Change in AIM wording concerning procedure turn

On Thu, 06 Oct 2005 18:06:34 GMT, "Steven P. McNicoll"
wrote:


Alright, here's a real world example for you. You're flying AWI123 from
KORD to KGRB, Chicago departure puts you in the east departure track on a
360 heading and hands you off to Chicago Center. Around the Kenosha, WI,
area Chicago Center tells you to proceed direct to GRB VORTAC. Down the
road a piece you're handed off to Green Bay approach. At GRB the ILS RWY 36
approach is in use, and the approach controller notices you're present track
will intercept the localizer about fifteen miles from DEPRE, the LOM/IAF.
On initial contact you're told "descend and maintain 3,000 join the runway
36 localizer". About three minutes later you hear the same instruction
issued to EGF456. When you're about five miles from DEPRE the approach
controller says "AWI123 cleared ILS runway three six contact tower one one
eight point seven." When you reach DEPRE will you continue towards the
runway or will you start a procedure turn?

http://www.myairplane.com/databases/...s/00873I36.PDF


If I understand your scenario properly, I have intercepted the FAC about 15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

On Thu, 06 Oct 2005 17:12:16 -0400, Ron Rosenfeld
wrote:

If I understand your scenario properly, I have intercepted the FAC about 15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?

Ron,

You've lsot me a bit here. I thought your earlier posts and
references to 97.20 were arguing that a procedure turn is mandatory by
regulation in all cases when it's charted and the standard exceptions
(NoPT, vectors to final, etc.) don't apply.

The standard exceptions don't apply in this scenario proposed by
Steven.

If I misunderstood your earlier posts about 97.20, then perhaps we've
had a similar point of view all along.

I'm intrigued.

Tim.

On Thu, 06 Oct 2005 16:18:46 -0600, Tim Auckland wrote:

On Thu, 06 Oct 2005 17:12:16 -0400, Ron Rosenfeld
wrote:

If I understand your scenario properly, I have intercepted the FAC about 15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE). I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?

Ron,

You've lsot me a bit here. I thought your earlier posts and
references to 97.20 were arguing that a procedure turn is mandatory by
regulation in all cases when it's charted and the standard exceptions
(NoPT, vectors to final, etc.) don't apply.

The standard exceptions don't apply in this scenario proposed by
Steven.

If I misunderstood your earlier posts about 97.20, then perhaps we've
had a similar point of view all along.

I'm intrigued.

Tim.

As I just wrote to Steve, I would have assumed that ATC was setting this up
as a "radar vectors to final situation" and queried them to ensure there
was no misunderstanding since they did not use the standard verbiage. But
the way I was set up was identical to that used for radar vectors to final.


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

"Ron Rosenfeld" wrote in message
...

If I understand your scenario properly, I have intercepted the FAC about
15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE).
I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I
should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?


Why did you not execute the procedure turn? You've not been vectored to a
final approach course or fix, you're not an a segment marked NoPT, and
you've not been cleared for a timed approach from a holding fix. Is it not
your position that if the procedure has a PT charted it must be flown unless
one of those applies?

On Fri, 07 Oct 2005 00:46:46 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
.. .

If I understand your scenario properly, I have intercepted the FAC about
15
miles South of DEPRE and then turned inbound (to the N, towards DEPRE).
I
am at 3000'. At 5 miles from DEPRE I am cleared for the approach. I
should
be below the GP at that point so I would just continue along until
intercepting the GP, and then descend into the airport.

The presence of an aircraft behind me is irrelevant.

What is your point?


Why did you not execute the procedure turn? You've not been vectored to a
final approach course or fix, you're not an a segment marked NoPT, and
you've not been cleared for a timed approach from a holding fix. Is it not
your position that if the procedure has a PT charted it must be flown unless
one of those applies?


I would have assumed this was a "radar vectors to final" situation and
queried ATC to verify, since they didn't use the magic words that I
understand to be necessary for me to assume radar vectors. But ATC has had
me lined up with the FAC for quite some distance; I've been in radar
contact; I've been assigned an appropriate altitude to intercept the GP
from below; I've not crossed any IAF prior to DEPRE.

If that confirmation is not forthcoming, then I would inform ATC that I am
obliged to execute a procedure turn at DEPRE. I would maintain my last
assigned altitude of 3000' until crossing DEPRE.


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

"Ron Rosenfeld" wrote in message
news

I would have assumed this was a "radar vectors to final" situation and
queried ATC to verify, since they didn't use the magic words that I
understand to be necessary for me to assume radar vectors.


Why would you have assumed it was a "radar vectors to final" situation if
they didn't use the magic words that you understand to be necessary to
assume radar vectors? You're not being vectored in this situation, that
should be clear.



But ATC has had
me lined up with the FAC for quite some distance; I've been in radar
contact; I've been assigned an appropriate altitude to intercept the GP
from below; I've not crossed any IAF prior to DEPRE.


The approach controller did nothing to line you up with the FAC. He simply
told you to intercept the FAC as your previous clearance of direct GRB
VORTAC crossed it some fifteen miles from the LOM at a shallow angle.



If that confirmation is not forthcoming, then I would inform ATC that I am
obliged to execute a procedure turn at DEPRE. I would maintain my last
assigned altitude of 3000' until crossing DEPRE.


And when they informed you that you weren't being vectored you'd proceed to
fly the PT turn, which upon completion you'd be in the exact same position.

Of course, that wouldn't happen. Upon informing ATC you felt obligated to
fly the PT they'd vector you out of the way of the following traffic. Then
they'd either vector you back to the FAC, which would prohibit flying the
PT, or send you direct to the IAF so you could happily fly your PT without
endangering anyone else.

On Fri, 07 Oct 2005 03:40:31 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
news

I would have assumed this was a "radar vectors to final" situation and
queried ATC to verify, since they didn't use the magic words that I
understand to be necessary for me to assume radar vectors.


Why would you have assumed it was a "radar vectors to final" situation if
they didn't use the magic words that you understand to be necessary to
assume radar vectors? You're not being vectored in this situation, that
should be clear.



But ATC has had
me lined up with the FAC for quite some distance; I've been in radar
contact; I've been assigned an appropriate altitude to intercept the GP
from below; I've not crossed any IAF prior to DEPRE.


The approach controller did nothing to line you up with the FAC. He simply
told you to intercept the FAC as your previous clearance of direct GRB
VORTAC crossed it some fifteen miles from the LOM at a shallow angle.



If that confirmation is not forthcoming, then I would inform ATC that I am
obliged to execute a procedure turn at DEPRE. I would maintain my last
assigned altitude of 3000' until crossing DEPRE.


And when they informed you that you weren't being vectored you'd proceed to
fly the PT turn, which upon completion you'd be in the exact same position.

Of course, that wouldn't happen. Upon informing ATC you felt obligated to
fly the PT they'd vector you out of the way of the following traffic. Then
they'd either vector you back to the FAC, which would prohibit flying the
PT, or send you direct to the IAF so you could happily fly your PT without
endangering anyone else.

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.

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.

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

My closing thoughts:

If I do ever find myself in the scenario described, I think I'd let
ATC know what I'm planning to do and fly straight on in.

In the apparently highly unikely case that I did get challenged by a
FAA inspector, I'd base my defense on 97.3(p), arguing that a
procedure turn is by definition only relevant "when it is necessary to
reverse direction to establish the aircarft on an intermediate or
final approach course."

It seems to me that the 1994 opinion doesn't gel with 97.3(p). I
think it promotes unnecessary maneuvering in IMC, and I think it would
be a good thing if it were revisited.

I'm not a lawyer and I don't fully understand all the legal
ramifications of the 1994 opinion, but wouldn't it be great if common
sense were allowed to prevail every now and then.

(Just my $0.02 worth.)

Tim.

On Fri, 07 Oct 2005 08:40:07 -0400, Ron Rosenfeld
wrote:

On Fri, 07 Oct 2005 03:40:31 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
news

I would have assumed this was a "radar vectors to final" situation and
queried ATC to verify, since they didn't use the magic words that I
understand to be necessary for me to assume radar vectors.


Why would you have assumed it was a "radar vectors to final" situation if
they didn't use the magic words that you understand to be necessary to
assume radar vectors? You're not being vectored in this situation, that
should be clear.



But ATC has had
me lined up with the FAC for quite some distance; I've been in radar
contact; I've been assigned an appropriate altitude to intercept the GP
from below; I've not crossed any IAF prior to DEPRE.


The approach controller did nothing to line you up with the FAC. He simply
told you to intercept the FAC as your previous clearance of direct GRB
VORTAC crossed it some fifteen miles from the LOM at a shallow angle.



If that confirmation is not forthcoming, then I would inform ATC that I am
obliged to execute a procedure turn at DEPRE. I would maintain my last
assigned altitude of 3000' until crossing DEPRE.


And when they informed you that you weren't being vectored you'd proceed to
fly the PT turn, which upon completion you'd be in the exact same position.

Of course, that wouldn't happen. Upon informing ATC you felt obligated to
fly the PT they'd vector you out of the way of the following traffic. Then
they'd either vector you back to the FAC, which would prohibit flying the
PT, or send you direct to the IAF so you could happily fly your PT without
endangering anyone else.

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.

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.

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

I agree, though telling ATC may not even be required but may keep you
safe. Moreover, I think the FAA meant as much based on their
explanation of changes that added the additional language to the AIM
that confused us:

"This [change to the AIM] is for those folks that think a procedure
turn is required unless it meets one of the exceptions which does not
include 'if the aircraft is aligned within 90 degrees of the inbound
course.'"

See http://www.faa.gov/ATPUBS/AIM/Exofchg/exchg3.html, and scroll down
to entry w.

So, the FAA added this language to satisfy people who thought a
procedure turn is required even when no course reversal is required
(e.g., when intercepting the FAC at 89 degrees) at the correct altitude.

"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.



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.