Oct 18 course reversal change

On 2 Nov 2005 10:05:34 -0800, "rps" wrote:

"A procedure turn is the maneuver prescribed boldwhen it is necessary
to reverse direction/bold to establish the aircraft inbound on an
intermediate or final approach course."

FAA's explanation of the AIM change (August change, not this one)
implies that no PT is required "if the aircraft is aligned within 90
degrees of the inbound course."
(http://www.faa.gov/ATpubs/AIM/Exofchg/exchg3.html.) I couldn't find
the FAA's explanation for the October change, which has not made its
way into FAA's online version of the AIM.

Yes, but the discussion of a procedure turn in the AIM is merely a
definition. The point that most seem to miss is that the "prescribing" is
done by the procedure designer when applying the various TERPs
requirements; and not by the pilot while flying the approach.


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

I agree, but the problem is this: suppose you are flying from an IAF on
a course that does not indicate NoPT but the chart depicts a PT, and
your course is mostly aligned with the FAC. Are you going to fly the
PT? You could confirm with ATC, but what if ATC is too busy to talk or
you have comm failure?

My guess is that ATC is not expecting you to fly the PT in this
circumstance even when a PT is depicted on the chart because it is not
"necessary to reverse direction."

"rps" wrote in message
ps.com...
I agree, but the problem is this: suppose you are flying from an IAF on
a course that does not indicate NoPT but the chart depicts a PT, and
your course is mostly aligned with the FAC. Are you going to fly the
PT? You could confirm with ATC, but what if ATC is too busy to talk or
you have comm failure?

Actually, according to what the AIM now says (with the October NOTAM), you'd
have to fly the PT regardless of what ATC tells you. There's a provision to
fly an otherwise prohibited PT if ATC approves; but there's no provision to
skip a required PT, even if ATC approves. In general, ATC can't approve a
deviation from the requirements of a charted approach; and according to the
AIM now, a charted PT is part of those requirements.

However, the last time a chart such as you just described was discussed
here, I emailed the FAA's chart-error address, and they replied that the
omission of NoPT was a charting error; they promptly issued a NOTAM to
correct it.

My guess is that ATC is not expecting you to fly the PT in this
circumstance even when a PT is depicted on the chart because it is not
"necessary to reverse direction."

I'd hesitate to guess what ATC expects, but flying the PT in that case would
be contrary to what the AIM now says the pilot is required to do. The
revised phrasing does not say that the PT must only be flown when necessary
to reverse direction; it does say that the charted PT *must* be flown,
except if certain specified conditions obtain (and already being aligned
with the FAC is not one of those conditions).

--Gary

On 2 Nov 2005 15:31:35 -0800, "rps" wrote:

I agree, but the problem is this: suppose you are flying from an IAF on
a course that does not indicate NoPT but the chart depicts a PT, and
your course is mostly aligned with the FAC. Are you going to fly the
PT? You could confirm with ATC, but what if ATC is too busy to talk or
you have comm failure?

My guess is that ATC is not expecting you to fly the PT in this
circumstance even when a PT is depicted on the chart because it is not
"necessary to reverse direction."

It really depends on the specifics. I am assuming that in your
hypothetical example, not only is there not a NoPT notation, but you are
also NOT receiving radar vectors to the final approach course. Under
current guidance and regulations (and written legal opinion) as I
understand them, there is no authorization available for the pilot to
choose to "skip" a charted procedure turn absent one of the prohibited
circumstances in the regulations and in the AIM.

It may well be that there is an error in the charting, or errors in ATC
procedures. I've seen and heard of both. I think those issues should be
corrected on the ground. There have also been examples which "seem" like
there should be a NoPT notation, but closer examination reveals some TERPs
violation that would ensue, sometimes having to do with descent gradients;
sometimes having to do with hypotheticals that don't exist in the real
world.

Under the new AIM guidance posted by Tim, it seems that ATC may specify
"CLEARED STRAIGHT-IN (type) APPROACH" and this would tell you that they are
providing radar vectors and really, really don't want you to do a procedure
turn. The only thing new is this new verbiage, and also the implication
that ATC will be able to provide radar vectors to an intermediate fix. I
don't know if the ATC requirements for ATC to be able to do that have been
published yet.


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

Here's my current spin on all of this.

I think the AIM writers have an impossible job to do -- they're trying
to clarify two FARS which essentially contradict each other. Hence
the ambiguiity in the AIM.

The FARS in question are

97.3(p) which defines the Procedure Turn as "the maneuver prescribed
when it is necessary to reverse direction..."

and

97.20 which includes by reference the textual description of the
standard instrument procedures, which apparently state that the
Procedure Turn is mandatory (except in the well-known very specific
exceptions).


So, by definition (97.3(p)), Procedure Turns are only relevant when a
course reversal is required, but 97.20 states that a Procedure Turn is
mandatory even if a course reversal is not required.

To me, these two FARS are contradictory.

It's not surprising that the AIM is confusing when it tries to explain
them.

The 1994 legal opinion appears to have been based on 97.20, but I
don't see how it can be reconciled with 97.3(p).

Even within the FAA, there are apparently two schools of thought on
this: the August AIM revision writer clearly supported 97.3(p),
whereas the current proposed revision writers are backing 97.20.

I think the FAA should review 97.20 and the legal opinion in the light
of 97.3(p).

Personally, I hope 97.3(p) wins. To me it's safer, more efficent,
mostly in general use when circumstances highlighting the ambiguity
actually exist, and far more accessible to the piloting community.

Tim.



On Mon, 31 Oct 2005 10:29:53 -0800, wrote:

The FAA recognized that a mistake had been made in the recent revision
to the AIM concerning course reversals; that the wording was in conflict
with the 1994 legal interpretation on the issue.

At last week's FAA/Industry Aeronautical Charting Forum the following
language was adopted to replace the recent change in AIM language.
Because of the long lead time in amending the AIM, the following
language will soon appear in the NTAP (Notice to Airmen Publication)
portion of the FAA's web site:

"New: Revised October 18, 2005

5-4-9. Procedure Turn

A procedure turn is the maneuver prescribed when it is necessary to
reverse direction to establish the aircraft inbound on an intermediate
or final approach course. The procedure turn or hold-in-lieu-of-PT is a
required maneuver when it is depicted on the approach chart. However,
the procedure turn or hold-in-lieu-of-PT is not permitted when the
symbol "No PT" is depicted on the initial segment being used, when a
RADAR VECTOR to the final approach course is provided, or when
conducting a timed approach from a holding fix. The altitude
prescribed for the procedure turn is a minimum altitude until the
aircraft is established on the inbound course. The maneuver must be
completed within the distance specified in the profile view.
Note
The pilot may elect to use the procedure turn or hold-in-lieu-of-PT when
it is not required by the procedure, but must first receive an amended
clearance from ATC. When ATC is Radar vectoring to the final approach
course or to the Intermediate Fix, ATC may specify in the approach
clearance “CLEARED STRAIGHT-IN (type) APPROACH” to insure the procedure
turn or hold-in-lieu-of-PT is not to be flown. If the pilot is
uncertain whether the ATC clearance intends for a procedure turn to be
conducted or to allow for a straight-in approach, the pilot shall
immediately request clarification from ATC (14 CFR Part 91.123). "

"Tim Auckland" wrote in message
...
Here's my current spin on all of this.

I think the AIM writers have an impossible job to do -- they're trying
to clarify two FARS which essentially contradict each other. Hence
the ambiguiity in the AIM.

The FARS in question are

97.3(p) which defines the Procedure Turn as "the maneuver prescribed
when it is necessary to reverse direction..."

and

97.20 which includes by reference the textual description of the
standard instrument procedures, which apparently state that the
Procedure Turn is mandatory (except in the well-known very specific
exceptions).


So, by definition (97.3(p)), Procedure Turns are only relevant when a
course reversal is required, but 97.20 states that a Procedure Turn is
mandatory even if a course reversal is not required.

To me, these two FARS are contradictory.

I don't think so. The text in 97.3p merely explains what the FAA's rationale
is in prescribing a procedure turn. But once the FAA issues such a
prescription--by charting a PT on an approach plate--then the PT is
mandatory (as stated in the 1994 legal opinion and the newly revised AIM
wording).

I think you're reading 97.3p as though it said "We hereby prescribe that you
perform a PT when you think it is necessary to reverse direction..."; but it
was apparently intended to mean "When our TERPS designers think it is
necessary for you to reverse direction, they prescribe a PT (by charting it
on an approach plate)".

--Gary

On Thu, 3 Nov 2005 11:36:25 -0500, "Gary Drescher"
wrote:

"Tim Auckland" wrote in message
.. .
Here's my current spin on all of this.

I think the AIM writers have an impossible job to do -- they're trying
to clarify two FARS which essentially contradict each other. Hence
the ambiguiity in the AIM.

The FARS in question are

97.3(p) which defines the Procedure Turn as "the maneuver prescribed
when it is necessary to reverse direction..."

and

97.20 which includes by reference the textual description of the
standard instrument procedures, which apparently state that the
Procedure Turn is mandatory (except in the well-known very specific
exceptions).


So, by definition (97.3(p)), Procedure Turns are only relevant when a
course reversal is required, but 97.20 states that a Procedure Turn is
mandatory even if a course reversal is not required.

To me, these two FARS are contradictory.

I don't think so. The text in 97.3p merely explains what the FAA's rationale
is in prescribing a procedure turn. But once the FAA issues such a
prescription--by charting a PT on an approach plate--then the PT is
mandatory (as stated in the 1994 legal opinion and the newly revised AIM
wording).

I think you're reading 97.3p as though it said "We hereby prescribe that you
perform a PT when you think it is necessary to reverse direction..."; but it
was apparently intended to mean "When our TERPS designers think it is
necessary for you to reverse direction, they prescribe a PT (by charting it
on an approach plate)".

I agree that is in line with the 1994 legal opinion, but I still
wonder if it's what the original drafters of 97.3(p) intended.

If the original drafters of 97.3(p) intended Procedure Turns to be
used in all cases, why did they include the words "reverse direction"
at all?

Wouldn't it have been far simpler just to say something along the
lines of: "the Procedure Turn (when charted, and when not prohibited
by 91.175(j) ) is the procedure used to establish the aircraft on an
intermediate or final approach course"?

(I'd still like the FAA to review the legal opinion.)

Tim.

but it
was apparently intended to mean "When our TERPS designers think it is
necessary for you to reverse direction, they prescribe a PT (by charting it
on an approach plate)".

Some charts come with a "noPT sector", which makes sense to me.
Otherwise, the TERPS designers don't really know where I'm coming from,
and whether or not I need to reverse direction.

Jose
--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

"Jose" wrote in message
m...
but it was apparently intended to mean "When our TERPS designers think it
is necessary for you to reverse direction, they prescribe a PT (by
charting it on an approach plate)".

Some charts come with a "noPT sector", which makes sense to me. Otherwise,
the TERPS designers don't really know where I'm coming from, and whether
or not I need to reverse direction.

Yup, the cleared-direct case is a problem (with most existing approach
charts) under the new AIM wording. On the other hand, controllers only clear
you direct to the FAF under circumstances that would permit them to vector
you, right? So if they just announce they're vectoring you sometime before
you arrive at the fix, then the PT is no longer required (or permitted) and
the problem doesn't arise.

--Gary

"Tim Auckland" wrote in message
...
On Thu, 3 Nov 2005 11:36:25 -0500, "Gary Drescher"
wrote:
I think you're reading 97.3p as though it said "We hereby prescribe that
you
perform a PT when you think it is necessary to reverse direction..."; but
it
was apparently intended to mean "When our TERPS designers think it is
necessary for you to reverse direction, they prescribe a PT (by charting
it
on an approach plate)".

I agree that is in line with the 1994 legal opinion, but I still
wonder if it's what the original drafters of 97.3(p) intended.

If the original drafters of 97.3(p) intended Procedure Turns to be
used in all cases, why did they include the words "reverse direction"
at all?

I suspect they were simply being informative by mentioning the rationale for
the prescription when they stated the definition of a PT. It makes sense
that they'd want pilots to understand what PTs are supposed to be for (even
though, like any other feature of an approach chart, a PT might mistakenly
be prescribed when it's not supposed to be).

--Gary