"Dave Butler" wrote in message
...

I think the ambiguity is whether a visual approach (for example) is a
"newly
assigned altitude".

There is no ambiguity whatsoever about a being "Cleared for the visual" --
you may descend at will and you need not acknowledge this to ATC.

The only question of ambiguity comes up with the "pilot discretion"
clearance, although I believe the initial acknowledment "out of 5000 for
3000 pilot discretion" meets the requirement in the AIM. I am acknowledging
that I will descend to 3000 but that the rate of the descent will be at my
discretion -- whether that is 500 FPM or 1000FPM or 10FPM or 0FPM or whether
the rate varies during the descent, I am still complying with the altitude
clearance I was assigned.

Let us suppose you are correct that an initial acknowledgment "out of 5000
for 3000 pilot discretion" is not sufficient but instead I need to report
when I choose to begin the descent. Well, if that were true, then what
would happen when I accept the altitude assignment "N102KY will maintain
3000 BLOCK 5000"? With a block altitude, do I have to report every time I
change altitude?

I think the question of whether a report is required hinges on whether a
clearance for a visual approach is a "newly assigned altitude". I don't
think
it's clear cut, but I see the rationale for your interpretation.


Again, there may be some ambiguity a delayed descent after a "pilot
discretion" clearance. There is no ambiguity a "Cleared for the Visual"
clearance -- you may descend at will without notifying ATC other than
acknowledging the clearance. The same is true as well if you are cleared
for an instrument approach -- you may descend at will per published routes
and/or published safe altitudes with no further acknowledgment to ATC.

In fact, that is an interesting corollary to this thread. Suppose you are
flying enroute cleared DIRECT to your destination and ATC gives you the very
short instruction "N102KY Cleared Approach XXY Airport." I maintain that in
this situation you may descend at will as you choose for any visual or
instrument approach and you need not report any altitude changes to ATC.
You need only acknowledge the approach clearance and then you may descend at
will.

--
Richard Kaplan, CFII

www.flyimc.com