Course Reversal

MidlifeFlyer said:
It's correctness aside, I've never quite understood the argument that the later opinion somehow overturned this statement without ever mentioning it.
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Had the second opinion been a separate letter addressed to someone else that only coincidentally overlapped the previous letter, then I don't think it would have overturned that earlier paragraph. But given that it was a whole do-over of the original letter, I think it a reasonable interpretation that a view that was expressed but not repeated has lost its force, the same way that if ATC doesn't repeat a crossing restriction, it goes away.

Ideally, they should have said "we deleted paragragh x because it was stupid," but they never seem to say such things. ;)
 
tgrayson said:
But given that it was a whole do-over of the original letter,
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I think we're talking about two different letters. Yes, the 1994 letter was sort of a do-over of a 1993 letter both of which deal with a non-radar environment. I'm not sure that you can really imply a negative but even if you can, we're still dealing with a non-radar environment.

The one I refer to goes much further back - to 1977, and doesn't mention a distinction between radar and non-radar.
Ideally, they should have said "we delete paragraph x because it was stupid," but they never seem to say such things. ;)
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Actually, I have see things like:

==============================
You also stated your belief that an earlier interpretation issued by this office was incorrect. We answer your questions below and we find that you correctly identified an error in an earlier interpretation.
==============================

and

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This interpretation of section 91.303(c) reverses the interpretation issued on July 14, 1999 in a letter to Earl Lawrence from Donald Byrne, Assistant Chief Counsel which you cited as incorrect.
==============================

I don't think the question, "in a radar environment, may ATC clear you straight in from a FAF that they would have been able to vector you with 2 miles of?" is as clear as some on both sides of the debate would have us believe.
 
MidlifeFlyer said:
The one I refer to goes much further back - to 1977, and doesn't mention a distinction between radar and non-radar.
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Oh, that one. There was a lot of bizarre stuff in that letter, like the distinctions between mandatory, permissive, or prohibited procedure turns, terminology which doesn't appear in the AIM or regulations, unless they read very differently back then.
 
tgrayson said:
Oh, that one. There was a lot of bizarre stuff in that letter, like the distinctions between mandatory, permissive, or prohibited procedure turns, terminology which doesn't appear in the AIM or regulations, unless they read very differently back then.
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I assume the definition of "bizarre" is "something I don't agree with." :D
 
tgrayson said:
...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?
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...and what is a procedure turn?
"
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 confusion lies in the term "course reversal".

Who gets to say "when it is necessary to execute a course reversal".
It has become as widely interpreted as the AIM recommended procedure for non-tower traffic patterns.

Yes, EatsleepFly, I'm talking low, slow, simple, having made the approach vfr manytimes.

The "standard" is that anywhere in the world, in any kind of airplane, if you always do the full PT, you will always be safe and have the time to proceed cautiously, as in the vfr pattern entry.

However, if you, the pilot responsible for everything you do, make the final decision that a course reversal is not necessary, and in fact can contribute to more potential danger, it seems the wording provides the latitude for pilot judgment.

Most of the original wording in the regs and procedures are "loose", or have broad application exactly for the purpose of providing executive authority to the pilot. He/She is always operating under the authority and responsibility of 91.3 (Authority) and 91.103 (Responsibility for Situational Awareness).
 
nosehair said:
Who gets to say "when it is necessary to execute a course reversal".
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Well, the choices are:

(a) Approach designers using published criteria and mathematically derived templates to insure pilots who can't see out the window have terrain separation.

(b) the pilots who can't see out of the window.

So far, the AIM and FAA Legal seem to have gone with (a). But who knows? Keep trying to see if they'll change their mind and finally admit that (b) is the answer that makes the most sense.

BTW, I'm sure that, so long as you guarantee your own terrain separation on the tape, ATC will let you do pretty much what you want so long as it doesn't impact traffic, radar or no, so go ahead and ask for whatever you want. The practical reality is that the FAA probably won't catch you unless, like that guy who did the right thing by canceling IFR when he broke out in Class E (but not 500 below), there happened to be some FAA dude listening in.
 
If I will be doing something that requires a PT, I make sure I specifically request radar vectors or full procedure, just so I am clear and ATC is clear on what I want to do. That seems to be the most prudent way to avoid any of these "pseudo vector" clearances.

I have been put on a vector that would take me into some large antennas near my airport. If I didn't query ATC, I would be dead. Just because ATC clears you for something, it doesn't mean they are right in doing so.
 
SteveC said:
How do you end up on the final approach course in a non-radar environment in your "straight in no vectors scenario"?
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Just dumb luck that direct to that VOR just happened to be 1 degree off of the final approach course in that case. Also, I think it was far enough away from the approach facility that they would have lost me at the published FAF altitude.

There was an extremely strong crosswind (48 kts, my forward speed was 90), which is probably why I didn't end up with vectors all the way.
 
MidlifeFlyer said:
Well, the choices are:

(a) Approach designers using published criteria and mathematically derived templates to insure pilots who can't see out the window have terrain separation.

(b) the pilots who can't see out of the window.
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?? These answers make me think you don't understand the question: who says I have to make a course reversal when I am exactly lined up on final when I reach the IAF? Why do I have to make a "Course Reversal"?

Your answer (a) answers the question: "How do I make a course reversal in order to get lined up on final?".

Your answer (b), I don't get. ??
So far, the AIM and FAA Legal seem to have gone with (a).
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Oh, you mean with the continued re-writes of the same contorted confusions. All of the legal interps just repeat the reg or AIM in a specific answer to a specific question in the government fashion of not taking any responsibility in the interpretation.

If the question is asked "Can I go straight-in if I am already lined up, etc., at the IAF?", the government entity answering that question cannot say yes, because the etc I put in there requires too many ifs, ands, and buts, so the generic answer is to quote the AIM. ..and the AIM description of the PT gets connected to the purpose of the PT, so that some think that a depiction of a PT requires the execution of the PT.
But the purpose of the PT is in the definition of a course reversal, which is to get turned around to get aligned on final. If that is not necessary, then the PT need not be executed. It is when the pilot makes a decision to execute a turn that he must fly the turn as depicted.

...and, of course, many FAA folks & senior instructors believe the "must-do-PT-no-matter-what" to be the manta, also, so the myth is perpetuated. You/we have all seen many examples of that in many areas.

Really. I haven't seen a black-and-white command that you must make a course reversal when you are already on final. Have you?
 
nosehair said:
?? These answers make me think you don't understand the question:
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Could be. What are your choices for answers to your question so each person can decide what answer makes the most sense?
Oh, you mean with the continued re-writes of the same contorted confusions. All of the legal interps just repeat the reg or AIM in a specific answer to a specific question in the government fashion of not taking any responsibility in the interpretation.
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Maybe so, but those are the folks charged by the FAA with deciding what the regs mean (and the folks that get to take your pilot certificate away if you do something that doesn't agree with them).

I think that may summarize the times you and I disagree on regs. You want the FAA's regs to mean what you want. I'm satisfied with accepting what the FAA says the FAA's regs mean and dealing with that reality. Where I might say the FAA's interpretation is stupid but that's what we have to deal with, you will say the FAA's interpretation is stupid and therefore doesn't count.
 
MidlifeFlyer said:
Where I might say the FAA's interpretation is stupid but that's what we have to deal with, you will say the FAA's interpretation is stupid and therefore doesn't count.
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Don't really mean to come across like that. I am saying that the first sentence in the AIM, the Book of guidance that we use to conform to regulations, says what a procedure turn is, and it says it is prescribed when a course reversal is necessary.

The letters of interpretation of the "necessary" part of that statement has not been defined. All these letters that I have seen address a specific example other than a simple "can-you-go-straight-in" when you are "established" on final?
Haven't seen it. That's still my question.
 
nosehair said:
Don't really mean to come across like that. I am saying that the first sentence in the AIM, the Book of guidance that we use to conform to regulations, says what a procedure turn is, and it says it is prescribed when a course reversal is necessary.

The letters of interpretation of the "necessary" part of that statement has not been defined. All these letters that I have seen address a specific example other than a simple "can-you-go-straight-in" when you are "established" on final?
Haven't seen it. That's still my question.
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A definition of what something is does not imply how it is used.

And how about the definition of "prescribe?"

Do pilots "prescribe" procedure turns or does the FAA?

Playing with the terms to twist them into what you want to say (similar to your position that you get to decide whether your student is "really" the sole manipulator when his are the only hands on the controls) is what I meant by saying that you decide the rules you like don't count.

I actually like it.

"A traffic light is a device that is set up to control traffic flow at intersections" means that if I, as the driver, don't see any traffic, I am well within my rights to disregard the red light.
 
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