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Change in AIM wording concerning procedure turn



 
 
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  #1  
Old October 7th 05, 09:39 PM
Steven P. McNicoll
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"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.


  #2  
Old October 8th 05, 01:14 PM
Ron Rosenfeld
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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)
  #3  
Old October 9th 05, 01:00 AM
Steven P. McNicoll
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"Ron Rosenfeld" wrote in message
...

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."


So, Ron, did you delete that portion for brevity, or because including it
weakened your argument?

So how does the 1994 legal opinion supposedly eliminate the 1977 legal
opinion in all cases if the 1994 opinion is expressly limited to non-radar
environments?



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.


I didn't set this situation up, this situation was set up by geography,
runway alignment, navaid placement, and departure procedures for MKE and
ORD. This is not a hypothetical, it's a real world example, it happens
regularly and has been for probably three decades or so.

What do you mean by "functionally equivalent to radar vectors to the final
approach course"? Is AWI123 being vectored or is it on it's own navigation?



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


So what? AWI123 didn't join the segment to which NoPT applies.



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


Well, given the absence of any radar vector to the final approach course,
I'd be a fool to claim anything else.



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.


Cite that requirement. Why doesn't DEPRE count as an IAF in this scenario?


  #4  
Old October 9th 05, 03:23 AM
Ron Rosenfeld
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On Sun, 09 Oct 2005 00:00:02 GMT, "Steven P. McNicoll"
wrote:


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.


Cite that requirement.


7110.65 4-8-1. APPROACH CLEARANCE
a. ... Standard Instrument Approach Procedures shall commence at an Initial
Approach Fix or an Intermediate Approach Fix if there is not an
Initial Approach Fix.

Why doesn't DEPRE count as an IAF in this scenario?


What is the minimum altitude at DEPRE when it is being used as an IAF?

How is the initial segment defined?

How will you navigate from DEPRE to the FAF for the ILS approach?

---------------------------------------


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
  #5  
Old October 9th 05, 04:34 AM
Steven P. McNicoll
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"Ron Rosenfeld" wrote in message
...

7110.65 4-8-1. APPROACH CLEARANCE
a. ... Standard Instrument Approach Procedures shall commence at an
Initial
Approach Fix or an Intermediate Approach Fix if there is not an
Initial Approach Fix.


That requirement is not violated. AWI123 intercepts the localizer fifteen
miles south of DEPRE. DEPRE is an IAF.



What is the minimum altitude at DEPRE when it is being used as an IAF?


AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
approach. He follows the localizer down and crosses DEPRE at 2141 MSL.



How is the initial segment defined?


The segment between the intial approach fix and the intermediate fix or the
point where the aircraft is established on the intermediate course or final
approach course.



How will you navigate from DEPRE to the FAF for the ILS approach?


Lateral guidance is provided by the localizer, if I've passed DEPRE I've
passed the FAF.


  #6  
Old October 9th 05, 05:31 AM
Jose
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AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
approach. He follows the localizer down and crosses DEPRE at 2141 MSL.


Wasn't there an accident recently caused by a misunderstanding like what
is suggested here? If you are (umpty ump) miles south of the IAF, but
above the initial approach altitude, and get cleared for the approach,
when can you descend? I recall (perhaps imperfectly) that some airliner
descended inappropriately and ran into terrain, while still above the
altitude for the IAF. A clearance for the approach is not (AFAIK) a
clearance to -descend- to the approach altitude from an otherwise
assigned higher one.

If I'm missing something here, what is it?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.
  #7  
Old October 9th 05, 02:20 PM
Steven P. McNicoll
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"Jose" wrote in message
t...

AWI123 is level at 3000 and five miles south of DEPRE when cleared for
the approach. He follows the localizer down and crosses DEPRE at 2141
MSL.


Wasn't there an accident recently caused by a misunderstanding like what
is suggested here?


What misunderstanding do you believe is suggested here?



If you are (umpty ump) miles south of the IAF, but
above the initial approach altitude, and get cleared for the approach,
when can you descend?


Immediately. If the aircraft is not yet established on a segment of a
published route or instrument approach procedure ATC must assign an altitude
to maintain until it is. Sometimes in the situation I described here
aircraft report on the localizer on initial contact with GRB approach, when
they are 30 miles or so from the field. They can be cleared for the
approach at that time, "cross SENNA at or above 3000, cleared ILS runway
three six approach."



I recall (perhaps imperfectly) that some airliner
descended inappropriately and ran into terrain, while still above the
altitude for the IAF. A clearance for the approach is not (AFAIK) a
clearance to -descend- to the approach altitude from an otherwise assigned
higher one.

If I'm missing something here, what is it?


Doesn't sound like a recent accident to me, sounds like TWA514, but that was
over thirty years ago.


  #8  
Old October 10th 05, 09:18 PM
Ron Rosenfeld
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On Sun, 09 Oct 2005 03:34:29 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
.. .

7110.65 4-8-1. APPROACH CLEARANCE
a. ... Standard Instrument Approach Procedures shall commence at an
Initial
Approach Fix or an Intermediate Approach Fix if there is not an
Initial Approach Fix.


That requirement is not violated. AWI123 intercepts the localizer fifteen
miles south of DEPRE. DEPRE is an IAF.



What is the minimum altitude at DEPRE when it is being used as an IAF?


AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
approach. He follows the localizer down and crosses DEPRE at 2141 MSL.



How is the initial segment defined?


The segment between the intial approach fix and the intermediate fix or the
point where the aircraft is established on the intermediate course or final
approach course.



How will you navigate from DEPRE to the FAF for the ILS approach?


Lateral guidance is provided by the localizer, if I've passed DEPRE I've
passed the FAF.


Just so I understand exactly what you are saying, is it your position that,
when using DEPRE as the IAF for the purpose of starting this SIAP, if one
is inbound, the legal minimum altitude at DEPRE is 2141'?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
  #9  
Old October 10th 05, 09:35 PM
Steven P. McNicoll
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"Ron Rosenfeld" wrote in message
...

Just so I understand exactly what you are saying, is it your position
that,
when using DEPRE as the IAF for the purpose of starting this SIAP, if one
is inbound, the legal minimum altitude at DEPRE is 2141'?


There is no Minimum Descent Altitude on an ILS approach, there is instead a
Decision Height. AWI123 is level at 3000 and five miles south of DEPRE, on
the localizer, when cleared for the approach. The aircraft leaves 3000
about 2.7 miles south of DEPRE, where it intercepts the glideslope. It
follows the glideslope down, crossing DEPRE at 2141 MSL, to the decision
height of 882 MSL. From that point it will either complete the approach
visually or execute the missed approach procedure.


  #10  
Old October 10th 05, 09:21 PM
Ron Rosenfeld
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On Sun, 09 Oct 2005 03:34:29 GMT, "Steven P. McNicoll"
wrote:


"Ron Rosenfeld" wrote in message
.. .

7110.65 4-8-1. APPROACH CLEARANCE
a. ... Standard Instrument Approach Procedures shall commence at an
Initial
Approach Fix or an Intermediate Approach Fix if there is not an
Initial Approach Fix.


That requirement is not violated. AWI123 intercepts the localizer fifteen
miles south of DEPRE. DEPRE is an IAF.



What is the minimum altitude at DEPRE when it is being used as an IAF?


AWI123 is level at 3000 and five miles south of DEPRE when cleared for the
approach. He follows the localizer down and crosses DEPRE at 2141 MSL.



How is the initial segment defined?


The segment between the intial approach fix and the intermediate fix or the
point where the aircraft is established on the intermediate course or final
approach course.



How will you navigate from DEPRE to the FAF for the ILS approach?


Lateral guidance is provided by the localizer, if I've passed DEPRE I've
passed the FAF.


One other question which I keep forgetting to ask:

Does the TRACON have appropriate radar coverage and setup to use Radar
Vectors to Final in this area?


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




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