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Velocity173
So are you a controller? I'd like to get an answer I can trust, if you check out the two links I gave, they conflict with what you said.
The last time I asked was about 2 months ago, I was actually on a flight review with an instructor, I had gotten FF, was going to climb, and had told them before I took off, that I was planning on climbing to 3,500. When I started climbing the cloud deck a few miles from the airport was at about 2,500 so I stopped at 2,000. I called up the controller and asked if I was cleared through the Delta ahead, he said "I thought you were going to 3,500?" I told him about the deck which went about 3 miles into the delta. He told me he'd take care of it, then told me I was cleared in and to maintain 2,000 or above.
Not anymore I’m not. But we’ve brought up this particular subject on POA a million times and all current and former controllers are in agreement. While talking to a radar facility and receiving FF, they are required to coordinate with any tower facilities for that aircraft.
As far as the FAA director of communications letter, personally I believe he / she is interpreting 91.129 incorrectly. They are also adding a practice that isn’t in the controller manual.
First, does 91.129 specifically state to contact tower for arrival / through flight? No, it states to contact the facility providing ATC services. The facility providing ATC services could be tower, but in this case, you’re receiving FF it’s radar and not tower. The only part of 91.129 that even states to specifically contact tower, is in departing flight. Obviously approach / center wouldn’t make sense to contact them on the ground, that’s why tower is mentioned. Another example is conducting a GCA. By being in contact with the RFC, you’re in contact with the facility providing ATC services. Contacting tower for a GCA wouldn’t make any sense.
The second part of the letter I disagree with, is letting the pilot know that they’ve coordinated with tower. Basically making up a policy and phraseology that doesn’t exist in the .65. There is no policy to let a pilot know that the controller has done their job. No final controller on a GCA is going to blurt out over the radio “I’ve coordinated your arrival with tower.” And if you’re a pilot doing a GCA, are you going to ask in the middle of an approach if they’ve done their job?
Now getting back to my first reply. You stated you must be talking with the tower or need to make sure you’re cleared. No, you don’t need to talk to tower and don’t need to make sure you’re cleared. But as I stated earlier, if you personally feel the need to do it, by all means do it. I can tell you if the coordination wasn’t done, QA will be going after ATC for an OD and not you for a 91.129 violation. It would be pretty stupid of ATC to blame you for them not adhering to their own regs.
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