Course Reversal vs Hold

[dmspilot]

Someone said above that the hold here has a leg limit of 8nm. It’s not a limit, per se, right (?), ie you’re expected to fly an 8nm leg, not just stay within 8nm.

If I’m wrong about that and you you just have to stay within the limit, how do you get a GTN series navigator to initiate the “turnaround” prior to reaching 8 miles?

I had a related experience flying a course reversal that was listed with 5nm legs. I was at about 4.8nm out and the controller asked me when I was going to turn around and I was like... “umm.. where the chart says to do so at 5nm...?”

It is the maximum limit of the outbound straight portion. There is no need to finish the turn by then, only to start it.

 

[AA5Bman]

So... we’ve got some conflicting answers here, and no FAR to point to? Come on you can do better than that! Kidding, but I seriously thought you were supposed to fly the prescribed length. If not, how do they keep track of your position in the event of lost comms (for instance in a non-radar environment)?

 

[dmspilot]

So... we’ve got some conflicting answers here, and no FAR to point to? Come on you can do better than that! Kidding, but I seriously thought you were supposed to fly the prescribed length. If not, how do they keep track of your position in the event of lost comms (for instance in a non-radar environment)?

Your position is holding at XYZ at such-and-such an altitude until EFC time.

 

[MauleSkinner]

So... we’ve got some conflicting answers here, and no FAR to point to?

There is no reg that specifies how to fly a hold.

the Instrument Procedures Handbook says:

DME and IFR-certified GPS equipment offer some additional options for holding. Rather than being based on time, the leg lengths for DME/GPS holding patterns are based on distances in nautical miles. These patterns use the same entry and holding procedures as conventional holding patterns. The controller or the instrument approach procedure chart specifies the length of the outbound leg. The end of the outbound leg is determined by the DME or the along track distance (ATD) readout. The holding fix on conventional procedures, or controller-defined holding based on a conventional navigation aid with DME, is a specified course or radial and distances are from the DME station for both the inbound and outbound ends of the holding pattern. When flying published GPS overlay or standalone procedures with distance specified, the holding fix is a waypoint in the database and the end of the outbound leg is determined by the ATD. Instead of using the end of the outbound leg, some FMS are programmed to cue the inbound turn so that the inbound leg length matches the charted outbound leg length.

No indication that anything other than the specified length is acceptable when either time or distance is published.
the AIM says:

A holding pattern in lieu of procedure turn may be specified for course reversal in some procedures. In such cases, the holding pattern is established over an intermediate fix or a final approach fix. The holding pattern distance or time specified in the profile view must be observed. For a hold-in-lieu-of-PT, the holding pattern direction must be flown as depicted and the specified leg length/timing must not be exceeded.

Says it must not be exceeded, but also says it must be flown “as depicted”.
The only exception I can find published, also in the AIM:

1. When holding at a fix and instructions are received specifying the time of departure from the fix, the pilot should adjust the aircraft's flight path within the limits of the established holding pattern in order to leave the fix at the exact time specified. After departing the holding fix, normal speed is to be resumed with respect to other governing speed requirements, such as terminal area speed limits, specific ATC requests, etc. Where the fix is associated with an instrument approach and timed approaches are in effect, a procedure turn must not be executed unless the pilot advises ATC, since aircraft holding are expected to proceed inbound on final approach directly from the holding pattern when approach clearance is received.

 

[RussR]

So... we’ve got some conflicting answers here, and no FAR to point to? Come on you can do better than that! Kidding, but I seriously thought you were supposed to fly the prescribed length. If not, how do they keep track of your position in the event of lost comms (for instance in a non-radar environment)?

Simple answer is, they don't. If you're in a holding a pattern, you're "in the holding pattern". They don't care where in the holding pattern you are, because you're the only one in the holding pattern at that altitude, and the entire holding pattern airspace is "yours" while you're there. It's not like they are going to put two airplanes in the same holding pattern at the same altitude, just on opposing legs.

If they need you to exit the holding pattern, they will tell you. If they need you to exit at a certain time, they will tell you. The classic example of this is "timed approaches", which is in the AIM but certainly isn't used very much any more.

 

[AA5Bman]

They’re not going to tell you anything in a lost comms event! An 8 mile leg (x2) vs. two 1-minute legs are a lot different time-wise.

Is this clear as mud to everyone else too?

 

[aterpster]

They’re not going to tell you anything in a lost comms event! An 8 mile leg (x2) vs. two 1-minute legs are a lot different time-wise.

The HILPT has to be quite high to have 8 mile legs. Take ALS RNAV 20, for example. It's at 10,800 and has 7 miles legs. But, what if it were 1 minute legs. In my jet at 230 knots, (more like 245 true) I'll go out a lot further on a 1 minute leg than you will in a Cessna 182.

 

[midlifeflyer]

They’re not going to tell you anything in a lost comms event! An 8 mile leg (x2) vs. two 1-minute legs are a lot different time-wise.

Is this clear as mud to everyone else too?

Well, two things are pretty clear to me in this discussion:

1. Not everyone flies holds at Cessna 172 speeds.
2. The distance is a maximum not an absolute.

 

[AA5Bman]

@midlifeflyer @aterpster Guys - you’re missing my point. My point is just that for whatever leg and whatever plane, in the event of lost comms they need to know how long of legs you are flying to know how long to protect the airspace. Which, logically, makes me think that if it says 8nm legs or one-minute legs or whatever, then that is what they are expecting you to fly.

 

[midlifeflyer]

@midlifeflyer @aterpster Guys - you’re missing my point. My point is just that for whatever leg and whatever plane, in the event of lost comms they need to know how long of legs you are flying to know how long to protect the airspace. Which, logically, makes me think that if it says 8nm legs or one-minute legs or whatever, then that is what they are expecting you to fly.

I definitely missed that point because that's not how it works. ATC is going to protect your entire route of flight, including the full approach and missed approach area, from the time they are aware of lost comm until they know you are on the ground. They are not going to look at a clock and figure "well, he should be there by now, so what the heck." If they are actually expecting anything, it's the hopeful expectation that you will get on the ground in the most expeditious and safest way you can.

 

[aterpster]

@midlifeflyer @aterpster Guys - you’re missing my point. My point is just that for whatever leg and whatever plane, in the event of lost comms they need to know how long of legs you are flying to know how long to protect the airspace. Which, logically, makes me think that if it says 8nm legs or one-minute legs or whatever, then that is what they are expecting you to fly.

Midlife beat me to it. Russ more or less said the same thing.

 

[midlifeflyer]

Midlife beat me to it. Russ more or less said the same thing.

Perhaps interesting though...at one time I was concerned that perhaps they used the size of the holding pattern for separation purposes in much the same way as @AA5Bman apparently thinks. IOW, not for other aircraft approaching, but it might allow another aircraft to pass through based on the predicted movement. Then a controller told me, "that's not the way it works."

 

[RussR]

The HILPT has to be quite high to have 8 mile legs.

Or be designed at 310 kts for Cat E at a joint-use airfield.

 

[AA5Bman]

Okay fair enough. For what it's worth, I just took an IFR refresher course (I know that's a little bit like saying I just stayed at a Holiday Inn last night, but still) and there's a lot of talk in the lost comms section about EFC times and when to leave the holding fix and what-not so you would get the impression that they are keeping track of those times, but maybe they'll just protect the airspace until they hear from you on the ground or are discovered by SAR.

Other than that FAA opinion piece posted above which seems relatively clear but is totally news to me, I am still wondering why this is not specifically addressed by a FAR.

 

[midlifeflyer]

Okay fair enough. For what it's worth, I just took an IFR refresher course (I know that's a little bit like saying I just stayed at a Holiday Inn last night, but still) and there's a lot of talk in the lost comms section about EFC times and when to leave the holding fix and what-not so you would get the impression that they are keeping track of those times, but maybe they'll just protect the airspace until they hear from you on the ground or are discovered by SAR.

Other than that FAA opinion piece posted above which seems relatively clear but is totally news to me, I am still wondering why this is not specifically addressed by a FAR.

Because not everything about how to operate in the system is addressed in a FAR. If it were, the FAR would be the size of the FAR, AIM, IPH, a number of ACs, the ATC handbook (Order 7110.65) and a number of other FAA publications combined.

Lost comm is probably one of the more interesting subjects. The bare rules and how to apply them need to be understood. But at the same time, operating in the system also requires an understanding of how the system actually works, which is not fund in any book of regulations. Consider, these are rules originally written for overheating vacuum tube radios in a nonradar environment. I think they still have a lot of value if we are talking about an ATC-side com failure, but with the newer equipment we fly these days, pilot-side lost comm is a rarity unless it is also an emergency. What is the real likelihood of both of your coms failing, but the integrated nav receivers remaining intact? I've had one true lost comm in 30 years (VFR) and I was convinced the next thing would be the smell of burning insulation. Then, of course, is widespread radar (and now ADS-B) where they know where you are and can see what you are doing.

My all-time favorite lost comm line is the very first paragraph of the AIM discussion of failure in 6-2-1. I think it applies to so much more than lost comm:

6-4-1. Two-way Radio Communications Failure

a. It is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio communications failure. During two-way radio communications failure, when confronted by a situation not covered in the regulation, pilots are expected to exercise good judgment in whatever action they elect to take. Should the situation so dictate they should not be reluctant to use the emergency action contained in 14 CFR Section 91.3(b).​

 

[aterpster]

Or be designed at 310 kts for Cat E at a joint-use airfield.

Yes, I noticed that at a joint use airport in one of the Dakotas. Is that in the 8260.19 somewhere?

 

[RussR]

Yes, I noticed that at a joint use airport in one of the Dakotas. Is that in the 8260.19 somewhere?

It's in the 8260.3D, paragraph 17-2-3a. The wording in that paragraph and the note changed subtly since the holding criteria was moved from the (now canceled) 7130.3, but the end result is still 310 kt patterns at joint-use airports with Cat E.

 

[aterpster]

It's in the 8260.3D, paragraph 17-2-3a. The wording in that paragraph and the note changed subtly since the holding criteria was moved from the (now canceled) 7130.3, but the end result is still 310 kt patterns at joint-use airports with Cat E.

I was at a meeting at AFS-420 when ATO washed their hands of the 7130.3.