Report Leaving Assigned Altitude?

Richard Kaplan wrote:
"Dave Butler" wrote in message
...


(a) When vacating any previously assigned altitude or flight level for a

newly

assigned altitude or flight level.


I agree this is an interesting question and raises an area of some
ambiguity.

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


However, my interpretation in all the cases discussed in this thread is that
an intermediate altitude is not an assigned altitude and an approach
clearance certainly is not an assigned altitude.

I agree completely about intermediate altitudes. With respece to approach
clearances, I wouldn't say "certainly", but I'll give you that.


In other words, I interpret the above AIM section to require the pilot to
provide a readbak of any altitude change. That readback might be "N102KY
out of 5000 for 3000" or it might be "N102KY out of 5000 for 3000 pilot
discretion" or it might be "N102KY will cruise 3000" -- any of these in my
opinion satisfy the AIM requirement.

I disagree about "out of 5000 for 3000 pilot discretion". I think that readback
merely acknowledges the clearance and does not provide any information about
when I might exercise my discretion to actually leave that altitude. When I
leave the altitude, perhaps minutes later, I assert that a seperate report is
required.



The AIM doesn't say (for example) "...unless the altitude assignment is
superceded by a clearance for a visual approach".


Take the somewhat more extreme example of a DME step-down approach. Surely
you will agree that there is no need to report to ATC each time you proceed
to a new step-down altitude. Why not? Beause these step-down altitudes
were not "assigned" by ATC; you were instead "cleared for the approach"

I agree the step downs are not assigned altitudes and never asserted anything
different.

which is approval to descend as published on the approach plate without any
further discussion with ATC. "Cleared for the visual" is just another
extension of this underlying theme -- you may descend at will upon being
"Cleared for the visual" as long as you do not violate another FAA rule in
the process such as minimum altitude requirements.

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.

Dave
Remove SHIRT to reply directly.

"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

OK, I can see that I am swimming upstream, here, so this will be my last shot
(see inline). Thanks for the thought-provoking responses.

Dave
Remove SHIRT to reply directly.

Richard Kaplan wrote:
"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.

Which is tantamount to saying "a clearance for a visual approach is not a newly
assigned altitude". OK. I can accept that. BTW, whether or not you may "descend
at will" has never been in dispute.


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.

Complying with the altitude clearance is not an issue. The issue is whether a
report is required for leaving the assigned altitude.


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?

No, you only need to report "leaving an assigned altitude for a newly assigned
altitude". When you change altitudes within a block, you're not doing that.



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.

The question is not about whether you may descend at will. It's the required
report that's at issue.

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.

Again, whether you may descend at will is not at issue. If you're leaving an
assigned altitude for a newly assigned altitude, you're supposed to report. I'll
grant that an approach clearance is not clearly a "newly assigned altitude".

One of the reasons why it is not required to report descending when you are
cleared for the visual approach is because it is quite plausible that you
will be out of radio contact when you begin your descent. When the
controller says "Cleared for the approach" not only is he assuring there are
no airplanes on your intended course to the airport, but also he is
transferring terrain avoidance responsibility solely to you, whereas
previously he shared this responsibility with you.

--
Richard Kaplan, CFII

www.flyimc.com