Defining the MAP during a nonprecision approach

MidlifeFlyer said:
This is the same rule that led the Chief Counsel's office (and the AIM, although one is "non-regulatory") to say that a depicted PT mist be followed regardless of whether the pilot thinks it's necessary to reverse course.
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Ah, but they didn't say that, Mike.
You are doing exactly what denver is saying; you're "quoting" the chief counsel's decision as if it read the way you said here "the PT must be followed regardless of whether the pilot thinks is necessary"...the letter does not say that.
It merely quotes the TERPs paragraph. It is government speak for "Whatever those technical terms mean; that's what the pilot must do".
What it does NOT say is that the pilot cannot make the decision about whether a course reversal is necessary. That question was not asked nor answered in the letter.

And you cannot imply that because a "time box" is displayed on a chart that it MUST be used. It is a guide. Seriously.
If you have other information, any other information that more accurately shows your position, and you don't use it, and you crash because you were going by time rather than the other information, and this in evidence, what do you think the general public, the FAA, the insurance companies, your wife, and your girlfriend would think?
 
nosehair said:
And you cannot imply that because a "time box" is displayed on a chart that it MUST be used. It is a guide. Seriously.
If you have other information, any other information that more accurately shows your position, and you don't use it, and you crash because you were going by time rather than the other information, and this in evidence, what do you think the general public, the FAA, the insurance companies, your wife, and your girlfriend would think?
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By the same token, if you crash during an instrument approach that requires timing to define the MAP, and the investigation looks into the cockpit and finds the clock or timing device and finds it reading zeros or the sweep-hand zeroed out; what would the same above people think? Same thing. Regardless of what any other supposedly more-accurate device would say. Because that more-accurate device didn't keep you from hitting the ground or the obstruction that was attached to it.
 
MikeD said:
By the same token, if you crash during an instrument approach that requires timing to define the MAP, and the investigation looks into the cockpit and finds the clock or timing device and finds it reading zeros or the sweep-hand zeroed out; what would the same above people think? Same thing. Regardless of what any other supposedly more-accurate device would say. Because that more-accurate device didn't keep you from hitting the ground or the obstruction that was attached to it.
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Yes, my position is based on a pilot making the decision to use a better device, technique, method, or whatever, than the guesstimate method of the clock against the wind.
Your proposed scenario is quite the reach, but I like the attempt. In your example, the lack of evidence of using a timing device would not necessarily lead to a conclusion with evidence sufficient for a violation. If there were conclusive evidence of the other faulty equipment, then the PIC was making the wrong choice.
 
nosehair said:
Yes, my position is based on a pilot making the decision to use a better device, technique, method, or whatever, than the guesstimate method of the clock against the wind.

Your proposed scenario is quite the reach, but I like the attempt. In your example, the lack of evidence of using a timing device would not necessarily lead to a conclusion with evidence sufficient for a violation. If there were conclusive evidence of the other faulty equipment, then the PIC was making the wrong choice.
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Not a reach at all there son. The clock wouldn't reset itself to zero, it'd be there if it wasn't used. And if the pilot made the choice to use the "more accurate" method, and still ended up hitting the ground or something attached to it, then it wasn't really that accurate at the time, was it? I can compute a time just fine, and Id back it up if I had something else to, of course. Again, use whats available. But if I don't even use the basic item, and I still end up in the dirt while using something on my own, I don't know if the FAA would be too keen.....

.....that is, if you're still alive.

It goes both ways. Whether you like it or not, or whether I like it or not. In my longtime in aviation, Ive seen some interesting violations.
 
nosehair said:
?What? You're over my head.
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That might be the cause of you not understanding the Chief Counsel opinion letter.

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Finally, you ask whether a course reversal segment is optional "when one of the conditions of FAR section 91.175(j) is not present."
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if a SIAP does contain a procedure turn and ATC has cleared a pilot to execute the SIAP, the pilot must make the procedure turn when one of the conditions of Section 91.175(j) is not present.
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MidlifeFlyer said:
That might be the cause of you not understanding the Chief Counsel opinion letter.

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Finally, you ask whether a course reversal segment is optional "when one of the conditions of FAR section 91.175(j) is not present."
***
if a SIAP does contain a procedure turn and ATC has cleared a pilot to execute the SIAP, the pilot must make the procedure turn when one of the conditions of Section 91.175(j) is not present.
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See how that question is asked? (do I have to make a course reversal)"when one of the conditions of FAR section bla bla is not present?" I mean, how open ended is that?
Well, of course, the answer has to be covering all the bases. The question does not ask, "in the beginning, when reaching the IAF, and the IAF is also the FAF, and you are on course, and on FAF altitude, and you determine, as PIC, that a course reversal is not necessary to become established on final,...is a course reversal required at that time?"

The answer that is given to the general open ended question merely delegates the answer the the procedure, "if the SIAP contains a PT~ the the pilot must make the PT".
But the execution of that SIAP is what we are disagreeing on - the technical execution, that is, the technical decision as to when a course reversal is necessary by the pilot.

I'll bet a dollar to a doughnut that you won't get a legally binding opinion that a "course reversal" is necessary when the pilot says it is not, and all conditions of "established on final" are met.
 
FWIW, my dollars-to donuts bet is that if asked, (a) the Chief Counsel's opinion (or the FAA's position in an enforcement proceeding) , whichever way it goes, will be "legally binding" and (b) such an opinion would say that you were cleared for the approach as depicted and that in the absence of a straight-in clearance from ATC, the PT must be performed.
 
If a student did NOT start his time at the FAF on the approach listed on the OP, and only used his GPS to determine the MAP, I would consider that illegal (not that I would raise a fuss over it). Now if he/she started the timer, and used the GPS as situational awareness to determine changes in groundspeed and changed the time to MAP to reflect changes in groundspeed, this is an appropriate thing to do and would pass a check-ride from me.

This is the same as if you was flying a victor airway while slant/U if you still had a VFR GPS. Would I use the GPS? you bet I would, I would even link up the autopilot to the GPS as it is way more accurate than using a VOR, However, to make it legal you need to tune in the VOR and monitor it.
 
jrh said:
Maybe it's an anti-authority streak in my personality, but I avoid teaching anything "just because." I must have solid reasons for the lessons I pass on. It makes me feel like a lemming to do otherwise. If I can't explain the "why" behind a procedure, I figure I shouldn't bother teaching it.

I've thought the same thing, but I don't know who to contact.
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Its much more likely that these approaches will end up with gps overlays before the faa changes from time to gps.
 
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