Holding pattern in lieu of procedure turn

[roncachamp]

Where it says in 7110.65 that these "straight in" procedures are limited to advanced RNAV aircraft, and the only way to navigate to these fixes is with advanced RNAV equipment. Yes, we know that not all advanced RNAV equipment relies on GPS, but the restriction is the same for them, too.

But that's not the only way when the fix is within NAVAID limits.

 

[roncachamp]

Easy. When the approach designers determined a course reversal was necessary using approach design criteria.

But the issue is flying the HILPT/PT when course reversal is not necessary.

 

[Palmpilot]

But the Office of the Chief Counsel via the Karas letter has taken the position that "pilots flying in controlled airspace must comply with all ATC instructions, regardless of whether the pilot is flying VFR or IFR, in accordance with § 91.123(b)." It doesn't matter if the instruction is one that ATC is not authorized to issue, it doesn't matter if compliance with the instruction will require the pilot to violate another regulation, the only exception is an emergency.

The Karas letter didn't say "it doesn't matter if compliance with the instruction will require the pilot to violate another regulation." It wouldn't have made sense for them to say that, because they issued a relatively recent interpretation that pilots can't enter class B airspace without a clearance even if an ATC instruction would cause them to do so.

 

[roncachamp]

Apparently it confuses Steven. If anyone other than him has any further questions on this, I'll be happy to answer, but I will not be responding further to him.

I'll take it then that you were not able to find any problems caused by skipping an unnecessary course reversal in the ASRS article you referenced.

 

[nosehair]

When it's published as part of the approach, and you're not:

1. Getting vectors to final, or
2. Already holding at the fix at the depicted altitude, or
3. On an NoPT route, or
4. Cleared "straight in" by the controller

But the regulation says this: " stated in 97.3 that "Procedure turn means the maneuver prescribed when it is necessary to reverse direction to establish the aircraft on an intermediate or final approach course."

So, how do you rationalize that lacking any of these "conditions" requires a "course reversal"?

You are only stating what everyone (most everyone) has agreed the FAA has decreed.

But I have yet to see a specific legal document that says a "course reversal" is required when the airplane is "on course".

The FAA, and Chief Counsel opinions only sate what the regulation says.

It does not answer the question, "If the aircraft is on the final approach course and does not need a course reversal, is a course reversal required?"

I've seen this PT question debate all my life, and everyone just blindly says it is required if it is published.

Some say that the "Prescribed" is prescribed by the chart. That doesn't make sense, except that it is prescribed when it is necessary to make a course reversal.

Burning 5 to 10 minutes time doing an unnecessary "course reversal" is, in my humble opinion, actually detrimental to safety.

 

[poadeleted20]

As I said before, the requirement to perform the maneuver is the published procedure itself, which is regulatory in nature (Part 97). Once you are cleared for that approach, you must perform it as published or you are not complying with the regulatory procedure. There may be NoPT options in the procedure, and ATC has some authority to bypass course reversals and , but without that ATC authorization, you must fly it as published from where you join it or you're in violation of 91.123 because you're not doing what you were cleared to do (fly the approach as published, ATC authorizations to deviate notwithstanding).

 

[Palmpilot]

Easy. When the approach designers determined a course reversal was necessary using approach design criteria.

I agree. I think course reversals are "prescribed" by approach designers, not by controllers or pilots.

 

[poadeleted20]

I agree. I think course reversals are "prescribed" by approach designers, not by controllers or pilots.

Concur.

 

[Palmpilot]

The point is thinking it is unsafe is not the exception.

Au contraire. According to the Pilot/Controller Glossary, an emergency exists if the pilot is concerned about safety and requires timely assistance.

 

[Velocity173]

"The procedure turn or hold in lieu of procedure (PT) is a required maneuver when it is depicted on the approach chart." FAA-H-8261-1A

By not doing the PT you would not be complying with the IAP. Doesn't it strike anyone how odd it would be if aircraft could randomly excecute or not excecute the PT without telling ATC? There would be no positive control involved. Having the PT required (unless the big 4) makes the pilot's intentions predictable, that way you don't have the ASRS example of the controller chewing out the pilot.

 

[Palmpilot]

By the way, I'm thinking that the phrase "Unless otherwise authorized by the FAA" in 91.175(a) provides sufficient regulatory justification for controllers to issue straight-in clearances when a procedure turn would otherwise be required. Anyone have any thoughts on this?

 

[John Collins]

On both legs of my flight home from Pontiac Michigan yesterday I had controllers greet me with my first name. The first time that happened I thought maybe one of the controllers here was working at Detroit center and happened to recognize my N# but I was told that my name was on their flight strips. What's with that? I had filed via duats with Foreflight and according to the controller at Chicago center my name was in the remarks on the strip. I checked and it was NOT in the remarks section of the flight plan form on FF. Anyone else experienced this? It was kinda fun and spooky at the same time.

I talked to Jason at FF. We went flying today. He says that this happens when the user doesn't have their DUAT account setup, in which FF uses their corporate account. To make the FAA happy, they copy the pilot name to the comments field. They don't do this if the pilot has his account setup in FF.

 

[Palmpilot]

A solution!

 

[John Collins]

I'll take it then that you were not able to find any problems caused by skipping an unnecessary course reversal in the ASRS article you referenced.

Do you intend to follow the guidance that was effective June 3, 2013 in JO 7110.615, in particular these relevant directives:

c. Except for visual approaches, do not clear an aircraft direct to the FAF unless it is also an IAF, wherein the aircraft is expected to execute the depicted procedure turn or hold-in-lieu of procedure turn.

e. For both RNAV and conventional approaches, intercept angles greater than 90 degrees may be used when a procedure turn, a hold-in-lieu of procedure turn pattern, or arrival holding is depicted and the pilot will execute the procedure. If a procedure turn, hold-in-lieu of procedure turn, or arrival holding pattern is depicted and the angle of intercept is 90 degrees or less, the aircraft must be instructed to conduct a straight-in approach if ATC does not want the pilot to execute a procedure turn or hold-in-lieu of procedure turn.

 

[midlifeflyer]

But the regulation says this: " stated in 97.3 that "Procedure turn means the maneuver prescribed when it is necessary to reverse direction to establish the aircraft on an intermediate or final approach course."

So, how do you rationalize that lacking any of these "conditions" requires a "course reversal"?

You don't. You're making the error of treating a definition as a rule. A red traffic signal is generally defined as a mechanism to control traffic flow. That doesn't mean if there's no traffic you're free to disregard it.

Burning 5 to 10 minutes time doing an unnecessary "course reversal" is, in my humble opinion, actually detrimental to safety.

Three easy responses to that, based on one simple fact of IFR flight - you are operating in a system, not the wild, wild west. A system of rules like those specifically quoted by others.

1. You don't know whether or not ATC is handling other traffic based on ATC's expectation of what you are going to do when you get to that IAF. That's true whether ATC expects you to do the PT or not do the PT.

2. In a vacuum I agree with you. Doing a course reversal where straight in would work just fine is an unnecessary maneuver and unnecessary >180° degree turns can lead to potential errors that a shorter turn onto the FAC would not. So do you have a decision point with support for exactly how many degrees entitles a pilot to ignore the procedure turn without mentioning it to anyone? Or is your definition of "when necessary" no more than "when I personally feel like it"?

3. Which brings us to the third answer. The AIM tells us that one of the exceptions is being cleared "straight in." Solves the problems raised by your secret personal beliefs on what is proper, unnecessary maneuvering, the potential for conflicting traffic based on expectations, and the need to communicate your intentions.

 

[Jaybird180]

I agree. I think course reversals are "prescribed" by approach designers, not by controllers or pilots.

...anyone know why they add them? I do not know a reason why they can enhance safety, provided they are removed on all approaches (to eliminate the source of the confusion).

I talked to Jason at FF. We went flying today. He says that this happens when the user doesn't have their DUAT account setup, in which FF uses their corporate account. To make the FAA happy, they copy the pilot name to the comments field. They don't do this if the pilot has his account setup in FF.

Good to know, but it would have been nice for them to specifically state this somewhere.

 

[midlifeflyer]

...anyone know why they add them? I do not know a reason why they can enhance safety, provided they are removed on all approaches (to eliminate the source of the confusion).

Huh? Are you asking why there's a procedure turn showing the safe way for aircraft coming from the opposite direction to reverse course in a non-radar environment?

 

[Velocity173]

...anyone know why they add them? I do not know a reason why they can enhance safety, provided they are removed on all approaches (to eliminate the source of the confusion).


Good to know, but it would have been nice for them to specifically state this somewhere.

Just as the definition says. They're to reverse course so you can intercept the course inbound. Reduces some of the workload on the controller as well having not to vector aircraft to intercept on final all the time.

 

[azure]

I talked to Jason at FF. We went flying today. He says that this happens when the user doesn't have their DUAT account setup, in which FF uses their corporate account. To make the FAA happy, they copy the pilot name to the comments field. They don't do this if the pilot has his account setup in FF.

That's what I guessed, but didn't realize it was being done for that reason. But it confirms that the answer is simple: set up FF to use your DUATS account.

 

[azure]

The FAA is entitled to have all of the information you put on a flight plan, and ATC is an FAA function. (I'm not saying that ATC needs to have the information, however.)

I do think it could be regarded as a violation of privacy for ATC to use pilots' names over the radio. If Foreflight can't be persuaded to change their ways, perhaps controllers should be instructed not to do that.

Well, that was exactly my point, the FAA requires different pieces of information for different purposes. Some info is intended for ATC use. Other info (pilot name, alternate, etc) is not. And if they have that info, they are in a position to use it for purposes for which it is not intended, as happened to Lance.

Need to know, and all.

Fortunately, it's an easily avoided problem.

 

[nosehair]

In a radar environment , you're gonna be vectored to final. My debate is in the non-radar environment where you are simply cleared for approach and expected to do it on your own.
No other aircraft will be cleared into the approach airspace until you have completed your own approach. Whether or not you have to make a course reversal or how long it takes is not a factor in the controllers traffic flow.
I could make a tight 360 (in the direction prescribed by the PT ) to comply with what you think is required by regulation.
It is not.

 

[azure]

In a radar environment , you're gonna be vectored to final. My debate is in the non-radar environment where you are simply cleared for approach and expected to do it on your own.
No other aircraft will be cleared into the approach airspace until you have completed your own approach. Whether or not you have to make a course reversal or how long it takes is not a factor in the controllers traffic flow.
I could make a tight 360 (in the direction prescribed by the PT ) to comply with what you think is required by regulation.
It is not.

Not always. On the RNAV approach into my home field, I am usually given direct CELUB (the IAF/IF). And ATC often issues that instruction from a direction close enough to the sector boundary between NoPT and PT required that I ask for clarification, cleared straight in or not? (Though usually, the controller answers that he doesn't care. Personally, I'd like that to be on tape.)

 

[poadeleted20]

"The procedure turn or hold in lieu of procedure (PT) is a required maneuver when it is depicted on the approach chart." FAA-H-8261-1A

By not doing the PT you would not be complying with the IAP. Doesn't it strike anyone how odd it would be if aircraft could randomly excecute or not excecute the PT without telling ATC?

Based on all the posts, it seems the only person whom it does not strike that way is Steven, and he's not going to be convinced no matter what anyone says, so I don't think there's any further need for discussion.

 

[dtuuri]

By the way, I'm thinking that the phrase "Unless otherwise authorized by the FAA" in 91.175(a) provides sufficient regulatory justification for controllers to issue straight-in clearances when a procedure turn would otherwise be required. Anyone have any thoughts on this?

"The FAA's your only hope, so if you've got time to spare, just file a form in triplicate... and sign a questionaire." Arthur Godfrey in Teterboro Tower

See 91.903 and 91.905

dtuuri

 

[Palmpilot]

I don't see anything in those two rules that says that the waiver process is the only way for the FAA to authorize a deviation from a published approach procedure.

 

[dtuuri]

I don't see anything in those two rules that says that the waiver process is the only way for the FAA to authorize a deviation from a published approach procedure.

Where do you see another way?

dtuuri

 

[gismo]

That's what I guessed, but didn't realize it was being done for that reason. But it confirms that the answer is simple: set up FF to use your DUATS account.

I did have my DUATS account set up in FF but perhaps when I updated the IOS a couple months ago that got lost? I guess I'd better check.

Edit: My DUATS account wasn't set up anymore on FF so that was likely the reason my name showed up in the remarks.

 

[wsuffa]

In a radar environment , you're gonna be vectored to final. My debate is in the non-radar environment where you are simply cleared for approach and expected to do it on your own.
No other aircraft will be cleared into the approach airspace until you have completed your own approach. Whether or not you have to make a course reversal or how long it takes is not a factor in the controllers traffic flow.
I could make a tight 360 (in the direction prescribed by the PT ) to comply with what you think is required by regulation.
It is not.

At Culpeper (shown earlier), radar coverage is OK in certain places and altitudes - it's usually OK at about the hold level, but not always. It is not good below about 2000-2500 feet. You won't get vectors-to-final, even if the coverage is OK at the holding pattern level - you'll get the full approach. BTDT & made the request for VTF. (And besides that, if the radar goes down - as it did on my trip up to BTV - you're going to execute the whole approach in what would otherwise be a radar environment).

How you make the PT may affect traffic flow to busier airports - while the plane behind you won't get the approach clearance, if you ignore the PT (or HPILPT), it may leave a larger gap than necessary. That's beyond the whole "stabalized approach" thing.

 

[Palmpilot]

Where do you see another way?

dtuuri

I believe the controllers' manual passage authorizing ATC to issue straight-in clearances has already been quoted, and I believe there is a corresponding AIM passage.

 

[dtuuri]

I believe the controllers' manual passage authorizing ATC to issue straight-in clearances has already been quoted, and I believe there is a corresponding AIM passage.

I believe that passage pertains to radar vectored approaches, hence no waiver is required under 91.175(i): "Radar vectors may be authorized to provide course guidance through the segments of an approach to the final course or fix."

Here's the Notice. Do you see where I've missed that it applies to non-radar environments too?

dtuuri

 

[aterpster]

I believe that passage pertains to radar vectored approaches, hence no waiver is required under 91.175(i): "Radar vectors may be authorized to provide course guidance through the segments of an approach to the final course or fix."

Here's the Notice. Do you see where I've missed that it applies to non-radar environments too?

dtuuri

The way I understand that order radar is required for clearances direct to fixes inside the IF, along with the 30 degree angle limitation. As Jon Collins commented that requires just as much effort on the part of the controller that he may as well vector.

Further, as I understand it, clearances direct to the IF can be either in a radar or non-radar environment although the latter can get a bit tricking where there are lots of smaller MIA sectors (mountainous areas).

 

[John Collins]

The way I understand that order radar is required for clearances direct to fixes inside the IF, along with the 30 degree angle limitation. As Jon Collins commented that requires just as much effort on the part of the controller that he may as well vector.

Further, as I understand it, clearances direct to the IF can be either in a radar or non-radar environment although the latter can get a bit tricking where there are lots of smaller MIA sectors (mountainous areas).

Wally,

The order requires radar monitoring to the IF.

 

[aterpster]

Wally,

The order requires radar monitoring to the IF.

Hi John,

I don't read it that way and I don't believe Rich Boll does either. Rich was involved extensively with the DCP discussions. Inside the IF it is radar required.

Best regards,

Wally

 

[John Collins]

Hi John,

I don't read it that way and I don't believe Rich Boll does either. Rich was involved extensively with the DCP discussions. Inside the IF it is radar required.

Best regards,

Wally

Wally,

This is what I am referring to:

d. For RNAV-equipped aircraft operating on unpublished routes, issue approach clearance for conventional or RNAV SIAP only after the aircraft is:

1. Established on a heading or course direct to the IAF at an intercept angle not greater than 90 degrees and is assigned an altitude in accordance with b2. Radar monitoring is required for RNAV (RNP) approaches when no procedure turn or hold-in-lieu of procedure turn will be executed.

2.Established on a heading or course direct to the IF at an angle not greater than 90 degrees, provided the following conditions are met:

(a) Assign an altitude in accordance with b2 that will permit a normal descent to the FAF.

NOTE- Controllers should expect aircraft to descend at approximately 150-300 feet per nautical mile when applying guidance in subpara d2(a).
​

(b) Radar monitoring is provided to the IF.

(c) The SIAP must identify the intermediate fix with the letters “IF.”

(d) For procedures where an IAF is published, the pilot is advised to expect clearance to the IF at least 5 miles from the fix.​

3. Established on a heading or course direct to a fix between the IF and FAF, in accordance with Paragraph 5-9-1, Vectors to Final Approach Course, and Paragraph 5-9-2, Final Approach Course Interception.​

This isn't a change from the previous guidance as it also required radar monitoring to the IF.

 

[midlifeflyer]

In a radar environment , you're gonna be vectored to final. My debate is in the non-radar environment where you are simply cleared for approach and expected to do it on your own.
No other aircraft will be cleared into the approach airspace until you have completed your own approach. Whether or not you have to make a course reversal or how long it takes is not a factor in the controllers traffic flow.
I could make a tight 360 (in the direction prescribed by the PT ) to comply with what you think is required by regulation.
It is not.

Well, me and the FAA anyway.

 

[Palmpilot]

I believe that passage pertains to radar vectored approaches, hence no waiver is required under 91.175(i): "Radar vectors may be authorized to provide course guidance through the segments of an approach to the final course or fix."

Here's the Notice. Do you see where I've missed that it applies to non-radar environments too?

dtuuri

Where do you see anything in that document that says it only applies when an aircraft is radar vectored?

By the way, the exception to the PT requirement is in 91.175(j), not (i).

 

[Palmpilot]

Not always. On the RNAV approach into my home field, I am usually given direct CELUB (the IAF/IF). And ATC often issues that instruction from a direction close enough to the sector boundary between NoPT and PT required that I ask for clarification, cleared straight in or not? (Though usually, the controller answers that he doesn't care. Personally, I'd like that to be on tape.)

ATC never gives vectors to final for the Palo Alto approaches either.

Maybe they figure that we non-airline pilots know how to navigate on our own.

 

[dtuuri]

Where do you see anything in that document that says it only applies when an aircraft is radar vectored?

How do you get around this?

Par 4-8-1 d.2.(b) Radar monitoring is provided to the IF.
​

I take the position(s) that:

1. Part 91.175 has specific requirements for written waivers in 91.905, except when being radar vectored to final
2. All the talk in the notice about "straight-in" approaches is specifically when being vectored
3. There's a prerequisite for being "established" on a heading or course with an interception angle less than (fill in the blank)° to whatever fix they're discussing. That's "radar talk" in my view. How else can they know the plane's "established"? Ask every pilot, with apologies to Verizon, "Can I clear you now?"​

I guess confusion still reigns. <sigh>

By the way, the exception to the PT requirement is in 91.175(j), not (i).

If I were talking about PTs, I'd have quoted (j). I was talking about radar vectors negating the need for waivers.

dtuuri

 

[poadeleted20]

How do you get around this?

Par 4-8-1 d.2.(b) Radar monitoring is provided to the IF.
​

I take the position(s) that:

1. Part 91.175 has specific requirements for written waivers in 91.905, except when being radar vectored to final
2. All the talk in the notice about "straight-in" approaches is specifically when being vectored
​

Your position is incorrect. It applies to approaches where vectors to final are not being provided and you're navigating on your own with an Advanced RNAV system like GPS, such as direct to the IF or direct to another fix on the final approach course between the IF and the FAF.
​

 

[dtuuri]

Your position is incorrect. It applies to approaches where vectors to final are not being provided and you're navigating on your own with an Advanced RNAV system like GPS, such as direct to the IF or direct to another fix on the final approach course between the IF and the FAF.
​

I hear you, but I take a more broad view: They can't do that legally without a waiver, so they need do it in conjunction with legal vectoring. That's why radar monitoring is required even though you might have RNAV capability. They just can't cut out a section of an approved SIAP without it.

dtuuri