roncachamp
Final Approach
Waivers can be issued only for facilities that are short-staffed.
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Holding pattern in lieu of procedure turn
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Waivers can be issued only for facilities that are short-staffed.
Or condolences, depending on how he feels about it!
aterpster
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aterpster
TWA Training Department Part 121 FAA approved training program for the entire time I was there.
roncachamp
Final Approach
Post the documents.
roncachamp
Final Approach
It is my custom to post documentation that supports my position. I don't have to be asked.
aterpster
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aterpster
roncachamp
Final Approach
But they do not support your position.
MarkZ
En-Route
As an En-route Controller, a straight in clearance allows me to move more traffic in and out of airports. By accepting them (when safe to do so) the system moves efficiently.
The Pilot/Controller glossary and AIM are correct. The PIC can deny clearances if the PIC feels that the clearance (or instruction, they're the same to me) will jeopardize safety of flight.
I make mistakes when I'm working traffic - I'm human.
I also am working radar in a windowless room, possibly hundreds of miles away from you. I don't know if you are getting chop, icing, IMC/VMC, wind gusts, etc. unless you communicate that to me. That's why informative PIREP's (even for smooth and CAVOK) are so important, they let me build a mental image of what's going on in my sky.
That's also why, if you can't comply with a clearance given, it's more important to let me know what you CAN do rather than just what you CANNOT do. Each aircraft handles differently, each PIC has different limits, and I can only guesstimate your capabilities.
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Velocity173
Welcome to POA Mark. Now that Steven is retired, I believe you're are only current controller in threads. 
nosehair
Cleared for Takeoff
http://155.178.201.160/d-tpp/1307/05261VA.PDF
After looking a bit, I'll use this one. Several of the old local simple vor approaches that I used to use, and go straight in when on final at the IAF now have this "NoPT" when within a range of inbound courses that we are discussing.
For this discussion, pretend the "NoPT" note is not there. The straight-in that we are discussing would still apply.
Now, with the "NoPT" note, you don't have the option of a PT.
But, anyway, this is a typical example of an approach where you may be aligned with the inbound radial (course) when arriving at the IAF.
My reading of the words of law about the PT are that when the law says "When the pilot is cleared for a SAIP, then that procedure must be flown."
It seems that most people are reading that as saying, "...the procedure TURN must be flown."
The SAIP is the WHOLE procedure, which includes a procedure turn WHEN a course reversal is necessary to align the aircraft on final. That is the definition of the PT. The PT is an integral PART of the SAIP, but the SAIP is not the PT by itself.
The rule does not say the procedure turn must be flown if one is charted. It says the PROCEDURE must be flown. The necessity of making a course reversal is up to the PIC.
For the sake of argument, I have consistently said "when you are ON COURSE at the IAF, but my old school teaching has allowed that "on course" determination to be judged by the pilot. In old school terms, it was about within 30 degrees of final, but could be 45. We intercept final on a 45 in a standard PT, so it is up to the pilot.
The chart I have shown (and several others) actually make the "NoPT" note when within that approximate range.
Note that a PIC can still go straight-in when he is NOT within that range if he/she so chooses. He/she does not have the option when within the range, unless requested and cleared by ATC.
Also, this area of the country (Fla. panhandle) is remote with little traffic. A responsible, aware pilot would say "straight-in" just to ley everyone know what he intends, but when there is no traffic, do you, as a controller, really give a hoot whether he goes straight in or makes the PT?
Sometimes, the decision to go straight-in or do a turn may not be apparent until on top of the IAF.
roncachamp
Final Approach
That doesn't appear to be a non-radar environment.
But it is there, so this is not a real-world example of an IAP in a non-radar environment where an aircraft can be issued a valid route that does not require a course reversal and has not been tagged NoPT.
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Velocity173
So with the CEW example. An aircraft is direct CEW VORTAC and is not on the 263 thru the 358. They get cleared for the VOR-A approach. So you're saying the pilot decides if the PT is necessary or not?
roncachamp
Final Approach
Do you see a potential problem if a pilot decided it wasn't necessary? What if the approach clearance included "straight-in" under those same conditions?
John Collins
En-Route
As an aside, you are not reading the chart correctly. The NoPT note only applies if you are arriving on V198-241 eastbound or V115 southbound.
The NoPT does not apply to approaching CEW on off airway courses between CW CEW 263 and 358 radials.
roncachamp
Final Approach
Why not?
John Collins
En-Route
The note reads (emphasis is mine): "NoPT for arrival on CEW VORTAC airway radials 263 CW 358."
This has been a well discussed topic at the ACF-IPG. You can read the following for more details: http://www.faa.gov/about/office_org...0/afs420/acfipg/open/media/Hist_11-02-297.pdf
This has been a well discussed topic at the ACF-IPG. You can read the following for more details: http://www.faa.gov/about/office_org...0/afs420/acfipg/open/media/Hist_11-02-297.pdf
roncachamp
Final Approach
You can find a lot of absurd notes on IAPs. Let's say I'm inbound to CEW on the 315° radial at 3000' and cleared for the VOR-A approach, the clearance does not include "straight-in". What bad thing might happen to me if I skip the PT?
John Collins
En-Route
On this specific approach, not likely anything other than dealing with the potential violation, same as would be the case in many other situations where you violate a rule and no harm comes of it.
Most SIAP contain a means of transitioning from the enroute airway system to the approach. TERPS requires that airways and feeder routes meet certain obstacle clearance requirements and in most cases, random routes are not evaluated. The exception is a TAA segment. Radar vectoring or monitoring permits flying on uncharted routes when the controller amongst other responsibilities assigns the altitude. Clearances to a FAF that is also an IAF requires that the PT be flown, this is a clarification to the .65 guidance that went into effect after you left.
Clip4
Touchdown! Greaser!
You are a instrument rated pilot / retired controller and don't know this stuff?
roncachamp
Final Approach
I believe I do know it quite well.
roncachamp
Final Approach
A potential violation of the AIM?
What if the controller includes "straight-in" where it's wrong to do so? If the pilot did the PT anyway would he be facing a potential violation of FAR 91.123?
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Velocity173
Yeah the problem is the pilot isn't executing the approach as depicted. It's like not complying with the MA procedure as depicted. Both can be overriden by ATC but when a pilot changes their route of flight without notifying anyone, there's no positive control there.
'The procedure turn or hold-in-lieu-of-PT is a required maneuver when it is depicted in the approach chart, unless cleared by ATC for a straight-in approach.'
You'd think the FAA would remove that statement from the AIM and the IPH if they didn't want it to be mandatory.
roncachamp
Final Approach
Why is that a problem? We're talking about a maneuver that upon completion puts the pilot in the same position he was in about four minutes earlier.
No it isn't.
How so? If you believe that skipping an unneeded course reversal poses some problem to ATC then by all means please explain just what that problem is.
I think if the FAA wants it to be mandatory they should put that statement in the FARs instead of in a publication that says it is not regulatory, that only provides information which reflects examples of operating techniques and procedures which may be requirements in other federal publications or regulations, and is made available solely to assist pilots in executing their responsibilities required by other publications.
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Velocity173
Already explained the problem Steven you just fail to accept it. I'm not going to explain it again. All the guidance in the AIM and the IPH support the FARs. This has been pointed out to you several times already as well. Even without the FARs, I'd take the guidance in the AIM and IPH just as good operating practice over one controller's opinion.
roncachamp
Final Approach
Is it too much trouble to identify the message in which you explained it previously?
Not true, the FARs never state when a PT is required, only when it is prohibited.
What's in the AIM and IPH are just the opinions of the writers.
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Velocity173
Your reference is in pages 1-10 of this thread.
aterpster
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aterpster
Line controllers set neither policy nor procedures.
John Collins
En-Route
nosehair
Cleared for Takeoff
But retired controllers provide legal opinions.
So does this 50 year flight instructor. Go ahead, ask your Friendly FSDO Inspector what specific FAR he would use to violate a pilot not flying a PT when no course reversal was required .
Violations are written on FAR s.
AIM material, etc. can be used as supporting, but not primary.
John Collins
En-Route
The FAA General Counsel has written an opinion on the subject regarding the meaning of 91.175 which they opined that the use of the PT is mandatory. I would think that if the FAA wants to violate the pilot, they will find a regulation that works for them. 91.3, 91.13, and 91.123 are catch alls in this situation.
Clip4
Touchdown! Greaser!
aterpster
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aterpster
That link doesn't work for me.
John Collins
En-Route
He is citing the 1994 Chief Counsel opinion to Tom Young regarding joining a DME arc in a non radar environment and when a PT is required. Weren't you involved?
Clip4
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aterpster
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Indeed I was. I wrote the two ALPA letters. The first from Tom Young, for which the FAA's reply was wrong, wrong, and then wrong.
I then wrote a second letter for John O'Brien, manager of ALPA's Engineering & Air Safety Department, which pointed out to the FAA how wrong they had everything. FAA legal then got an FAA TERPs expert to help them write the letter that stuck.
Their first letter, written in 1993, was based on the help of an ATO manager, who didn't know his behind from second base, at least in the subject matter at issue.
John Collins
En-Route
Do you still have a copy of the original 93 response that was wrong?
aterpster
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I may. But, where I don't know.
The problem was the 900 pound gorilla known as ATO. The attorney, who is a nice and well-meaning lady, went to Chief Counsel to seek expert help. He wrongly referred her to ATO, with the mistaken thought that instrument approach procedures are a subset of air traffic rules. That is true legally, but not technically.
After they got burned they sought out the resident AFS TERPs expert, who resided at the Puzzle Palace at the time. I knew him well. He was the correct choice.
nosehair
Cleared for Takeoff
As I have already said, you guys are hanging your hat on the statement in the last paragraph, "...the pilot must execute the SAIP "
That language is an exact quote of the regulation, not an interpretation of the question " Is a course reversal required when one is not necessary?"
Election of the published procedure includes common English reading of the term for the PT which is prescribed when a course reversal is necessary.
I have yet to see a document that expressly says this specific maneuver must be expected when not necessary.
That language is an exact quote of the regulation, not an interpretation of the question " Is a course reversal required when one is not necessary?"
Election of the published procedure includes common English reading of the term for the PT which is prescribed when a course reversal is necessary.
I have yet to see a document that expressly says this specific maneuver must be expected when not necessary.
John Collins
En-Route
The question is whose opinion determines if it is necessary, the pilot's or the TERPS designer of the approach. If the TERPS designer put the PT on the procedure, it was his/her opinion that the PT was necessary. That opinion becomes a regulation after it goes thru the process. I realize this will not convince you and if you want to get a specific answer from the Office of the Chief Counsel, they are usually more than willing to provide one, albeit it may take a half a year.
Would an answer to the following question satisfy you?
To the Chief Counsel,
97.3 defines: "Procedure turn means the maneuver prescribed when it is necessary to reverse direction to establish the aircraft on an intermediate or final approach course."
If a Procedure turn (PT) is charted as part of a SIAP and none of the conditions stated in 91.175(j) exist, the aircraft is cleared direct to the IAF/FAF and for the approach (cleared straight in is not part of the approach clearance), and arriving at an IAF/FAF from a direction and altitude such that the execution of the PT is not necessary to reverse direction to establish the aircraft on the final approach course, may the pilot chose to not fly the PT and continue straight in or must they fly the PT even though it isn't necessary (in the pilot's opinion).