Holding pattern in lieu of procedure turn

This thread has been fun but adding Jepp's opinion makes it even better!

I want a cage death match between someone at Jepp and the Chief Counsel's office. Two shall enter, only one shall survive!!!!

Bwahaha.
 
John, thank you for your input, but I've seen the implausible explanation that the implausible"author" of the approach plan has determined that a PT is necessary when a course reversal is not.
Plain English reading of the definition of a PT when incorporated within the whole picture of executing the whole Standard Procedure would indicate that the execution of the Turn is dependent on the necessity of making a course reversal.
The wording of your question.is still too full of your "vagaries" that I would not submit it to any govt. official who cannot actually make such a technical decision. The answer is in the regs . That's what he will say.
A better question is to whoever says the "approach designer" has determined that you need to make a PT when you don't need to make a course reversal.
Who said that?
 
nosehair said:
John, thank you for your input, but I've seen the implausible explanation that the implausible"author" of the approach plan has determined that a PT is necessary when a course reversal is not.
Plain English reading of the definition of a PT when incorporated within the whole picture of executing the whole Standard Procedure would indicate that the execution of the Turn is dependent on the necessity of making a course reversal.
The wording of your question.is still too full of your "vagaries" that I would not submit it to any govt. official who cannot actually make such a technical decision. The answer is in the regs . That's what he will say.
A better question is to whoever says the "approach designer" has determined that you need to make a PT when you don't need to make a course reversal.
Who said that?
Click to expand...

The approach designer does not make the decision about whether a course reversal is required. The TERPs criteria are quite cut and dried in that regard; alignment, and descent gradient requirements of initial approach segments or feeder routes leading to the intermediate segment. TAAs are a special case.

What the designer does have some control over is how he/she places the terminal routing leading to the intermediate segment. In some case the design can be sufficiently optimized that a course reversal is not even included in the design. In other cases airspace, terrain, and/or ATC constraints limit design flexibility.

But, once the design is finalized and released into the federal register, all terminal routes, segments, minimums, and altitudes are a regulation, per se. (Part 97.XX)
 
nosehair said:
Plain English reading of the definition of a PT when incorporated within the whole picture of executing the whole Standard Procedure would indicate that the execution of the Turn is dependent on the necessity of making a course reversal.
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You know, nosehair, I can actually see your reasoning when I really try hard. Of course, seeing what you believe and agreeing with it aren't the same thing. I'm sure you agree, though, that Part 91.175(a) refers us to Part 97. But do you agree that it refers us to Subpart C, more specifically, since that is where the SIAP is actually documented? If you can, then it ought to be apparent that the depicted track is a required one--there are no options charted. It's black or white and, under TERPS, assumes you can only arrive via published routes. Now, if you want to understand what a charted "Procedure turn" is or what "NoPT" or "Hold in lieu of PT" means THEN you refer to the definitions in 97.3. That section explains the nomenclature used in the procedure you MUST adhere to under 91.175(a) & 97.20. Can you see my reasoning too?

dtuuri
 
The depicted track is required when a course reversal is required ...
 
nosehair said:
I have yet to see a document that expressly says this specific maneuver must be expected when not necessary.
Click to expand...

Did you mean to write executed there?

Assuming you did, I'm pretty sure you have seen a document that says it must be executed when not necessary; the AIM. What you haven't seen is a regulation that says it must be executed when not necessary.
 
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John Collins said:
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.
Click to expand...

No, the question is what he wrote; "Is a course reversal required when one is not necessary?"
 
dtuuri said:
You know, nosehair, I can actually see your reasoning when I really try hard. Of course, seeing what you believe and agreeing with it aren't the same thing. I'm sure you agree, though, that Part 91.175(a) refers us to Part 97. But do you agree that it refers us to Subpart C, more specifically, since that is where the SIAP is actually documented? If you can, then it ought to be apparent that the depicted track is a required one--there are no options charted. It's black or white and, under TERPS, assumes you can only arrive via published routes. Now, if you want to understand what a charted "Procedure turn" is or what "NoPT" or "Hold in lieu of PT" means THEN you refer to the definitions in 97.3. That section explains the nomenclature used in the procedure you MUST adhere to under 91.175(a) & 97.20. Can you see my reasoning too?
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Your reasoning is inconsistent with the AIM, which tells pilots PTs are flown at the controller's option.
 
John Collins said:
In your opinion.
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It's not a matter of opinion. Nobody questions the need for the maneuver when it's necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course. We're discussing the situation where upon completion of the maneuver the aircraft is in the same place and on the same course it was a few minutes earlier.
 
roncachamp said:
It's not a matter of opinion. Nobody questions the need for the maneuver when it's necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course. We're discussing the situation where upon completion of the maneuver the aircraft is in the same place and on the same course it was a few minutes earlier.
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That is still your opinion, just doesn't hold any weight for me.
 
The "opinion" of the PIC counts.
We are not driven by atc clearances or requests.
The PIC decides when and where he/she "begins final descent."
 
nosehair said:
The "opinion" of the PIC counts.
We are not driven by atc clearances or requests.
The PIC decides when and where he/she "begins final descent."
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That is just so wrong. Why even have controlled airspace and approach plates if the pilot can descend whenever he decides? This thread has gone on far past any hope of resolving the issue to the satisfaction of the few over the consensus of the many.
 
Witmo said:
That is just so wrong. Why even have controlled airspace and approach plates if the pilot can descend whenever he decides? This thread has gone on far past any hope of resolving the issue to the satisfaction of the few over the consensus of the many.
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Amen.
 
Lot's of arguing on this topic, sheesh. I always query the controller if I'm not cleared for the straight in as to whether or not they are expecting me to fly the HILPT or procedure turn. Makes it easier on both of us.
 
Turningfinal said:
Lot's of arguing on this topic, sheesh. I always query the controller if I'm not cleared for the straight in as to whether or not they are expecting me to fly the HILPT or procedure turn. Makes it easier on both of us.
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+1. That's the important thing as far as I'm concerned, having the pilot and ATC on the same page. Whether the course reversal is necessary or not, if the controller expects me to fly it I will fly it.
 
azure said:
+1. That's the important thing as far as I'm concerned, having the pilot and ATC on the same page. Whether the course reversal is necessary or not, if the controller expects me to fly it I will fly it.
Click to expand...

How do you know he expects you to fly it?
 
Turningfinal said:
Query the controller. It's not that hard to do.
Click to expand...

Yup. Whenever an approach clearance is issued where there's an unnecessary course reversal and "straight-in" is not included, pilots should query the controller because he probably just forgot to include it and the unexpected maneuver could cause problems with following traffic.
 
roncachamp said:
How do you know he expects you to fly it?
Click to expand...
Sometimes he says "cleared straight in". Sometimes, I'm on a NoPT route. Sometimes, the reversal is clearly required. Otherwise, I ask, or request a straight in clearance if the reversal is unnecessary.
 
azure said:
Sometimes he says "cleared straight in". Sometimes, I'm on a NoPT route. Sometimes, the reversal is clearly required.
Click to expand...

In all of those cases you'd be expected not to fly it.

Otherwise, I ask, or request a straight in clearance if the reversal is unnecessary.
Click to expand...

Good.
 
[FONT=Arial,Bold][FONT=Arial,Bold]GOVERNMENT/INDUSTRY CHARTING FORUM[/FONT][/FONT]
[FONT=Arial,Bold][FONT=Arial,Bold]Instrument Procedures Group[/FONT][/FONT]
[FONT=Arial,Bold][FONT=Arial,Bold]October 25, 2005[/FONT][/FONT]
[FONT=Arial,Bold][FONT=Arial,Bold]HISTORY RECORD[/FONT][/FONT]
[FONT=Arial,Bold][FONT=Arial,Bold]FAA CONTROL # 05-02-260[/FONT][/FONT][FONT=Arial,Bold]
[FONT=Arial,Bold]SUBJECT: ACF Closed Issue Re: Course Reversals Negated by AIM Change[/FONT]​


[FONT=Arial,Bold]BACKGROUND/DISCUSSION: [/FONT]
[/FONT]​
Because of years of confusion and erosion of certain​
procedural aspects of instrument approach procedures by both pilots and air traffic control,
in 1993 the Air Line Pilots Association wrote FAA chief counsel asking for legal interpretations about certain aspects pertaining to the conduct of instrument approach procedures, including a precise, unambiguous ruling about when a prescribed course
reversal is required.



On November 28, 1994, FAA’s chief counsel’s office issued a responsive letter of interpretation, which included the following language pertaining to course reversals:​


​
​
[FONT=Arial,Italic][FONT=Arial,Italic]“Finally, you ask whether a course reversal segment is optional ‘when one of the conditions [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]of FAR section 91.175(j) is not present.’ Section 91.175(j) states that in the case of a radar [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]vector to a final approach course or fix, a timed approach from a holding fix, or an approach [/FONT][FONT=Arial,Italic]for which the procedures specifies ‘no procedure turn,’ no pilot may make a procedure turn [/FONT][FONT=Arial,Italic]unless cleared to do so by ATC.”[/FONT][/FONT]​

[FONT=Arial,Italic][FONT=Arial,Italic]“Section 97.3(p) defines a procedure turn, in part, as a maneuver prescribed when it is [/FONT][FONT=Arial,Italic]necessary to reverse direction to establish the aircraft on an intermediate or final approach [/FONT][FONT=Arial,Italic]course. A SIAP may or may not prescribe a procedure turn based on the application of [/FONT][FONT=Arial,Italic]certain criteria contained in the TERPs. However, if a SIAP does contain a procedure turn [/FONT][FONT=Arial,Italic]and ATC has cleared a pilot to execute the SIAP, the pilot must make the procedure turn [/FONT][FONT=Arial,Italic]when one of the conditions of Section 91.175(j) is not present.”[/FONT][/FONT]​





The cited language did not create new instrument flight operating procedures. Rather, it clearly set forth the requirements for course reversals that had been intended by the Flight Standards Service from the inception of TERPS criteria in November, 1967.​

But, the foregoing letter of legal interpretation had little, if any, practical effect to correct the

misunderstandings prevalent among pilots and controllers because the aviation community has no effective or uniform access to FAA legal interpretations. Thus, the issue was brought
to the ACF for the purpose of working a change to the AIM so that the mandate of the legal
interpretation would be set forth in an effective and continuing manner to the pilot community and to air traffic controllers. It took several years of discussion and AIM amendments to provide language of sufficient precision and clarity to finally put an end to the morass of pilot community and air traffic
controller “sharp-shooting” the language. The AIM was eventually amended to contain the following precise, clear and unambiguous language, which language was the ​
​


[FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]final [/FONT][/FONT]consensus of the ACF on the matter:​





[FONT=Arial,Italic][FONT=Arial,Italic]“5-4-9. Procedure Turn[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]a. A procedure turn is the maneuver prescribed when it is necessary to perform a course[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]reversal to establish the aircraft inbound on an intermediate or final approach course. The[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]procedure turn or hold in lieu of procedure turn is a required maneuver. The procedure turn [/FONT][FONT=Arial,Italic]is not required when the symbol ‘No PT’ is shown, when RADAR VECTORING to the final [/FONT][FONT=Arial,Italic]approach course is provided, when conducting a timed approach, or when the procedure [/FONT][FONT=Arial,Italic]turn is not authorized. The hold in lieu of procedure turn is not required when RADAR [/FONT][FONT=Arial,Italic]VECTORING to the final approach course is provided or when ‘No PT’ is shown. The[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]altitude prescribed for the procedure turn is a minimum altitude until the aircraft is [/FONT][FONT=Arial,Italic]established on the inbound course. The maneuver must be completed within the distance [/FONT][FONT=Arial,Italic]specified in the profile view.”[/FONT][/FONT][FONT=Arial,Italic]​


[/FONT]​
The foregoing language lay to rest the morass of user “sharp shooting” of previous AIM language about course reversals. But, this past August, the settled language was amended without first being considered and discussed at the ACF. The new language is cited below. The fatal blow to all the previous work done to set this issue straight is emphasized in bold type:​

[FONT=Arial,Italic][FONT=Arial,Italic]“5-4-9. Procedure Turn[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]{New-2005-17 a. revised August 4, 2005}[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]a. A procedure turn is the maneuver prescribed to perform a course reversal to establish the[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]aircraft inbound on an intermediate or final approach course. The procedure turn or hold in [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]lieu of procedure turn is a required [/FONT][/FONT][FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]maneuver when it is necessary to perform a course [/FONT][/FONT][FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]reversal. [/FONT][/FONT]​





[FONT=Arial,Italic][FONT=Arial,Italic]The procedure turn is not required when the symbol "No PT" is shown, when [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]RADAR VECTORING to the final approach course is provided, when conducting a timed [/FONT][FONT=Arial,Italic]approach, or when the procedure turn is not authorized. The hold in lieu of procedure turn is[/FONT]
[FONT=Arial,Italic]not required when RADAR VECTORING to the final approach course is provided or when [/FONT][FONT=Arial,Italic]"No PT" is shown. The altitude prescribed for the procedure turn is a minimum altitude until [/FONT][FONT=Arial,Italic]the aircraft is established on the inbound course. The maneuver must be completed within [/FONT][FONT=Arial,Italic]the distance specified in the profile view.” [/FONT]​
[/FONT]





The phrase “when it is necessary to perform a course reversal” has ignited the “sharp shooters” debate with vigor greater than past ad hoc community debates about the issue. In a few short weeks, the myriad of discussions in various aviation forums have completely undone the years of effort by the ACF on this issue.​





[FONT=Arial,Bold][FONT=Arial,Bold]RECOMMENDATION: [/FONT][/FONT]​









The aviation community needs to be informed on a priority basis that the August, 2005, change to the AIM was in error, and that the language cited above
that existed prior to August, 2005 is still the directive practice set forth by the office of primary responsibility for this issue: Flight Standards Service. ​






Further, until the language is corrected and effectively disseminated to the aviation community, not only is Flight Standards Service’s mandate thwarted, so is chief counsel’s 1994 legal ruling.​



A change to the AIM, although essential, will take too long to set the issue straight before the new misunderstandings become embedded within the system. NBAA submits that the confusion created by the new AIM language represents a critical safety of flight issue that must be first resolved by timely NOTAM action, with the AIM language to be corrected in the next AIM open cycle. Thus, it is also recommended that an immediate GENOT or general

FDC NOTAM be issue to rescind the new AIM language and to restate the recently rescinded AIM language as being the language that is in full force and effect.​


​









Finally, the substance of this issue is not reopened by this issue paper. The issue about AIM language for course reversals had been the subject of much previous ACF discussion, amendments, and debate. The issue was properly closed in the past and settled with the AIM language that existed prior to August, 2005, and cited above. The issue set forth by​


this issue paper is limited to getting the agreed-to language back into the hands of the aviation community as soon as possible.​











[FONT=Arial,Bold][FONT=Arial,Bold]COMMENT: [/FONT][/FONT]​




This recommendation affects the Aeronautical Information Manual, the FAA chief counsel’s legal ruling dated November 18, 1994, the ATC 7110.65 series handbook, and the general procedural control of the orderly and proper use of standard instrument approach procedures.​





[FONT=Arial,Bold][FONT=Arial,Bold]SUBMITTED BY: [/FONT][/FONT]​




Steve Bergner​



[FONT=Arial,Bold][FONT=Arial,Bold]ORGANIZATION: [/FONT][/FONT]​




National Business Aviation Association (NBAA)​



[FONT=Arial,Bold][FONT=Arial,Bold]DATE: [/FONT][/FONT]​




October 7, 2005.​



[FONT=Arial,Bold][FONT=Arial,Bold]PHONE: [/FONT][/FONT]​




(845) 583-5152​



[FONT=Arial,Bold][FONT=Arial,Bold]FAX: [/FONT][/FONT]​




(845) 583-5769​



[FONT=Arial,Bold][FONT=Arial,Bold]Email: [/FONT][/FONT]​




bergners@granitelp.com​



[FONT=Arial,Bold]INITIAL DISCUSSION (Meeting 05-02): [/FONT]​





New issue introduced by Steve Bergner,​



NBAA. NBAA is concerned that language in the most recent AIM paragraph 5-4-9 is misleading and contradicts the FAA General Council opinion discussed at the ACF in the early 1990’s. The current language could cause pilot confusion on when a course reversal is required and lead to violation of 14 CFR Part 91.175(j). Tom Schneider, AFS-420, stated

that his office is in agreement with the NBAA concern. Tom presented the following draft
language for the AIM to resolve the issue, noting that it would not be published until the August 06 AIM revision. The consensus was that the proposed language would resolve the issue. Mark Ingram, ALPA, recommended the draft language be published in the Notices to Airmen Publication (NTAP) as soon as possible. Tom agreed to pursue this.​





ACTION: AFS-420.​



​
​
[FONT=Arial,Bold][FONT=Arial,Bold]Proposed AIM Revision: [/FONT][/FONT]

[FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]5-4-9. Procedure Turn[/FONT][/FONT]
[FONT=Arial,Italic][FONT=Arial,Italic]: A procedure turn is the maneuver[/FONT][/FONT]​





[FONT=Arial,Italic][FONT=Arial,Italic]prescribed when it is necessary to reverse direction to establish the aircraft inbound on an[/FONT][/FONT]​


[FONT=Arial,Italic]
[FONT=Arial,Italic]intermediate or final approach course. The procedure turn or hold-in-lieu-of-PT is a required[/FONT]

[FONT=Arial,Italic]maneuver when it is depicted on the approach chart. However, the procedure turn or holdin-[/FONT]

[FONT=Arial,Italic]lieu-of-PT is not permitted when the symbol "No PT" is depicted on the initial segment[/FONT]
[FONT=Arial,Italic]being used, when a RADAR VECTOR to the final approach course is provided, or when [/FONT][FONT=Arial,Italic]conducting a timed approach from a holding fix. The altitude prescribed for the procedure [/FONT][FONT=Arial,Italic]turn is a minimum altitude until the aircraft is established on the inbound course. The [/FONT][FONT=Arial,Italic]maneuver must be completed within the distance specified in the profile view.[/FONT]​

[/FONT]​

​
[FONT=Arial,Italic]

[/FONT]






[FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]Note[/FONT][/FONT]​






[FONT=Arial,Italic][FONT=Arial,Italic]: The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when it is not [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]required by the procedure, but must first receive an amended clearance from ATC. When [/FONT][FONT=Arial,Italic]ATC is Radar vectoring to the final approach course or to the Intermediate Fix, ATC [/FONT][/FONT][FONT=Arial,BoldItalic][FONT=Arial,BoldItalic]may [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]specify in the approach clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]the procedure turn or hold-in-lieu-of-PT is not to be flown. If the pilot is uncertain whether [/FONT][/FONT][FONT=Arial,Italic][FONT=Arial,Italic]the ATC clearance intends for a procedure turn to be conducted or to allow for a straight-in [/FONT][FONT=Arial,Italic]approach, the pilot shall immediately request clarification from ATC (14 CFR Part 91.123).[/FONT][/FONT]​





[FONT=Arial,Bold]MEETING 06-01: [/FONT]​




Tom Schneider, AFS-420, stated that immediately following the last ACF, AFS-420 published the agreed upon AIM text in the NTAP. The text has been forwarded for publication in the August AIM change.​




Action: None Required - Pending Publication.​







[FONT=Arial,Bold][FONT=Arial,Bold]MEETING 06-02: [/FONT][/FONT]​




Bill Hammett, AFS-420 (ISI), briefed that the ACF agreed upon text was published in the August AIM. ​



ISSUE CLOSED.​
 
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Other than the later expansion of the straight-in clearance option, that ACF record certainly does a good job of explaining the purpose of the current AIM language.
 
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