I'm not sure where you're getting an implied requirement that you be able to geographically locate where you intercept the GS. I get being able to locate yourself while ON the GS but I don't understand the need to identify when I intercept the GS (geographically). The KTOL approach is a case in point. There are plenty of others, heck the OP's approach minus the Maltese Cross is an example. You could drop down to any altitude between ICOTE (2600) and TEBOC (2000) and intercept the GS. I could very easily be in white needles (RNAV mode) between ICOTE and TEBOC, switch to Green needles (Ground Nave mode) and grab the GS from below before TEBOC. Crossing TEBOC would be the FAF, Position and Altitude Check @ 2000 feet MSL.
KTVF ILS 31
KFAR ILS 36 here Dewey is just a marker, no real "accurate" geographic position.
KRAP ILS 32 This one is a great example. I can shoot this approach with no DME thus no way to ID YAVUK (7.2 DME I-RAP)
All three of those demonstrate my point better than yours, though. In all three cases, some kind of geographic range information is provided. Even in the third case, where you might be flying the approach without DME, according to the note ADF or DME is required... so then you would have to have an ADF, and you would then have range information to orient yourself as to how far along you are on the approach course based off of the RANCH navaid. If for some reason you didn't pick up the glideslope you would at least be able to figure that out by RANCH, 1 mile later. The KFAR ILS 36 includes a marker, which provides some kind of range information too (it let's you know that you are right over the marker, x miles from the runway). And the first approach has both a DME and an outer marker included in the approach, too. So all three of those approaches provide some kind of range information to the pilot near the glideslope intercept point. (Near is relative, here, but within a mile on all three).
But I think part of why we may be talking past each other is because you're talking primarily about what the pilots are required to do, and I'm talking about what the approach designers are required to do. Now, I'm not saying that a
pilot is required to positively identify a "FAF" on a precision approach... I'm saying that I BELIEVE (but can't find it explicitly stated in 8260.3b) that the
approach designer is required to provide pilots with enough information to maintain their SA regarding their range or geographic position at some points along the approach course. In particular, near the glideslope intercept point. I'm not aware of ANYTHING that says pilots have to do anything with that information. (Even the FAF altitude check that you mention isn't required by the FARs to my knowledge. Unless I'm mistaken, it's a common airline company policy and a common pilot technique... but I don't know of a section of the FAR that says you HAVE to check it. )
The AIM description of the ILS system is another piece of, call it circumstantial evidence, along this line of thinking. Pay particular attention to the wording of 3(b) and 4.
AIM paragraph 1-1-9 said:
1−1−9. Instrument Landing System (ILS)
a. General
1. The ILS is designed to provide an approach path for exact alignment and descent of an aircraft on final approach to a runway.
2. The ground equipment consists of two highly directional transmitting systems and, along the approach, three (or fewer) marker beacons. The directional transmitters are known as the localizer and glide slope transmitters.
3. The system may be divided functionally into three parts:
(a) Guidance information: localizer, glide slope;
(b) Range information: marker beacon, DME; and
(c) Visual information: approach lights, touchdown and centerline lights, runway lights.
4. Precision radar, or compass locators located at the Outer Marker (OM) or Middle Marker (MM), may be substituted for marker beacons. DME, when specified in the procedure, may be substituted for the OM. ...
AIM said:
2. Ordinarily, there are two marker beacons associated with an ILS, the OM and MM. Locations with a Category II ILS also have an Inner Marker (IM). When an aircraft passes over a marker, the pilot will receive the indications shown in
TBL 1-1-3.
(a) The OM normally indicates a position at which an aircraft at the appropriate altitude on the localizer course will intercept the ILS glide path.
It never comes right out and says, "the approach plate must depict enough information to allow pilots to determine their distance from the field at or near the glideslope intercept point," or "the approach plate must depict a point within a mile of the glideslope intercept point," or anything like that. But it does say that:
1. an ILS system is supposed to present some range information to the pilot (AIM 1-1-9, para. 3b above),
2. The OM is a required part of the system that can only be substituted by certain types of equipment that are suitable alternatives (1-1-9 para. a. 4 and the paragraph we've been discussing previously, FAR 91.175(k).
3. The OM normally indicates the position that an aircraft will intercept the GS when at the appropriate altitude (AIM 1-1-9, para f. 2(a) ) .
Go back to the OP's original ILS and imagine if the TEBOC fix simply weren't there. For sake of the argument presume that we still have ICOTE defined in some way. In fact for this argument, imagine it were defined by a crossing radial instead of a GPS point so that you didn't have some way to easily compute a distance off of it. So passing ICOTE you would drop down to 2000' and wait for the GS to center up... But suppose it never did, or somewhere in that 7 mile drive to the lightning bolt the GS went out of service. At ICOTE, 12 miles from the runway you might not think anything of the fact that the GS wasn't picking up, because GS serviceable range is only out to 10 NM anyways (although most of them can be picked out much farther). But how far would you go before you realized that you've gone way past where you should have picked up the glideslope, and how would you determine that? Timing from some an intermediate fix like ICOTE, especially where no timing block is established? It's conceivable that in an airplane with the minimum equipment required to fly the approach in that instance (1 VOR/ILS receiver and that's it, e.g.), you could easily fly right past the field looking without ever realizing that you've missed the approach. (Of course, you would get called by the controller first... unless you were radio out).
That pretty much sums up my whole argument. It makes SENSE that every ILS should include some kind of range to the field information (even if it's just the OM). The AIM and the FAR's seem to imply that they should all have that information, but I can't find a sentence in the actual TERPs manual that says that the approach designer MUST provide that information... yet it seems that every approach in the world contains that information. Or at least, every approach that I'm familiar with, AND all the ones in this thread. So from that I conclude:
1. There is probably some regulatory requirement to present that kind of information on the plate, and I just don't know the reference.
And
2. That's why TEBOC is depicted on the plate. Whether it should or shouldn't have a maltese cross is splitting hairs (IMO), but I think the point HAS to be on the plate, based on the reasoning above.
