Procedure turn required?

[tgrayson]

Sorry, but my computer won't read a pdf file. can you copy and paste that LOI?

You really should install acrobat. You can get it here:

http://get.adobe.com/reader/

Then you should read the TERPS article I posted, because I can't make it text. Here's the LOI:


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.

Section 91.175(a) provides that unless otherwise authorized by the Administrator, when an instrument letdown to a civil airport is necessary, each person operating an aircraft, except a military aircraft of the United States, shall use a standard instrument approach procedure prescribed for the airport in Part 97.

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.

You also ask whether a Distance Measuring Equipment (DME) arc initial approach segment can be substituted for a published IAF along any portion of the published arc. A DME arc cannot be substituted for a published IAF along a portion of the published arc. If a feeder route to an IAF is part of the published approach procedure, it is considered a mandatory part of the approach.

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



 

[ppragman]

Where would this aircraft be coming from? There is no published route in that direction. TERPS has no criteria for random arrivals from any direction, other than a TAA.

I dunno, maybe

"Depart Corvallis VOR on the XXX degree radial, intercept the Newberg 166 degree radial, cleared to Newberg VOR"

Or maybe they clear you direct to newberg from some random point and you just so happen to be exactly on the 166 radial.


Then when established on the R-166, "cleared VOR/DME-C approach to the Hillsboro airport, contact Hillsboro tower, good day."

I don't know why they'd give you something like that, but they could I suppose.

 

[tgrayson]

Or maybe they clear you direct to newberg from some random point and you just so happen to be exactly on the 166 radial.

That merely restates my point that TERPS has no criteria for random routes. How could they possibly evaluate every single thing you could possibly do? Rather, they only evaluate the safety of the routes they publish.

 

[ppragman]

That merely restates my point that TERPS has no criteria for random routes. How could they possibly evaluate every single thing you could possibly do? Rather, they only evaluate the safety of the routes they publish.

Exactly, but you do see that it could be logical for you not to make a procedure turn and how a controller could be confused that you didn't go straight-in in certain circumstances, right? Frankly, if you're lined up for the straight-in its a little ridiculous to turn around, track out, then track in again. Even if you're lined up within 30 degrees or so it would be easier in many many circumstances to simply dive and drive. Not saying that that's what you should do, or how you should operate, but honestly, is it not just a little ridiculous to do a course reversal if you're already lined up?

 

[Roger, Roger]

Like I said....

With the increasing use of random RNAV routes and "proceed direct to the FAF" clearances, it would make good sense to start putting NoPT sectors onto traditional charts. Probably won't happen though.

 

[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.


Oh yeah, I remember that exchange now.
The problem with this "interpretation" is the way it is asked: "when one of the conditions of 91.175(j) is not present."
That leaves it wide open to coming in from anywhere. Legal speak requires her to repeat the regulation.

Her answer (or the question) has not focused on the meaning of the term "when it is necessary", as in a direct question that puts the pilot on the final approach course at altitude configured for landing and ready to begin final descent, and yet having to turn away from the airport and fly at least five more minutes (of exposure to weather) to return to then same spot (hopefully) to begin the final descent.

Think about the unnecessary liability.

 

[tgrayson]

Her answer (or the question) has not focused on the meaning of the term "when it is necessary"

It was not necessary. She stated the conditions where the PT was not required and "on course" wasn't one of them. Does nothing ever persuade you from a point of view that you hold?

Think about the unnecessary liability.

You've really got this wrong. The opinion was solicited by ALPA and resulted in TWO letters. The first letter said the exact opposite from what this one did and behind the scenes action got it "corrected". The second interpretation she offered is consistent with the way the FAA wants it to work.

 

[tgrayson]

honestly, is it not just a little ridiculous to do a course reversal if you're already lined up?

Of course it is.

The problem is that different pilots will have different ideas about how far out of alignment they can be before it becomes unsafe. Many people operate under the assumption that if they can't think of a reason for a rule, then there must not BE a reason. Without clear guidance, you would likely see many pilots zooming outside the protected area as they maneuvered towards final.

 

[drunkenbeagle]

My emphasis added.

I personally would not expect a pilot to do a 180 degree turn just to fly a course reversal if they were established on a course (not a vector) that allowed them to intercept the final approach course without having to make a rather drastic turn. For instance, if you filed or asked for direct to an initial/intermediate fix that allowed for an easy intercept of the localizer/final approach course, and all I stated was "maintain 2500 until FIX, cleared XXX approach", (in my personal, non-official opinion) I certainly wouldn't expect the pilot to fly a procedure turn in this instance. However, to comply with the .65 *I* personally would add the "cleared for the straight in" just to CYA.

I'm sure requiring that explicit clearance is probably a result of someone doing something stupid and killing themselves, then a lawyer suing the FAA because we didn't explicitly instruct the pilot that he didn't have to fly a procedure turn that was depicted when it made no sense to do so.

Entirely consistent with my experience, for what it is worth. But I am just an intoxicated canine on the Internet...

 

[Orange Anchor]

Here's a much better article by one of the leading experts in the country on instrument approaches and someone who is consulted when the AIM recommendations are written:
http://www.terps.com/ifrr/jul96.pdf

Wally eats and breathes this stuff. Nice guy. Ever met him?

 

[SIUav8er]

I did a procedure turn the other day in IMC at CYS on a VOR approach (no radar), and got chewed out by approach because I didnt let him know I was going to do it even though it was required and he never said to do anything otherwise.

yes... I hate when that happens! there seems to always be confusion on ATC's part about whether a PT is required or not. I have experienced this myself several times. What i do is ask if they want to fly straight in or do the turn. Maybe not technically correct according to the AIM, but never hurts to simply ask to make sure I am doing what ATC expects me to do.

 

[tgrayson]

Wally eats and breathes this stuff. Nice guy. Ever met him?

Nope, but we co-existed in the same Compuserve aviation forum for many years. He was the most formative influence in my instrument training. His series of IFR Refresher articles really lit up my understanding of instrument flight when I was an instrument student. Someone showed up here briefly 7 or 8 months ago that I was pretty sure was Wally.

I have many years of archives of his posts and most of them are solid gold. There is really no one writing who was more clued in about what was happening in the instrument flight world. I owe him a great deal.

 

[cloudman]

Yeah, but is the Crazy Ivan left or right on the bottom half of the hour?

Tactics Dr. Ryan, Tactics.........

 

[ppragman]

Tactics Dr. Ryan, Tactics.........

"Two pings, just two pings."

 

[Roger, Roger]

It's not marked that way, but going Crazy Ivan on the approach might cause some problems. :bandit:

"Always wanted to try one"

 

[tgrayson]

Hmmm....there is actually a recent change to the AIM Guidance:

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, unless cleared by ATC for a straight−in approach.


​

I sent a query to Wally Roberts on this change and he forwarded my note to someone working on the committee involved with making the change. I received an explanation this evening and I've requested permission to post it. If I get it, I will post the letter. But the substance is that this isn't a carte blanche authority for ATC to waive PTs. They can only do so when one of the conditions exists that makes a PT not required.

I think the language is a grave mistake, because I don't think most pilots will read it in that context.

 

[ghogue]

I think the language is a grave mistake, because I don't think most pilots will read it in that context.

I completely agree. I think it was just meant to reinforce to pilots what has been required all along. I've already seen in other forum's where some people think it is carte-blanche for the controller to clear them straight-in at their discretion. Just going to cause more confusion.

 

[MikeD]

But the substance is that this isn't a carte blanche authority for ATC to waive PTs. They can only do so when one of the conditions exists that makes a PT not required.

Which is exactly what I was proposing get changed from the current language, as it makes practical sense in some cases.

I think the language is a grave mistake, because I don't think most pilots will read it in that context.

Agree it shouldn't be a carte blanche.

 

[nocturnalaviator]

i'd either get a vector to join final course and gain clearance, eliminating the PT. Or if cleared to the VOR and cleared for the approach from the south, i'd clarify whether straight in clearance was assumed or course reversal. When in doubt ASK! Check this out!

Here's a couple of incidents of pilot/controller confusion
http://asrs.arc.nasa.gov/docs/cb/cb_363.pdf


Happy Landings

Yeah thanks for stealing MY POST WingThief!! :bandit:

 

[Barty]

But the substance is that this isn't a carte blanche authority for ATC to waive PTs. They can only do so when one of the conditions exists that makes a PT not required.

I think the language is a grave mistake, because I don't think most pilots will read it in that context.

That needs to be made clear in the 7110.65, as there is no such language indicating that we cannot waive a PT as we see fit, outside of clearing an aircraft to certain fixes on RNAV approaches. It is consistent with 91.175 in that it specifies we must give permission for a PT to be flown when one is not required, but is silent on how the language "cleared for the straight in XYZ approach" cannot be used, outside of the exception for an RNAV approach (ie., angle of intercept with the final approach course would be greater than 90 degrees).

If TERPS doesn't want us waiving PTs as we see fit, then they need to sit down with the ATO and put additional exceptions into the .65, because as it stands right now it doesn't say anything on the topic outside of RNAV approaches.