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#1
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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
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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
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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? |
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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
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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
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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
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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
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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
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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
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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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