When to do the procedure turn?

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.

Don't know if you two have a history, but I hope you don't talk to anyone like that when you're not behind a computer screen. Not cool.
 
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".
No it's -

"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."

IOW, the chart designers place a PT in the procedure, using TERPS and other criteria, when they determine a course reversal is necessarty. If they do that, it's required unless one of the exceptions in th reg applies.
 
Don't know if you two have a history, but I hope you don't talk to anyone like that when you're not behind a computer screen. Not cool.
We're old buddies and spar periodically over all sorts of things. Besides, I've never been one for political correctness. Shoulda heard me in my college race relations class.
 
:D

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OK, now we're gettin' down to it.
This first sentence, .."may or may not prescribe.." explains that some approaches do not have a PT. There isn't room enough for the necessary obstruction clearance, etc, so the approach is designed with methods of establishing on final with no PT.
"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."
Then, the second sentence goes on to say that when the approach shows a PT, and the pilot is cleared to do the SAIP~ here is the sticking point:
When you are cleared to do the SAIP~ on your own~ with no radar. My school of thought -as well as most controllers-and old school (before radar) pilots, is that you decide when you need a course reversal.

Just like holding airspace, if you know the approach airspace available to stay well within the approach corridor, as well as being configured for being on final, there is no definitive purpose or reason to make a course reversal.
IOW, the chart designers place a PT in the procedure, using TERPS and other criteria, when they determine a course reversal is necessarty. If they do that, it's required unless one of the exceptions in th reg applies.
There are approaches that show a required PT-such as a specific radial outbound arcing over (teardrop fashion) onto the inbound course, and others. But the more typical straight outbound/inbound course with the 45 barb showing direction of turn; that type of SIAP does not mean to me that I must make a course reversal when it is not necessary.

The language in the LOI does not do it, Mark. Just plain English. It won't stand up in court.
I don't think a single airman has ever been violated for not doing a PT. That violation standing alone. Not connected with any other actual safety violation.
 
Then, the second sentence goes on to say that when the approach shows a PT, and the pilot is cleared to do the SAIP~ here is the sticking point:
When you are cleared to do the SAIP~ on your own~ with no radar. My school of thought -as well as most controllers-and old school (before radar) pilots, is that you decide when you need a course reversal.
I agree with you completely about ATC expectations about this. And it would be nice if the AIM, which went through a number of revisions over the past 2-3 years in an attempt to clarify the point has never really done so. But ATC expectations doesn't define the rule as it applies to pilot operations.

The language in the LOI does not do it, Mark. Just plain English. It won't stand up in court.
On that I'd definitely disagree. If a pilot on his own managed to cause a loss of separation or caused injury to others because he didn't do a required PT, the FAA enforcement folks would have no trouble at all in satisfying the NTSB or the US appellate courts that the LOI view is the correct one. Plenty of case law on the topic of "the FARs say what the FAA says they say," so long as not arbitrary, capricious or contrary to existing law. I can't imagine a problem with the FAA meeting that standard on this LOI.

I don't think a single airman has ever been violated for not doing a PT. That violation standing alone. Not connected with any other actual safety violation.
We don't know that since most enforcement actions are resolved at conference and are not reported. But I'll assume you're correct. After all, Who's going to report it? ATC is expecting it. No incident occurred. Heck you can fly a non-FIKI airplane into heavy icing conditions, pick up a load and, so long as there is no incident, accident or special handling, the likelihood of enforcement is minimal.

But I though the discussion was about what the rule is, not whether it's ok to disregard it and get away with it.

The other comment that gives a lot of food for thought is about the course reversal in the case of a barbed PT. Since all the barb tells you is the side for the turn but not how to do it, a good case can be made that a 0 degree turn is as legal as a a 360.

But given the current reg language, AIM language and LOI, I'll still go with taking 3 seconds to query "Is N1234X cleared straight in?" to be sure ATC and I agree on what is going to happen.
 
If a pilot on his own managed to cause a loss of separation or caused injury to others because he didn't do a required PT, the FAA enforcement folks would have no trouble at all in satisfying the NTSB or the US appellate courts that the LOI view is the correct one. Plenty of case law on the topic of "the FARs say what the FAA says they say," so long as not arbitrary, capricious or contrary to existing law. I can't imagine a problem with the FAA meeting that standard on this LOI.

Very true.
 
But ATC expectations doesn't define the rule as it applies to pilot operations.
Right. I mean no implication that it does; only that there would be no reason to expect a traffic separation conflict. We are all aware that "cleared for the XX approach" in a non radar environment gives you the approach airspace until you report "field in sight-cancel IFR", or "missed approach". You can make as many PT's as you need, or none, whichever you decide. Keeping ATC advised is part of what you would do in case you do something a little unusual, or in case you are not sure. That is an integral part of executing an SAIP.
If a pilot on his own managed to cause a loss of separation or caused injury to others because he didn't do a required PT, the FAA enforcement folks would have no trouble at all in satisfying the NTSB or the US appellate courts that the LOI view is the correct one.
Yes, as I said, you would need to know what you are doing if you decide not to do a course reversal. I can't think of any way possible that a separation problem or a compromise of airspace, or unsafe flight condition that would initiate an enforcement action.
Not doing a course reversal when one is not needed for the flight is not an enforceable action. It may be in association with some other related careless and reckless action which would be the FAR violation.
The other comment that gives a lot of food for thought is about the course reversal in the case of a barbed PT. Since all the barb tells you is the side for the turn but not how to do it, a good case can be made that a 0 degree turn is as legal as a a 360.
Now I think you're gettin in to my court of thinkin ;)
But given the current reg language, AIM language and LOI, I'll still go with taking 3 seconds to query "Is N1234X cleared straight in?" to be sure ATC and I agree on what is going to happen.
Oh, me too. Just making the point that it is not an in-stone requirement. Many times a non-radar full approach may begin at an altitude position where radio contact is not possible.
...aaand as the case has been made already, getting ATC approval for an illegal action doesn't make it legal, so that doesn't change anything in our point of view on this subject. Confirming a straight-in is just the right thing to do for universal teamwork.
 
Oh, me too. Just making the point that it is not an in-stone requirement. Many times a non-radar full approach may begin at an altitude position where radio contact is not possible.
...aaand as the case has been made already, getting ATC approval for an illegal action doesn't make it legal, so that doesn't change anything in our point of view on this subject. Confirming a straight-in is just the right thing to do for universal teamwork.

Being that it is a NON-RADAR environment by definition, it would be kind of difficult to pull the tapes and bust you, no ? :)
 
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