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100 Above TDZE Prior to MAP on LOC/DME???

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Xav8tor

Wingback Tin Kicker
Joined
Jan 15, 2005
Posts
52
Do you go 100 Above TDZE Prior to MAP on LOC/DME?

:confused: I read a copy of the factual reports (Operations, FDR, CVR, etc.) on the J32 accident last year in IRK. According to investigation interview statements made by pilots, managers and an FAA inspector, a lot of pilots are under the impression that, upon seeing the approach lights during a non-precision approach, it is permissible to continue descent from MDA to 100 feet above the touchdown zone – REGARDLESS of the aircraft’s distance to the threshold. In other words, after crossing the FAF and doing the old chop and drop to MDA, for example, at two miles DME from the runway/MAP you see the ALS, (but not the VASI or runway lights), they thought it was permissible (and safe) to go ahead and keep on going down to 100 feet while still that far out.



I know how I have always understood, applied, and taught that reg and related procedures, but I am curious to know what you guys (and girls) think and how you interpret and apply it, assuming you use standard 121 (i.e., airline "style") profiles and procedures. I re-read the TERPS and know that what a lot of people assume about obstacle clearance and tolerances is more than a little optimistic. Take a 75 foot altimeter error, toss in another 20 feet for a reading a little off due to rapid changes in baro pressure or measurement error, add in another 20 or 30 feet of altitude variation due to wind/rough air, etc., and the permissible obstruction clearance guarantee even as close in as the MM is at best a few feet.



But in this example, we are talking 1 to 1.5 nm from the threshold and 100 above TDZE in slightly rolling terrain. What do you think about when planning and briefing an approach such as this? Also, the IRK LOC/DME 36 NOS plate shows an approx. 100 foot obstacle almost on, just barely right, of the LOC/extended centerline about 3/4 to a mile out. Jepps don’t chart final controlling obstacles, or any approach obstructions, lower than 400 AGL, so the Jepp for that approach looks like a clear shot. The reason I noted that is I am thinking, even if I was taught and thought that going to 100 above TDZE 1.5 out upon seeing the approach lights (but not a VASI or the runway) was kosher, I might have second thoughts if the plate I had in front of me showed a 95 foot tall clump of trees between me and the runway.



The final, and perhaps most, interesting thing, one that really threw me for a loop reading these factual reports, is that the NTSB seems to have found that the crew of the same flight under similar weather conditions the night before the accident almost did the exact same thing and had to do an abrupt pull up of sorts to avoid hitting the trees at about the same place.



Comments and clarification anyone? I’ve done a good bit of accident analysis and flew 32’s on similar approaches hundreds of times, and did probably close to 1000 hours of II instruction. With all of that, I am still scratching my head on this trying to figure out what everyone was thinking, and I am mainly talking about those on up the chain here. It’s not like the crew weren’t paying attention and just flew it in. From what I am reading, they thought the continued descent was the right thing to do and were trained that way, maybe going all the way back to their instrument rating and in flight school (at an aviation college). One guy (I think it was someone from a FSDO) said dropping to 100 AGL two miles out was perfectly safe and legal and obstacle clearance was guaranteed by the TERPS, which is of course, not quite correct.



Who has a clue in this scenario? What would you do (have done)? Not Monday morning quarterbacking or second guessing a deceased crews’ decision, but trying to understand how it could happen and more importantly, WHY? Are most pilots operating on those assumptions, interpretations of the regs, and NP approach procedures described above?


Thanks.
 
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Guys, the relevant reg(s) are written so that they apply equally to both precision and non-precision approaches. However, the thinking behind some of the responses is hinting at the potential trap I am exploring here. Remember, in this scenario, there is of course not a glideslope, and we are assuming the VASI is not yet visible...just the approach lights at time the decision was made to continue descent from MDA.

Thanks again, now, please keep it up. Put yourself in this situation and tell me how you think it through. I have an answer but I want to hear yours.
 
I stay high

Personally I fly the particular approach's altitude profiles on a visual unless I have VASI or glideslope. That means that once crossing the FAF I'll stay at MDA until landing is assured and no obstacles are seen. Tough to see trees and hills at night but you have to know the terrain. 100 agl farther out than short final is asking for trouble.
 
There is always a minimum visbility published for any given approach. I like to think that in a senario where you are shooting an approach to minimums, when you are at minimums, you can descend without any worry, after all you have the approach lights in sight which are about 1500' from the threshold. I really have a hard time believing that you could start a descent to 100' above TDZE at a distance so far away from the threshold that you would risk hitting an obsticle (assuming on a visual approach you fly a standard three degree approach). I may be wrong, but I have always been under the impression the the TERPS took into account this senario (not the visual senario, but the poor visability senario).
 
Three letters...

VDP

Ride touched on this above... regardless of the whether one is published or not, you should always calculate one. Take the HAT and divide by 300 and that will give the distance from the end of the runway (in NM) to start down for a 3 degree glide. Most aircraft nowadays have nav equipment that will allow you to know exactly how far you are from the end of the runway but even if your aircraft doesn't, if you're working off the approach light concept in 91.175, then you should still know how far out you are... because you have a visual reference. FWIW, I would be very reluctant to descend below the MDA on a non-precision approach based solely on approach lights, even though the rules allow for it. I lost a very good friend to this very thing... turns out they weren't approach lights.

BTW, one of the requirements in 91.175 for operating below DH/MDA is that the aircraft be continuously in a position from which a descent to a landing on the intended runway can be made at a normal rate of descent using normal maneuvers. Most people interpret that as don't try and dive for the runway at the last minute but I think you could make the argument that it also means don't drag it in... that isn't normal either.

cc
 
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Reported viz on the ASOS was 3 miles. Of course, those things can be a little optimistic, even wayyyy different from flight visibility, which sounds like it was about half that, which is still twice the min required. A couple of you hit the nail on the head in saying calculate a VDP when there isn't one published. That philosophy came out in response to the push a few years back to reduce CFITs.

The TERPS do NOT take into account obstacle clearance predicated on seeing approach lights as a criteria for descending to 100 AGL (actually 100 above TDZE) regardless of distance from the runway. Think about it this way: it is CAVU but you are flying IFR and see the lights 6 or 8 miles out. You don't xcl IFR, chop and drop down to 100 agl and drag it in. There are too many things out there you can hit.

More realistically, just after crossing the FAF, I don't recall the exact criteria, but the TERPS make allowances for obstacles for the first mile or so, then MDA guarantees at least 250 feet of clearance. On a non-precision approach they take the tallest obstacle along the final path, then add 250 (if the altimeter is locally reported) and that's MDA. MDA is the only thing protecting you until you see a VASI or PAPI. This particular approach has another quirk in that a 3 degree glideslope is more shallow than that required for a constant rate of descent (3.41), but that doesn't directly come into play in this scenario.

Take a close look at the plate kindly linked above. Look about 3/4 to a mile out, just about 2 DME almost dead on the loc. See that +/- 1059 obstacle? Those are trees and that is the controlling obstacle for the final approach segment. It isn't on the Jepp. I'm not sure it would change every pilot's decision who already was assuming that leaving MDA that far out was OK, but if I knew that little inverted V was between me and the threshold, I might think again. That is really a side point to the basic question though.

Are a lot of experienced pilots under the impression that "approach lights in sight" means going to 100 above is safe? In other words, does anyone see, beyond supposed common sense, any limitation on that? Where? How were you taught? What does the guy with more stripes say? In two initials and a bunch of recurrents, I don't remember anyone ever hitting this exact issue. Sure the "What must you see or else miss" question is always on a test, but I haven't heard it explained since I was an instrument student with a TERPS geek for a CFII, well not really a geek, probably the best pilot I've ever known.

I agree that the "normal rate of descent" part of the rule can be stretched to mean too low as well, but as stated above, most people interpret that as prohibiting 400 foot dives over the threshold. I think it is already obvious that the reg and training needs to be clarified. My MO in low viz has always been to remain at MDA until I get the VASI, and if none, until I see the whole picture. On an ILS, I've had the PNF call the ball and kept on going for another 100, but we're talking non-precision here.
 
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FN, Those guys put that page up shortly after the crash. SOP-just the normal post crash broad speculation. The NTSB reports I'm trying to figure out were released a few weeks ago. In 20 years of IFR flying from loads of double I work to flying the line, I never gave this issue much thought and it just blows my mind that the exact same thing hasn't happened before. Also, having ditched NOS for Jepps before I even took my INST ride, I always thought they had more info and were generally better. Now I find out they don't put obstacles less than 400 feet AGL on a plate. Makes no sense to me.

By the way, did you find that avatar somewhere on the web or is that your pooch? That has got to be one of the funniest pictures I have ever seen in my entire life. I LMAO every time I see it. I swear that dog is laughing, not just panting.
 
Xav8tor said:
is that your pooch? That has got to be one of the funniest pictures I have ever seen in my entire life. I LMAO every time I see it. I swear that dog is laughing, not just panting.

...oops, FN, he thinks that's your DOG! MMWAAHAAHAAaa...
 
Illini Pilot said:
the 100 rule is only on a precision approach

down to 100' feet, two miles out is not a normal descent to landing

let me clarify about that...

that isn't an FAR rule...but think about it? are you REALLy going to drop down to 100' if you are on a VOR approach without a FAF, you are within 10 and are cleared and established? no.

(3) Except for a Category II or Category III approach where any necessary visual reference requirements are specified by the Administrator, at least one of the following visual references for the intended runway is distinctly visible and identifiable to the pilot:

(i) The approach light system, except that the pilot may not descend below 100 feet above the touchdown zone elevation using the approach lights as a reference unless the red terminating bars or the red side row bars are also distinctly visible and identifiable.

only a precision runway is going to have the ALS, unless you are doing it to a prec. runway that also is served by a NP approach. so when i said it only applies to prec. approaches, i misstated what i meant to say. if you are shooting a VOR approach, hit your VDP or whatever and only see the ALS, going down to 100' abv TDZE is perfectly fine. however, you CANNOT do it 2 miles out, that violates:

(1) The aircraft is continuously in a position from which a descent to a landing on the intended runway can be made at a normal rate of descent using normal maneuvers, and for operations conducted under part 121 or part 135 unless that descent rate will allow touchdown to occur within the touchdown zone of the runway of intended landing;



just remember:
 
“The final, and perhaps most, interesting thing, one that really threw me for a loop reading these factual reports, is that the NTSB seems to have found that the crew of the same flight under similar weather conditions the night before the accident almost did the exact same thing and had to do an abrupt pull up of sorts to avoid hitting the trees at about the same place.”

Would you please show us your source here, where is this information coming from?

Isn’t it funny how good we all are at speculating on how things should have been done? Would we still be such experts had we been in their shoes? Just wonder…
 
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I have to believe fatigue played a part in this. I know coming in at the end of a 14+ hour long day, trying to pick out the airport lights from the rest of the city lights especially on a non precision approach is tough. I have seen lights I thought were the runway only to realize a couple seconds later it was a street or something else. It would be really nice if the FAA would recognize that it's foolish to permit us to work potentially a 16 hour duty day without any mandatory breaks at an airline yet jobs like truckers only can work 10 hours and must take a break in that time.
 
OK Nose, I'll bite. You mean it isn't his dawg? Or even a dog at all? My near vision isn't even close to perfect but my Photoshop skills are OK. It's only a 6.06 kb 92 dpi GIF, but when I blow it up and enhance, it still looks like a dawg to me. Is it a mask, costume, digital fake? Come on man, don't keep me hangin. Oh crap...now I get it. Are you saying that it is his biatch? I think she's cute if that's the case.

Seriously, I gotta know about that pic. It is just way too funny. BTW, the waveform and spectrogram ("voiceprint") on my current avatar is a short half second or so human sound, but it isn't speech.
 

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