On Fri, 07 Oct 2005 20:39:54 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
news

Well, there are FAA facilities that do not follow the same rules as they
are published and interpreted by Washington. SoCal is another. There has
been a push to standardize these kinds of things.


Are you saying a rule was violated in this scenario? If so, what rule was
violated?



There was an old (1977) legal opinion indicating that pilots could get
authorization from ATC to eliminate PT's when they were sort of lined up
with the FAC and at an appropriate altitude. This supposedly was
eliminated by the 1994 opinion; however, that 1994 opinion (which I quoted
before) referred specifically to non-radar environments and was mute on
radar environments.


The 1994 opinion you posted does not differentiate between nonradar and
radar environments.

The full text, which has been posted previously by others, makes it clear
that the opinion refers to a non-radar environment. Here is the relevant
portion.

"This is a clarification of our response to your letter of
August 23, 1993. In that letter you requested an
interpretation of Section 91.175 of the Federal Aviation
Regulation (FAR) (14 C.F.R. Section 91.175). You address
the necessity of executing a complete Standard Instrument
Approach Procedure (SIAP) in a non-radar environment while
operating under Instrument Flight Rules (IFR). Our response
assumes that each of the specific scenarios you pose speaks
to a flight conducted under IFR in a non-radar environment."





There is no question in my mind that it would be safe to fly straight in
from the position you set up. Perhaps the simplest way of getting that
ATC facilities practice in line with the regulations would be to designate
SENNA as an IAF. The route from OSH, which includes the route from SENNA
to DEPRE, is a NoPT route, and ATC has placed me on that route crossing
SENNA.


That ATC facility's practice is already in line with the regulations.


No, it seems to me that you've set up a situation which is quite similar
to, and understood by most, to be functionally equivalent to radar vectors
to the final approach course.

It also happens to include a segment prior to the FAF which is part of a
NoPT routing from a different IAF.

However, you claim this procedure is NOT equivalent to RV to FAC.

So you've effectively ignored the ATC requirement to start an approach at
an IAF. That is a requirement for ATC unless giving radar vectors IAW
7110.65 5-9-1. You may say that DEPRE is an IAF (which it is) but it is not
being used as one in this scenario.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)