When to do the procedure turn?
- Thread starter Chief Captain
- Start date
What's your definition of outside the enroute structure? Does it mean to be off a published airway?
It's happened to me many times before where I'm cleared direct to an IAF where a procedure turn is depicted and I'm already relatively aligned with the final approach course and at the appropriate altitude for the approach.
A controller won't clear you to a fix off airway below their minimum vectoring altitude.
This is where the reg doesn't make sense to follow: If you are already aligned with the final approach course and at the appropriate altitude, why would you turn AWAY from the final approach course to get yourself....established....on the final approach course? I'm not saying I disagree with the rules. I'm saying there are times when you're legally required to do one when it makes no sense to do it. If there's any confusion, it's up to the pilot to verify either the full procedure or straight in with their controller.
Take the approach juxtapilot posted for example. He nails my argument right on the head.
So, you're saying if you're approaching the IAF from the south and are aligned (let's say within 20 degrees) of the final approach course, you're going to turn more than 180 degrees to track a radial outbound, then turn 270 degrees to intercept (PT) the final approach course? that's 430 degrees of unnecessary turning if you don't request straight in. But hey, if you want to do that, then by all means, don't request straight in. Do all that turning. That's cool with me.
juxtapilot
Snowflake
Yes, so you fly direct Newburg, turn around, and do the PT... Just doesn't make sense. I've never done it since they always clear straight in.
MidlifeFlyer
Well-Known Member
Not sure what you mean by "two course reversals." I see a PT in the chart you show with a maximum PT altitude of 6,000'. The airways leading to Newburg have MEAs between 3600' and 6000' depending on the direction you're coming from. So, without a PT to lose altitude, depending on where you are coming from a straight in may require a drop of up to 5000' or so from the IAF/FAF to the runway (did I do the math correctly?),He's not saying he disagrees with the rules, but there are approaches that require a PT when already established on the inbound leg...
On this approach if you're coming from the south you would still need to do a PT... It doesn't make sense to have to do 2 course reversals (It's like doing a parallel entry to a hold that you're entering from the south [like the one depicted on that chart.]) However you're required to do them unless you meet the criteria that waives the PT.
MidlifeFlyer
Well-Known Member
No. I'm going to ask the controller if I'm cleared straight in. If I get a yes, I fly straight in. If I get a no, I make the turn or take the risk of a n enforcement action for disobeying and instruction, failing to do the PT as depicted, and/or causing a loss of separation.
Ok cool, so we agree that there are times when it's not practical to do one, but you're legally required to. That's all I was looking for, and that's all I was arguing.
In the GPS or timing clock thread, just do whatever "makes sense".
Why isn't the same standard being applied here to PTs that don't make sense?
(I know, I asked the same question in two threads).
MidlifeFlyer
Well-Known Member
Re: Defining the MAP during a nonprecision approach
Go ahead. Make your guess at GS, start the timer, recalculate GS as you descend and and the wind shifts counterclockwise and loses speed, and feel free to take something that really shows where you are with a grain of salt
.
Nothing in the timing/DME scenario changes anything that affects anyone. OTOH, skip the PT without a straight in clearance and you're potentially doing something that affects other users of the airspace and could cause a loss of separation.
Besides, most of the discussion surrounds whether using something that tells you where you are for real is in fact prohibited or not. The only good argument I've seen that it's prohibited is that some plates do show the DME distance.
I don't think so. Here we're talking situational awareness. You are still going to the same point in space.
Go ahead. Make your guess at GS, start the timer, recalculate GS as you descend and and the wind shifts counterclockwise and loses speed, and feel free to take something that really shows where you are with a grain of salt
.Nothing in the timing/DME scenario changes anything that affects anyone. OTOH, skip the PT without a straight in clearance and you're potentially doing something that affects other users of the airspace and could cause a loss of separation.
Besides, most of the discussion surrounds whether using something that tells you where you are for real is in fact prohibited or not. The only good argument I've seen that it's prohibited is that some plates do show the DME distance.
MidlifeFlyer
Well-Known Member
Same answer in 2 threads. Skipping the PT when it's required or doing the PT when it's prohibited affects other aircraft in the system. Flying to a given point in space doesn't, whether you use timing or DME to get there.
And, while we know that a depicted PT is required in the absence of an exception, we (or at least I) don't know that using DME to located the MAP is prohibited.
And, while we know that a depicted PT is required in the absence of an exception, we (or at least I) don't know that using DME to located the MAP is prohibited.
I don't think so. Here we're talking situational awareness. You are still going to the same point in space.
Go ahead. Make your guess at GS, start the timer, recalculate GS as you descend and and the wind shifts counterclockwise and loses speed, and feel free to take something that really shows where you are with a grain of salt
Nothing in the timing/DME scenario changes anything that affects anyone. OTOH, skip the PT without a straight in clearance and you're potentially doing something that affects other users of the airspace and could cause a loss of separation.
Besides, most of the discussion surrounds whether using something that tells you where you are for real is in fact prohibited or not. The only good argument I've seen that it's prohibited is that some plates do show the DME distance.
I think its one of those that just hasn't been addressed one way or the other yet. Doesn't seem like a huge deal, used in conjunction with the timing.
Heck, use the timing and the GPS if its there. No reason not to. Though Im personally comfortable enough with timing only that its really a non-issue to me. But as I said, if GPS is there, it'd be dumb to ignore it.
And the PT deal, I forgot to qualify that iI was assuming you're the only one on the particular approach; just as you'd be the only one at the MAP at the time. If by yourself, and you don't do a needless PT, its a non-issue, IMO.
MidlifeFlyer
Well-Known Member
Go ahead. Assume you're the only one there. As I recall there's a verifiable story about a pilot who canceled IFR when the field was clearly in sight as a courtesy to ATC and got busted because there happened to be an FAA inspector on the ground who heard the cancellation. The pilot was still in controlled airspace when he cancelled and busted VFR minimums.
All we're trying to do is determine what the rule is.
Since ignorance isn't a defense anyway, it's nice to know what the rule is before one decides to violate it.
All we're trying to do is determine what the rule is.
Since ignorance isn't a defense anyway, it's nice to know what the rule is before one decides to violate it.
It'd be interesting to know the actual rule too; but my take on it is if you have GPS available, why not use it as a reference in addition to hacking the clock? It's there. Use it. If it fails for whatever reason, the clock is still available. More than likely at the MAP, the two will be matched up very close. Rule-wise, I don't see how using the GPS as a reference, if you've hacked the clock, is any sort of violation. Using it as a primary means to determine the MAP though, I too would love to know if it can be done legally. Common sense wise, it does make sense.
Maybe as you said in your first post, this isn't a can of worms we want to open?
nosehair
Well-Known Member
Sorry I can't open a pdf file so I could copy the part you (and everyone else) reference in this LOI, but my memory of this continuous on-going question/interpretive answer in the LOI just does the government two-step and simply quotes the part that says "if a PT is depicted, it must be flown as depicted." But the question (and the answer) does NOT address the meaning of the phrase "if a course reversal is necessary".
That is the issue. If a course reversal is necessary. Is there a specific LOI on that?
Corporate Pilot
Well-Known Member
I am not a big fan of doing a PT if you do not need to. If you are in a radar environment they will give you vectors and you are not required to do the PT. If you are not in a radar environment, which I flew in a lot in my career, they will not clear the next airplane for the approach until the first airplane has canceled IFR so there would be no loss of separation. I have been flying this way since the early 80’s and have never had a problem.
I do believe that if you were lined up for an approach outside of the FAF, under radar, that required a PT and you did it. ATC would ask what are you doing?
I do believe that if you were lined up for an approach outside of the FAF, under radar, that required a PT and you did it. ATC would ask what are you doing?
Id been released by ARTCC to CTAF in pretty lousy IMC to shoot the approach....one of those ones with a needless PT from where I was arriving from. Was already picking up ice fairly well, and saw no need as the only person on the approach to spend more time airborne and picking up more ice, in order to fly a PT I didn't need for course reversal purposes. If there was someone else airborne on the approach or other traffic hazard, a) they shouldn't have been there, b) ARTCC would've mentioned something or c) if ARTCC didn't know about them, then neither would I and it wouldn't matter anyway.
Of course, this is a very specific situation. If Im flying VMC practice approaches and everyone is flying a PT and its indeed a potential separation or flow issue of some kind (such as "maintain VFR, IFR separation not provided"), then I do as the Romans do.
MidlifeFlyer
Well-Known Member
Huh? You may be the only human being left on plant earth who has a computer and can't open a pdf file.
But the question (and the answer) does NOT address the meaning of the phrase "if a course reversal is necessary".
That is the issue. If a course reversal is necessary. Is there a specific LOI on that?[/QUOTE]No that's not the issue - it's only your issue. I know your view is that "a course reversal is necessary" is a statement of some rule about when =you= need to do the PT, when all it is is part of the definition of what a PT is and part of what the designers cosnider them =they= prescribe a PT.
But the LOI does in fact answer your question (although I know you don't accept that). The language you generally hang your hat on is "A procedure turn is the maneuver prescribed when it is necessary to reverse direction..." As though "prescribing" is something the pilot does. I' isn't. The FAA "prescribes" procedure turns when it creates the SIAP, not nosehair when he's been cleared for the approach.
I'm not sure what can be clearer than...
==============================
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.
==============================
I can't see where it says
==============================
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 or the pilot personally decides he doesn't feel like it.
==============================
Here's the whole opinion:
==============================
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
==============================
MidlifeFlyer
Well-Known Member
I think you are correct. ATC generally expects you to go straight in even though the rule says that you must execute the PT. I almost "failed" an IPC a number of years ago when the CFII, who was also a controller, argued that you're not supposed to do the PT (of course, he had no support for his view).
There are also those who believe that the controller can't clear you straight in except in specific circumstances (none of which have come up in this discussion). It's basic that ATC can't make something illegal legal via a clearance. And ATC may not even know or care about pilot restrictions.
I'm a middle grounder (or at least I think I am) on that piece. Personal theory is that the rule requires the PT but that it's really all about you and ATC being on the same page. So long as you're both on the same page, even if it's technically improper, there's no one who's going to report it, so it may not make a difference.
The "same page" theory tells me to say, "Confirm N1234X is cleared straight in" which only takes a few seconds.
Agree. Especially on the "being on the same page" part between you and ATC.
nosehair
Well-Known Member
Yeah, yeah, I know. Long story too long to share here..
But I am glad you reprinted so it is visible for all to see.
This is the rule we are living by. The maneuver (the type of turn) prescribed (depicted, etc.) when it is necessary to reverse direction to establish the aircraft on an intermediate or final approach course.
This means that, if you do need to reverse direction, the type of turn to do that is prescribed by the depicted chart.
At the end of this statement, this phrase, "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." is confusing, and I think is the source of the confusion. Taken alone, it would seem to require a turn, no matter what. But taken in context of the leading phrase, "when a course reversal is necessary", it follows that the bolded statement applies to the action required "when the course reversal is necessary".
The italics are the subject of this debate. This question is not in the letter.
The question is: When you are established on the final approach course, at a proper altitude to comply with descent gradients, is a course reversal necessary?
That specific point is not made here:
...aaand finally, as you can plainly see, the letter only quotes Section 97.3 "defines a PT bla bla bla..." because the question did not address the specific point of being on course on altitude at the FAF. It asked "if a course reversal is optional when one of the conditions of 91.175(j) are not present". BIG BIG difference. Do you see the difference?
MidlifeFlyer
Well-Known Member
It really is amazing how you manage to find very clear language confusing and reject entire phrases when it's contrary to your firmly held beliefs. Almost religious in your approach.
nosehair
Well-Known Member
OK, I don't see how that will help me see how this loi addresses the issue of "when a course reversal is necessary".
It seems that your interpretation of that phrase is "when it is necessary to depict a procedure turn on the chart, the pilot must fly it".
That seems to be the popular interpretation, in general and on this board, but you are right that I am religious about the way I interpret it, which is "when it is necessary to reverse course to become established on final."
Long, long ago, before radar, there were no "vectors to final". Everybody did a procedure turn. If you had to. If there was a "transition" from enroute to final that was labeled NoPT, then you couldn't make a PT, like it still is, but if you were within 30 to 35 degrees, you could, if you wanted to, turn final. If you were on (or close enough) altitude. The call was up to you. Like making an entry turn into a holding pattern. PT's were recommended if you were beyond 30 degrees, and if you made a PT, the turn had to be as depicted on the chart.
Then along came radar, and everybody started using radar vectors to final and the procedure turn became a "school exercise", like the holding pattern entry. The idea that you couldn't go straight-in except under the specific conditions of 91.175(j) was born.
Some approaches do not have a PT depicted. The chart will show a (or some) transitions that will establish you on final, so there is no PT depicted.
So, the language means "if you have to make a course reversal, then you must make the reversal in the manner shown on the chart."
It seems that your interpretation of that phrase is "when it is necessary to depict a procedure turn on the chart, the pilot must fly it".
That seems to be the popular interpretation, in general and on this board, but you are right that I am religious about the way I interpret it, which is "when it is necessary to reverse course to become established on final."
Long, long ago, before radar, there were no "vectors to final". Everybody did a procedure turn. If you had to. If there was a "transition" from enroute to final that was labeled NoPT, then you couldn't make a PT, like it still is, but if you were within 30 to 35 degrees, you could, if you wanted to, turn final. If you were on (or close enough) altitude. The call was up to you. Like making an entry turn into a holding pattern. PT's were recommended if you were beyond 30 degrees, and if you made a PT, the turn had to be as depicted on the chart.
Then along came radar, and everybody started using radar vectors to final and the procedure turn became a "school exercise", like the holding pattern entry. The idea that you couldn't go straight-in except under the specific conditions of 91.175(j) was born.
Some approaches do not have a PT depicted. The chart will show a (or some) transitions that will establish you on final, so there is no PT depicted.
So, the language means "if you have to make a course reversal, then you must make the reversal in the manner shown on the chart."