GPS Approach question

[midlifeflyer]

I'll chime in here on this one. Midlife is familiar with my take on the "when is a PT required" question. Everyone is missing the essential ingrediant. The AIM explains and describes a Procedure Turn with the opening statement: "A procedure turn is the maneuver prescribed when it is necessary to perform a course reversal to establish the aircraft inbound on an intermediate or final approach course." Look at that statement. Don't read anymore(yet).

Thanks. Between the two of us we'll at least get the parameters of the argument down.

My point, which I think is backed up by the FAR, AIM, and legal opinions is that (1) a definition of a phrase is not a legal statement of it's effect on our conduct, so you can't "just stop there," and, far more importantly, (2) the TERPS guys, not you and I, get to decide when "it is necessary" by putting it in, leaving it out, and specifically showing NoPT sectors.

 

[nosehair]

(1) a definition of a phrase is not a legal statement of it's effect on our conduct, so you can't "just stop there,"

...and likewise, you can't just read the second sentence, "a procedure turn is required", by itself, either. They both go together. Like this, in human speak: "If a course reversal (or alignment) is required, the direction of the turn is depicted by the barbed arrow, or holding pattern, or other bold line as depicted". When the approach chart shows "NoPT", that means we (the TERPS guys) have determined that the course is closely aligned enough that a course reversal is and should not be required, so we will depict it as such so that you must request a PT if you need one. 91.175(j) and the AIM language on NoPT all spell out conditions under which you SHALL NOT make a PT except when requested. It DOES NOT say "EXCEPT under these conditions, YOU SHALL ALWAYS make a PT even when you are aligned."

Mark, I'm not making this up, I'm reading *in context*, all the language I can find on the subject and cannot find a definitive statement that says you must do a PT even when you don't need to make a course reversal. The legal opinion does not answer that question.

 

[ackattacker]

http://www.naco.faa.gov/d-tpp/0506/05187I35L.PDF

Coming from the south east or sout west I could easily Vector my self to this ILS. HISER is a Compass Locator and IGFK has DME. I still have to do the PT though, if Im not being radar vectored.

I don't think it's quite the same thing. This approach doesn't have a seperate IAF and FAF. Also, at a bare minimum it only required an ILS and an ADF, so the approach has to assume that you don't have DME and therefore cannot safely descend until you cross the IAF "outbound". GPS approaches don't have to make that assumption.

 

[DC8 Flyer]

I don't think it's quite the same thing. This approach doesn't have a seperate IAF and FAF. Also, at a bare minimum it only required an ILS and an ADF, so the approach has to assume that you don't have DME and therefore cannot safely descend until you cross the IAF "outbound". GPS approaches don't have to make that assumption.

Its showing a point though. The FAR/AIM doesnt specify between GPS and Ground Based approaches when having to do PTs. Just because a GPS approach gives you the bigger picture doesn't mean you can just start doing straight in approaches when you want to (I know thats not what youre saying).

You bring up a good point about knowing where you are more with a GPS, the same is true with the GFK ILS35L, if I have DME, I know exactly where I am using DME and the LOM. Same thing with GPS. So by your logic if I am properly equipped I should be able to skip the procedure turn and "vector" my self to final. But we both know that isnt true, so why would it be with a GPS approach?

Nosehair brought up a good point about course reversal being required only when you have to get established on the intermediate or final course. Remeber established means on course and altitude. So I may be on the final course going the right way but I'm 1000' high because of the MEA or MSA or ATC, etc. I would then have to use a PT to loose that altitude and become established.

 

[midlifeflyer]

******** FDC NOTAMs ********
!FDC 5/6452 GUM FI/T GUAM INTL, AGANA, GUAM
RNAV (GPS) RWY 24R ORG-B ...
TERMINAL ROUTE:
BAGBE TO WABOX: BAGBE NOW DESIGNATED AS (IAF).
ADD NOTE: NOPT.

!FDC 5/6451 GUM FI/T AGANA INTL, AGANA, GUAM
RNAV (GPS) RWY 24L ORIG-B ...
TERMINAL ROUTE:
BAGBE TO CIBOL: BAGBE NOW DESIGNATED AS (IAF).
ADD NOTE: NOPT.

!FDC 5/6450 GUM FI/T GUAM INTL, AGANA, GUAM
RNAV (GPS) Z RWY 6L ORIG-C ...
TERMINAL ROUTE:
PULEE TO OBALE: PULEE NOW DESIGNATED AS (IAF).
ADD NOTE: NOPT.

!FDC 5/6449 GUM FI/T GUAM INTL, AGANA, GUAM
RNAV (GPS) RWY 6R ORIG-B ...
TERMINAL ROUTE: PULEE TO DALPE: PULEE NOW DESIGNATED AS (IAF).
ADD NOTE: NOPT.

!FDC 5/6447 GUM FI/T GUAM INTL, AGANA, GUAM
RNAV (GPS) Y RWY 6L ORIG ...
TERMINAL ROUTE:
PULEE TO OBALE: PULEE NOW DESIGNATED AS (IAF)
ADD NOTE: NOPT ALTERNATE MINIMUMS: ALL CATS STANDARD.

Although, nosehair and dhc would say its redundant (in fact dhc would say it doesn't ecven exist)

 

[midlifeflyer]

Mark, I'm not making this up, I'm reading *in context*, all the language I can find on the subject and cannot find a definitive statement that says you must do a PT even when you don't need to make a course reversal. The legal opinion does not answer that question.

I think

==============================
However, if a SIAP does contain a procedure turn and ATC has cleared a pilot to execute the SIAP, the pilot must make the procedure turn when one of the conditions of Section 91.175(j) is not present.
==============================

is pretty clear.

On the other hand, show me one thing from the FAA that suggests that a PT is always optional - which is what I think the argument ultimately comes down to. If you say that's not a fair reading of the argument, show me the FAA documents 9even unofficial ones) that set out the parameters for the exercise of the pilot's options.

 

[nosehair]

show me one thing from the FAA that suggests that a PT is always optional -

..."when a course reversal is necessary"...

That is a part of the SAIP. When the pilot determines that a course reversal is necessary to align himself with the final approach course, then he must do it in accordance with the SAIP.

The conditions of "NoPT" are conditions under which it is NOT the pilots option. He must get clearance to do a PT under those conditions. The rule does not say, "Under all other conditions, you shall do a PT." It says you must follow the SAIP. Following the SAIP does not mean specifically "Do the PT", it means "IF you must do a course reversal, do the PT."

I don't think there is a case of a pilot being violated for not doing a PT when he was reasonably aligned on course and continued straight-in, do you?

Mark, let me explain a little about my thinking. First, I do not, and have not, flown a lot of unfamiliar, actual instrument approaches. Most of my experience is in a training or local familiar approach environment where I know when I am in a safe environment so that a continuation straight-in without a PT is not in any way a "bet" on my rightness of suggesting that a PT is determined by the pilot. It is always very obvious that a PT is not needed, and is probably not expected by the local controllers. Additionally, I don't normally teach this as a routine. Training is usually limited to "standardized" conditions, and standardly, I train to be able to execute an approach anywhere based on chart knowledge, and that is not local familiar knowledge.

If I am in a strange environment, or do not have that warm fuzzy feeling about "on-course""on-altitude""on-speed""landing-checks-complete", then a course reversal may become necessary and I am not suggesting to compromise safety in any way. But when you know you are established on final approach, and the wx is rapidly deteriorating, and think you must "do the PT anyway", I think that is a compromise of safety.

...

 

[puddlejumper]

"Cleared For The Straight-In Approach"

I seem to remember the ATC-Pilot Glossary including the phrase: "Cleared For The Straight-In Approach" Is that still the case Mark?

I used to fly into Camden County, NJ (19N) a lot. http://www.naco.faa.gov/d-tpp/0508/05496VB.PDF Coming up from the south over SBY, ATC would always clear me direct to VCN. DTK of 020 or so. I would get them to descend me to 2100' and then clear me for the approach. To avoid the PT, I would request the "straight-in approach" and confirm no PT was expected. They'd almost always say, "yeah sure, whatever" and I would do my thing. I guess that would fall under being radar-vectored, but being cleared to an IAF too. I'd like to see the "straight-in" clearance brought back if it's not that commonly used.

-PJ

 

[midlifeflyer]

I seem to remember the ATC-Pilot Glossary including the phrase: "Cleared For The Straight-In Approach" Is that still the case Mark?

It's still in the Glossary:

==============================
STRAIGHT-IN APPROACH IFR - An instrument approach wherein final approach is begun without first having executed a procedure turn, not necessarily completed with a straight-in landing or made to straight-in landing minimums.
==============================

BTW, I do think that there is still an open question floating around about it being okay for ATC to clear straight in even where a PT is mandatory.

The problem with the 1994 opinion is that it starts off talking about a non-radar environment. Although the 'unless it meats a 91.175 exception' ends up getting pretty global, you can choose to read it in that context and go back to a 1977 opinion where the FAA says that ATC can authorize exactly what you described.

From ATC input, it's pretty clear that as far as ATC is concerned, they'd rather you continue straight in. And, pretty obviously, since it would probably be ATC that would complain if you did it a way they didn't want, you are probably fine as a practical matter. (nosehair, no, I don't know of a single enforcement case in which the issue has come up. Since ATC wants you to go ahead, they probably won't gripe so it would likely take an accident for the issue to come up.) Of course the same could be said for a VFR flight entering Class B without a clearance. If ATC expected you to but just didn't say so, you'd have a violation no one would prosecute.)

And I think that ATC may well be taught that it's ok. Problem is that there is absolutely nothing in the regs or AIM that says so. You can play with "when necessary" all you want, but it says that a PT is "prescribed" when necessary; it doesn't say "a PT is flown when the pilot decides it's necessary." The the AIM section follows with a series of circumstances in which it's is not mandatory =for the pilot=, none of which are "when the pilot thinks it's safe." Think of how simple it would be to make it clear.

 

[nosehair]

You can play with "when necessary" all you want, but it says that a PT is "prescribed" when necessary; it doesn't say "a PT is flown when the pilot decides it's necessary."

There! There it is! "A PT is prescribed when necessary." Who do you think is responsible for determining "when necessary"? Not the pilot? Are you implying that the fact that a PT is shown on the SIAP that it is necessary?
Well, they show a missed approach. Is that necessary? Sometimes. The pilot decides. They show minimum altitudes. Is it necessary to descend to those altitudes? If you want to get the best chance of breaking out, yes...but, the pilot decides. If you need to make a course reversal to establish yourself on final, how do you do that? Well, the SIAP shows the side of the final approach course to make the reversal on, but how do you do it?..the pilot decides.
All through the material we read about how to do stuff, options are given about what, why, and how to do stuff,...and I can't get a good feeling about the material saying "The pilot decides how much fuel to put on..." It is an ASSUMPTION....an obvious conclusion.

If you would read what a course reversal is in the AIM or the FAA instrument flying handbook without,*repeat*, without the pre-conceived idea that a PT must be flown *except* for the conditions under which is is *prohibited* from being flown, maybe it would click.

You say,"think how easy it would be to make it clear". It is clear to me. But even if it was not, that is not the road to go down. There are way, way too many regs that are not clear, and no bureaucrat is going to stick his neck out and change to be more clear for the likes of you and me.