CTL and the PTS

aterpster

aterpster

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An associate pointed out to me that the instrument rating PTS for circle to land has failed to address the new, larger circle to land areas (the "C" icon).

He is correct. The PTS states the pilot being tested must remain within the distance dictated by the applicable visibility minimum.

That doesn't work.
 
Aren't most (all) circle to land approaches at least 1 mile of visibility? Who can't stay within a mile of the airport on a circle to land? Or am I missing something?
 
EdFred said:
Aren't most (all) circle to land approaches at least 1 mile of visibility? Who can't stay within a mile of the airport on a circle to land? Or am I missing something?
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Large aircraft with high minimum airspeed can't stay inside 1 mile without pulling substantial G's. The inverse C allows them more breathing space, without needing G suits and without increasing the min vis penalty. But it seems to do so at the cost of losing visual sight of the runway during the circling, which is ATerpster's point, as I understand it.
 
RotorDude said:
Large aircraft with high minimum airspeed can't stay inside 1 mile without pulling substantial G's. The inverse C allows them more breathing space, without needing G suits and without increasing the min vis penalty. But it seems to do so at the cost of losing visual sight of the runway during the circling, which is ATerpster's point, as I understand it.
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The few approaches I pulled up local to me all had 2 mile visibility for C and D CTL. Also, if it's a PTS thing, how many people are taking their IR ride in a C or D aircraft?

Edit: 1.5 for Cat C, 2 for Cat D.
 
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EdFred said:
The few approaches I pulled up local to me all had 2 mile visibility for C and D CTL. Also, if it's a PTS thing, how many people are taking their IR ride in a C or D aircraft?

Edit: 1.5 for Cat C, 2 for Cat D.
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Look for approaches with the inverse C icon in the CTL minima (those are the ones affected).
And the PTS doesn't declare itself to apply to class A only, so any question about C or D is fair game for the DPE during the oral.
Edit: here is an example.
According to the inverse C rules, cat D will have 3.7nm radius, and in this approach they only need 2.5sm min vis.
http://www.nbaa.org/ops/airspace/is...rotected-airspace-for-circling-approaches.php
 
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Practical Test Standards. Checkride stuff.
 
I was working with CFII a few months back. Retired airline pilot. We were talking about circling approaches. He showed me his Airman Certificate, ATP. On the back where ratings and limitations are was something about DC9's and Circling To Land. I don't remember if it was that he could or he couldn't. Probably could. It kind of blew me away that it was considered that serious an operation that it would be put on the Certificate.
Reading this thread it looks like once again a new rule, regulation or procedure was established without proper research into how it affected other existing rules and regulations so now there is a conflict. I got back into flying after many years off and started in on learning GPS in preparation for an IPC a few months ago. There seems to be a lot of these conflicts nowadays. A lot seem to be a result of rapidly changing technology. Some seem to be like everything is done by committee and each member gets their turn to do something their way, or each member has an area of specialty and no one is in charge of making sure all the pieces fit together. At the rate we're going someday it's going to be "you're damned if you do and you're damned if you don't" every time you fly.
 
luvflyin said:
I was working with CFII a few months back. Retired airline pilot. We were talking about circling approaches. He showed me his Airman Certificate, ATP. On the back where ratings and limitations are was something about DC9's and Circling To Land. I don't remember if it was that he could or he couldn't. Probably could. It kind of blew me away that it was considered that serious an operation that it would be put on the Certificate.
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Yes, that was because his airline elected to not train to circle to land, so he was not tested for it on his rating ride.

But, it has nothing to do with him flying a G/A airplane or even a biz jet under Part 91 only.
 
4. Does not exceed the visibility criteria or descend below the
appropriate circling altitude until in a position from which a
descent to a normal landing can be made.
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The way I read that is that the pilot must adhere to FAR 91.175. So as long as on the checkride he doesn't descent out of the circling MDA unless he has the visibility that is listed on the approach plate he is good.

luvflyin said:
I was working with CFII a few months back. Retired airline pilot. We were talking about circling approaches. He showed me his Airman Certificate, ATP. On the back where ratings and limitations are was something about DC9's and Circling To Land. I don't remember if it was that he could or he couldn't. Probably could. It kind of blew me away that it was considered that serious an operation that it would be put on the Certificate.
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It probably said "ATP Circling Approach - VMC Only" or "DC-9 Circling Approach VMC Only"

That is because the visuals for the sim were not good enough to adequately depict a circling maneuver when he got his type rating or for his ATP certificate if it was done in the sim. To get the "ATP" circle restriction removed he would have to go up in an airplane and demonstrate a circle or if it was limited only to the DC-9 he would have to go up in the DC-9 and demonstrate a circle.
 
RotorDude said:
Look for approaches with the inverse C icon in the CTL minima (those are the ones affected).
And the PTS doesn't declare itself to apply to class A only, so any question about C or D is fair game for the DPE during the oral.
Edit: here is an example.
According to the inverse C rules, cat D will have 3.7nm radius, and in this approach they only need 2.5sm min vis.
http://www.nbaa.org/ops/airspace/is...rotected-airspace-for-circling-approaches.php
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I should know the answer to this but am not completely sure. Is a missed approach mandatory if sight of the airport is lost? Or does landmarks sufficient to navigate to the airport make it ok to continue?
 
luvflyin said:
I should know the answer to this but am not completely sure. Is a missed approach mandatory if sight of the airport is lost? Or does landmarks sufficient to navigate to the airport make it ok to continue?
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91.175 (e) Missed approach procedures. Each pilot operating an aircraft, except a military aircraft of the United States, shall immediately execute an appropriate missed approach procedure when either of the following conditions exist:
...

(2) Whenever an identifiable part of the airport is not distinctly visible to the pilot during a circling maneuver at or above MDA, unless the inability to see an identifiable part of the airport results only from a normal bank of the aircraft during the circling approach.
 
Here is a snippet of the minimums section on the Jepp chart for French Valley, CA (F70). I have also included the CTL containment areas from the FAA source document. In parenthesis I show those values in statute miles.

So, there was already a conflict with 91.175(e)(2) under "old" TERPs, more so under new TERPs CTL maneuvering area limits, at least when visibility is at minimums:

Jepp%20F70%20CTL_zpstc6bgm6i.jpg
 
aterpster said:
Here is a snippet of the minimums section on the Jepp chart for French Valley, CA (F70). I have also included the CTL containment areas from the FAA source document. In parenthesis I show those values in statute miles.

So, there was already a conflict with 91.175(e)(2) under "old" TERPs, more so under new TERPs CTL maneuvering area limits, at least when visibility is at minimums:
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It seems obvious that the FAA does not expect the pilot to keep the runway threshold in sight while circling. The NBAA document clearly shows the radii measured from the respective runway threshold, so I don't see how you can keep the threshold in sight while circling within the inverse C tolerances. You might see other parts of the airport, but not the runway you are supposed to be maneuvering towards.

Edit: looking at the Instrument Rating PTS, and specifically at the "D. TASK: CIRCLING APPROACH" section, I don't see where it conflicts with FAR 91.175(e)(2) which says missed approach should be executed if "an identifiable part of the airport is not distinctly visible to the pilot during a circling maneuver at or above MDA, unless the inability to see an identifiable part of the airport results only from a normal bank of the aircraft during the circling approach." The PTS simply says "Does not exceed the visibility criteria" (during the circling approach) without specifying to what point, so there is no conflict there that I can see.
I do think that with the new inverse C tolerances you may lose contact with the runway threshold while maneuvering (even wings level), but presumably by identifying some landmark on airport property you may continue.
 
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A lot of MDA's probably went up when the new circling areas to be protected got bigger as terrain/obstructions where found just outside the old area to be protected. An increase in the visibility requirement wouldn't be necessary to keep the rocks and towers below the MDA.

The area to be protected is based on assumed radius of turns based on assumed air speeds and how those air speeds translate into ground speeds to calculate the radius of turns and the amount of space required. Altitude and sometimes temperatures are considered. I don't remember what those air speeds are, 1.3 of Vs or Vso or something similar.

While not increasing visibility requirements kinda doesn't make sense if you assume that we are all going to be flying out at the edge of the airspace to be protected, not increasing it doesn't necessarily conflict. The MDA is what protects us from the rocks.

91.175 (e) (2) says you have to Miss if you lose the Airport when at or above the MDA.

91.175 (c) says you can't go below the MDA without the Runway Environment.

91.175 (e) (1) says you have to Miss if you lose the Runway Environment.

I don't see a need to raise the Visibilty Requirement to match the Airspace to be protected. Many aircraft can be safely flown at speeds less than the speed used to calculate the MDA.
 
RotorDude said:
It seems obvious that the FAA does not expect the pilot to keep the runway threshold in sight while circling. The NBAA document clearly shows the radii measured from the respective runway threshold, so I don't see how you can keep the threshold in sight while circling within the inverse C tolerances. You might see other parts of the airport, but not the runway you are supposed to be maneuvering towards.

Edit: looking at the Instrument Rating PTS, and specifically at the "D. TASK: CIRCLING APPROACH" section, I don't see where it conflicts with FAR 91.175(e)(2) which says missed approach should be executed if "an identifiable part of the airport is not distinctly visible to the pilot during a circling maneuver at or above MDA, unless the inability to see an identifiable part of the airport results only from a normal bank of the aircraft during the circling approach." The PTS simply says "Does not exceed the visibility criteria" (during the circling approach) without specifying to what point, so there is no conflict there that I can see.
I do think that with the new inverse C tolerances you may lose contact with the runway threshold while maneuvering (even wings level), but presumably by identifying some landmark on airport property you may continue.
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The threshold does not have to be in sight until you leave the CTL MDA. An identifiable part of the runway does during the CTL maneuver. I'm not advocating an increase in the visibility minimum. I am pointing out a disconnect between the new CTL criteria and the requirement to keep an identifiable part of the runway in sight. Higher performance business jets need the newer airspace.
 
aterpster said:
The threshold does not have to be in sight until you leave the CTL MDA. An identifiable part of the runway does during the CTL maneuver. I'm not advocating an increase in the visibility minimum. I am pointing out a disconnect between the new CTL criteria and the requirement to keep an identifiable part of the runway in sight. Higher performance business jets need the newer airspace.
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But according to 91.175(e)(2) all you need to have is "an identifiable part of the airport" in sight, which is not quite the same as "runway". So I really don't see any clear discrepancy at the moment, when comparing that to the very broad PTS language that I quoted above.
 
Gucci Pilot said:
It probably said "ATP Circling Approach - VMC Only" or "DC-9 Circling Approach VMC Only"

That is because the visuals for the sim were not good enough to adequately depict a circling maneuver when he got his type rating or for his ATP certificate if it was done in the sim. To get the "ATP" circle restriction removed he would have to go up in an airplane and demonstrate a circle or if it was limited only to the DC-9 he would have to go up in the DC-9 and demonstrate a circle.
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Actually it's because the airline doesn't have it in their OpSpecs and does not have it in their training program.

The OpSpec in question is C-075 CAT I IFR LANDING MINIMUMS—CIRCLING APPROACHES
 
Do some of the Airlines have company Visibilty minimums higher than the plate minimums for some approaches? If so, do those minimums change if your hauling boxes instead of passengers? Ferry flights? If I'm getting what PTS is about correct, I don't see that the difference between the plate visibility minimum and the larger airspace to be protected radius would cause a problem. Unless of course the examiner picked an Approach to fly during the checkride where it would be impossible to stay within that distance safely.
 
luvflyin said:
Do some of the Airlines have company Visibilty minimums higher than the plate minimums for some approaches? If so, do those minimums change if your hauling boxes instead of passengers? Ferry flights? If I'm getting what PTS is about correct, I don't see that the difference between the plate visibility minimum and the larger airspace to be protected radius would cause a problem. Unless of course the examiner picked an Approach to fly during the checkride where it would be impossible to stay within that distance safely.
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Using F70 (posted above) as an example, in a CAT C airplane (most biz jets), according to the PTS during a check ride I must remain within 2 statute miles, not within 3.36 statute miles ("C" Icon distance).
 
aterpster said:
Using F70 (posted above) as an example, in a CAT C airplane (most biz jets), according to the PTS during a check ride I must remain within 2 statute miles, not within 3.36 statute miles ("C" Icon distance).
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As I noted above, you'll have to remain within 2 statute miles min vis of the nearest distinct airport feature, not the runway. The 3.36 sm OTOH is from the runway thresholds. So there is no obvious conflict between the requirements, as long as you can identify some part of the airport while circling.
 
Ok. Got it. Has it come up before that a checkride was failed because it was being done in an airplane that just couldn't be safely flown within the visibility requirement? In other words, the airspace to be protected is TERP'd out there at 3 miles. The visibility requirement on the plate is 2 miles. The airplane being used for the checkride has performance characteristics that make it unable to safely circle within 2 miles of the airport?
 
luvflyin said:
Ok. Got it. Has it come up before that a checkride was failed because it was being done in an airplane that just couldn't be safely flown within the visibility requirement? In other words, the airspace to be protected is TERP'd out there at 3 miles. The visibility requirement on the plate is 2 miles. The airplane being used for the checkride has performance characteristics that make it unable to safely circle within 2 miles of the airport?
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The way I see it, the min vis requirements tell you that you'll have a chance of seeing part of the airport while circling at MDA. The new inverse-C CTL distance table tells you that if you stay within those radii from the thresholds, you'll have terrain/obstacle protection. So you need to stay within the prescribed distances while circling at MDA, and if at any point (wings level) you can't stay in contact with any distinct airport feature, you go missed. This should work for PTS/oral, checkrides, and real life.
 
luvflyin said:
Ok. Got it. Has it come up before that a checkride was failed because it was being done in an airplane that just couldn't be safely flown within the visibility requirement? In other words, the airspace to be protected is TERP'd out there at 3 miles. The visibility requirement on the plate is 2 miles. The airplane being used for the checkride has performance characteristics that make it unable to safely circle within 2 miles of the airport?
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You would have to ask Capt Ron that question. My airline didn't do CTL and I never had to do it on an light airplane ICC (or whatever it is called these days).
 
RotorDude said:
As I noted above, you'll have to remain within 2 statute miles min vis of the nearest distinct airport feature, not the runway. The 3.36 sm OTOH is from the runway thresholds. So there is no obvious conflict between the requirements, as long as you can identify some part of the airport while circling.
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The 2.92 n.m (3.36 s.m.) is a circle drawn from each threshold and the tangents of the circles are joined, as shown in the AIM. The new circling criteria were developed because CAT C birds couldn't remain within the old 1.7 n.m., nor CAT D within the old 2.3 n.m.

Attached is the FAA's TERPs map for CTL at F70.
 

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aterpster said:
An associate pointed out to me that the instrument rating PTS for circle to land has failed to address the new, larger circle to land areas (the "C" icon).

He is correct. The PTS states the pilot being tested must remain within the distance dictated by the applicable visibility minimum.

That doesn't work.
Click to expand...

Doesn't 91.175 require a missed approach if you lose sight of the airport? Seems like that's where you'd be if you exceed the distance of the visibility minimum.

It's apparently important not to increase the visibility minimum...maybe we need another circling limitation that we can put on the pilot certificate?
 
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aterpster said:
The 2.92 n.m (3.36 s.m.) is a circle drawn from each threshold and the tangents of the circles are joined, as shown in the AIM. The new circling criteria were developed because CAT C birds couldn't remain within the old 1.7 n.m., nor CAT D within the old 2.3 n.m.

Attached is the FAA's TERPs map for CTL at F70.
Click to expand...

Yes, I get that part. Presumably the difference between the vis mins and the protected radii/tangents distances is designed to allow the pilot to see "airport" vs. "runway" while circling at MDA. It is not clear in my mind what "airport" means in this context, and to be honest I consider this type of approach, esp. in marginal conditions at night, risky at best. Add a fast/heavy type to the mix with a huge turning radius, and I can see why some companies would downright prohibit it.
 
RotorDude said:
The way I see it, the min vis requirements tell you that you'll have a chance of seeing part of the airport while circling at MDA. The new inverse-C CTL distance table tells you that if you stay within those radii from the thresholds, you'll have terrain/obstacle protection. So you need to stay within the prescribed distances while circling at MDA, and if at any point (wings level) you can't stay in contact with any distinct airport feature, you go missed. This should work for PTS/oral, checkrides, and real life.
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That's pretty much the way I see it to. I'd hate to see that the difference between airspace to be protected and the Visibility requirement on the plate lead to increasing the Visibility minimum. Some category C's are probably one knot short of being a D and some are probably one knot over being a B. No need to penalize those that can fly the approach safely with a lower Visibilty minimum to accommodate those that need a little more. That can be dealt with with Personal and Company minimums.
 
luvflyin said:
That's pretty much the way I see it to. I'd hate to see that the difference between airspace to be protected and the Visibility requirement on the plate lead to increasing the Visibility minimum. Some category C's are probably one knot short of being a D and some are probably one knot over being a B. No need to penalize those that can fly the approach safely with a lower Visibilty minimum to accommodate those that need a little more. That can be dealt with with Personal and Company minimums.
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I don't have an issue with the present visibility minimum. My issue is with the PTS. Presumably, I am getting a proficiency check on a nice clear day. Using F70 as the example, I should not have to remain within 2 statute miles. Say I am in a biz jet at the mid to upper limit of Category C. I should have to demonstrate that I understand the protected airspace with the inverse C and that I show I can remain within that distance (there is table in the FAA legend and the AIM; attached).

In actual operations, when the visibility is reported as 2 miles, I may or may not be able to keep an identifiable part of the airport in sight circling at close to 2.8 n.m. If I cannot I go missed approach.
 

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aterpster said:
I don't have an issue with the present visibility minimum. My issue is with the PTS. Presumably, I am getting a proficiency check on a nice clear day. Using F70 as the example, I should not have to remain within 2 statute miles. Say I am in a biz jet at the mid to upper limit of Category C. I should have to demonstrate that I understand the protected airspace with the inverse C and that I show I can remain within that distance (there is table in the FAA legend and the AIM; attached).

In actual operations, when the visibility is reported as 2 miles, I may or may not be able to keep an identifiable part of the airport in sight circling at close to 2.8 n.m. If I cannot I go missed approach.
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Again, I don't see any kind of conflict between the PTS and the current regs or the new inverse C. All the PTS requires (in VI. AREA OF OPERATION: INSTRUMENT APPROACH PROCEDURES, task D) is that, rather broadly, the applicant not "exceed the visibility criteria". This does not mean the applicant must stay within 2 miles of the runway (in your example), but since the "criteria" (91.175(e)(2)) include keeping a distinct part of the airport in sight while circling at MDA, the applicant should explain (while flying in VMC per your IPC example) that missed approach must be initiated unless the specified criteria can be maintained.
Where is the conflict or issue?
 
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RotorDude said:
Again, I don't see any kind of conflict between the PTS and the current regs or the new inverse C. All the PTS requires (in VI. AREA OF OPERATION: INSTRUMENT APPROACH PROCEDURES, task D) is that, rather broadly, the applicant not "exceed the visibility criteria". This does not mean the applicant must stay within 2 miles of the runway (in your example), but since the "criteria" (91.175(e)(2)) include keeping a distinct part of the airport in sight while circling at MDA, the applicant should explain (while flying in VMC per your IPC example) that missed approach must be initiated unless the specified criteria can be maintained.
Where is the conflict or issue?
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In the F70 Category C example "Not exceeding the visibility criteria" is not subject to interpretation. Anything other than not exceeding 2 statute miles is interpreting rather than applying that provision of the PTS.

The pertinent language:

4. Does not exceed the visibility criteria or descend below the appropriate circling altitude until in a position from which a descent to a normal landing can be made.
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At F70 in a Category C airline "2 statute miles" must necessarily substitute for "the visibility criteria."

Granted, that would not apply in actual flight operations, only a check ride being conducted using the instrument rating PTS. (or Task E for the ATP -Airplane).
 
aterpster said:
In the F70 Category C example "Not exceeding the visibility criteria" is not subject to interpretation. Anything other than not exceeding 2 statute miles is interpreting rather than applying that provision of the PTS.

The pertinent language:

At F70 in a Category C airline "2 statute miles" must necessarily substitute for "the visibility criteria."

Granted, that would not apply in actual flight operations, only a check ride being conducted using the instrument rating PTS. (or Task E for the ATP -Airplane).
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I am not saying that "not exceeding the visibility criteria" is a substitute for not exceeding 2sm (in your example). I think the latter is part of the former, since when you specify a distance "2sm" the question is "from where to where". Well, one endpoint is the pilot's eyes, and the other is the distinct airport feature which the pilot must identify and keep in sight (wings level) while at MDA, or else the missed approach must be initiated.
So again, no conflict between the (broadly worded) PTS requirement and the inverse C or other regs.
 
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Looks like no one is pressing to have the Visibility minimum increased on the Aprroach plates. Whew.
 
The issue seems to be one of "I wouldn't do a CTL in this airplane with only two miles vis, therefore I shouldn't have to demonstrate it." The airlines and the FAA have historically handled that with a "VMC Only" circling limitation on the pilot's certificate, but apparently changing the protected airspace definition with circling radii not readily available in the cockpit should change that.
 
luvflyin said:
Looks like no one is pressing to have the Visibility minimum increased on the Aprroach plates. Whew.
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Correct. The issue is the PTS requirement, not the charted visibility value.

In the example the automated reported visibility may be 2 miles but when I am circling to land on Runway 36, I may easily be able to keep the airport in sight at 3 miles, or so.
 
I guess it is kind of a gray area when giving flight checks. Seem to me the solution is to not pick Approaches where failure is just about assured. Or pick that Approach and wait for the right answer which is "I won't do that Approach in this airplane with that visibility. It exceeds my personal/company minimums." How often does someone take an ATP checkride in a thousands of dollars an hour airplane?
 
luvflyin said:
I guess it is kind of a gray area when giving flight checks. Seem to me the solution is to not pick Approaches where failure is just about assured. Or pick that Approach and wait for the right answer which is "I won't do that Approach in this airplane with that visibility. It exceeds my personal/company minimums." How often does someone take an ATP checkride in a thousands of dollars an hour airplane?
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I mentioned that option to Cap'n Ron several months ago. His response was you have no choice on an IPC.

As to an ATP ride, I agree, not too likely in the airplane in a CAT C jet. But, if you don't want the circling restriction on your type rating (and most biz jet pilots do not) you have to comply with the PTS either in the simulator or the airplane.
 
aterpster said:
I mentioned that option to Cap'n Ron several months ago. His response was you have no choice on an IPC.

As to an ATP ride, I agree, not too likely in the airplane in a CAT C jet. But, if you don't want the circling restriction on your type rating (and most biz jet pilots do not) you have to comply with the PTS either in the simulator or the airplane.
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Do you have to make sure they fly the airplane in a way that the passengers would be nice and comfy? Or will just safely be good enough. Maybe it's really not all that big a deal. The "airspace to be protected" has a margin for error built into it. Maybe the visibilty minimum on those plates is pretty close to the "anticipated radius of flight path."
 
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