Procedure Turn or Not KPWM ILS 29 from CDOGG1 Arrival
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aterpster
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aterpster
As usual, when you know you're wrong you revert to form.
aterpster
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aterpster
But, it wouldn't be had the left hand and the right hand coordinated the design of the STAR and the IAP.
aterpster
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aterpster
Or the controller could take them off the STAR and use the direct-to-the-IF option. But, most of them don't understand how to properly do that one.
roncachamp
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It's a question. Answer it or ignore it, but drop the attitude.
John Collins
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Since this case the fix is an IF/IAF, one could be cleared direct to the fix as it is an IAF, straight in, but if it were only an IF, that isn't yet permitted on a non GPS or RNAV approach. There is a good possibility it will be in the future, but not yet.
aterpster
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aterpster
You are correct.
aterpster
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aterpster
I recommend you take it to AFS-420 since you have beat it to death here. They are the office of responsibility for IAP procedural issues in the AIM. I would suggest, though, that you not tell them they don't understand the FARs, as you posted here. It won't help any dialogue you may have with them.
roncachamp
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I recommend you take it to AFS-420 since you have beat it to death here. They are the office of responsibility for IAP procedural issues in the AIM. I would suggest, though, that you not tell them they don't understand the FARs, as you posted here. It won't help any dialogue you may have with them.
The statements in the AIM are evidence that they do not understand the FARs.
poadeleted20
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Since they help write those particular FARs...
roncachamp
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If you're trying to say they don't understand what they write I certainly wont dispute it.
poadeleted20
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snoboy
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According to my training AND my interpretation of the regulations this is THE logical answer.
aterpster
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aterpster
You do have a point about FAA management orders, etc., and in particular the 7110.65 and related directives and newsletters.
roncachamp
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Yes, them as well.
roncachamp
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Please explain how logic and your training lead to that interpretation of the regulations.
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Velocity173
Listen, it's quite clear you didn't even realize there were exceptions to not having to do a procedure turn. Instead of admitting your error you just rambled on about regulatory things. Not every thing we do in aviation is governed by the FARs (SOPs, Op Specs). Also you still haven't answered my question of the definition of NoPT according to 97.3. If PTs aren't required, why even have NoPT on an approach plate in the first place? So we just arbitrarily do them and you just sit back and find out by observing a target turning outbound? As Ron has said it's part of the SIAP. Not doing it would be like not complying with a required course or altitude on the approach.
roncachamp
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Oh, I don't mind admitting an error, but before I can admit an error I have to err. Are procedure turns one of the things we do in aviation that is governed by the FARs?
I answered your question in message #64.
Ron has proven to be an unreliable source of information.
poadeleted20
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Yeah -- every time I disagree with Steven, he says I'm unreliable. And, apparently, so is the FAA Flight Standards Service.
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Velocity173
OK let me get this straight. You work at a facility that has a PT. You have pilots that randomly do this PT and some that don't. You have no idea if they are going to do it because they don't tell you. How is that positive control? Sounds like reactive control to me.
Look at Taters situation. It's obvious he thought he was going to do a straight in just like you would believe. If he was to assume that and have other aircraft behind him it would screw up the whole plan. Just like I said, the confusion exists because controllers think we are going to inform them that we are doing this REQUIRED PT. Then when we do it we get chewed out because we didn't tell them. By the FAA requiring this procedure, it eliminates the need to constantly inform ATC what we are doing while reducing frequency congestion.
The only thing that I'll give you on this whole discussion is that it probably wouldn't require the need to be mandatory since it's at a IAF/IF. aterpster could probably explain that. We didn't cover PTs in detail in my TERPs class. The fact is until they change the plates it's mandatory based on the definitions in the FARs of HILPT, NoPT and in this case their SOP.
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roncachamp
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Are you referring to this portion of what I wrote in post #64?
If so, you missed the part in bold blue.
How does the plan get screwed up for following traffic by the front guy skipping the PT?
Then the regulations should be changed to state when PTs are required. I'll let you take the lead on that.
But it's not mandatory based on the definitions in the FARs of HILPT, NoPT, and PT. Confusion exists because the FARs and AIM do not agree, see post #51 for the explanation.
Sheesh. It seems simple to me, but maybe that's because I am a lawyer, and have to deal with judicial interpretations of arcane regulations all the time - made worse, when the "judge" administering the reg is an ALJ. The agency almost always wins.
But I digress (and who would expect that from me?).
If I am cleared for the approach and am approaching from any directions from which the "No PT" notation does not apply, I must, if I am to fly the Approach as published, fly the PT.
If I found myself in Captain's position and wished not to fly the PT (and assuming I am in a RADAR environment), I'd simply request radar vectors to the final approach course.
Many and many are the times I have observed lawyers arguing against the application of mildly ambiguous rules and regs, and most frequently, such arguments are met with rolling eyes and harsh rulings... more so in administrative law, where the ALJ almost never goes counter to the agency's attack dogs. In this instance, If I were approached by a pilot who had been violated for bypassing the PT, I'd tell him or her that the best angle would be to hope for leniency based upon the SIAP's "ambiguity," and I would hope the pilot in question had filed an ASRS report.
But I digress (and who would expect that from me?).
If I am cleared for the approach and am approaching from any directions from which the "No PT" notation does not apply, I must, if I am to fly the Approach as published, fly the PT.
If I found myself in Captain's position and wished not to fly the PT (and assuming I am in a RADAR environment), I'd simply request radar vectors to the final approach course.
Many and many are the times I have observed lawyers arguing against the application of mildly ambiguous rules and regs, and most frequently, such arguments are met with rolling eyes and harsh rulings... more so in administrative law, where the ALJ almost never goes counter to the agency's attack dogs. In this instance, If I were approached by a pilot who had been violated for bypassing the PT, I'd tell him or her that the best angle would be to hope for leniency based upon the SIAP's "ambiguity," and I would hope the pilot in question had filed an ASRS report.
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Velocity173
No this is your view on it. This is also a total assumption. Don't tell me you wouldn't do what the controller did in ASRS # 2. You know darn well the majority of controllers believe the pilot has to be either cleared for it or the pilot must tell you he's doing it. Both incorrect.
roncachamp
Final Approach
What arcane regulation are you interpreting to mean that? Must you still do that if the controller adds "straight-in" to the clearance?
roncachamp
Final Approach
That's a question; it doesn't provide any view or assumption.
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Velocity173
But that's the reason why the FAA makes it mandatory. To prevent controllers from assuming things. Would you have reacted the same way as controller in # 2? Also I asked why even have NoPT on an approach plate if PTs aren't required anyway? Your answer is it's required in some cases. What cases?
Whether the pilot thinks its useful or not is irrelevant though, it's not within his operating scope to make that determination, he is bound to the procedure as published without one of the listed intervening factors. The controller OTOH does have within his published scope of possibilities to determine it useful or not and issue vectors making the entire issue moot.
Although the Chief Counsel cited 97.3, I find 92.20(b) more instructive:
[emphasis added]
Since the approach procedures are incorporated into the regulations by reference, it then becomes a matter of interpreting the approach document. (Of course, that can be the subject of debate in itself!
)
aterpster
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aterpster
Although the Chief Counsel cited 97.3, I find 92.20(b) more instructive:
[emphasis added]
Since the approach procedures are incorporated into the regulations by reference, it then becomes a matter of interpreting the approach document. (Of course, that can be the subject of debate in itself!
It shouldn't be. If a SIAP has a course reversal and the route you are flying does not state NoPT" or does not lead to a route with "NoPT" then the procedure requires you to do the course reversal with the exception of the ATC interventions set forth in 91.177 or, with RNAV, a compliant clearance to the intermediate fix.
roncachamp
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Wouldn't it be better to do it the other way round? What's the downside in not flying an unneeded course reversal?
Nope.
As I said in post #71:
aterpster
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aterpster
Is this a regulatory/directive discussion or is it about your personal preferences?
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Velocity173
FIG 4-8-2.)
FIG 4-8-2
Approach Clearance Example
For RNAV Aircraft
EXAMPLE-
Aircraft 1 can be cleared direct to CENTR. The intercept angle at that IAF is 90 degrees or less. The minimum altitude for IFR operations (14 CFR Section 91.177) along the flight path to the IAF is 3,000 feet. If a hold in lieu of pattern is depicted and a straight-in area is not defined (e.g.,“ No PT” indicated at the fix), the aircraft must be instructed to conduct a straight-in approach if ATC does not want the pilot to execute a procedure turn.“Cleared direct CENTR, maintain at or above three thousand until CENTR, cleared straight-in R-NAV Runway One Eight approach.”
I don't know why the controller would have to clear the aircraft for a straight in. Clearly the pilot has less than a 90 degree intercept here. Possibly because the PT is REQUIRED???
FIG 4-8-2
Approach Clearance Example
For RNAV Aircraft
EXAMPLE-
Aircraft 1 can be cleared direct to CENTR. The intercept angle at that IAF is 90 degrees or less. The minimum altitude for IFR operations (14 CFR Section 91.177) along the flight path to the IAF is 3,000 feet. If a hold in lieu of pattern is depicted and a straight-in area is not defined (e.g.,“ No PT” indicated at the fix), the aircraft must be instructed to conduct a straight-in approach if ATC does not want the pilot to execute a procedure turn.“Cleared direct CENTR, maintain at or above three thousand until CENTR, cleared straight-in R-NAV Runway One Eight approach.”
I don't know why the controller would have to clear the aircraft for a straight in. Clearly the pilot has less than a 90 degree intercept here. Possibly because the PT is REQUIRED???
roncachamp
Final Approach
The controller doesn't have to clear the aircraft for a straight-in, "the aircraft must be instructed to conduct a straight-in approach if ATC does not want the pilot to execute a procedure turn.“
Required by what though? Not by the need for a course reversal, else it wouldn't be at the controller's option. Not by the FARs. Not by any obstacle clearance issues. It's required only by a statement in a self-described advisory publication. Has it truly not occurred to you that if the controller can remove that requirement by adding "straight-in" to the approach clearance there's no actual need for it?
Let's say you're flying Aircraft #1 and there are no other aircraft inbound to the airport. ATC clears you for the approach. If the clearance includes "straight-in" you join the FAC at CENTR, if it doesn't include "straight-in" you take a lap. The only difference is taking a lap means you fly about four minutes longer than needed. There's no ATC issue because there's no other traffic.
Now let's say you're flying Aircraft "1 and Aircraft #2 is inbound via LEFTT. ATC clears you for the approach and clears Aircraft #2 to hold at CENTR, #2 will be cleared for the approach once you cancel IFR. ATC doesn't want to delay Aircraft #2 any longer than necessary so the controller includes "straight-in" with your approach clearance. But even if he doesn't include it there's still no ATC issue because Aircraft #2 still holds at CENTR until you cancel IFR.
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Required by the simple fact it doesn't say NoPT. It seems that you believe it's only required if the turn is greater that 90 degrees. Nope, 7110.65 just says if it's over 90 degrees the aircraft must be allowed the PT. This situation it's still required because it says you MUST clear him for a straight in if you don't want him to do a PT. Obviously this statement is in the 7110.65 because the pilot will do a PT unless otherwise cleared. Pretty cut and dry to me. Plus going back to your sit back and watch attitude just isn't positive control. Even if I had no traffic I just wouldn't observe an IFR aircraft and not even know if he is going to do a PT until I see him turn outbound. By making it mandatory it allows the controller to know exactly what the pilot's intentions are regardless of traffic while reducing confusion/freq congestion. As IFR pilots, how many optional things do we just randomly do without talking to ATC in the NAS? Seems like that would be a recipe for disaster to me.
And yes, if for sequencing, you can give him a staight in if less than 90 degrees. The biggest thing you're not grasping is that the PT is part of the course. It's part of the SIAP. That's why it's in bold. It's not an arrival pattern. It's required.
I just realized Henning has spoken on the previous page. That makes it offical. PT required unless the exceptions apply. End of case.
aterpster
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aterpster
That would be correct for an RNAV IAP provided the controller complies with all the requirements set forth in the 7110.65 and AIM for a straight-in from an IF. In this case the IAP is an ILS so a straight-in would require a vector to final in accordance with Chapter 5 of the 7110.65.
Having said all of that, this particular instance is an example of lousy melding of a STAR with an ILS IAP. An NoPT initial segment should have been added to make the STAR an operational advantage rather than a road block.
roncachamp
Final Approach
Please cite the FAR that supports that assertion.
I believe a course reversal is required when it's necessary to reverse course. Am I wrong?
Works for me, but we're talking about a situation where the turn is less than 90°.
But I don't have to clear him for a straight-in if it doesn't matter if he does a PT or not.
It's obvious to me this statement is in JO 7110.65 because the statement, "The procedure turn or hold-in-lieu-of-PT is a required maneuver when it is depicted on the approach chart, unless cleared by ATC for a straight-in approach", is in AIM paragraph 5-4-9.a. The question remains, why does the AIM make executing the course reversal the default when the PT or hold-in-lieu-of-PT is not required by the procedure?
Positive Control is the separation of all air traffic within designated airspace by ATC. It's rather meaningless when there is no other traffic.
Why? If there's no other traffic flying or not flying the PT doesn't matter to ATC.
Making the straight-in mandatory would preclude pilots from making the course reversal when the PT or HILPT is not required by the procedure but they would prefer to do so anyway, as you described in message #6. I already know the pilot's intention, it's to fly the approach and land. Whether or not he elects to do the course reversal is unnecessary information when there's no other traffic.
It probably wouldn't if you had a controller's knowledge of ATC.
But it's not required by the FARs, it's required by a statement in a self-described advisory publication that was put there by folks who obviously do not have a good understanding of ATC. The AIM recognizes that the course reversal is not always required by the procedure, examine the note that follows paragraph 5-4-9.a.:
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Velocity173
I did ATC for 8 yrs and if I did it in your haphazard way I would have been fired. Your lack of control in this situation is almost like the vision of Free Flight. While I agree with the principles of Free Flight it doesn't cover this situation in the present day. Watching a random PT unfold is no different than watching an aircraft assume his own route without telling ATC. Who cares if there isn't any traffic at the time? It's just poor lazy controlling, plan and simple.
You just simply can't get around the definition of NoPT. That means it's not required. Once again, if it's never required anyway there's no point in posted it on a plate. Your reference to the note in 5-4-9 actually supports this. "Not require by the procedure" is NoPT. If there's no NoPT indicated then common sense suggests it's required by the procedure.
What makes me laugh is your own 7110.65 clarifies it. You must clear him for a straight in if you don't want him to do a PT. I don't care how you try and warp that sentence from the 7110.65, it means the aircraft WILL do the PT if you don't give him a straight in.
You site regulations but then you give your asumptions of when you believe as a controller they should do a PT. "I believe a course reversal is required when it's necessary to reverse course." Just like the controller assumed in ASRS # 2. Well he's less than 90 degrees it shouldn't be required right? Yeah show me that in the regs. Obviously the 7110.65 doesn't care if he's less than 90 degrees because the example given shows maybe a 60 degree offset and it still has the controller issuing a straight in in order to prevent the aircraft from doing the required PT.
You also haven't acknowledged the fact that the PT is part of the SIAP. If I'm direct that fixed and get cleared for the approach I have to do it as depicted. That is regulatory. And while the AIM not being regulatory matters, It mirrors the regs. It just provides a different way of defining why a PT is required. If you can't understand the definitions of NoPT, HILPT, the requirement to adhere to an approach procedure, and the common sense guidance that the AIM provides, well then I'm sorry. It sure seems like we have a lot of professional instrument pilots and controllers here that disagree with you.
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