Does it matter? 4 NM leg or minute outbound?

[Shiftace]

So a student posed this question:

If there is a HILPT, say for an RNAV approach, and you have to make a lap in the pattern for course reversal - do you have to fly the published distance (4 or 7 nm)? Say it is a parallel entry, can I do 1 minute leg outbound? and turn around? Or do I have to fly the published distance.

I found the Young LOI that kinda hits on this, but nothing concrete. Do you have any source that says either way.

S

 

[drunkenbeagle]

I'm not aware of another source, but what I teach is to do the 4 mile legs as published. I also teach to load the hold in lieu into the GPS, and that way what you are flying is going to line up with what the GPS is saying. The hold is already more work than most GA pilots are used to, especially without an autopilot. Why make things harder?

The Instrument Procedure book, Ch. 4 page 49 says "A holding pattern-in-lieu-of procedure turn may be specified for course reversal in some procedures. In such cases, the holding pattern is established over an intermediate fix or a FAF. The holding pattern distance or time specified in the profile view must be observed. For ahold-in-lieu-of PT, the holding pattern direction must be flown as depicted and the specified leg length/timing must not be exceeded."

I read that to mean that you can't exceed the distance or time, and if it is depicted explicitly, you have to follow that too. Plus, I can't think of a good reason not to in real life.

 

[milleR]

My interpretation has always been that the holding pattern defines the protected area. The 'must be observed' language means that you are not to exceed the limitations of the depicted area. If ATC were to tell you to 'hold as published' then yes, you'd fly it as written. But for a PT a one minute outbound leg would be perfectly fine.

 

[drunkenbeagle]

My interpretation has always been that the holding pattern defines the protected area. The 'must be observed' language means that you are not to exceed the limitations of the depicted area. If ATC were to tell you to 'hold as published' then yes, you'd fly it as written. But for a PT a one minute outbound leg would be perfectly fine.

I find it as ambiguous as "direct to the IAF, cleared for the approach." Is that straight in, or with the course reversal? 99% of the time, straight in, unless it isn't? I just learned to read back "cleared for the straight in approach" so it is on the tapes.

 

[MikeD]

The hold is already more work than most GA pilots are used to, especially without an autopilot. Why make things harder?

wow. GA has gotten soft. A hold is too much work now, esp without an autopilot.

The Instrument Procedure book, Ch. 4 page 49 says "A holding pattern-in-lieu-of procedure turn may be specified for course reversal in some procedures. In such cases, the holding pattern is established over an intermediate fix or a FAF. The holding pattern distance or time specified in the profile view must be observed. For ahold-in-lieu-of PT, the holding pattern direction must be flown as depicted and the specified leg length/timing must not be exceeded."

I read that to mean that you can't exceed the distance or time, and if it is depicted explicitly, you have to follow that too. Plus, I can't think of a good reason not to in real life.

I find it as ambiguous as "direct to the IAF, cleared for the approach." Is that straight in, or with the course reversal? 99% of the time, straight in, unless it isn't? I just learned to read back "cleared for the straight in approach" so it is on the tapes.

Does SNoRT apply, is the only question.

 

[MidlifeFlyer]

There was a Chief Counsel letter in 2011 (see page 3) saying that the distance in a published hold is a maximum and you can shorten it without ATC approval. If, however, its a custom hold and ATC gives a leg distance , it's a 91.123 instruction.

Practically speaking, the entire protected area of the hold is protected from both a terrain and traffic standpoint, so it really doesn't matter (unless ATC specifies a distance). As a matter of practice I Inform ATC if I am going to shorten the legs since I figure it may affect their timing for other ops.

 

[MidlifeFlyer]

I find it as ambiguous as "direct to the IAF, cleared for the approach." Is that straight in, or with the course reversal? 99% of the time, straight in, unless it isn't? I just learned to read back "cleared for the straight in approach" so it is on the tapes.

It shouldn't be ambiguous. The basic rule in 91.175(j) is pretty straightforward. "In the case of a radar vector to a final approach course or fix, a timed approach from a holding fix, or an approach for which the procedure specifies "No PT," no pilot may make a procedure turn unless cleared to do so by ATC.

FAA guidance and interpretations have made it clear that the opposite is equally true: when none of those conditions exits, the published course reversal is required unless ATC clears you straight in.

The only ambiguity is ATC's tendency (despite what the 7110.65 says) to expect straight in with no straight in instruction when the aircraft is in a position which makes a straight in reasonable - >90% angle and, I guess, an appropriate altitude (which is really ambiguous). In those situations, I'll add, "confirm cleared straight in" to my readback.

 

[drunkenbeagle]

The only ambiguity is ATC's tendency (despite what the 7110.65 says) to expect straight in with no straight in instruction when the aircraft is in a position which makes a straight in reasonable - >90% angle and, I guess, an appropriate altitude (which is really ambiguous). In those situations, I'll add, "confirm cleared straight in" to my readback.

That's exactly what I do as well. But more often than not, it is a student on the radio, and the frequency is too busy to ask...

 

[MikeD]

It shouldn't be ambiguous. The basic rule in 91.175(j) is pretty straightforward. "In the case of a radar vector to a final approach course or fix, a timed approach from a holding fix, or an approach for which the procedure specifies "No PT," no pilot may make a procedure turn unless cleared to do so by ATC.

FAA guidance and interpretations have made it clear that the opposite is equally true: when none of those conditions exits, the published course reversal is required unless ATC clears you straight in.

The only ambiguity is ATC's tendency (despite what the 7110.65 says) to expect straight in with no straight in instruction when the aircraft is in a position which makes a straight in reasonable - >90% angle and, I guess, an appropriate altitude (which is really ambiguous). In those situations, I'll add, "confirm cleared straight in" to my readback.

SNoRT.

Course reversal hold not required for Staight in approach, NoPT routing, Radar Vectors, or Timed Approach. In the case of timed, in a hold for an EAC/EFC, hold can be shortened as needed to cross the hold fix inbound to
meet that time.

Agreed. Straightforward.

 

[MikeD]

Here’s one for you that has come up. Was hearing it firsthand as it was occurring. RNAV 23 to P08 below. Uncontrolled field, multiple airplanes doing practice approaches VFR via CTAF. Notice the HILO hold at DARAY is 5800’ hard altitude.

Let’s say you have one airplane coming in from the west. Calls on CTAF heading to DARAY, one turn in holding for the approach. Calls crossing DARAY outbound. At the same time, another plane calls up inbound for the approach from BOCPO. Both planes are at 5800’, airplane 1 is now approaching DARAY on the inbound leg of the hold, less than a mile from the fix. Airplane 2 is approaching DARAY from BOCPO, less than a mile from the fix. Assuming both planes would arrive at DARAY at the same time and co-altitude, who has the right of way, if the two crews of the planes were going to argue over who goes first?

Does the hold aircraft have the right of way, because it’s VMC/VFR, and it’s the aircraft “on the right”, plan-view-wise, approaching the hold fix at DARAY?

Or, would the BOCPO leg traffic have right of way due to being on a NoPT routing, and really having nowhere else to go other than turn inbound on the intermediate segment (assuming everyone is trying to follow the approach plate altitude limitations). Airplane 1 in the hold does have a place to go, being about to make an outbound turn in the hold again. Though, the two aircraft in question at the time; were arguing the point on CTAF as both were approaching the same fix, DARAY, at the same altitude. Not really the time and place to force trying to be “right”, in my opinion. I was a third aircraft coming up from ITEMM and approaching BOCPO, listening to the radio grumbling increasing, and finally refereed with the above.

https://aeronav.faa.gov/d-tpp/2609/09213R23.PDF