B A R R Y wrote:
Steven P. McNicoll wrote:
B A R R Y wrote:

You're still VFR while flying IFR practice approaches. No
separation or terrain warning is provided.


FAA policy is to provide separation to VFR aircraft while conducting
practice instrument approaches where it is practical to do so. Generally,
that means Class D airspace or higher with good radar coverage.


Some background:


Order JO 7210.3V Facility Operation and Administration

Part 2. AIR ROUTE TRAFFIC CONTROL CENTERS

Chapter 6. En Route Operations and Services

Section 4. Services

6-4-4. PRACTICE INSTRUMENT APPROACHES

To the extent practicable, each ARTCC should provide IFR separation to
aircraft not on IFR flight plans conducting practice instrument approaches
to airports where that ARTCC provides approach control service.

a. At locations where IFR separation is applied to VFR aircraft conducting
practice instrument approaches and that airport has a nonapproach control
tower or an AFSS/FSS, provisions for handling such aircraft, including
aircraft being provided DF services, shall be included in a letter of
agreement.

b. ARTCCs shall issue a letter to airmen advising users of airports where
IFR separation is provided for VFR aircraft conducting practice instrument
approaches. The letter should include appropriate frequencies for the
airport concerned.



Part 3. TERMINAL AIR TRAFFIC CONTROL FACILITIES

Chapter 10. Terminal Operations, Services, and Equipment

Section 4. Services

10-4-5. PRACTICE INSTRUMENT APPROACHES

a. VFR aircraft practicing instrument approaches at the approach control's
primary airport shall be provided IFR separation in accordance with
FAAO JO 7110.65, Air Traffic Control, Chapter 4, Section 8, Approach
Clearance Procedures.

NOTE-
The primary airport is the airport from which approach control service is
provided, except for remoted facilities where the facility air traffic
manager will designate the primary airport.

b. IFR separation to VFR aircraft in accordance with FAAO JO 7110.65,
Chapter 4, Section 8, Approach Clearance Procedures, shall be provided
to all secondary airports under the approach control's jurisdiction to the
extent possible within existing resources. Where separation service is
provided to an airport with an AFSS/FSS that provides LAA, or a
nonapproach control tower, provisions for handling such aircraft, including
aircraft being provided DF service, shall be included in a LOA.

c. Where standard separation is not provided to VFR aircraft conducting
practice approaches, instruct the aircraft to maintain VFR and provide
traffic information.

d. At airports where the tower does not provide approach control service,
handle practice instrument approaches in accordance with a LOA between
the tower and the facility providing approach control service.

e. Facilities shall issue a letter to airmen advising the users of those
airports where standard separation is provided for VFR aircraft conducting
practice instrument approaches. The letter should specify which facility
will handle the aircraft practicing instrument approaches and include the
appropriate frequencies.

REFERENCE-
Para 4-5-2, Letters to Airmen.



Part 4. FLIGHT SERVICE STATIONS

Chapter 13. Flight Service Operations and Services

Section 4. Services

13-4-2. PRACTICE INSTRUMENT APPROACHES

At locations providing Local Airport Advisories (LAA) where either an
ARTCC or an approach control facility provides standard separation to
VFR aircraft practicing instrument approaches, provisions for handling
such aircraft shall be included in a letter of agreement.



Order JO 7110.65S Air Traffic Control

Chapter 4. IFR

Section 8. Approach Clearance Procedures

4-8-11. PRACTICE APPROACHES

Except for military aircraft operating at military airfields, ensure that
neither VFR nor IFR practice approaches disrupt the flow of other
arriving and departing IFR or VFR aircraft. Authorize, withdraw
authorization, or refuse to authorize practice approaches as traffic
conditions require. Normally, approaches in progress should not be
terminated.

NOTE-
The priority afforded other aircraft over practice instrument approaches is
not intended to be so rigidly applied that it causes grossly inefficient
application of services.

a. Separation.

1. IFR aircraft practicing instrument approaches shall be afforded standard
separation in accordance with Chapter 3, Chapter 4, Chapter 5, Chapter 6,
and Chapter 7 minima until:

(a) The aircraft lands, and the flight is terminated, or

(b) The pilot cancels the flight plan.

2. Where procedures require application of IFR separation to VFR aircraft
practicing instrument approaches, standard IFR separation in accordance
with Chapter 3, Chapter 4, Chapter 5, Chapter 6, and Chapter 7 shall be
provided. Controller responsibility for separation begins at the point where
the approach clearance becomes effective. Except for heavy aircraft/B757,
500 feet vertical separation may be applied between VFR aircraft and
between a VFR and an IFR aircraft.

REFERENCE-
FAAO JO 7210.3, Para 6-4-4, Practice Instrument Approaches.
FAAO JO 7210.3, Para 10-4-5, Practice Instrument Approaches.

3. Where separation services are not provided to VFR aircraft practicing
instrument approaches, the controller shall;

(a) Instruct the pilot to maintain VFR.

(b) Advise the pilot that separation services are not provided.

PHRASEOLOGY-
"(Aircraft identification) MAINTAIN VFR, PRACTICE APPROACH APPROVED, NO
SEPARATION SERVICES PROVIDED."

(c) Provide traffic information or advise the pilot to contact the
appropriate facility.

4. If an altitude is assigned, including at or above/below altitudes, the
altitude specified must meet MVA, minimum safe altitude, or
minimum IFR altitude criteria.

REFERENCE-
FAAO JO 7110.65, Para 7-7-5, Altitude Assignments.

5. All VFR aircraft shall be instructed to maintain VFR on initial contact
or as soon as possible thereafter.

NOTE-
This advisory is intended to remind the pilot that even though ATC is
providing IFR-type instructions, the pilot is responsible for compliance
with the applicable parts of the CFR governing VFR flight.

b. Missed Approaches.

1. Unless alternate instructions have been issued, IFR aircraft are
automatically authorized to execute the missed approach depicted
for the instrument approach being flown.

REFERENCE-
FAAO JO 7110.65, Para 4-8-9, Missed Approach.

2. VFR aircraft are not automatically authorized to execute the missed
approach procedure. This authorization must be specifically requested
by the pilot and approved by the controller. When a missed approach
has been approved, separation shall be provided throughout the
missed approach.

REFERENCE-
FAAO JO 7110.65, Para 7-2-1, Visual Separation.



Aeronautical Information Manual
Official Guide to Basic Flight Information and ATC Procedures

Chapter 4. Air Traffic Control

Section 3. Airport Operations

4-3-21. Practice Instrument Approaches

a. Various air traffic incidents have indicated the necessity for adoption
of measures to achieve more organized and controlled operations where
practice instrument approaches are conducted. Practice instrument
approaches are considered to be instrument approaches made by
either a VFR aircraft not on an IFR flight plan or an aircraft on an IFR
flight plan. To achieve this and thereby enhance air safety, it is Air
Traffic's policy to provide for separation of such operations at locations
where approach control facilities are located and, as resources permit, at
certain other locations served by ARTCCs or parent approach control
facilities. Pilot requests to practice instrument approaches may be approved
by ATC subject to traffic and workload conditions. Pilots should anticipate
that in some instances the controller may find it necessary to deny approval
or withdraw previous approval when traffic conditions warrant. It must be
clearly understood, however, that even though the controller may be
providing separation, pilots on VFR flight plans are required to comply with
basic VFR weather minimums (14 CFR Section 91.155). Application of ATC
procedures or any action taken by the controller to avoid traffic
conflictions does not relieve IFR and VFR pilots of their responsibility to
see-and-avoid other traffic while operating in VFR conditions (14 CFR
Section 91.113). In addition to the normal IFR separation minimums (which
includes visual separation) during VFR conditions, 500 feet vertical
separation may be applied between VFR aircraft and between a VFR aircraft
and the IFR aircraft. Pilots not on IFR flight plans desiring practice
instrument approaches should always state `practice' when making requests to
ATC. Controllers will instruct VFR aircraft requesting an instrument
approach to maintain VFR. This is to preclude misunderstandings between the
pilot and controller as to the status of the aircraft. If pilots wish to
proceed in accordance with instrument flight rules, they must specifically
request and obtain, an IFR clearance.

b. Before practicing an instrument approach, pilots should inform the
approach control facility or the tower of the type of practice approach
they desire to make and how they intend to terminate it, i.e., full-stop
landing, touch-and-go, or missed or low approach maneuver. This
information may be furnished progressively when conducting a series
of approaches. Pilots on an IFR flight plan, who have made a series of
instrument approaches to full stop landings should inform ATC when
they make their final landing. The controller will control flights
practicing instrument approaches so as to ensure that they do not
disrupt the flow of arriving and departing itinerant IFR or VFR aircraft.
The priority afforded itinerant aircraft over practice instrument
approaches is not intended to be so rigidly applied that it causes
grossly inefficient application of services. A minimum delay to itinerant
traffic may be appropriate to allow an aircraft practicing an
approach to complete that approach.

NOTE-
A clearance to land means that appropriate separation on the landing runway
will be ensured. A landing clearance does not relieve the pilot from
compliance with any previously issued restriction.

c. At airports without a tower, pilots wishing to make practice instrument
approaches should notify the facility having control jurisdiction of the
desired approach as indicated on the approach chart. All approach control
facilities and ARTCCs are required to publish a Letter to Airmen depicting
those
airports where they provide standard separation to both VFR and IFR aircraft
conducting practice instrument approaches.

d. The controller will provide approved separation between both VFR and IFR
aircraft when authorization is granted to make practice approaches to
airports where an approach control facility is located and to certain other
airports served by approach control or an ARTCC. Controller responsibility
for separation of VFR aircraft begins at the point where the approach
clearance becomes effective, or when the aircraft enters Class B or Class C
airspace, or a TRSA, whichever comes first.

e. VFR aircraft practicing instrument approaches are not automatically
authorized to execute the missed approach procedure. This authorization
must be specifically requested by the pilot and approved by the controller.
Separation will not be provided unless the missed approach has been
approved by ATC.

f. Except in an emergency, aircraft cleared to practice instrument
approaches must not deviate from the approved procedure until cleared
to do so by the controller.

g. At radar approach control locations when a full approach procedure
(procedure turn, etc.,) cannot be approved, pilots should expect to be
vectored to a final approach course for a practice instrument
approach which is compatible with the general direction of traffic at that
airport.

h. When granting approval for a practice instrument approach, the controller
will usually ask the pilot to report to the tower prior to or over the final
approach fix inbound (nonprecision approaches) or over the outer marker or
fix used in lieu of the outer marker inbound (precision approaches).

i. When authorization is granted to conduct practice instrument approaches
to an airport with a tower, but where approved standard separation is not
provided to aircraft conducting practice instrument approaches, the tower
will approve the practice approach, instruct the aircraft to maintain VFR
and issue traffic information, as required.

j. When an aircraft notifies a FSS providing Local Airport Advisory to the
airport concerned of the intent to conduct a practice instrument approach
and whether or not separation is to be provided, the pilot will be
instructed to contact the appropriate facility on a specified frequency
prior to initiating the approach. At airports where separation is not
provided, the FSS will acknowledge the message and issue known traffic
information but will neither approve or disapprove the approach.

k. Pilots conducting practice instrument approaches should be particularly
alert for other aircraft operating in the local traffic pattern or in
proximity to the airport.




Some local data points.

I flew three practice approaches tonight (7/29).

#1 - LDA 2 into KHFD. BDL Approach specifically stated "remain VFR".
HFD Tower called out so much traffic, I couldn't call my missed. None
of the traffic was anything near IFR separation.


There is no mention of practice approaches in the Bradley
TRACON/Hartford-Brainerd FCT Letter of Agreement. Bradley TRACON has
provided no Letters to Airmen to the Facility Directives Repository.

You state, "None of the traffic was anything near IFR separation." Was any
of that traffic IFR? HFD has Class D airspace. No separation is provided
between IFR and VFR aircraft in Class D airspace, so no separation would be
provided between IFR aircraft and VFR aircraft on practice instrument
approaches. Even if there were provisions for separation for VFR aircraft
on instrument approaches at HFD, visual separation is an approved method of
IFR separation and that can be pretty close.



#2 - ILS 5 to KGON. PVD Approach stated "Remain VFR, no traffic
separation provided" KGON tower controller seemed pretty bored, I was
the only thing around.


Providence ATCT has provided no Letters to Airmen to the Facility Directives
Repository.

The Providence ATCT/Groton FCT Letter of Agreement states:

Providence Airport Traffic Control Tower (PVD ATCT) shall:

(1) Exercise control jurisdiction for all aircraft operating IFR and SVFR to
or from the GON Airport within PVD ATCT delegated airspace, and shall apply
standard IFR separation to all practice approaches.




#3 - VOR-A to KIJD. PVD Approach stated "Remain VFR, no traffic
separation provided after ORW VOR." He did have me keep the squawk
all the way to the airport, even after switching to CTAF.


KIJD has no control tower or FSS, it seems to be a bit short on resources.
I have to wonder why the controller was providing separation at all.