No "NoPT" marking on a straight-in feeder route - how to explain?

[aterpster]

The procedures for KUWL are being revised this December.

The good news is both runway ends are getting RNAV with LPV.

The bad news is the VOR 27 will remain the same.

You can see all this at the coordination website. Enter "KUWL." Once there, click on the coordination tab:

https://www.faa.gov/air_traffic/flight_info/aeronav/procedures/application/

 

[nosehair]

When necceasary means as required by the chart, not what you determine is required.

Right! As required by the chart when a course reversal is necessary .

 

[nosehair]

I decided to bring this IAP to the attention of one of the gurus in the approach design department in OKC. He said the HILPT is mandatory unless provided radar vectors to the final approach course. He also stated the approach shouldn't have been designed that way.

This guy was on your side of the understanding , or misunderstanding, as the case may be.
OKC verbal interpretations are no more creditable than your local FSDO.

The legal problem is the language and meaning of words and phrases like course reversal , as required, and as depicted, and how they relate.

In cases where the language of the law is confusing, legal precedence is to follow common sense.

Let's look for some kind of common sense reasoning for making a 360° course reversal reversal reversal when none is required as in this approach.

 

[aterpster]

This guy was on your side of the understanding , or misunderstanding, as the case may be.
OKC verbal interpretations are no more creditable than your local FSDO.

The legal problem is the language and meaning of words and phrases like course reversal , as required, and as depicted, and how they relate.

In cases where the language of the law is confusing, legal precedence is to follow common sense.

Let's look for some kind of common sense reasoning for making a 360° course reversal reversal reversal when none is required as in this approach.

We work together all the time. This was an email exchange.

Nonetheless I previously pointed out the regulatory framework by showing the forms and the federal register entry.

 

[Clip4]

I decided to bring this IAP to the attention of one of the gurus in the approach design department in OKC. He said the HILPT is mandatory unless provided radar vectors to the final approach course. He also stated the approach shouldn't have been designed that way.

I suspect vectors to final are not possible due to the distance from IND's ASR antenna and the fact the procedure is almost certainly not video mapped.

My response to him was the procedure doesn't comply with criteria.

Nonetheless, controllers can waive the requirements of an approach only when authorized by the 7110.65. As we know controllers often violate FAA policy but they don't have to go to enforcement hearings.

If you speak to one of the gurus, ask him why the regs are designed to require the PT where the pilot already aligned with the final approach course

My thoughts are it is provided to allow for descent if needed an to slow/configure the plane for the approach. I like to know why they are requiring it.

 

[Clip4]

Right! As required by the chart when a course reversal is necessary .

No required by the chart except the for exceptions. Re- read 91.175(a).

 

[Palmpilot]

In cases where the language of the law is confusing, legal precedence is to follow common sense.

My understanding is that what legal precedents actually say is that courts are reluctant to adopt interpretations that nullify part of the text. If you assume that the first sentence of AIM 5-4-9a makes the PT not mandatory (when the stated exceptions are not present), then the second sentence would be nullified and serve no purpose. That ignores a long-standing principle of legal interpretation.

 

[John Collins]

If you speak to one of the gurus, ask him why the regs are designed to require the PT where the pilot already aligned with the final approach course

My thoughts are it is provided to allow for descent if needed an to slow/configure the plane for the approach. I like to know why they are requiring it.

I haven't spoken to the guru, but my understanding is that an approach generally begins at an IAF and typically has 4 segments, the initial segment, the intermediate segment, the final approach segment, and the missed approach segment. A feeder segment is added if the IAF is not part of the airway structure. The feeder segment is to provide a route from the airway to the IAF or IOW the fix where the approach begins. The initial segment is intended to transition the aircraft to the intermediate fix or intermediate segment. The intermediate segment is intended to permit the aircraft to configure for the final approach segment and to slow to a normal approach speed. Generally this is a level segment or a segment that has a low descent gradient so its purpose can be accomplished.

When there is a PT or HILPT at the FAF and there isn't an IF, the intermediate segment is designated to begin after the PT or HILPT is completed. In this case, the PT is required to connect the initial segment with the intermediate segment. This is true regardless of whether or not the initial segment course and intermediate segment course are the same and in fact in most cases they are the same course. So, the PT is the maneuver that is required to align the aircraft with the intermediate course or another way of saying it is: "A procedure turn is the maneuver prescribed to perform a course reversal to establish the aircraft inbound on an intermediate or final approach course."

The intermediate course connects to the final approach segment and allows the aircraft to transition to the proper configuration and speed for the descent.

Note: If you load this approach using the GNS430W or GTN750, and select RID as the starting point, the hold is included in the resulting flightplan without an option for the pilot to choose if they wish to fly it or not.

 

[nosehair]

My understanding is that what legal precedents actually say is that courts are reluctant to adopt interpretations that nullify part of the text. If you assume that the first sentence of AIM 5-4-9a makes the PT not mandatory (when the stated exceptions are not present), then the second sentence would be nullified and serve no purpose. That ignores a long-standing principle of legal interpretation.

You are hitting the nail on the head. About what is causing the confusion.

The first sentence describes the turn as a maneuver "when necessary to ESTABLISH..on final ."
The second sentence says the "necessary turn to get established will be as depicted on the chart"

In other words, if a course reversal is necessary to get established, the turn shall be as depicted, ie., "a required maneuver".

 

[John Collins]

You are hitting the nail on the head. About what is causing the confusion.

The first sentence describes the turn as a maneuver "when necessary to ESTABLISH..on final ."
The second sentence says the "necessary turn to get established will be as depicted on the chart"

In other words, if a course reversal is necessary to get established, the turn shall be as depicted, ie., "a required maneuver".

I wonder what the .. words in your quote-paraphrase that were left out.

I will highlight the left out key words of the quote that I presume were paraphrased in part from 97.3 and or from the CC opinion. First 97:3 states in part:

Procedure turn means the maneuver prescribed when it is necessary to reverse direction to establish the aircraft on an intermediate or final approach course.

The CC opinion stated:

A procedure turn is the maneuver prescribed to perform a course reversal to establish the aircraft inbound on an intermediate or final approach course.

The left out words must have no bearing on the subject.

So the approach starts at the IAF. OK you just arrived at the IAF and on the course that is the same as the one used for both the final and intermediate segment of the approach. There is an intermediate segment on the approach, but from your location at the IAF, how do you get to the intermediate segment, since it is behind you. You fly the HILPT which is used as the maneuver to perform a course reversal to establish the aircraft on the intermediate approach course.

This is a GPS overlay approach, so if the HILPT is not required for the feeder route, it certainly wouldn't be required for a direct to ECONO from due south as that is well under the 90 degree requirement. But alas, this is prohibited by 7110.65 which states:

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.

Just to be clear, I am not arguing this is a well designed approach and would much rather have the IAF at RID with an IF about 6 NM from the FAF as a cross radial and remove the IAF designation at ECONO and the HILPT.

Also I realize that you can't be convinced, but others hopefully won't fall into the trap of believing that they get to decide if the PT/HILPT is required or not based on your logic. If it is on the chart and one of the 4 exceptions don't apply, it is mandatory.

 

[aterpster]

If you speak to one of the gurus, ask him why the regs are designed to require the PT where the pilot already aligned with the final approach course

My thoughts are it is provided to allow for descent if needed an to slow/configure the plane for the approach. I like to know why they are requiring it.

The approach was not designed correctly.

 

[Clip4]

The approach was not designed correctly.

I was speaking of any approach where a HILPT is depicted and aligned with the final course.

 

[aterpster]

I was speaking of any approach where a HILPT is depicted and aligned with the final course.

How about an example?

 

[Captain]

I haven't spoken to the guru, but my understanding is that an approach generally begins at an IAF and typically has 4 segments, the initial segment, the intermediate segment, the final approach segment, and the missed approach segment. A feeder segment is added if the IAF is not part of the airway structure. The feeder segment is to provide a route from the airway to the IAF or IOW the fix where the approach begins. The initial segment is intended to transition the aircraft to the intermediate fix or intermediate segment. The intermediate segment is intended to permit the aircraft to configure for the final approach segment and to slow to a normal approach speed. Generally this is a level segment or a segment that has a low descent gradient so its purpose can be accomplished.

When there is a PT or HILPT at the FAF and there isn't an IF, the intermediate segment is designated to begin after the PT or HILPT is completed. In this case, the PT is required to connect the initial segment with the intermediate segment. This is true regardless of whether or not the initial segment course and intermediate segment course are the same and in fact in most cases they are the same course. So, the PT is the maneuver that is required to align the aircraft with the intermediate course or another way of saying it is: "A procedure turn is the maneuver prescribed to perform a course reversal to establish the aircraft inbound on an intermediate or final approach course."

The intermediate course connects to the final approach segment and allows the aircraft to transition to the proper configuration and speed for the descent.

Note: If you load this approach using the GNS430W or GTN750, and select RID as the starting point, the hold is included in the resulting flightplan without an option for the pilot to choose if they wish to fly it or not.

The bold part has me satisfied. I was wondering what 'the box' would do. If I loaded this approach and the hold was there for a 'strange' reason that would be enough to cue me something was askew and I'd query ATC.

Afraid I'm switching teams on this one with that concern squelched. I'm now just of the opinion it's a stupid approach...and to hear they are changing the other two at this field and leaving this one alone? Face Palm

 

[aterpster]

...and to hear they are changing the other two at this field and leaving this one alone? Face Palm

The plan was to remove the "or GPS" but otherwise leave it a mess.

My organization has objected and have been assured it will be changed. Simply put, it does not come close to being compliant with criteria.

The screwed up TERPs maps are on the FAA coordination website for the world to see.

Apparently, the newer younger developers do not understand VOR approach criteria. Further, they apparently just accepted the noncompliant 1995 design.

That's your federal tax dollars at work.