Change in AIM wording concerning procedure turn

"Ron Garret" wrote in message
...

But I'm the one who posed the original question, and my question is what
you would do if you were *flying* the approach (as it currently exists)
and lost comm.


Which I have twice answered.

In article .net,
"Steven P. McNicoll" wrote:

"Ron Garret" wrote in message
...

But I'm the one who posed the original question, and my question is what
you would do if you were *flying* the approach (as it currently exists)
and lost comm.


Which I have twice answered.

Ah, so you have.

You said you'd go straight in.

So my followup question (if you'll indulge me) is: do you acknowledge
that this would be a technical violation of the FARS? (You'd have to
start descending below the MEA on V21 before passing an IAF for the
approach.)

rg

"Ron Garret" wrote in message
...

Ah, so you have.

You said you'd go straight in.

So my followup question (if you'll indulge me) is: do you acknowledge
that this would be a technical violation of the FARS? (You'd have to
start descending below the MEA on V21 before passing an IAF for the
approach.)


I wouldn't have to stay on V21, I could move over two degrees to the 200
radial used for the approach. As for a possible technical violation of the
FARs, I've had a complete communications failure for unknown reasons, and
while my navigational radios are functioning, I'm not sure how long they
will continue to do so. To avoid a possible loss of navigational capability
in IMC I'm using the emergency authority granted me by
FAR 91.3 to deviate from any rule of Part 91.

As for a possible technical violation of the
FARs, I've had a complete communications failure for unknown reasons, and
while my navigational radios are functioning, I'm not sure how long they
will continue to do so. To avoid a possible loss of navigational capability
in IMC I'm using the emergency authority granted me by
FAR 91.3 to deviate from any rule of Part 91.

Good enough. But suppose your radios are all working fine, but you just
can't get a word in edgewise. I won't speculate as to how that might be
possible at this particular (middle of nowhere) facility, I'll just note
that it happens where I fly.

You go straight in, as you said you would.

Would =that= be a technical violation of the FARs, since you don't have
91.3 to rely upon?

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

"Jose" wrote in message
. ..

Ok. He's a new controller and he's nervous.


What's he nervous about?



He dropped his pencil behind the console after wondering if he
accidentally
may have let somebody cross the FAC outside the LOM, and he won't issue
the clearance until he knows it's ok.


Wouldn't a quick look at the radar scope tell him if it's ok?



As he reaches down to pick up the pencil he hit his head just as
his boss came in.


Why didn't he just take another pencil? Why did he hit his head? What does
his boss have to do with any of this?



He really wants to be a lot less polite to you, but he
limits himself to telling you to wait a moment (while he gets his ****
together).


Why does he want to be less polite to me? Is he just antisocial by nature?



It's my scenario, you can't say "it wouldn't happen" as a response.


Okay, but then my response can be just as unrealistic as your scenario.



In any case, it doesn't matter -why- it happens this way this time - as
the pilot you deal with it or get sent to the back of the line (which may
be the smartest thing to do at this point).

There's traffic following me. I'm not turning around.

There's always traffic following you. In this case EGF456 is also cleared
for the approach, but he may well be at 2500 feet coming from the west, or
9000 feet coming from the North. You don't know. He may well not be
"following" you.


But he's been following me all the way from ORD. How can he now be coming
from the west or the north if we departed ORD just three minutes apart? If
he's now coming from the west, how was the GRB controller able to descend
him below the 4000' traffic that's keeping me up at 5,000? If he's coming
from the north, how was the GRB tower controller able to launch that
departure?

"Jose" wrote in message
. ..

That wasn't part of the original scenario, but I'll bite.


Yes it was. If you reread the original scenario you'll find; "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." Then you modified the original scenario with the following:

"This time, on initial contact you're told 'maintain 5,000 join the runway
36 localizer' Then, five miles from DEPRE the approach controller says
'AWI123 cleared ILS runway three six contact tower one one eight point
seven'."

"You acknowledge, then lose coms. Dive? PT? Racetrack?"

You said nothing about deleting the EGF456 flight.



He will be at
5000 while I am descending in the hold to 3000. At 500 feet per minute
I'll have 1500 feet of vertical clearance when he goes whizzing by
overhead.


How do I know that? I've lost comms, I can't hear transmissions to other
aircraft any better than I can hear those directed at me. The controller
let 4000' traffic cross the localizer near the LOM when he had two aircraft
inbound for the approach, so I know I'm not being worked by the sharpest
spoon in the drawer. I'm not turning towards traffic following me.



But this is the crux of the matter. I've already said that if I were at
the right altitude and reasonably on track, I'd go right in (no PT).
You've indicated the same, and also that if you were not at the right
altitude (say, 5000 feet), you'd get a new vector (and likely be sent to
the back of the line) if you couldn't get an earlier clearance. This is
also reasonable and I'd do the same.

If you are dealt an inappropriate slam dunk (5000 on a 3000 approach), do
you go missed or make it work? If you make it work, how would you lose
the altitude?


I'd go missed.

That wasn't part of the original scenario, but I'll bite.

Yes it was. If you reread the original scenario you'll find; "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."

That EGF456 was following you since the beginning of your flight was not
part of the scenario, at least not as presented. I took it as another
aircraft that could be coming from anywhere, which is now also cleared
for the same approach you are on and presumably will be following you.

If you are dealt an inappropriate slam dunk (5000 on a 3000 approach), do
you go missed or make it work? If you make it work, how would you lose
the altitude?

I'd go missed.

Good enough. Thanks.

Jose
--
Get high on gasoline: fly an airplane.
for Email, make the obvious change in the address.

Jose wrote:
As for a possible technical violation of the FARs, I've had a complete
communications failure for unknown reasons, and while my navigational
radios are functioning, I'm not sure how long they will continue to do
so. To avoid a possible loss of navigational capability in IMC I'm
using the emergency authority granted me by
FAR 91.3 to deviate from any rule of Part 91.


Good enough. But suppose your radios are all working fine, but you just
can't get a word in edgewise. I won't speculate as to how that might be
possible at this particular (middle of nowhere) facility, I'll just note
that it happens where I fly.

You go straight in, as you said you would.

Would =that= be a technical violation of the FARs, since you don't have
91.3 to rely upon?

Sure, if you can't communicate, either for reasons of congestion or
hardware failure, the end result is the same and use can use 91.3 as needed.

Matt

"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?

"Ron Rosenfeld" wrote in message
...

It is also unclear whether the drafter even checked with the TERP's people
who design the procedures, to see if such language meets with their
approval.


Why is their approval required?



Or if he checked with the regulatory office to resolve the
conflict with their 1994 opinion.


What's the conflict there?