What do you do in the real world?

On 03/11/07 11:41, Ron Garret wrote:

[ snip ]


First, the regs explicitly sanction "making up your own stuff" (as you
put it) in emergency situations, which lost comm in IMC can easily give
rise to.

Well, *anything* can lead to an emergency situation. However, there are
regulations written specifically for the case of lost communications.
If you deem that lost communications is an emergency, and use that to
justify doing whatever you want, you're in violation of the regs.


Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again.

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

First of all, this is what the regulations tell you to do, and this is
what you must do. Period. The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.


rg



--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

Mxsmanic wrote:
Tim writes:


How is this an emergency?


It endangers the flight and other flights around it. Losing all communication
in crowded, controlled airspace is clearly an emergency.

Bull****. The radio has no bearing on the safety of flight. The flight
controls all work fine. That is why you file an ifr flight plan. You
state on it your airspeed. If not under radar, you make position
reports. If under radar no need to. This is why the regulations (you
already quoted) require different procedures in VFR.



If you already know the answer and were given instructions by
controllers to do this in the past, why pose it here?


If you already know the answer, why have you still not provided it?

Many other have also discussed it and you already posted the relevant
FAR section. The OP claims he got instructions from the local
controllers. So, if that is the case, he should just follow those
instructions. (Or perhaps they are not regulatory)



While your specific example may work for you in this case, applying that
logic in other places will get you killed. If you follow the regs the
way they are written you will be fine and you won't get in trouble.


So what's the answer?

See the FARs you already posted.



If you have an emergency (and I don;t think a non-op comms radio qualifies)
then you certainly can do whatever you need to do to make a safe ending
to the flight.


Why doesn't an inoperative radio qualify? You're in airspace that requires
two-way radio communication.

If you are saying that an inop radio is an emergency then I would
question your judgment as a pilot. If the pilot thinks it is an
emergency, then by all means, "declare" one and treat it as such.

Are you saying that piper cubs are always flying around in states of
emergency? (they have no electrical system and no radios) - unless
modified to have them.



So you are saying you don't know what you are supposed to do when you
reach a clearance limit and there is no published hold?


So enlighten everyone by explaining exactly what he should do.


I thought the regs were clear. Others have also offered it up here.

On Sun, 11 Mar 2007 14:25:54 -0400, Tim
wrote:

First, the regs explicitly sanction "making up your own stuff" (as you
put it) in emergency situations, which lost comm in IMC can easily give
rise to.
How is this an emergency?

While losing comm in IMC alone might not qualify as an emergency, more
likely than not it is caused by a more serious malfunction (alternator
failure or even an electrical fire). As without comms the controller
has no way of knowing if that is the case, he is going to vector
everybody out of your area anyway.

Every controller I have discussed this situation with (OK, I'm talking
about Germany here, but the regulations in this case are essentially
the same) told me that the best course of action would be to land
asap.

Imagine losing comm five minutes after takeoff for a three hour flight
in the soup, at night, over mountains. Would you really continue or
simply land at the airport you have just departed from? My certificate
would be the least of my worries, but then you could still quite
easily make an argument for emergency authority, IMHO.

Tobias

In article , Tim
wrote:

Ron Garret wrote:
snip



First, the regs explicitly sanction "making up your own stuff" (as you
put it) in emergency situations, which lost comm in IMC can easily give
rise to.

How is this an emergency?

I didn't say it was an emergency. I said it could easily give rise to
one.

Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

I don't see how with a gps you know where you are and with 2 VORs (for
example) you don't know where you are.

I didn't say that either. I said with moving map GPS you know EXACTLY
where you are AT A GLANCE. With VORs it takes time to twiddle knobs and
cross-reference the results against a chart, and the margin of error is
much larger.

Just because they were written before GPS does not mean they are no
longer valid.

I didn't say that they weren't valid. I said that procedures designed
for VORs make less sense when MMGPS is available.

Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again. This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

If you already know the answer and were given instructions by
controllers to do this in the past, why pose it here?

That was for a completely different set of circumstances.

How does going to FUL require what you state? Cannot you pick which
approach and IAF?

It's a tangent, so if you really want to get into that you should start
a new thread. Or look up the old one. Or look at the charts.

Why do you choose the VOR procedure at FUL rather than the LOC/DME? In
that case it is easy to pick the approach with nopt.

Not as easy as you might think. The preferred routing (which is the one
you will invariably be assigned) from AVX to FUL is V21 SLI Direct.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.


So you are saying you don't know what you are supposed to do when you
reach a clearance limit and there is no published hold?

Are you sure direct VNY means KNVY and not eh vor or an iaf? Did the
controllers say "...SNS, direct" or "...SNS, direct KVNY?" there is a
difference I think.

The exact wording of my clearance was "Cleared to the Van Nuys airport
via left turn to heading 140 vectors to Salinas VOR then direct."

I've never heard a clearance that ended with anything other than an
unqualified "direct" or "then as filed".

VNY IS an IAF. So is FIM. Why not choose those as IAFs and follow a
published approach rather than your own vectors?

Because I've flown into LA from the north dozens if not hundreds of
times. Invariably my initial clearance ends with a direct leg to KVNY
which is unflyable at 9000 feet (which is the altitude I always file
for). Invariably my clearance is amended once I reach LA Center's
airspace to direct LHS, LYNXXN arrival, and then amended further to be
vectors for the ILS. This is more direct and therefore safer than any
"by the book" route.

But next time I'll try getting that route from the outset and see what
happens.

rg

In article ,
Mark Hansen wrote:

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

Correct.

First of all, this is what the regulations tell you to do, and this is
what you must do. Period.

I'm not asking what is the required course of action. I am asking what
is the wisest course of action.

The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Quite so, but keeping my ticket is not my only consideration. There is
also the safety of the flight to consider. Following the regs requires
more time in the air, more maneuvering, more fuel consumption, and
unnecessary traversal of extremely crowded airspace in IMC. All this
entails additional risk. If I'm faced with a choice of risking my
ticket or risking my safety I'll take the former.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

That seems like a sensible idea. I think I'll try that.

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.

And what if there is no published hold (as is the case in the current
situation)?

rg

Tim wrote:


If you are saying that an inop radio is an emergency then I would
question your judgment as a pilot. If the pilot thinks it is an
emergency, then by all means, "declare" one and treat it as such.

He's not a farkin pilot, he's not even close.

Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

I don't see how with a gps you know where you are and with 2 VORs (for
example) you don't know where you are.


I didn't say that either. I said with moving map GPS you know EXACTLY
where you are AT A GLANCE. With VORs it takes time to twiddle knobs and
cross-reference the results against a chart, and the margin of error is
much larger.


Why is that relevant?


Just because they were written before GPS does not mean they are no
longer valid.


I didn't say that they weren't valid. I said that procedures designed
for VORs make less sense when MMGPS is available.

You imply that you can do something better than what the regs say and
your justification seemed to be that it is because the regs were written
before gps. I apologize for misunderstanding your meaning.



Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again. This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

If you already know the answer and were given instructions by
controllers to do this in the past, why pose it here?


That was for a completely different set of circumstances.

Again, I misunderstood then. I only quoted you and responded based on
what you wrote.



How does going to FUL require what you state? Cannot you pick which
approach and IAF?


It's a tangent, so if you really want to get into that you should start
a new thread. Or look up the old one. Or look at the charts.

How is that a tangent? You can choose any IAF and any approach that
you are able to do when the clearance ends in "direct" - and the airport
is the clearance limit.



Why do you choose the VOR procedure at FUL rather than the LOC/DME? In
that case it is easy to pick the approach with nopt.


Not as easy as you might think. The preferred routing (which is the one
you will invariably be assigned) from AVX to FUL is V21 SLI Direct.

Again, "direct" does not mean direct to the airport. Direct means you
go to an IAF then get to the airport. How are you supposed to land?
You can;t just go to the airport and circle down to land - that is the
whole reason for having defined instrument approaches.



And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.


So you are saying you don't know what you are supposed to do when you
reach a clearance limit and there is no published hold?

Are you sure direct VNY means KNVY and not eh vor or an iaf? Did the
controllers say "...SNS, direct" or "...SNS, direct KVNY?" there is a
difference I think.


The exact wording of my clearance was "Cleared to the Van Nuys airport
via left turn to heading 140 vectors to Salinas VOR then direct."

I've never heard a clearance that ended with anything other than an
unqualified "direct" or "then as filed".

Right. See above regarding what that last "direct" means. It does not
mean go froom the penultimate fix to the airport. It means go to an
IAF then fly the approach.



VNY IS an IAF. So is FIM. Why not choose those as IAFs and follow a
published approach rather than your own vectors?


Because I've flown into LA from the north dozens if not hundreds of
times. Invariably my initial clearance ends with a direct leg to KVNY
which is unflyable at 9000 feet (which is the altitude I always file
for). Invariably my clearance is amended once I reach LA Center's
airspace to direct LHS, LYNXXN arrival, and then amended further to be
vectors for the ILS. This is more direct and therefore safer than any
"by the book" route.

But next time I'll try getting that route from the outset and see what
happens.

rg

My initial (and I guess overzealous) reaction to your post was that it
seemed like you just didn;t care what "the book" said or what you are
supposed to do based on part 91 regs for ifr flight. That is scary to me.

I'll just drop it here.

In article , Tim
wrote:


Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

I don't see how with a gps you know where you are and with 2 VORs (for
example) you don't know where you are.


I didn't say that either. I said with moving map GPS you know EXACTLY
where you are AT A GLANCE. With VORs it takes time to twiddle knobs and
cross-reference the results against a chart, and the margin of error is
much larger.


Why is that relevant?

Because the standard procedures involve compromises to compensate for
the delays and errors inherent in VOR navigation. When those delays and
errors do not exist the compromises can make the flight less safe than
it would have been under different procedures.

Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again. This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

If you already know the answer and were given instructions by
controllers to do this in the past, why pose it here?


That was for a completely different set of circumstances.

Again, I misunderstood then. I only quoted you and responded based on
what you wrote.

You must not be reading very carefully. I say right there in the part
you quoted that I was talking about a different trip (AVX-FUL).


How does going to FUL require what you state? Cannot you pick which
approach and IAF?


It's a tangent, so if you really want to get into that you should start
a new thread. Or look up the old one. Or look at the charts.

How is that a tangent?

Because it's a different route. The circumstances are different. What
one does when flying to FUL may or may not apply when flying to VNY. I
only brought up FUL because it's a data point where I've had occasion to
ask controllers for their input, and they unequivocally told me NOT to
follow the regs. (Yes, I know that what controllers say doesn't matter.
Nonetheless, it's a data point.)

You can choose any IAF and any approach that
you are able to do when the clearance ends in "direct" - and the airport
is the clearance limit.

Yes, but by the book you have to fly to the clearance limit first.
91.181(b) is quite clear about this.

Why do you choose the VOR procedure at FUL rather than the LOC/DME? In
that case it is easy to pick the approach with nopt.


Not as easy as you might think. The preferred routing (which is the one
you will invariably be assigned) from AVX to FUL is V21 SLI Direct.

Again, "direct" does not mean direct to the airport.

That's news to me. Where in the regs does it say that?

Direct means you
go to an IAF then get to the airport. How are you supposed to land?

My reading of 91.185(c)(3)(ii) seems to imply that you have to fly to
the airport first, then to an IAF.

You can;t just go to the airport and circle down to land - that is the
whole reason for having defined instrument approaches.

If you're saying that it's stupid to fly to the airport first, I agree
with you. Hence my question.

Right. See above regarding what that last "direct" means. It does not
mean go froom the penultimate fix to the airport. It means go to an
IAF then fly the approach.

I'm pretty sure you're wrong about that.

My initial (and I guess overzealous) reaction to your post was that it
seemed like you just didn;t care what "the book" said or what you are
supposed to do based on part 91 regs for ifr flight. That is scary to me.

Of course I care. But that doesn't mean that I blindly follow the rules
without thinking.

rg

Ron Garret wrote:

Again, I misunderstood then. I only quoted you and responded based on
what you wrote.


You must not be reading very carefully. I say right there in the part
you quoted that I was talking about a different trip (AVX-FUL).

I was trying to just use your examples.




How does going to FUL require what you state? Cannot you pick which
approach and IAF?


It's a tangent, so if you really want to get into that you should start
a new thread. Or look up the old one. Or look at the charts.

How is that a tangent?


Because it's a different route. The circumstances are different. What
one does when flying to FUL may or may not apply when flying to VNY. I
only brought up FUL because it's a data point where I've had occasion to
ask controllers for their input, and they unequivocally told me NOT to
follow the regs. (Yes, I know that what controllers say doesn't matter.
Nonetheless, it's a data point.)

So you are saying that one has to change operating rules based on the
route of the flight. That is exactly why we are having difficulty
understanding each other. The rules are in place to define what to do
under all circumstances. Saying that something applies in one instance
and not another is bad. What are the criteria then for defining which
set of our own rules that deviate from the FARs is necessary? The ONLY
one i am aware of the the one regarding emergencies.



You can choose any IAF and any approach that
you are able to do when the clearance ends in "direct" - and the airport
is the clearance limit.


Yes, but by the book you have to fly to the clearance limit first.
91.181(b) is quite clear about this.


It is your clearance limit because that is where you filed to and where
you want to land. You cannot commence your approach until your
clearance limit time/time on your flight plan.


Why do you choose the VOR procedure at FUL rather than the LOC/DME? In
that case it is easy to pick the approach with nopt.


Not as easy as you might think. The preferred routing (which is the one
you will invariably be assigned) from AVX to FUL is V21 SLI Direct.

Again, "direct" does not mean direct to the airport.


That's news to me. Where in the regs does it say that?


When you don't lose comms and you file and fly to an airport and do not
get vectors, where do you go to? You go to an IAF, right? Or do you
always go to the airport, then to a navaid that defines an IAF?


Direct means you
go to an IAF then get to the airport. How are you supposed to land?


My reading of 91.185(c)(3)(ii) seems to imply that you have to fly to
the airport first, then to an IAF.


You can;t just go to the airport and circle down to land - that is the
whole reason for having defined instrument approaches.


If you're saying that it's stupid to fly to the airport first, I agree
with you. Hence my question.


Right. See above regarding what that last "direct" means. It does not
mean go froom the penultimate fix to the airport. It means go to an
IAF then fly the approach.


I'm pretty sure you're wrong about that.


My initial (and I guess overzealous) reaction to your post was that it
seemed like you just didn;t care what "the book" said or what you are
supposed to do based on part 91 regs for ifr flight. That is scary to me.


Of course I care. But that doesn't mean that I blindly follow the rules
without thinking.

I misunderstood your initial question and I apologize for any demeaning
statements. It appeared to me that you were not aware of what the FARs
stated. Again, my apologies.


rg

snip

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

If you don't believe that if your clearance limit is the airport and
that you can pick any approach and IAF and execute it when lost coms,
then you can try this:

from "Instrument Flying Handbook"
FAA H 8083 15
page 10-11

http://www.faa.gov/library/manuals/a...-8083-15-2.pdf

"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."