FAA ambiguity

Begin rant mode.....
There is a thread in the IFR newsgroup regarding pattern entry that
currently has over 50 posts and offers many differing opinions on the
subject. Many of these disparate positions have merit. This rant is
not about pattern entry or the expected personality clashes or even
the flames that thread of this type are filled with.

What bothers me, and what I find to be absolutely incredible, is the
lack of clear direction that is provided by the numerous documents
that are produced by the FAA. The aforementioned thread is a good
example. I believe, possibly incorrectly, that most of the regulars
that frequent the aviation newsgroups are generally knowledgeable and
have a more than casual interest in the subject of aviation. The very
fact that so many experienced pilots can disagree on a subject as
basic as pattern entry is an indication to me that the FAA failed in
it's regulatory responsibilities. Surely, one would think that
between the FAR and the AIM that this, and many similar issues, would
be addressed definitively, but such is not the case. With many
issues, they seem to dance all around the subject without really
addressing it in a manner that cannot be misconstrued or
misinterpreted. I can't think of any other facet of my life where I
face so much regulation that does so little to define the proper
parameters for compliant operation.

Sorry for babbling on, but how can it be that this situation has
existed for so long without remedy? I work in a bureaucracy and
regularly deal with other bureaucracies, but I can find to parallel to
this example.

....End rant mode

Rich Russell

If you are referring to VFR pattern entry, here's what the FAA says is
correct:

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/74c9017c9457e4ab862569d800780551/$FILE/AC90-66A.pdf




"Richard Russell" wrote in message
news
Begin rant mode.....
There is a thread in the IFR newsgroup regarding pattern entry that
currently has over 50 posts and offers many differing opinions on the
subject. Many of these disparate positions have merit. This rant is
not about pattern entry or the expected personality clashes or even
the flames that thread of this type are filled with.

What bothers me, and what I find to be absolutely incredible, is the
lack of clear direction that is provided by the numerous documents
that are produced by the FAA. The aforementioned thread is a good
example. I believe, possibly incorrectly, that most of the regulars
that frequent the aviation newsgroups are generally knowledgeable and
have a more than casual interest in the subject of aviation. The very
fact that so many experienced pilots can disagree on a subject as
basic as pattern entry is an indication to me that the FAA failed in
it's regulatory responsibilities. Surely, one would think that
between the FAR and the AIM that this, and many similar issues, would
be addressed definitively, but such is not the case. With many
issues, they seem to dance all around the subject without really
addressing it in a manner that cannot be misconstrued or
misinterpreted. I can't think of any other facet of my life where I
face so much regulation that does so little to define the proper
parameters for compliant operation.

Sorry for babbling on, but how can it be that this situation has
existed for so long without remedy? I work in a bureaucracy and
regularly deal with other bureaucracies, but I can find to parallel to
this example.

...End rant mode

Rich Russell

AIM 3-2-1 says that it is the responsibility of the pilot to insure that ATC
clearance or radio communication requirements are met prior to entry into
Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services. Which
is right?? You will learn that the FAA has many hands, and few of them know
what the others are doing. It also has fiefdoms, called regions, which
interpret the regulations in unique ways.

Bob Gardner

"Richard Russell" wrote in message
news
Begin rant mode.....
There is a thread in the IFR newsgroup regarding pattern entry that
currently has over 50 posts and offers many differing opinions on the
subject. Many of these disparate positions have merit. This rant is
not about pattern entry or the expected personality clashes or even
the flames that thread of this type are filled with.

What bothers me, and what I find to be absolutely incredible, is the
lack of clear direction that is provided by the numerous documents
that are produced by the FAA. The aforementioned thread is a good
example. I believe, possibly incorrectly, that most of the regulars
that frequent the aviation newsgroups are generally knowledgeable and
have a more than casual interest in the subject of aviation. The very
fact that so many experienced pilots can disagree on a subject as
basic as pattern entry is an indication to me that the FAA failed in
it's regulatory responsibilities. Surely, one would think that
between the FAR and the AIM that this, and many similar issues, would
be addressed definitively, but such is not the case. With many
issues, they seem to dance all around the subject without really
addressing it in a manner that cannot be misconstrued or
misinterpreted. I can't think of any other facet of my life where I
face so much regulation that does so little to define the proper
parameters for compliant operation.

Sorry for babbling on, but how can it be that this situation has
existed for so long without remedy? I work in a bureaucracy and
regularly deal with other bureaucracies, but I can find to parallel to
this example.

...End rant mode

Rich Russell

On Wed, 5 Jan 2005 13:51:59 -0800, "Bob Gardner"
wrote:

AIM 3-2-1 says that it is the responsibility of the pilot to insure that ATC
clearance or radio communication requirements are met prior to entry into
Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services. Which
is right?? You will learn that the FAA has many hands, and few of them know
what the others are doing. It also has fiefdoms, called regions, which
interpret the regulations in unique ways.

Bob Gardner

That's exactly my point. My state's driving manual does a better job
of making it clear what your responsibilites are when driving than the
FAA does for flying. For many topics you can cite FARs, AIM quotes,
advisory circulars and FAA FAQs and still have pilots disagree on what
is being said. I find it amazing that this is acceptable to the
flying community. I guess at least part of the problem is that we
can't fix it and the FAA doesn't acknowledge the problem.
Rich Russell

"Richard Russell" wrote in message
...
On Wed, 5 Jan 2005 13:51:59 -0800, "Bob Gardner"
wrote:

AIM 3-2-1 says that it is the responsibility of the pilot to insure that
ATC
clearance or radio communication requirements are met prior to entry into
Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services.
Which
is right?? You will learn that the FAA has many hands, and few of them
know
what the others are doing. It also has fiefdoms, called regions, which
interpret the regulations in unique ways.

Bob Gardner

That's exactly my point. My state's driving manual does a better job
of making it clear what your responsibilites are when driving than the
FAA does for flying. For many topics you can cite FARs, AIM quotes,
advisory circulars and FAA FAQs and still have pilots disagree on what
is being said. I find it amazing that this is acceptable to the
flying community. I guess at least part of the problem is that we
can't fix it and the FAA doesn't acknowledge the problem.
Rich Russell

The fix could be much worse than what we have now. Be careful what you ask
for, you might get it.

Bob Gardner wrote:

AIM 3-2-1 says that it is the responsibility of the pilot to insure that ATC
clearance or radio communication requirements are met prior to entry into
Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services. Which
is right??

I don't see any conflict. The AIM tells me that it's my responsibility to handle
things before I enter the controller's airspace and the ATCH says it's the
controllers' responsibility after I get in there. Two different scenarios and
locations in the air.

George Patterson
The desire for safety stands against every great and noble enterprise.

I can't count the number of times I have been flying with a student on
flight following, and upon approaching Class D airspace hear the question
"Should I switch over to the tower?" I think the existing situation is
confusing to many pilots. Added to this, and extending the thread a tad, is
the situation where the tower has ceded the top 500 feet of its D airspace
to the overlying approach control, so the student learns, to his surprise,
that he need not call the tower at all but can stay with approach. This is
not a big deal except that it leads to a lot of unnecessary transmissions:
"Approach, BuzzBird 35X, should I switch over to the tower now?" "Negative,
stay with me."

Bob Gardner

"G.R. Patterson III" wrote in message
...


Bob Gardner wrote:

AIM 3-2-1 says that it is the responsibility of the pilot to insure that
ATC
clearance or radio communication requirements are met prior to entry into
Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services.
Which
is right??

I don't see any conflict. The AIM tells me that it's my responsibility to
handle
things before I enter the controller's airspace and the ATCH says it's the
controllers' responsibility after I get in there. Two different scenarios
and
locations in the air.

George Patterson
The desire for safety stands against every great and noble enterprise.

"Bob Gardner" wrote in message
...
AIM 3-2-1 says that it is the responsibility of the pilot to insure that
ATC clearance or radio communication requirements are met prior to entry
into Class B, C, or D airspace; the Air Traffic Control Handbook tells
controllers that it is their responsibility to coordinate the passage
through that airspace of flights to which they are providing services.
Which is right??

Perhaps both? I don't see the inconsistency. If I'm in two-way contact with
ATC for flight following, then I've met my responsibility under 91.129c1 or
91.130c1 with respect to transiting Class C or D (Class B, of course,
requires an explicit clearance). Additionally, the controller may have some
responsibility to coordinate with other controllers, as per the ATC
Handbook.

--Gary

Recently, Bob Gardner posted:

AIM 3-2-1 says that it is the responsibility of the pilot to insure
that ATC clearance or radio communication requirements are met prior
to entry into Class B, C, or D airspace; the Air Traffic Control
Handbook tells controllers that it is their responsibility to
coordinate the passage through that airspace of flights to which they
are providing services. Which is right??

Perhaps it's a matter of how one reads these things? For example, I
interpret your above statement as follows:

* The ATC handbook states that controllers must coordinate the passage
through their airspace.

* AIM 3-2-1 says that pilots must adhere to the instructions of ATC prior
to entry into Class B, C, D airspace.

In other words, pilots must follow the instructions they are given by ATC
before entering controlled airspace. Ergo, all pattern entry in controlled
airspace is determined by ATC. Where's the conflict?

Neil

"Richard Russell" wrote in message
news

Sorry for babbling on, but how can it be that this situation has
existed for so long without remedy? I work in a bureaucracy and
regularly deal with other bureaucracies, but I can find to parallel to
this example.


1. Because the real world is simply too complicated for "perfect"
regulations which have no room for misinterpretation or ambiguity.

2. Because the regs were written a long time ago in a more innocent age when
precision wasn't so important.

3. Because ambiguity serves the FAA's bureaucratic interests by giving it
the wiggle room to interpret things its way when it serves its purpose.

-cwk.