Approach Vis question

[zugzug]

Carl

Ok, glad I could help.

 

[TIS]

Put down the correct answer and then put down the training department for having such a messed up recurrent study packet.

 

[jackbo]

Without sounding dumb, it is basically the same thing. The reg says you can't continue past the FAF but most airlines interpret that as you can't start the approach.

If you want to get technical, you can't continue past the FAF but I don't think (not sure -- just my opinion) that a controller can/will even clear you for an approach in the vis is below mins.

I guess what I'm trying to say is that the reg is specific but most interpret it the way your packet says. I don't think it is horrilby wrong to say you can't start the approach, because that is how most explain it.

No offense to TIS, but I don't think by saying that your training department is doing you a huge disservice.

 

[nosehair]

I guess what I'm trying to say is that the reg is specific but most interpret it the way your packet says. I don't think it is horrilby wrong to say you can't start the approach, because that is how most explain it.

We are "starting" the approach when we "begin the final descent" which is at the FAF. Am I right? We tend to think of "starting" the approach at an earlier point - like when we begin the approach checklist or something like that, but we are just preparing and readying for the decision to "begin final descent" at the FAF.

 

[TIS]

Without sounding dumb, it is basically the same thing. The reg says you can't continue past the FAF but most airlines interpret that as you can't start the approach.

Fine. If that's the case then there should be a GOM reference that says this instead of ambiguity - or worse - NO guidance at all.

If you want to get technical, you can't continue past the FAF but I don't think (not sure -- just my opinion) that a controller can/will even clear you for an approach in the vis is below mins.

Sure they can but they also know that you can't accept the clearance so you'll usually get a question. Does this sound familiar? "ABC is below minimums. Say your intentions." The restriction is on the pilot not the controller.

I guess what I'm trying to say is that the reg is specific but most interpret it the way your packet says. I don't think it is horrilby wrong to say you can't start the approach, because that is how most explain it.

Well, it's not accurate though. What you can't do is commence the final approach segment - however that's defined. You can navigate on published segments of the approach to get to a holding fix - often located at the FAF you know. We used to get the below mins question all the time and we'd just tell them to get us to the FAF or to someplace where we could sit and wait. The idea was to give the report a chance to change in our favor so we could shoot the approach. When it's an RVR report thats happens more readily than a new ATIS.

No offense to TIS, but I don't think by saying that your training department is doing you a huge disservice.

Offend me all you like if I'm wrong. But if the company says one thing in a training department document and the FAA says another in their regulations and there is nothing about it in the GOM then the FAA wins. It's that simple.

TIS

 

[jackbo]

Sure they can but they also know that you can't accept the clearance so you'll usually get a question. Does this sound familiar? "ABC is below minimums. Say your intentions." The restriction is on the pilot not the controller.

I agree with everything you said.

I just wasn't sure if the controller could legally clear you for the approach or not. I realize the onus is on the pilot, but I wasn't sure how much the controller could or couldn't do.

Again, I think saying "You can't start the approach" is an over simplification used by some people as a way to explain the difference between 121 and 91. But you are correct to say that should be clarified. I can see what you mean that it could lead a person to believe that they couldn't even be on a published segment, etc. without the required vis and that is not true.

This is where trying to make it easier can make it much more muddy.

Offend me al you like if I'm wrong. But if the company says one thing in a trining department document and the FAA says another in their regulations and there is nothing about it in the GOM then the FAA wins. It's that simple.

The offense part was tongue-in-cheek. I know you are looking for clear and CONSISTENT guidance from the company and that is awesome. I know it would take more than that to truly offend you! It's all good, man...

 

[TIS]

Again, I think saying "You can't start the approach" is an over simplification used by some people as a way to explain the difference between 121 and 91. But you are correct to say that should be clarified. I can see what you mean that it could lead a person to believe that they couldn't even be on a published segment, etc. without the required vis and that is not true.

Yup and to provide an example, how about a situation in which you need to fly a full procedure beginning at a VOR located on the field out to a PT and then back in on whatever kind of course defines the approach. Now also suppose that the 8-10 minutes it takes to do that and get back to the FAF is all it's gonna take for the fog that's making the airport IFR finish clearing above minimums.

I think we (and anyone else here) would agree that the intent of the rule is to limit the pilot to only those approaches that have a reasonable chance of success. An approach begun when the airport weather is below what it takes to land cannot be considered a circumstance in which this is so. The line has to be drawn somewhere and that line is drawn at the FAF. In my example this is where the final decision must be made as to commencement of the final approach segment.

Simply saying that you cannot start an approach ignores the reality of these types of situations. It might be more accurate to say that company policy is NOT to accept an approach clearance unless the airport is better than minimums. You CAN, however, fly published initial and intermediate segments of an approach while you wait for a better report. That's what oughtta be in the GOM and that's what the training department should be telling people.

On the other hand, if the company REALLY doesn't want people flying ANY part of a procedure without the airport being above minimums, that should be equally clear in the GOM.

TIS

 

[Singlecoil]

Yup and to provide an example, how about a situation in which you need to fly a full procedure beginning at a VOR located on the field out to a PT and then back in on whatever kind of course defines the approach. Now also suppose that the 8-10 minutes it takes to do that and get back to the FAF is all it's gonna take for the fog that's making the airport IFR finish clearing above minimums.

I think we (and anyone else here) would agree that the intent of the rule is to limit the pilot to only those approaches that have a reasonable chance of success. An approach begun when the airport weather is below what it takes to land cannot be considered a circumstance in which this is so. The line has to be drawn somewhere and that line is drawn at the FAF. In my example this is where the final decision must be made as to commencement of the final approach segment.

Simply saying that you cannot start an approach ignores the reality of these types of situations. It might be more accurate to say that company policy is NOT to accept an approach clearance unless the airport is better than minimums. You CAN, however, fly published initial and intermediate segments of an approach while you wait for a better report. That's what oughtta be in the GOM and that's what the training department should be telling people.

On the other hand, if the company REALLY doesn't want people flying ANY part of a procedure without the airport being above minimums, that should be equally clear in the GOM.

TIS

I would disagree with that. If you are doing a full procedure approach, you are most likely non-radar. If you receive and approach clearance, you don't have a clearance to do a procedure and enter holding at the FAF waiting for the vis to come up. You have a clearance for the approach. In fact, it if is non-radar you'll probably get, "Cleared approach, switch to advisory frequency". If you can't legally shoot the approach, don't accept an approach clearance. The controller WILL clear you for the approach if the vis is down, as he has no idea what your mins are. You could have company specific mins that are lower than published. It is up to you to refuse the approach clearance. You could just ask to be cleared to the FAF for holding via the procedure turn. That way you both know what the plan is.

 

[TIS]

You're operating on a misconception here

You do not have to refuse the approach clearance. You can indeed shoot some, but not all, of the approach. To do this you need either an approach clearance or a clearance to become established on a segment of the approach along with an altitude to maintain as you do so.

The prohibition is against commencing the final approach segment not accepting a clearance for the approach. Read the regulation.

(b) Except as provided in paragraph (d) of this section, no pilot may continue an approach past the final approach fix, or where a final approach fix is not used, begin the final approach segment of an instrument approach procedure—

2) At airports within the United States and its territories or at U.S. military airports, unless the latest weather report for that airport issued by the U.S. National Weather Service, a source approved by that Service, or a source approved by the Administrator, reports the visibility to be equal to or more than the visibility minimums prescribed for that procedure. For the purpose of this section, the term “U.S. military airports” means airports in foreign countries where flight operations are under the control of U.S. military authority.

The language is specific, clear, and unambiguous - you cannot CONTINUE an approach past the FAF with the weather down. According to what you've said you can't even begin but the regulation speaks to continuing. How can you continue something that you can't begin? What's the reason for the particular wording of the regulation?

Wouldn't you agree that the weather could be marginal at your intended destination but still above minimums, and that you could accept a clearance and subsequently learn (prior to the FAF) that the weather had gone below minimums? In this instance what do you do? Using your logic (taken to a ridicuous extreme I'll admit) you would have to reject ANY approach clearance issued because the weather MIGHT go down between when you got the clearance and commencing the final approach segment.

I agree that when cleared for the approach you are not authorized to hold anywhere unless you obtain additional clearance to do so. So you fly the procedure and about a mile or two from the FAF you get the weather. If it's a no go you tell ATC that the weather is below your mins and you need to do something different. You'll probably hold at the FAF. All of this is identical to what you would do in the scenario I proposed. As a practical matter you do the same thing whichever way it comes at you.

But, maybe we'll just have to disagree. That's okay with me.

TIS

 

[Big Air]

And just to confuse the issue...

In the Navy, we can go all the way to the MAP regardless of the Wx and the Air Farce cannot even start the approach if the Wx is below published mins.