Course Reversal

[drunkenbeagle]

You said you were cleared direct, and "cleared direct" is notorious in the industry for NOT being a vector and for NOT being safe when the fix is the FAF.

You are correct. I'll try not to do it again. But already established inbound, it seemed like the more prudent move to do it straight in.

I guess the better question, why did I end up with that clearance in the first place? Since the IAF that would let me do it straight in was maybe a mile off my course.

 

[tgrayson]

You are correct. I'll try not to do it again. But already established inbound, it seemed like the more prudent move to do it straight in.

To be honest, I expect that most pilots would have done the same thing. In the situation you described, it may not have been unsafe if the angle of interception was small and, in reality, there's no one looking over your shoulder to enforce the letter of the law.

I guess the better question, why did I end up with that clearance in the first place? Since the IAF that would let me do it straight in was maybe a mile off my course.

ATC may well have *expected* you to do what you did, but was being careful to avoid telling you not to do the PT.

We have a local approach that has a feeder route that intersects the FAC at about a 90 degree angle. The route is *not* labeled NoPT, so the PT is required. However, I gather that most people don't do it, because ATC always acts surprised when I turn outbound. I've learned to inform them ahead of time that I intend to do the PT. I shouldn't have to do that....

 

[nosehair]

I don't see how you get that from that paragraph. But this is pretty explicit:

5-4-9. Procedure Turn​

a. A procedure turn is the maneuver prescribed when it is necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course. The procedure turn or hold-in-lieu-of-PT is a required maneuver when it is depicted on the approach chart.
​

The conflict in understanding is, I think, within the above two sentences:
Initially, a. is saying to the pilot, or controller, what to do, "when it is necessary to reverse direction to establish the aircraft on final"..the term "when it is necessary" is, it seems, a directive to the pilot, or controller, to make the decision as to the necessity to "reverse direction" to "establish the aircraft inbound on final".
The following sentence describes the "procedure turn maneuver" that is required as it is depicted on the chart. Some (most) are depicted as the open ended 45 degree barb, but is restricted to one side, some are depicted as a holding pattern, some are depicted as a teardrop, ans so on. The rule is written to say that "if you (the pilot, or controller) determine a course reversal is needed to get aligned, the turn is depicted on the chart".

That, I think is the source of the wide-spread mis-understanding and application by good pilots and controllers everywhere.

I don't know if that's the intended meaning, or if the meaning is as flat as the "Always, no matter what, if it's depicted-on-the-chart-you-have-to-do-it interpretation, I cannot say.

I do have a problem making the AIM interpretation as if it were the chart designers viewpoint. I read AIM and regulatory stuff as written to the pilot in the field. ...But I also constantly look for every grain of knowledge that may save my bacon and since no entity, including govt. is perfect, I consider the source of the information.

If the pilot is really in compliance with 91.103, having all available information, ie., a true familiarity with the approach, and local approach controllers, and the straight-in does not, in any way, in the remotest of "imaginary scenarios" cause any increased danger, no one in the FAA would attempt a violation based solely on the wording of the above quote.

 

[tgrayson]

I don't know if that's the intended meaning, or if the meaning is as flat as the "Always, no matter what, if it's depicted-on-the-chart-you-have-to-do-it interpretation, I cannot say.

The latter IS the meaning because the people who wrote the paragraphs in the AIM say that's the meaning they want to convey. And Wally Roberts, who wrote the article I linked to above, is one of the people who was involved in writing the paragraph in the AIM. And they're all sick to death of rewriting the AIM guidance on this to forestall pilots who want to read in permissiveness where none is provided. If the FAA had wanted to give the pilot any discretion in performing the maneuver, the AIM would have said so, without requiring the pilot to read between the lines.

Regardless, if there were ever any doubt, the letter of interpretation from the FAA removes it:


Nov. 28, 1994
Mr. Tom Young, Chairman
Charting and Instrument Procedures Committee
Air Line Pilots Association
535 Herndon Parkway
Herndon, VA 22070

Dear Mr. Young

This is a clarification of our response to your letter of August 23, 1993. In that letter you requested an interpretation of Section 91.175 of the Federal Aviation Regulation (FAR) (14 CFR Section 91.175). You address the necessity of executing a complete Standard Instrument Approach Procedure (SIAP) in a non-radar environment while operating under Instrument Flight Rules (IFR). Our response assumes that each of the specific scenarios you pose speaks to a flight conducted under IFR in a non-radar environment.

[non-pertinent material deleted]

Finally, you ask whether a course reversal segment is optional "when one of the conditions of FAR section 91.175(j) is not present." Section 91.175(j) states that 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 procedures specifies "no procedure turn," no pilot may make a procedure turn unless cleared to do so by ATC.

Section 97.3(p) defines a procedure turn, in part, as a maneuver prescribed when it is necessary to reverse direction to establish the aircraft on a intermediate or final approach course. A SIAP may or may not prescribe a procedure turn based on the application of certain criteria contained in the TERPs. However, 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.

If you have any questions regarding this matter, please contact Patricia R. Lane, Manager, Airspace and Air Traffic Law Branch, at (202) 267-3491.


Sincerely,
/s/
Patricia R. Lane
for Donald P. Byrne
Assistant Chief Counsel
Regulations Division

 

[drunkenbeagle]

ATC may well have *expected* you to do what you did, but was being careful to avoid telling you not to do the PT.

We have a local approach that has a feeder route that intersects the FAC at about a 90 degree angle. The route is *not* labeled NoPT, so the PT is required. However, I gather that most people don't do it, because ATC always acts surprised when I turn outbound. I've learned to inform them ahead of time that I intend to do the PT. I shouldn't have to do that....

If I want a course reversal, I'll ask for the full procedure. Because unless I say that, ATC is always surprised that I'm doing one (legally required or not).

BTW, the letter you posted makes it about as clear as mud to me. It specifies a non-radar environment, while omitting the procedure turn requires radar vectors. I've always been in radar contact in such situations, just not receiving radar vectors.

In the example I point out, I was receiving radar vectors that put me on final until 15 miles out from the FAF. If the hadn't said that pesky "cleared direct" it would have been (more) legal. As I understand it, the vectors need to continue to the FAF for the PT to be omitted, but I'm not sure where this is written.

 

[tgrayson]

Crap, I accidentally overwrote my original post. Here's a rewrite:

It specifies a non-radar environment, while omitting the procedure turn requires radar vectors. I've always been in radar contact in such situations, just not receiving radar vectors.

The existence of radar that you're not using doesn't change anything. Note that they said the non-radar was an assumption, not a requirement for the truth of what the letter said. Regardless, you need to look at the big picture. The FAA has lots of clear statements saying the PT is required, and none saying that it's at the pilot discretion. Prior to the letter, and prior to numerous AIM changes, the FAA view wasn't nearly as clear; those who were educated during that time frame continue to teach the way they were taught and read into the new language their own views on the subject. These are the same people who keep calling Flight Reviews "BFRs".

BTW, this letter wasn't the first one on the subject; the legal department screwed up the first one and a second one was quickly issued, which is why it's a "clarification". Here's one paragraph that was removed from the incorrect letter, and it's instructive for what they didn't want to say:

Under Section 91.123(a), a pilot may not deviate from an ATC clearance except in an emergency or unless an amended clearance has been obtained. Accordingly, if a pilot does not wish to execute a published course reversal procedure, he may request ATC for an authorization to deviate from the published approach procedure. In the absence of such an authorization, a pilot may not consider the published course reversal procedure optional.​

 

[drunkenbeagle]

The FAA has lots of clear statements saying the PT is required, and none saying that it's at the pilot discretion. Prior to the letter, and prior to numerous AIM changes, the FAA view wasn't nearly as clear; those who were educated during that time frame continue to teach the way they were taught and read into the new language their own views on the subject.

I totally agree it is required. Just out of curiosity, do you know of anyone getting in trouble for this? While it may be a rule, it is one that I also see broken fairly often.

A change to ATC phraseology requiring "cleared for the full procedure" would probably not be a bad idea, to make it clear, since vectors to final is the norm 99% of the time around here. When told to expect an approach and being vectored, it is easy to assume the vectors will continue to the FAF, which isn't always the case.

 

[Roger, Roger]

1. We need to continue to teach our students when the PT is required and when it may be skipped, and to make sure to put them in the situations that could cause them to improperly skip a PT.

2. Teach them to think ahead enough to avoid confusion. I've noticed that these conflicts come up most often when the student is "along for the ride" and just doing what ATC says, rather than thinking for themself and being PIC. Most of these situations are pretty easy to avoid by a) requesting a NoPT transition b) requesting vectors or c) just notifying ATC that they will do the PT.

 

[MikeD]

These are the same people who keep calling Flight Reviews "BFRs".

"BFR" flows better when you say it. Kind of like TCA!.

 

[nosehair]

Finally, you ask whether a course reversal segment is optional "when one of the conditions of FAR section 91.175(j) is not present." Section 91.175(j) states that 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 procedures specifies "no procedure turn," no pilot may make a procedure turn unless cleared to do so by ATC.

Section 97.3(p) defines a procedure turn, in part, as a maneuver prescribed when it is necessary to reverse direction to establish the aircraft on a intermediate or final approach course. A SIAP may or may not prescribe a procedure turn based on the application of certain criteria contained in the TERPs. However, 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.

This does not address my specific point of whether or not the pilot decides himself when it is necessary to make a course reversal in order to get aligned; it addresses the requirements and conditions under which a prodedure turn may or may not be made, but it does not say, specifically, that the pilot shall always make a PT unless the chart says "NoPT".

BTW, I am not arguing for or against either side, but only pointing at the specific point of mis-understanding.

 

[drunkenbeagle]

This does not address my specific point of whether or not the pilot decides himself when it is necessary to make a course reversal in order to get aligned; it addresses the requirements and conditions under which a prodedure turn may or may not be made, but it does not say, specifically, that the pilot shall always make a PT unless the chart says "NoPT".

tgrayson's position is 100% correct, the PT is required if the plate doesn't provide otherwise, or you don't have radar vectors to final, or hold-in-leiu or timed.

I think much of the problem comes from ATC not expecting the course reversal when you are alreday established inbound. Probably because many/most pilots won't do the PT when they are already established inbound...

For better or worse, if there is traffic holding behind me, I'm probably more likely to not take the PT in the straight in no vectors scenario, I don't like shutting down an untowered field for 30+ minutes when I know someone is behind me.

 

[SteveC]

...

For better or worse, if there is traffic holding behind me, I'm probably more likely to not take the PT in the straight in no vectors scenario...

How do you end up on the final approach course in a non-radar environment in your "straight in no vectors scenario"?

 

[tgrayson]

does not say, specifically, that the pilot shall always make a PT unless the chart says "NoPT".

...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.
​

How could it be any clearer, without it being addressed specifically to you?

 

[MidlifeFlyer]

How do you end up on the final approach course in a non-radar environment in your "straight in no vectors scenario"?

The scenario is a clearance direct to a navaid or waypoint that is a FAF. Fly to it and turn inbound instead of outbound.

Surprised you asked since I can see multiple scenarios at your home base for the GRR VOR 35. In bound from the east on V510, from the west on V274 or even from either direction on V84 if the controller says at some point near BOHRR, "turn right/left, direct GRR; cleared for the VOR 35 approach."

I'm actually somewhere between tgrayson and nosehair on this one – I think that the controller =can= clear you straight in in any of these scenarios. I've seen articles describing these as "pseudo-vectors" even though you are actually being placed outside the approach gate.

Of course, even (or especially) in these situations, I'd always query the controller if I was cleared straight in, it being important that you and the controller are both on the same page.

 

[SteveC]

The scenario is a clearance direct to a navaid or waypoint that is a FAF. Fly to it and turn inbound instead of outbound.

Surprise you asked since I can see multiple scenarios at your home base for the GRR VOR 35. In bound from the east on V510, from the west on V274 or even from either direction on V84 if the controller says at some point near BOHRR, "turn right/left, direct GRR; cleared for the VOR 35 approach."

I'm actually somewhere between tgrayson and nosehair on this one – I think that the controller =can= clear you straight in in any of these scenraios.

I'll blame miscommunication. I assumed by the way he wrote that sentence that he meant that he was established on the final approach course prior to the FAF, and I couldn't understand how he got there without vectors. Direct to the fix doesn't get you established inbound. In hindsight I can see that my assumption was probably incorrect, and that he was talking about just skipping the PT, thus the "straight in" wording. Communication fail on my part.

 

[EatSleepFly]

The scenario is a clearance direct to a navaid or waypoint that is a FAF. Fly to it and turn inbound instead of outbound.

Unless there is a "NoPT," I don't believe that would be legal in a non-radar environment. For some reason I had it in my head that approaches in a non-radar environment had to begin at an IF/IAF, but I can't find a very solid reference for it. The IPH says it (but of course isn't regulatory) and the letter that tgrayson posted indirectly supports it.

The AIM also says:

6. A procedure turn is not required when an approach can be made directly from a specified intermediate fix to the final approach fix. In such cases, the term "NoPT" is used with the appropriate course and altitude to denote that the procedure turn is not required. If a procedure turn is desired, and when cleared to do so by ATC, descent below the procedure turn altitude should not be made until the aircraft is established on the inbound course, since some NoPT altitudes may be lower than the procedure turn altitudes.

Which to me is even more implication (if the letter above isn't enough) that if you aren't joining the approach from an IF/IAF to the FAF, a procedure turn IS required.

In any case, even if it is legal to proceed own nav to the FAF and just turn inbound, it isn't very realistic unless you're in a slow, simple airplane and/or going into an airport with no terrain or obstructions. I honestly can't say that I've ever done it, except to set up for a visual.

:dunno:

 

[tgrayson]

For some reason I had it in my head that approaches in a non-radar environment had to begin at an IF/IAF,

The letter I posted contains that language, but I deleted it to remove clutter. It states:

First you ask whether an arriving aircraft must begin the SIAP at a published Initial Approach Fix (IAF). A pilot must begin a SIAP at the IAF as defined in Part 97. Descent gradients, communication, and obstruction clearance, as set forth in the U.S. Standard for Terminal Instrument Approach Procedures (TERPs), cannot be assured if the entire procedure is not flown.
​

 

[MidlifeFlyer]

Unless there is a "NoPT," I don't believe that would be legal in a non-radar environment.

I think you may be correct.

At least one argument behind the general concept of it being ok for ATC to send you direct to the FAF and then go straight in is that, in a a radar environment, it's a "pseudo vector" - just easier for ATC to say "proceed direct XXX, cleared for the VOR 23 approach straight in" than "turn left heading 220, maintain 3000 until established, cleared for the VOR 23 approach."

That argument falls apart when not in a radar environment.

OTOH, the even in a non-radar environment contingent has some ammo also - the earlier opinion that tgrayson says FAA Legal screwed up on and which said
==============================
However, ATC may "authorize" a deviation from the prescribed procedure when it determines that a different approach procedure is appropriate
==============================

It's correctness aside, I've never quite understood the argument that the later opinion somehow overturned this statement without ever mentioning it.

 

[EatSleepFly]

The letter I posted contains that language, but I deleted it to remove clutter. It states:

First you ask whether an arriving aircraft must begin the SIAP at a published Initial Approach Fix (IAF). A pilot must begin a SIAP at the IAF as defined in Part 97. Descent gradients, communication, and obstruction clearance, as set forth in the U.S. Standard for Terminal Instrument Approach Procedures (TERPs), cannot be assured if the entire procedure is not flown.
​

Ah ha! Didn't think to look through interpretations. Thanks!

 

[EatSleepFly]

At least one argument behind the general concept of it being ok for ATC to send you direct to the FAF and then go straight in is that, in a a radar environment, it's a "pseudo vector" - just easier for ATC to say "proceed direct XXX, cleared for the VOR 23 approach straight in" than "turn left heading 220, maintain 3000 until established, cleared for the VOR 23 approach."

That (the bold) wouldn't be a legal clearance either if XXX is the FAF, unless it was specifically requested by the pilot (see below).

5-9-1. VECTORS TO FINAL APPROACH COURSE

Except as provided in para 7-4-2, Vectors for Visual
Approach, vector arriving aircraft to intercept the
final approach course:

a. At least 2 miles outside the approach gate unless
one of the following exists:

1. When the reported ceiling is at least 500 feet
above the MVA/MIA and the visibility is at least
3miles (report may be a PIREP if no weather is
reported for the airport), aircraft may be vectored to
intercept the final approach course closer than 2 miles
outside the approach gate but no closer than the
approach gate.

2. If specifically requested by the pilot, aircraft
may be vectored to intercept the final approach
course inside the approach gate but no closer than the
final approach fix.