us up a few posts. ;-) I believe this to be
insupportable even in theory, not to mention contrary to ATC practice
and expectation.

I would appreciate your agreeing or disagreeing with the following
statements:

1) ATC has the right to clear me to any fix they choose, as long they
assign me an altitude at or above MVA/MIA, yes?

2) And it doesn't matter if my course happens to underlie any
published segment, such as an airway, feeder route, or IAP, because I
have an assigned altitude based on MVA, which assumedly meets 91.177
minimums and I'm not currently executing an IAP.

3) Once I arrive at that fix, if cleared for the approach, none of
the previous altitudes I flew while getting there suddenly become
illegal.



(As supporting evidence, the AIM says "Once cleared to fly the TAA,
pilots are expected to obey minimum altitudes depicted within the TAA
icons, unless instructed otherwise by air traffic control." This is
clearly permissive.)

[Ron Natalie]

Greg Esres wrote:

>
> 3) Once I arrive at that fix, if cleared for the approach, none of
> the previous altitudes I flew while getting there suddenly become
> illegal.
>
The FAA has decided to take a literal reading of the rules.
Approaches start with either an IAF or vectors to final.
While you might get some slack from a controller, that's
not the official FAA party line.

[Sam Spade]

Greg Esres wrote:
> <<Suffice it to say that a clearance prior to the new procedure does
> not negate the TAA sectors, unless it were a vector to within the
> intermediate segment.>>
>
> Ok, this backs us up a few posts. ;-) I believe this to be
> insupportable even in theory, not to mention contrary to ATC practice
> and expectation.
>
> I would appreciate your agreeing or disagreeing with the following
> statements:
>
> 1) ATC has the right to clear me to any fix they choose, as long they
> assign me an altitude at or above MVA/MIA, yes?

Yes, provided the fix is where you want to be going, or eithin reason.
>
> 2) And it doesn't matter if my course happens to underlie any
> published segment, such as an airway, feeder route, or IAP, because I
> have an assigned altitude based on MVA, which assumedly meets 91.177
> minimums and I'm not currently executing an IAP.

Yes, that is generally correct in spite of occasional violations of
91.177 by some MVAs and MIAs, but those are "technical" so far as the
FAA is concernec, and (as you state) so long as you are not currently
executing an IAP.
>
> 3) Once I arrive at that fix, if cleared for the approach, none of
> the previous altitudes I flew while getting there suddenly become
> illegal.

True enough, provided the approach clearance is issued crossing that fix.

But, you are not covering the circumstance where the controller places
you on a published segment, and clears you for an approach *within the
segment* at an altitude below the segment altitude. Until the new
direct-to-the-IF procedure came into effect that immediate places you in
violation of the Part 95 minimum altitude for the segment, which
typically would be a TAA.

And, the new procedure is not triggered unless the controller says the
magic words, not less than five miles from the IF. Further, the new
procedure can only be used for RNAV IAPs. (The magic words being: The
pilot is advised to expect clearance direct to the Intermediate Fix at
least 5 miles from the fix.)

>
>
>
> (As supporting evidence, the AIM says "Once cleared to fly the TAA,
> pilots are expected to obey minimum altitudes depicted within the TAA
> icons, unless instructed otherwise by air traffic control." This is
> clearly permissive.)
>
>
>
>

[Sam Spade]

Greg Esres wrote:

>
> (As supporting evidence, the AIM says "Once cleared to fly the TAA,
> pilots are expected to obey minimum altitudes depicted within the TAA
> icons, unless instructed otherwise by air traffic control." This is
> clearly permissive.)
>
>
>
>
To you it may be clearly permissive, to me it only implies that ATC can
assign an altitude higher than the TAA area altitude.

[Sam Spade]

Greg Esres wrote:


>
>
> (As supporting evidence, the AIM says "Once cleared to fly the TAA,
> pilots are expected to obey minimum altitudes depicted within the TAA
> icons, unless instructed otherwise by air traffic control." This is
> clearly permissive.)
>
>
>
>
4-8-1 b of 7110.65R states:

b. For aircraft operating on unpublished routes,
issue the approach clearance only after the aircraft is:

1. Established on a segment of a published route
or instrument approach procedure.

2. Assigned an altitude to maintain until the
aircraft is established on a segment of a published
route or instrument approach procedure.

Further down 4-8-1 states,

e. Where a Terminal Arrival Area (TAA) has been
established to support RNAV approaches use the
procedures under subpara b1 and b2 above.

Clearly, none of this can serve to clear an aircraft within a TAA right
base, left base, or direct entry area at an altitude below the published
IAP minimum altitude for that area.

Further, since the OLV IAP that started this thread was a TAA procedure,
I believe the controller failed to apply the published area altitude of
the TAA, especially if he issued the approach clearance prior to the IF.

The pilot should have been assigned not less than 2,800 until the IF.

When the new procedure was written it was all about off-route
clearances; TAAs were not discussed. Nonethess less, it does not negate
the existing ATC requirements for TAAs.

[A Lieberma]

Sam Spade > wrote in news:nKjDg.567$cw.432@fed1read03:

> Further, since the OLV IAP that started this thread was a TAA procedure,
> I believe the controller failed to apply the published area altitude of
> the TAA, especially if he issued the approach clearance prior to the IF.
>
> The pilot should have been assigned not less than 2,800 until the IF.

This would be my take on it with charts in hand.....

After all, once I am cleared for the approach, navigation is back in my
court, and if my radios decided to call it the day, would seem rather
"dangerous" in the clag flying lower then indicated on the approach charts.

Sure, i could squawk 7600, and climb back to 2800, but the more changes you
make in flight configurations, the more chance of errors developing.

I did file a ASR report as to me, there is a major discrepancy between what
the approach plate has and what instructions were given to me by ATC.

Would seem that MVA would be inheritantly dangerous should the radios quit
and here you are lower then what approach charts say you should be at.

Granted as one other poster pointed out, there was only one antenna that
was of any significant height, and not a factor in my approach, so 2100
would *seem* safe.

Allen

[Greg Esres]

<<The FAA has decided to take a literal reading of the rules.
Approaches start with either an IAF or vectors to final.>>

I'm not questioning that. In the approach in question, the clearance
fix WAS an IAF.

[Greg Esres]

<<To you it may be clearly permissive, to me it only implies that ATC
can assign an altitude higher than the TAA area altitude.>>

That's what I thought you say. ;-) However, the sentence says "obey
minimum altitudes". Any assigned higher altitude already obeys
minimums, so the following phrase would be unnecessary. Not obeying
minimums means going below. In English, anyway.

[Greg Esres]

<<Clearly, none of this can serve to clear an aircraft within a TAA
right base, left base, or direct entry area at an altitude below the
published IAP minimum altitude for that area.>>

That depends on how you're defining "on a route". First of all, a TAA
arrival sector doesn't really meet the definition of a route in the
Pilot/Controller's glossary, so that seems an open question. But that
really isn't the important question here, IMO.

Earlier, I asked you that if I were flying a path that coincided with
a feeder route or airway, but my clearance had included neither, then
would I be in violation of 91.177 by flying at a lower altitude than
published. You said that you could not envision such a thing. (I'm
sure you're familiar with clearances such as "cleared via the radials
of V-999..."

Regardless, you seem to arguing that if you are at a point in space
that is encompassed by *some* route, then that altitude is binding on
you. I am very much open to this interpretation, but I believe you
need to carry it to its logical conclusion.

I can think of three possible interpretations of what it means to be
"on a rroute"

1) As stated above, you are within the lateral confines
geogrraphically that is encompassed by *some* route,

2) You are within the lateral AND VERTICAL confines that is
encompassed by *some* route. (If you are below the minimum altitude,
you're not on that route.)

3) You are assigned a route by name,


What's your take?

[Sam Spade]

Greg Esres wrote:
> <<True enough, provided the approach clearance is issued crossing that
> fix.>>
>
> Ok, so the controller says "Cross DOCAP at or above 2,100, cleared OLV
> RNAV 36."
>
> You agree that this is ok, even under the old procedure, because the
> fix is an IAF? And do you agree that "Cleared direct to DOCAP,
> maintain 2,100" is essentially the same clearance?
>
> <<But, you are not covering the circumstance where the controller
> places you on a published segment, and clears you for an approach
> *within the segment* at an altitude below the segment altitude. >>
>
> True, I ignored that because that doesn't seem to be the clearance the
> OP got. I have yet to see a controller have any inklink of what TAA
> arrival sectors are, much less expect the pilot to use them.

Nonethless the TAA exists and the pilot correctly chose not to ignore
the *published* IAP altitude that applied to his flight. I agree that
the controller probably did not have a clue, which caused him or her to
violate the 7110.65R.

[Sam Spade]

Greg Esres wrote:

> <<To you it may be clearly permissive, to me it only implies that ATC
> can assign an altitude higher than the TAA area altitude.>>
>
> That's what I thought you say. ;-) However, the sentence says "obey
> minimum altitudes". Any assigned higher altitude already obeys
> minimums, so the following phrase would be unnecessary. Not obeying
> minimums means going below. In English, anyway.

But, using English without context is folly. I provided you with the
7110.65R cites, which negates your assessment of the words in the abstract.

[Sam Spade]

Greg Esres wrote:


> Regardless, you seem to arguing that if you are at a point in space
> that is encompassed by *some* route, then that altitude is binding on
> you. I am very much open to this interpretation, but I believe you
> need to carry it to its logical conclusion.

From the TAA Order(8260.45A):

"8.2.1 Straight-In Area.
The arc boundary of the straight-in area is equivalent to a feeder fix.
When crossing the boundary or when released by ATC within the
straight-in area, an aircraft is expected to proceed direct to the IF(IAF)."

So, since the FAA defines the arc boundary of the straight-in TAA area
as the equivalent of a feeder fix, then the entire area inside that arc
must be the equivalent of a feeder route. The TAA areas are published
under FAR 97 as IAP altitudes.

[A Lieberma]

Greg Esres > wrote in
:

> <<True enough, provided the approach clearance is issued crossing that
> fix.>>
>
> Ok, so the controller says "Cross DOCAP at or above 2,100, cleared OLV
> RNAV 36."
>
> You agree that this is ok, even under the old procedure, because the
> fix is an IAF? And do you agree that "Cleared direct to DOCAP,
> maintain 2,100" is essentially the same clearance?

Greg,

What you say above are not the same clearance.

Your first one clears me for the GPS 36 approach to the airport.

Your second one only clears me to DOCAP. If I am cleared direct to DOCAP,
then my take is that DOCAP is my clearance limit.

I better hear something before DOCAP or I will be asking if I am cleared
for the approach. If I don't hear anything then I would just hold at DOCAP
(direct entry from my 006 heading) and await a further clearance.

Allen