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FAF on an ILS approach?

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DrewBlows said:
Listen to Avbug. He is 100% correct, anyone who says otherwise is mistaken.

Hey, there's some street cred.

I agree though, he's right about the FAF thing. I don't know about the 135 stuff, not saying I disagree, just that I'm not up on the latest in that Part
 
A Squared,

The 135 info posted above is an observation from a plain english rendering...I'm more than open to observations on that posting. To be honest, I wasn't aware of the changes in the AIM or the regulation until this thread prompted me to look.

I wouldn't mind some discussion to pursue that further. I'd take it to Doc's, but I don't have the energy any more to keep up with that level of discussion, or the pace at which the folks there hammer away. Not like I used to.

What caught my attention was that formerly one couldn't start the approach if the weather was down, but if one had already begun the approach and was inside the FAF, one could continue for a look-see. If I'm reading the regulation correctly now, each successive part of 135.225 refers back to (b), which is specific only to eligible on-demand operations. This greatly narrows the applicability. It also would mean that operators not authorized by OpSpec A057 would not have this option...or more importantly, that operators who didn't know about the new wording might put themselves in legal jeopardy because of the change.

The regulation hadn't changed for as long as I remembered, and this thread prompted me to look at it again. If someone has a different view on that, I'd definitely like to hear it.
 
Read that newer reg more carefully and you will see that there is a serious disconinuity. Probably due to a cut-and-paste error when it re-written.

Hint: near the end.

I spent a long time showing that reg around and I think that the provision as we have always known it was meant to be retained, but was accidentally written out. Carefully compare the old and new regs and you will notice that the new one has a weird aspect to it. They inserted the eligible on-demand portion, and probably did not double-check that the letters from each section cross-referenced accurately.

Another little-known thing about this reg is that it went through more than one rewrite in a short period of time. Verrrry interesting.

I've shown it to a couple of inspectors who agreed that it was an error in the rewrite.
 
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I've shown it to a couple of inspectors who agreed that it was an error in the rewrite.

That's entirely possible, as I seriously doubt the intent was to limit the original provision only to operators authorized eligible on-demand. However, for the present, the provisions allowing continuance inside the FAF/GSIA apply only to operators with an Opspec A057 authorization...unless I'm missing something in the reading.

I didn't see any discontinuity in the regulation in it's current publication...but I do think it's unintentionally exclusionary.
 
avbug -

Try closely comparing the old and the new regs side-by-side.

It begins to look like many copy-and-paste errors I have seen in word processor documents.
 
§ 135.225 IFR: Takeoff, approach and landing minimums.

(a) Except to the extent permitted by paragraph (b) of this section, no pilot may begin an instrument approach procedure to an airport unless—
(1) That airport has a weather reporting facility operated by the U.S. National Weather Service, a source approved by U.S. National Weather Service, or a source approved by the Administrator; and
(2) The latest weather report issued by that weather reporting facility indicates that weather conditions are at or above the authorized IFR landing minimums for that airport.

If am NOT an eligible on-demand operator (henceforth EOD), I must have weather reporting, and the wx must be above mins to begin the approach.



(b) A pilot conducting an eligible on-demand operation may begin an instrument approach procedure to an airport that does not have a weather reporting facility operated by the U.S. National Weather Service, a source approved by the U.S. National Weather Service, or a source approved by the Administrator if—
(1) & (2) Certain conditions are met. (edited for space)


Good here too. If I am an EOD (authorized), I can begin the approach if other conditions are met without regard to (a) above.



(c) If a pilot has begun the final approach segment of an instrument approach to an airport under paragraph (b) of this section, and the pilot receives a later weather report indicating that conditions have worsened to below the minimum requirements, then the pilot may continue the approach only if the requirements of §91.175(l) of this chapter, or both of the following conditions, are met—
(1) The later weather report is received when the aircraft is in one of the following approach phases:
(i) The aircraft is on an ILS final approach and has passed the final approach fix;
(ii) The aircraft is on an ASR or PAR final approach and has been turned over to the final approach controller; or
(iii) The aircraft is on a nonprecision final approach and the aircraft—
(A) Has passed the appropriate facility or final approach fix; or
(B) Where a final approach fix is not specified, has completed the procedure turn and is established inbound toward the airport on the final approach course within the distance prescribed in the procedure; and
(2) The pilot in command finds, on reaching the authorized MDA or DH, that the actual weather conditions are at or above the minimums prescribed for the procedure being used.

WHOA!! That's weird. Read (2) again. Not worded well. That text belongs in the landing section. This paragraph is about continuing the approach, not about landing. How can I satisfy this paragraph. It says that I may CONTINUE the approach if (1) I am past the "magic point", and (2) if I find that I have minimums upon reaching MDA/DH.


Think about this. Suppose I am 5 seconds past the FAF when the WX drops below mins. I am still a long way from MDA/DH. How can I look into the future to satisfy condition (2)? I can't. Condition (2) is about making the landing after arriving at the MDA/DH.




(d) If a pilot has begun the final approach segment of an instrument approach to an airport under paragraph (c) of this section and a later weather report indicating below minimum conditions is received after the aircraft is—

Wait a minute again. This paragraph points to (c) which then, in turn, points to (b).

Paragraph (c) is about continuing approaches, not beginning them. It would have been correct to point back to (b) if this is what they meant. (b) is about beginning approaches as an EOD.


(1) On an ILS final approach and has passed the final approach fix; or
(2) On an ASR or PAR final approach and has been turned over to the final approach controller; or
(3) On a final approach using a VOR, NDB, or comparable approach procedure; and the aircraft—
(i) Has passed the appropriate facility or final approach fix; or
(ii) Where a final approach fix is not specified, has completed the procedure turn and is established inbound toward the airport on the final approach course within the distance prescribed in the procedure; the approach may be continued and a landing made if the pilot finds, upon reaching the authorized MDA or DH, that actual weather conditions are at least equal to the minimums prescribed for the procedure.


(e),(f),(g),(h),(i) Not applicable to this discussion.
 
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Here is the old FAR, which made sense; let's look at how it flows:


(a) No pilot may begin an instrument approach procedure to an airport unless --
(1) That airport has a weather reporting facility operated by the U.S. National Weather Service, a source approved by U.S. National Weather Service, or a source approved by the Administrator; and
(2) The latest weather report issued by that weather reporting facility indicates that weather conditions are at or above the authorized IFR landing minimums for that airport.
(b) No pilot may begin the final approach segment of an instrument approach procedure to an airport unless the latest weather reported by the facility described in paragraph (a)(1) of this section indicates that weather conditions are at or above the authorized IFR landing minimums for that procedure.
(c) If a pilot has begun the final approach segment of an instrument approach to an airport under paragraph (b) of this section and a later weather report indicating below minimum conditions is received after the aircraft is --
(1) On an ILS final approach and has passed the final approach fix; or
(2) On an ASR or PAR final approach and has been turned over to the final approach controller; or
(3) On a final approach using a VOR, NDB, or comparable approach procedure; and the aircraft --
(i) Has passed the appropriate facility or final approach fix; or
(ii) Where a final approach fix is not specified, has completed the procedure turn and is established inbound toward the airport on the final approach course within the distance prescribed in the procedure; the approach may be continued and a landing made if the pilot finds, upon reaching the authorized MDA or DH, that actual weather conditions are at least equal to the minimums prescribed for the procedure.


Read the old paragraph (b). That text is missing from the new reg.
The old (b) said that you could not begin the final segment if the wx is below mins. There is nothing in the new reg that states this. It was (IMO) accidentally removed.



 
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