What do you do in the real world?

Ron Garret wrote:

Again, I misunderstood then. I only quoted you and responded based on
what you wrote.


You must not be reading very carefully. I say right there in the part
you quoted that I was talking about a different trip (AVX-FUL).

I was trying to just use your examples.




How does going to FUL require what you state? Cannot you pick which
approach and IAF?


It's a tangent, so if you really want to get into that you should start
a new thread. Or look up the old one. Or look at the charts.

How is that a tangent?


Because it's a different route. The circumstances are different. What
one does when flying to FUL may or may not apply when flying to VNY. I
only brought up FUL because it's a data point where I've had occasion to
ask controllers for their input, and they unequivocally told me NOT to
follow the regs. (Yes, I know that what controllers say doesn't matter.
Nonetheless, it's a data point.)

So you are saying that one has to change operating rules based on the
route of the flight. That is exactly why we are having difficulty
understanding each other. The rules are in place to define what to do
under all circumstances. Saying that something applies in one instance
and not another is bad. What are the criteria then for defining which
set of our own rules that deviate from the FARs is necessary? The ONLY
one i am aware of the the one regarding emergencies.



You can choose any IAF and any approach that
you are able to do when the clearance ends in "direct" - and the airport
is the clearance limit.


Yes, but by the book you have to fly to the clearance limit first.
91.181(b) is quite clear about this.


It is your clearance limit because that is where you filed to and where
you want to land. You cannot commence your approach until your
clearance limit time/time on your flight plan.


Why do you choose the VOR procedure at FUL rather than the LOC/DME? In
that case it is easy to pick the approach with nopt.


Not as easy as you might think. The preferred routing (which is the one
you will invariably be assigned) from AVX to FUL is V21 SLI Direct.

Again, "direct" does not mean direct to the airport.


That's news to me. Where in the regs does it say that?


When you don't lose comms and you file and fly to an airport and do not
get vectors, where do you go to? You go to an IAF, right? Or do you
always go to the airport, then to a navaid that defines an IAF?


Direct means you
go to an IAF then get to the airport. How are you supposed to land?


My reading of 91.185(c)(3)(ii) seems to imply that you have to fly to
the airport first, then to an IAF.


You can;t just go to the airport and circle down to land - that is the
whole reason for having defined instrument approaches.


If you're saying that it's stupid to fly to the airport first, I agree
with you. Hence my question.


Right. See above regarding what that last "direct" means. It does not
mean go froom the penultimate fix to the airport. It means go to an
IAF then fly the approach.


I'm pretty sure you're wrong about that.


My initial (and I guess overzealous) reaction to your post was that it
seemed like you just didn;t care what "the book" said or what you are
supposed to do based on part 91 regs for ifr flight. That is scary to me.


Of course I care. But that doesn't mean that I blindly follow the rules
without thinking.

I misunderstood your initial question and I apologize for any demeaning
statements. It appeared to me that you were not aware of what the FARs
stated. Again, my apologies.


rg

In article ,
Tim wrote:

So you are saying that one has to change operating rules based on the
route of the flight.

No, I am not saying that. Why do you keep putting words in my mouth?

It is your clearance limit because that is where you filed to and where
you want to land.

No, it was my clearance limit because that is where I was cleared to.

I am beginning to suspect that MX is right and you don't actually have a
clue.

Again, "direct" does not mean direct to the airport.


That's news to me. Where in the regs does it say that?


When you don't lose comms and you file and fly to an airport and do not
get vectors, where do you go to? You go to an IAF, right?

Not usually. Usually I get vectors to the FAF. I fly in pretty
congested airspace where full approaches are quite rare.

I misunderstood your initial question and I apologize for any demeaning
statements. It appeared to me that you were not aware of what the FARs
stated. Again, my apologies.

Well, it's possible I'm missing something. We seem to have a difference
of opinion about what a direct clearance means. I'm still waiting for a
citation to support your position.

rg

On 03/11/07 11:41, Ron Garret wrote:

[ snip ]


First, the regs explicitly sanction "making up your own stuff" (as you
put it) in emergency situations, which lost comm in IMC can easily give
rise to.

Well, *anything* can lead to an emergency situation. However, there are
regulations written specifically for the case of lost communications.
If you deem that lost communications is an emergency, and use that to
justify doing whatever you want, you're in violation of the regs.


Second, a lot of the regs were written before the advent of moving-map
GPS. Many procedures that make sense if you're navigating on a VOR make
less sense if you always know at a glance exactly where you are.

Third, going by the book makes you do some overtly stupid things. The
classic example is going NORDO while flying from AVX to FUL. Going by
the book requires you to fly to SLI, reverse course, return to the exact
spot you just came from (which is over water BTW), and reverse course
again.

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

First of all, this is what the regulations tell you to do, and this is
what you must do. Period. The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.


rg



--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

In article ,
Mark Hansen wrote:

I haven't looked at this particular approach, but I'll assume you're
referring to the fact that your clearance limit is the airport, and
that the regs require you to go to the clearance limit first?

Correct.

First of all, this is what the regulations tell you to do, and this is
what you must do. Period.

I'm not asking what is the required course of action. I am asking what
is the wisest course of action.

The fact that some controllers tell you that
they would rather you do something different is irrelevant. They will
not be defending you in a certificate action case.

Quite so, but keeping my ticket is not my only consideration. There is
also the safety of the flight to consider. Following the regs requires
more time in the air, more maneuvering, more fuel consumption, and
unnecessary traversal of extremely crowded airspace in IMC. All this
entails additional risk. If I'm faced with a choice of risking my
ticket or risking my safety I'll take the former.

Incidentally, when I file an IFR flight plan, I select a fix which I can
use to initiate my approach, and put a note in the remarks section which
states:

"In the event of lost communications, XYZ shall be treated as my
clearance limit."

This way, I don't have to do the back and forth - and it's legal (and
expected by ATC).

That seems like a sensible idea. I think I'll try that.

This procedure is manifestly more dangerous than just flying the
approach straight in (because it involves more maneuvering, more time in
the air, more time over water). Moreover, under normal conditions the
approach is ALWAYS flown straight in (via vectors) and under NORDO
conditions the controllers expect you to fly the approach straight in (I
know because I asked them) notwithstanding that this technically
violates the regs.

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

Not really. According to the regs, you go to your clearance limit, then to
a point where you can begin your approach. Once you're on a published leg
of the approach, you fly it's altitudes. This means you can begin your
descent once you're on the IAP. If you need to hold at the fix to lose
altitude, you do that.

And what if there is no published hold (as is the case in the current
situation)?

rg

Ron Garret writes:

Quite so, but keeping my ticket is not my only consideration. There is
also the safety of the flight to consider. Following the regs requires
more time in the air, more maneuvering, more fuel consumption, and
unnecessary traversal of extremely crowded airspace in IMC. All this
entails additional risk. If I'm faced with a choice of risking my
ticket or risking my safety I'll take the former.

If you declare an emergency, there is no regulatory problem with this. You
don't put your license at risk simply because you do something that you deem
essential for the safety of your flight.

--
Transpose mxsmanic and gmail to reach me by e-mail.

Mark Hansen writes:

If you deem that lost communications is an emergency, and use that to
justify doing whatever you want, you're in violation of the regs.

You're never in violation of regulations if you deem a situation to be an
emergency. As the pilot in command, your decision on whether or not a
situation is an emergency is final (FAR 91.3).

Two-way communication by radio is required in controlled airspaces because it
is dangerous to have aircraft flying around in them without it. Therefore a
loss of radio communication is a potentially dangerous situation, and a pilot
may well condider it an emergency. The AIM makes this clear (6-4-1(b)). The
determination is made by the pilot alone. Pilots with emergencies are still
expected to adhere to the standard IFR lost-communications procedures to the
extent possible given the nature of their emergencies.

The AIM goes into more detail than the regulations from which it is derived,
but it still does not cover every situation, and explicitly says so.

--
Transpose mxsmanic and gmail to reach me by e-mail.

snip

And fourth, the regs leave a lot of stuff unspecified. If you go by the
regs in the current situation, you end up over KVNY at 11,000 feet, at
which point you're supposed to initiate your descent. But there's no
published hold at KVNY (to say nothing of the fact that KVNY is not an
IAF for any approach to KVNY) so you have no choice but to improvise at
that point.

If you don't believe that if your clearance limit is the airport and
that you can pick any approach and IAF and execute it when lost coms,
then you can try this:

from "Instrument Flying Handbook"
FAA H 8083 15
page 10-11

http://www.faa.gov/library/manuals/a...-8083-15-2.pdf

"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."

Tim wrote:


"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."


You should immediately pick an approach and land so you stop gumming up
the works.

Newps wrote:


Tim wrote:


"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."



You should immediately pick an approach and land so you stop gumming up
the works.


I agree - but the OP thinks that since his clearance limit is an airport
that he is to fly to that airport, THEN navigate to an IAF to do an
approach. He wanted to know what to do when arriving at a clearance
limit when there are no published holds at that point. I could not
believe someone flying IFR routinely does not know what to do. That is
why I posted it.

I hope you are not saying to do this at any airport.

In article , Tim
wrote:

Newps wrote:


Tim wrote:


"Holding Instructions
If you arrive at your clearance limit before receiving clearance
beyond the fix, ATC expects you to maintain the last assigned
altitude and begin holding in accordance with the depicted
holding pattern. If no holding pattern is depicted, you are
expected to begin holding in a standard holding pattern on
the course upon which you approached the fix. You should
immediately request further clearance."



You should immediately pick an approach and land so you stop gumming up
the works.


I agree - but the OP thinks that since his clearance limit is an airport

This is not a matter of opinion. My clearance limit was an airport
(KVNY to be precise).

that he is to fly to that airport, THEN navigate to an IAF to do an
approach.

That is what the regs say to do.

He wanted to know what to do when arriving at a clearance
limit when there are no published holds at that point. I could not
believe someone flying IFR routinely does not know what to do.

Believe it. I fly IFR routinely. (But I don't lose comm routinely.)

rg