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

[TonyC]

I asked:

1) You state that "according to investigation interview statements ... a lot of pilots are under the impression ..." Would you please tell us the exact number of pilots whose interview statements indicated they were under that impression? In other words, would you substitute an actual number for the phrase "a lot"?

Is this your answer?

... a surprisingly large proportion were interpreting the subject reg and procedure in a manner that the NTSB apparently feels almost led to at least one accident, and 24 hours later, did.

Now, what was that remark about unproductive semantic games?



.

 

[Xav8tor]

Tony,

I hope you are having fun. I'm not. Not that you or anyone else here cares, or should care, as of today, I don't have time for this anymore, not that I ever did. I actually started this thread motivated primarily, but not exclusively, with a sincere concern for the safety of people I don't even know, and a naive desire to think that I can "change the world," a little a bit at a time, or as I concluded my personal statement in my app to law school at the ripe age of 40, "one case, one client, at a time." Well, I never took the bar and still haven't shaken my addiction to the smell of kerosene or the adrenalin rush of a handflown ILS to the bottom topped off with a greaser dead on the stripes. I got a rush out of a cap panel light and running a QRH list, and I took pride in hearing pax get on my little J32 moaning about the size of the plane and the surely inferior skills of the pilots since the good ones were all on jets, then having those same people get off the plane smiling, saying it was the most fun, best flight, smoothest ride, they'd ever had.

I miss that, and I miss being who I was after reaching the top of the heap (yes, like most men, I was so proud of what I did that, in many ways, I defined my own self-worth by my profession), which to me, wasn't the left seat of a widebody, but steering the safety aspects of an entire airline operation, albeit small. I don't get that kind of satisfaction or credit in the end of the biz I'm in now because the rules are different, the goal is different, the opportunities are few and far between, and business is slower now than in the past 15 years. To satisfy my own needs, and to feed my "white hat" syndrome, I saw an opportunity to jump on a possible system safety problem, make a few calls, write a letter or two, maybe get a study going, culminating in effecting a change that saves a life down the road.

Play your word games all you want sir. And as for my answer you quoted above, what did you expect from someone who learned that in the first week of law school? As far as I am concerned, I directly answered your questions, but I am not going to bother to cut and paste quotes, or make a spreadsheet for you. Besides, this thread went off in a different direction and the number of answers (sample size) is too small, and, there are no controls. Furthermore, even one GA IFR pilot, much less an instructor, saying they teach that it is OK sometimes, is enough to consider taking action. If not just one person at a scheduled 121 carrier code-sharing with a major in a variant of their livery, who is on the certificate, in the training dept., check airmen, etc. says that maneuver is permitted and safe, but more than one, like two or three, then toss in a line pilot or two, and an inspector….can you say “Emergency Revocation”? I would have yanked that sheet of paper off their wall in a heartbeat. I swore I wasn’t going to make this a 3C 5966 thread but you keep bringing it up. As to the number of their pilots under this questionable impression, I admit it is relevant. I used to fly with some of the people that started that outfit when they were at AE. I think at least one was still there and not one of them was ever told to shoot a LOC/DME that way back then at AE. If I remember correctly, one was a check airman way back then and word was he really knew his stuff and expected his pilots to as well. If they didn’t, it was a one-way standby ticket home in a uniform with no brass. And...If I were Nick Sabatini ( a man I deeply admire and respect, in particular for his work with regional airline safety programs), I would be sending out a letter to every pilot in the database…as a minimum action.

As I said before, if you want a stat analysis of the percentage of witnesses interviewed whose interpretation and/or application of 91.175 is unsafe, needs qualification, however you choose to define it, then get the whole report, define and categorize the statements, control for the variables of your choice, and run an ANOVA or regression analysis on it, whichever you deem appropriate depending on your design and chosen variables. Then you will have to do the same thing with a broader sample population. Third you'll choose yet another design/analytic method to see if there is a significant difference between the first two. If you truly want an academic answer with "integrity and honesty" as you put it, although I think you might have meant something more along the lines of reliable and valid, then that is how you must go about it.

Alternatively, instead of obstinately engaging in a war of words with a person having both undergrad and grad majors in speech pathology/languages/communication sciences, and playing 20 questions with a brainwashed JD grad, you could instead do what I did today: spend ten hours researching the issue in a professional manner and plan on sharing the results via useful communication, presented clearly and objectively, which I would have done tonight had I not again fallen for your flame bait. I am embarrassed about doing that and apologize to others on the board for having done so…again.

For two reasons, one personal, the other people like you on this forum who turn participation into an unpleasant experience, I will soon be leaving this board as a poster. There must be a better place where professionals, interested amateurs, or even wannabees can productively exchange ideas, express opinions, and strongly disagree without impinging upon the mod's time and the owner's bandwidth. I may now be guilty of that out of my sheer verbosity (a serious fault) and my sorely missing crew room/airport lounge chat, but with nearly a half a century of life experience and admitted into PKP as a grad student (relatively uncommon), but with courses in gen psych, abnormal, developmental, educational, perception, rehab, human factors, B-Mod, psychotherapy and counseling, plus months of clinicals, I cannot fathom your motivation for what has amounted to an aggressive hijack of what started out to be a potentially useful thread and your choice of me as a target for personal attacks.

As I stated above, I will, if I still chose to at this point, share what I learned today in a farewell post hopefully tomorrow, because I said I would and because some pilots may benefit from it. I did. I will also no longer respond directly to your posts Tony, if for no other reason, than you don't seem to comprehend mine and I am trying to lower my normal style of writing to make it easier. I vaguely remember a B-Mod prof telling me a basic principle was: "An unreinforced response tends to extinguish over time." I won't be around long enough to see the result, but I 'm going to try an initial dose anyway.

Also, I wuz gonna make yew a gift of an enternet websight with a clickerable link to a video that where these three big shot lawyers frum the biggestest lawyer cumpaneez spends almostest a hole of an hour right in frunt of these really big guvernment men and I think their boss was a women who waz all anyways jawing like krazy about my most bestest ever thing I ever did what took me almos a year of kompooter reserchinging and book reading in five or six liebaries that I finully wrote down on a whole box of typin paper that rolled what I knows about airplanes and speeking and voices and rekordingn tapes and people's brains and videos and mooviemaking and how the laws in this here kuntry are now, why they got that way, and then next how theyz awt to bee in the future after when planes krash. Now all the other lawyers that git lucky and sign up a big plane case just copy the stuff I writ in my old paper because the guys on the other side said ther ain’t much point to arguing with what I said cause all the judges think it makes more cents than what all them big shots with cloths that costed more than my house have to say about. I bennthinkin about nex time working for the other side cause theat would be fun arguing with myself and I think I could win.

Anywayz, it won’t do no gud for you to read the papers or watch the movie since you don’t like me and my stupid ideaz and butt it wuldnt do iny gud also too bekauze they don't never mention my name cause for certain raisins they couldn't and for the main is the one guy wanted everybody to thunk he rilly wrote it cuz even sevin yeers later it wuz still being called the poster child and a masterpice and stuff like that so since evin if you called them and they do say I am the one that did all that stuff thin yew won't beleeve it anyway either cuase you think I would have set it al up. But like I sed, since you prolly kicked my rear on this thred why don’t you start one about cockpit voices tapes and stuff about thim. I might hang around and post sum back just for the fun cause I will still need to have sum fun sometimes even when I am too bizzy tryin to find a job or maybe finully sitting in a bar exam instead of a bar stool.

_______________________________

Did a ton of solid research and spent a few hours on the phone and got some credible answers folks. I will post the results of what I learned today from more than one horse's mouth about the original questions and a few other relevant issues some of you raised. Thanks again, especially you Tony. If I hadn't taken the bait I might never have learned as much as I did. Even though I have all but given up on putting it into professional use in the future, some of you can. And I will finally sleep without obsessing over a nagging question thinking it was sans solution.
_______________________

PS/Hint - Crow season opens tomorrow, not in 6 months as I thought yesterday. I’ll take a few pieces on a spinach salad. I admit I am not perfect and repeatedly have so save me a little. You can have the rest for an entrée. Better make it a double breaster.

 

[TonyC]

Good GRIEF! Where did all the hate come from? Why do you insist on taking everything I say as a personal insult? Are you that thin-skinned?


You still haven't given me a straightforward, direct answer to any question I've asked. I suppose I'd be forced to ask the judge to allow me to question you as a hostile witness.


Look, you come on this board, on this thread and others, laying out your credentials and expertise, you make a statement which I challenged. Big deal!


I submit that nobody that has responded on this thread is of the opinion that one can descend below the MDA REGARDLESS OF DISTANCE TO THE RUNWAY using only the ALS as a visual reference. If you think otherwise (as you seem to) you must be misinterpreting what they've said. I feel like you have similarly misinterpreted the data you've examined with regards to the aircraft accident in question.

I'm not attacking you - - I'm disagreeing with your ideas.

Plain and simple.


Thanks for the Hillbilly talk, though. I really enjoyed that.






P.S. Are you looking at my Avatar and reading my posts at the same time? Maybe that's what's got you so upset. That ain't me, ya' know?!


.

 

[FN FAL]

Thanks for the Hillbilly talk, though. I really enjoyed that.

P.S. Are you looking at my Avatar and reading my posts at the same time? Maybe that's what's got you so upset.

That river don't go to Aintry...(dueling banjos)

 

[Xav8tor]

I swore I would not do this but here is an INFORMAL analysis of what I felt were useable, direct, non-duplicative responses to the question on this INFORMAL flightinfo thread/”poll” which is only one source, and admittedly not a good one from an academic standpoint, of getting the answer to the question posed:

OK to leave MDA for 100 above TDZE based upon seeing ALS alone: 1*
Other potentially unsafe application, misconception, etc. of 91.175: 2
OK to Leave MDA only with Add’l visual reference/approach aid: 9

Total valid responses: 12
Percentage of responses indicating clarification of 91.175 may be prudent: 25%

* “I teach my students that if you can see the approach lights you can go lower (100ft) the idea being if you can see approach lights, you can see obstructions as well.” (Post #28)

Given the well-grounded emphasis on CFIT and ALAR, the ratio of those to all other types/phases of accidents, and the direct applicability of 91.175, I would conclude that if 25% of all IFR pilots are not applying the regulation (and related procedures/rules, etc.) correctly when making one of the most, if not the most important, command decisions of an IFR flight in (low) IMC, then yes, that is a substantial number, a lot, a sheetload, too many, whatever. As a safety professional, assuming the results are valid (which I am not assuming, but think they clearly indicate the need for a FORMAL study/survey that is well-controlled/designed to confirm my preliminary assumption), then yes, I believe the risk factor presented by the issue is unacceptable in quantity and quality terms and needs immediate proactive attention. Even if you toss out the 2 indirect responses that’s still 10% and IMHO, an unacceptable number if a 10 “n” sample is sufficient, which I admit it isn’t. Nevertheless, because the single clearly erroneous response is from a CFI, the impact of the “numbers” may be far greater due to the additional IFR pilots now in the system operating on the same unsafe assumption they were taught.

I needed the break and can’t follow my own resolve to not respond, so there you go. If I have the time and inclination, I’ll do the same breakdown on the witness interviews, but that will only further delay my posting the good info/answers I got yesterday.

BTW, yes, I do sometimes get a weird feeling when I look at your avatar. First, the guy looks like a younger version of my dearly departed uncle, an ex AAC/USAF bomber and test pilot/aeronautical engineer who helped me get started in aviation and was an all-around cool person (genius, but eccentric too). The expression is the same one I’ve seen on many faces (including my own) under a cross, and is exactly that of almost every pilot witness at the NTSB hearings I’ve attended. Third, it reminds me of the “starch in their underwear” type pilots I’ve had the displeasure of flying with, or even riding in a hotel van with. In other words, pretty much the opposite of my reaction to FN’s avatar. I’d like to have a high rez version of that pic. And speaking of avatar’s, when are you going to ask what that sound is on mine?

 

[SSDD]

X...

I've been following this thread and I think its about time for both of you to give it up!!!!!

You brought up what you perceived as a potential problem...THANKS!

Now please go do your research and get back to us with your results, but please stop trying to justify you opinions with endless posts of your background and qualifications.

 

[TonyC]

OK to leave MDA for 100 above TDZE based upon seeing ALS alone: 1*

* “I teach my students that if you can see the approach lights you can go lower (100ft) the idea being if you can see approach lights, you can see obstructions as well.” (Post #28)

Finally, a straight answer. Thank you. Now we can discuss something.

Here's where context comes in to play. If we were to interview MTpilot regarding this response, we might ask a question along the lines of, "Does this apply at any distance from the runway?" Now, you might point out that you already explained that in your original post. True. However, we being human, we make mistakes from time to time. I'm sure you're aware that people form answers to questions before they've heard the entire question. Sometimes it takes restating or explaining the question several times to get to the real information. If you reword the question and get a different answer, you have to dig deeper. MTpilot might answer, "Well of course not. Distance DOES matter. I thought you meant when we were already at the descent point." On the other hand, he might answer, "Absolutely. Anyplace I can see the lights, be it 1 mile, 5 miles, or 10 miles, it's OK to descend to 100' HAT." As you can see, the followup question makes all the difference.

So, we might disagree that MTpilot incorrectly applies the descent methodology. I don't fault you for your opinion; I just don't see it that way.


Similarly, we might disagree on the published reports. What you read as an indication that someone incorrectly applies a procedure, absent the in-context inteview-type analysis might be different from what I read.

I don't really care if we disagree. It doesn't hurt my feelings one bit. I hope it doesn't hurt your feelings. That wasn't the reason I posted on this thread to begin with. I posted to raise a flag on your statement regarding published VDPs and the existance or absence of a close-in obstacle. You stated, with authority, that a certain relationship was fact. In fact, it's not. That's my issue.

BTW, yes, I do sometimes get a weird feeling when I look at your avatar. First, the guy looks like a younger version of my dearly departed uncle, an ex AAC/USAF bomber and test pilot/aeronautical engineer who helped me get started in aviation and was an all-around cool person (genius, but eccentric too). The expression is the same one I’ve see on many faces (including my own) under a cross, and is exactly that of almost every pilot witness at the NTSB hearings I’ve attended. Third, it reminds me of the “starch in their underwear” type pilots I’ve had the displeasure of flying with, or even riding in a hotel van with. In other words, pretty much the opposite of my reaction to FN’s avatar. I’d like to have a high rez version of that pic. And speaking of avatar’s, when are you going to ask what that sound is on mine?

The man in my Avatar is Frederick W. Smith, Founder, Chairman, President, and Chief Executive Officer of FedEx Corportation. The photo was taken on 18 Jan 2005 during the "A380 Reveal" ceremony in Toulouse, France. You'd think the guy might be happy about the whole deal, him being the guy that ordered the first 10 freighter versions and all. On the contrary, he looks like he's angry that he has to share the stage with UPS. One of those "true colors" moments, if you ask me.

I don't plan to ask you what the sound on your Avatar is. Remember, I've already read all of this thread.

... the waveform and spectrogram ("voiceprint") on my current avatar is a short half second or so human sound, but it isn't speech.

That's more than I want to know.


EDIT: I can't find the picture of Fred on the Airbus website anymore. I'll PM you a link to YouSendIt.com where I just uploaded the image for you.

 

[TurboS7]

Be real. Fred is still a dreamer and a businessman, he is trying to figure out how many envelopes he can fit in that thing......LOL>

 

[Xav8tor]

SS,

I wouldn't have felt the need to do that if I my qualifications weren't called into question, perhaps because my style of writing and expressing an opinion makes it sound as if I am confident in the correctness or validity of my statements, which I am, unless I state otherwise. I know who/what I am/was, and not ever going to be, and to tell the truth, I am not all that proud of where I am right now in terms of my "station" in life and feel pretty dang worthless. Maybe that's part of the reason I wanted to jump in on this issue as I already stated my motivation, and it isn't ego, unless you confuse that with gratification from finding the smoking gun others glossed over, or enjoying a little credit for taking a difficult stand and trying to make the system a little safer.

I'd much prefer to do exactly what you suggested and remain more than humble, even totally anonymous, to a degree, my cover is already blown, and that is, I admit, my own fault. You do have a point, but I will not take even a substantial portion of the blame. In over a decade in the safety biz in varying environments and capacities, interacting with professional pilots and safety professionals from all over the country (and beyond), even in the most heated situations (i.e., immediately post crash), where accident theories were debated and the stakes, and emotions, were higher than you can possibly imagine until you "have the t-shirt", I have never experienced the sort of unprofessional behavior, disrespect, and just plain rudeness I've seen, and been subjected to, on this board, and I am not alone in feeling that way about some of the threads in the past month or two. You are right in that this may not be the best outlet for me as a stop-gap, but it was worth a try. To those of you who did participate in a productive manner, thank you.


Tony,

Thanks for the very reasonable response. Of course digging deeper is required. That is exactly what I've said more than once. On the witness interviews though, I hope they (NTSB) are digging deeper, but read in context with the other docket contents and knowing the scoop on NTSB techniques, and how this particular IIC approaches an accident, the mere fact that it is in there means they think they are onto something. I'll post the whole thing later, but it will take about three posts to get all 35 pages in there. To save space, I'll leave out the ones they didn't ask at all (i.e., other ops issues, but not this one). You will have no doubt that there is a big problem, at least there.

Regarding the accident flight itself, as Eddie postulated, and here is the best answer I can give him at the moment, it is possible for one who has not done a complete analysis of all relevant evidence to conclude on the NTSB CVR transcript alone, which is never a good idea, but not for the reasons they say in their “disclaimer,” along with a raw, rough FDR/radar profile plot, they weren't going to stop at any altitude. Having gone a little deeper, looked at a lot of other docs, I, for now at least, think that “in sight...continue" meant keep coming down. Note they cancelled the FD which had been in ALT hold mode for MDA just after that (and since they were obviously still in a descent he had to be fudging the FD with the CWS button, or just ignoring it). It is almost impossible to make those sort of conclusions without the tape itself, the FDR and/or radar data, other documents, and a ton of complex, long, tedious work. But again, aside from the witness interviews about 91.175 I want to avoid 5966 specific discussion. It is only an example (a darn good one) of what I still think is a potentially big safety problem across the whole system that is “fixable.”

As for the relationship between the presence or absence of a VDP being a very real possibility, but not necessarily probability, as a clue that an obstacle may be present, and concluding therefore that additional caution is advisable, sorry, but if and when I get to summarize the results of my findings from the past few days, especially yesterday, you will see that the statement I quoted from Whitt's flying is soundly based on fact and is a very prudent “safe side” assumption to make when thinking about how far out you should consider leaving MDA. There are a number of reasons a VDP might not be charted, but the presence of an obstacle in the final segment is a common one. I now have written quotes from various docs to back it up and some hugely credible explanations from individuals who I can’t name because they requested it, but let's just say they were very kind to take the time away from their rather high up in the chain responsibilities to help us all out. I'm sure you can verify what I hopefully get to post with a call to one of the guys in EAS at ALPA or check the member section of the website to see if there is a committee member who has looked at the issue. They'll back it up.

Re your avatar, maybe it was the French food? Re mine, you’re definitely a perceptive person. It might not be exactly what you think it is, but I have a feeling you are really close, but no cigar

 

[TurboS7]

You guys are scaring me I may never want to shoot a non-precision approach again.

 

[Xav8tor]

I know you’re just being facetious, but that’s one of the things that drove me nuts on the news reports after this, and similar accidents. I don’t think that an NP approach is inherently more dangerous, or difficult, than an ILS. FLOWN PROPERLY, as far as I’m concerned, one approach is a good as the other, the only difference being the probability of a miss. Other than island flying, my absolute favorite is handflying approaches, even NDB’s, down to mins.

Do a Google on 5966 and approach. You’ll see all sorts of statements inferring that the reason the plane went down was because IRK doesn’t have an ILS. And guess what? The town had been trying for months, maybe years, to get funding for a GS approved. Shortly after the crash, they got the approval.

Plenty of people would be satisfied with that as the probable cause and the proper remedial action too.

 

[Xav8tor]

For those who requested to see the interviews “in context” which I took to mean the whole report, converted from a pdf to txt, it is over 100,000 characters and this board has a 10,000 character limit per post. I don’t think the mods or most readers would appreciate that. The excerpts I posted were not cut/pasted with any alteration to advance a position in mind. I just posted the parts from those interviews that illustrated the issue. I did delete names.

If someone knows of a way to post attachments here, or can provide a public free host, I’ll upload the entire docket. It needs to be a server that doesn’t require registration for people to view and download the documents. The entire set of reports is 34 mb. Group Factuals are very different from the final reports most pilots are familiar with and contain more info than “accident reports” and would help those who really are interested in the nuts and bolts of how theories of causation/contributing factors are derived.

I won’t get around to posting my research summary on 91.175/VDP/Obstacles, etc. tonight, I’m tired and getting a little burnt out on this thread (as many are). However in reviewing the posts and integrating what I learned, I did see a nice AIM quote Clutch already posted that was mentioned by one expert I spoke with. It at least infers (to me it is pretty darn clear) that, if you want to play it safe, and you are deciding if it is OK to leave MDA yet, the absence of a VDP on the chart should be a heads up that premature descent from MDA is ill-advised due to (among other things) a potential obstacle danger (e.g., tall trees growing on rolling terrain):

“Approaches without VDPs have not been assessed for terrain clearance below the MDA, and may not provide a clear vertical path to the runway at the normally expected descent angle. Therefore, pilots must be especially vigilant when descending below the MDA at locations without VDPs.” (AIM 5-4-5)


More later.

 

[Xav8tor]

This issue apparently has burnt out here, and things are hitting the fan for me, so I don't know if I'll ever get around to writing what amounts to an accident analysis or factual brief, but here is a brief summary of what I learned and have concluded for myself. Your mileage may vary.

First as to whether a pilot considering when it is safe to leave MDA under IMC at a distance greater than where the VGSI intersects MDA, the obvious answer should be "don't do it" even if you do see other 91.175 visual clues (except of course the VASI/PAPI). Unless you are on a VGSI or at/above MDA, you are on your own for obstacle avoidance.

Assuming you are a pilot who knows that other things like no DME preclude publishing a VDP, and IMHO even if you don't, if you are for any reason thinking about leaving MDA on the basis of the ALS without more (i.e., until you are on the VASI) solely based upon 91.175 as written, again, don't do it, but if you do bother considering the lack of a published VDP when deciding, it is very reasonable to assume that an obstacle is a real possibility/reason for no "V" and you may hit it. In addition to the AIM cite above, elsewhere in the same section is the following:

f. Visual Portion of the Final Segment. Instrument procedures designers perform a visual area obstruction evaluation off the approach end of each runway authorized for instrument landing, straight-in, or circling. Restrictions to instrument operations are imposed if penetrations of the obstruction clearance surfaces exist. These restrictions vary based on the severity of the penetrations, and may include increasing required visibility, denying VDP's and prohibiting night instrument operations to the runway.


8260.19C CHG 3 7/14/03 Flight Procedures and
Airspace

SECTION 3. VISUAL DESCENT POINT (VDP)
430. ESTABLISHMENT. The VDP defines a
point on a straight-in nonprecision approach where a
normal descent from the MDA would commence if
the required visual references were acquired.

a. Establish a VDP provided the SIAP meets
the requirements of TERPS Volume 1, paragraphs
251, 252, and 253.

b. For chart clarity, a VDP should be no less
than (1 mile OPTIMUM) (0.5 miles MINIMUM)
from a final segment fix or MAP. If proximity closer
than 0.5 miles is required, consider one of the
following actions:
(1) Do NOT establish a VDP.
(2) Relocate the fix to the VDP location,
and do NOT establish a VDP.
(3) Relocate the fix to accommodate the 0.5
mile (or greater) requirement.
NOTE: Option (2) above increases MDA and
descent angle. Option (3) increases S/D
altitude.

c. Do NOT adjust visibility minimums to
accommodate a VDP.
d. Where used, the DME source must be the
same as the DME source for DME fixes in the final
segment.

431. FAA FORM 8260-9 ENTRIES. To facilitate
review, entries may be required in the REMARKS
section. Where a VDP is not established, give the
reason; e.g., obstacles penetrate VDP surface,
descent gradient, proximity to final approach
segment (FAS) fix, etc. (see paragraphs 857q and
860c).
432-439. RESERVED.

Now here is where it again gets complicated. In the 5966 example, were they in the visual segment at the relevant point/time? Well, that takes some math, a lot of TERPS steps, and graphing/charting, etc. and I don't have the time to do it. Also it is irrelevant. The point I wanted to suggest is that if you don't see a VDP charted and there is DME and a VASI (which you don't yet see), etc., the, or at least, a, safe assumption is that there is an obstacle out there. It is another reason to stay put at MDA regardless of what 91.175 says is "legal." The folks I spoke to agreed. Is it the only possibility? No...it might be that that approach simply hasn't been evaluated for a VDP yet, but I wouldn't bet my life on it.

That about sums it up for what one might consider if you don't see a 'V" and aren't doing a constant rate descent (another topic for another time). Since I did quote an “unverified” web source the first time I said it this and it was too broad a statement, I’ll take some “crow” on my salad. I still say it is a safety conscious way to think in the cockpit, and if I ever get in one again, I’ll try to remember it.

Next, the missing +/-1059 trees about between where they left MDA and the threshold. This was not their exact point of impact, which was a little further out, but that isn't my point. I stand on my opinion that if you insist you are going to leave MDA for 100 above TDZE on the basis of seeing the ALS alone because you think 91.175 says OK, and an obstacle is between you and the runway within 5 feet of your intended altitude, and close to the LOC course centerline, you're asking for trouble. But in fairness to Jepp users, you can't consider it if it isn't on the chart. No one I spoke with disagreed with that.

Should there be a change or clarification to 91.175? Forget my opinion, your opinion, or the "number" of people who think the ALS alone means you are good to go from MDA to 100 TDZE. Some do and within that group there are those that either don't consider distance from the threshold at all, or are uncertain about where the "safe" point is.

My research and calls to various people “in the loop/know” confirmed that it is already "under consideration" at various levels. There is evidence that the example operator is/was not the only one that permitted the procedure/profile in question. Whether the reg gets changed or the topic gets any other consideration is anyone's guess. Most of the time, the number of lives lost and amount of media attention seems to control whether a reg is changed/made in response to an air crash. That is just an opinion, but I did write a long paper for a legislation class on the subject and that is what my impression was 7 years ago.

Even though the FAA dual mandate has since then been eliminated (something I called for in that paper and still only got a B), the rulemaking process continues to have as much to do with money, perhaps more so, as it does safety. As a matter of fact, that too is the law. Oh yeah, toss in “politics.” I don't know if a single person can make a difference, but I do know that one is already trying to get 91.175 changed and it isn't me. He beat me to the punch by months. Personally, I wish him luck and hope that the NTSB makes an official recommendation to help push it through.

Thanks again for everyone's input. Business is bad and the horizon is obscured at best. If things get any worse, come see me at Home Depot. It sure doesn’t look like it’s going to be in aviation ever again.

Xav8tor

 

[TonyC]

Xav8tor,


Thanks for your calm, reasoned post. As I said in my very first post on this thread, I apprecaiate your zeal. You've certainly devoted a lot of time, energy, and thought to this subject, and it has been a healthy exercise for all. I'm sure we've all learned something here.

My caution against reading too much into a single statement or even a conversation taken out of context stands, but I think you understand that. A stark example of that caution can be seen when contrasting the title of this thread with the thoughtful discussion of VDP construction offered in your last post. If I were to put too much weight on the title alone, I might think you're of the opinion that one must remain at the MDA until the MAP. Given that the vast majority (at least in my limited experience) of MAPs are located at the end of the runway, and remaining at the MDA until then would make it impossible to land in the touchdown zone using normal maneuvers and normal rates of descent, such a practice would render non-precision approaches useless to me. The discussion in your last post makes it clear that this is by no means how you interpret the situation. Similarly, each voice should be given the same fair hearing.

Thank you for posts - - as I said, I think we've all learned a bit. I'm sure there are many who've read but not spoken that have learned more than we can know. And that's what it's all about, anyway - - learning.





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[Xav8tor]

Tony,

Thanks for the kind words, I can use them. Just got word for sure (saw it coming for a week or two) that I lost out on a position I’ve been chasing for over two years: perfect locale, great people, decent salary & benefits, stability, and getting to do a little bit of everything I’m good at. They had me thinking I was a shoe in. Maybe that’s why I’ve been a little “intolerant.”

Funny you should mention the thread title as a problem. I’ve been thinking about finally writing a book or TV/screenplay about some of my experiences, focusing on CVR’s and the “dark side” of air crash investigation. I chose the title first, before even doing an outline. I was chatting with someone who has been pretty successful at it and he said I broke a cardinal rule: NEVER write the title before you write the book. I knew that from writing papers in school, research, and briefs too, but it applies here too I guess.

If anyone ever has a question about CVR’s, ATC tapes, cockpit communications, language issues, etc., please start a thread, I’d love to participate. If any of you ever need professional advice in the area, I’ll give pilots a professional discount! I’ve done a bunch of them, including some of the big ones in the last ten years, so let me know.

Keep the blue side up (unless you are fortunate enough to do aerobatics) and keep your eyes open for changes/recommended procedures on non-precision approaches. It’s still early to say whether some of what was discussed would have changed things on 5966, but modern theory is, if only one relevant factor had been different, removed, defended against, etc., then the accident would not have occurred. If our discussion, even the “ranting,” makes one pilot think twice someday about ducking down a little low/too soon to get in, then it was all worth it.

Thanks again to all for the stimulating discussion and chance to talk shop.

X

PS - Wishing I could drop that “x”. This discussion helped make me miss the airline biz and the cockpit more than ever. If you’re still in the game, one last piece of advice/opinion: no matter how bad it gets (to a point of course), a crappy day on the line, or just about any position in aviation aside from lav service, is better than a great day at most other places you could be.