You are skipping over the part of the regulation which states that the
"point at which the turn may be commenced" is up to the pilot.


No, I'm not skipping that at all. I'm simply pointing out that if the pilot
is permitted to degenerate the entire thing down to just the reversal
itself, how is it that logic doesn't also show that the pilot can degenerate
the entire thing down to the final turn to the final approach course?

After all, ALL of the elements of the "reversal" are at the pilot's
discretion. A 90 degree left turn is "the same" as a 270 degree right turn.
If a 270 degree right turn is allowed, then a 90 degree left turn is too.



The difference between the 90 degree left turn and all of the
variations of the procedure turn (even with a zero-length outbound leg)
is that all those variations have you *established* on the final
approach course *prior* to reaching the FAF. In this sense the 90
degree left turn is not equal to the 270 right turn.

To me this seems the conceptual basis for the fact that the regs
require the procedure turn when it often doesn't "seem" that it should
be necessary.

Now if you happen to be coming from a direction where you *are* already
aligned on the final approach course and at the proper altitude prior
to reaching the FAF, I would agree that it doesn't make sense to do the
PT (though it may still be technically required by the regs). The
basis *I* use for skipping the turn in this case is: 1) I am flying a
hold-in-lieu-of-procedure turn, plus 2) I am established in the hold by
virtue of being established (+/- 10 degrees) on the inbound course
prior to reaching the holding point (the FAF). Ok, its a stretch, but
that's how I look at it!


Cheers,
John Clonts
Temple, Texas