What's wrong with this holding clearence??

[Hold West]

Hold West, are you saying that ATC can't issue a clearance limit that is beyond my hold point? I've had that very thing happen; when there wasn't enough room in the stack for us we were issued a clearance limit at the stack point (a charted hold) but asked to hold 50 miles prior to that point for 2 turns to allow time to reduce the stack. Any comments? If I'm believeing something incorrect I'd like to get it straightened out to make your job easier and keep myself out of the chief pilot's office. Thanks

By definition, your clearance limit is the holding point. The first thing out of a controller's mouth when issuing a hold is: "XYZ123, cleared to <insert holding fix here>" 'cause that's your new clearance limit. How was the clearance above phrased, exactly? Could be considered two ways:

1: It's a holding clearance with control instructions prior to entering the hold, e.g. "XYZ123, cleared to ABC VORTAC, hold east as published, maintain FL200, expect further clearance 0123. Make 2 left 360s 50 miles east of ABC."

2: Holding at the 50 DME point (clearance limit 1) before proceeding to the next holding fix: "XYZ123, cleared to the ABC 090 radial 50 DME fix, hold east on the 090 radial, maintain FL200. Make two turns in holding, then proceed to ABC VORTAC via last routing cleared. Expect 15 minute delay in published holding at ABC." Wow, ain't that cumbersome! But it meets all requirements of holding clearances.

I'd vote for option 3, which, if I wanted to stop you 50 miles prior to the stck, is issue a complete and correct holding clearance there, then clear you inbound to the next holding fix.

Again, I'd like to know exactly how the clearance you received above was phrased.

Here, in excruciating detail, are the holding requirements I have to meet, with some highlighting added by me:

(See next message)

 

[Hold West]

4-6-1. CLEARANCE TO HOLDING FIX​

Consider operational factors such as length of delay, holding airspace limitations, navigational aids, altitude, meteorological conditions when necessary to clear an aircraft to a fix other than the destination airport. Issue the following: ​

a. Clearance limit (if any part of the route beyond a clearance limit differs from the last routing cleared, issue the route the pilot can expect beyond the clearance limit).​

PHRASEOLOGY-
EXPECT FURTHER CLEARANCE VIA (routing).​

EXAMPLE-
"Expect further clearance via direct Stillwater V-O-R, Victor Two Twenty-Six Snapy intersection, direct Newark."​

b. Holding instructions.​

1. Holding instructions may be eliminated when you inform the pilot that no delay is expected.​

2. When the pattern is charted, you may omit all holding instructions except the charted holding direction and the statement "as published." Always issue complete holding instructions when the pilot requests them.​

NOTE-
The most generally used holding patterns are depicted on U.S. Government or commercially produced low/high altitude en route, area, and STAR Charts.​

PHRASEOLOGY-
CLEARED TO (fix), HOLD (direction), AS PUBLISHED,

or

CLEARED TO (fix), NO DELAY EXPECTED.​

c. EFC. Do not specify this item if no delay is expected.​

1. When additional holding is expected at any other fix in your facility's area, state the fix and your best estimate of the additional delay. When more than one fix is involved, state the total additional en route delay (omit specific fixes).​

NOTE-
Additional delay information is not used to determine pilot action in the event of two-way communications failure. Pilots are expected to predicate their actions solely on the provisions of 14 CFR Section 91.185.​

PHRASEOLOGY-
EXPECT FURTHER CLEARANCE (time),

and if required,

ANTICIPATE ADDITIONAL (time in minutes/hours) MINUTE/HOUR DELAY AT (fix),

or

ANTICIPATE ADDITIONAL (time in minutes/hours) MINUTE/HOUR EN ROUTE DELAY.​

EXAMPLE-
1. "Expect further clearance one niner two zero, anticipate additional three zero minute delay at Sweet."

2. "Expect further clearance one five one zero, anticipate additional three zero minute en route delay."​

2. When additional holding is expected in an approach control area, state the total additional terminal delay.​

PHRASEOLOGY-
EXPECT FURTHER CLEARANCE (time),

and if required,

ANTICIPATE ADDITIONAL (time in minutes/hours) MINUTE/HOUR TERMINAL DELAY.​

3. TERMINAL. When terminal delays exist or are expected, inform the appropriate center or approach control facility so that the information can be forwarded to arrival aircraft.​

4. When delay is expected, issue items in subparas a and b at least 5 minutes before the aircraft is estimated to reach the clearance limit. If the traffic situation requires holding an aircraft that is less than 5 minutes from the holding fix, issue these items immediately.​

NOTE-
1. The AIM indicates that pilots should start speed reduction when 3 minutes or less from the holding fix. The additional 2 minutes contained in the 5-minute requirement are necessary to compensate for different pilot/ controller ETAS at the holding fix, minor differences in clock times, and provision for sufficient planning and reaction times.

2. When holding is necessary, the phrase "delay indefinite" should be used when an accurate estimate of the delay time and the reason for the delay cannot immediately be determined; i.e., disabled aircraft on the runway, terminal or center sector saturation, weather below landing minimums, etc. In any event, every attempt should be made to provide the pilot with the best possible estimate of his/her delay time and the reason for the delay. Controllers/supervisors should consult, as appropriate, with personnel (other sectors, weather forecasters, the airport management, other facilities, etc.) who can best provide this information.​

PHRASEOLOGY-
DELAY INDEFINITE, (reason if known), EXPECT FURTHER CLEARANCE (time). (After determining the reason for the delay, advise the pilot as soon as possible.)​

EXAMPLE-
"Cleared to Drewe, hold west, as published, expect further clearance via direct Sidney V-O-R one three one five, anticipate additional two zero minute delay at Woody."

"Cleared to Aston, hold west on Victor two twenty-five, seven mile leg, left turns, expect further clearance one niner two zero, anticipate additional one five minute terminal delay."

"Cleared to Wayne, no delay expected."

"Cleared to Wally, hold north, as published, delay indefinite, snow removal in progress, expect further clearance one one three zero."

4-6-2. CLEARANCE BEYOND FIX​

a. If no delay is expected, issue a clearance beyond the clearance limit as soon as possible and, whenever possible, at least 5 minutes before the aircraft reaches the fix.​

b. Include the following items when issuing clearance beyond a clearance limit:​

1. Clearance limit or approach clearance.​

2. Route of flight. Specify one of the following:​

(a) Complete details of the route (airway, route, course, fix(es), azimuth course, heading, arc, or vector.)​

(b) The phrase "via last routing cleared." Use this phrase only when the most recently issued routing to the new clearance limit is valid and verbiage will be reduced.​

PHRASEOLOGY-
VIA LAST ROUTING CLEARED.​

3. Assigned altitude if different from present altitude.​

NOTE-
Except in the event of a two-way communications failure, when a clearance beyond a fix has not been received, pilots are expected to hold as depicted on U.S. Government or commercially produced (meeting FAA requirements) low/high altitude en route and area or STAR charts. If no holding pattern is charted and holding instructions have not been issued, pilots should ask ATC for holding instructions prior to reaching the fix. If a pilot is unable to obtain holding instructions prior to reaching the fix, the pilot is expected to hold in a standard pattern on the course on which the aircraft approached the fix and request further clearance as soon as possible.​

4-6-3. DELAYS​

a. Advise your supervisor or flow controller as soon as possible when you delay or expect to delay aircraft.​

b. When arrival delays reach or are anticipated to reach 30 minutes, take the following action:​

1. EN ROUTE. The center responsible for transferring control to an approach control facility or, for a nonapproach control destination, the center in whose area the aircraft will land shall issue total delay information as soon as possible after the aircraft enters the center's area. Whenever possible, the delay information shall be issued by the first center controller to communicate with the aircraft.​

2. TERMINAL. When tower en route control service is being provided, the approach control facility whose area contains the destination airport shall issue total delay information as soon as possible after the aircraft enters its approach control area. Whenever possible, the delay information shall be issued by the first terminal controller to communicate with the aircraft.​

3. Unless a pilot requests delay information, the actions specified in subparas 1 and 2 above may be omitted when total delay information is available to pilots via ATIS.​

PHRASEOLOGY-
(Airport) ARRIVAL DELAYS (time in minutes/hours).​

 

[Hold West]

More............

4-6-4. HOLDING INSTRUCTIONS​

When issuing holding instructions, specify:​

a. Direction of holding from the fix/waypoint.​

b. Holding fix or waypoint.​

NOTE-
The holding fix may be omitted if included at the beginning of the transmission as the clearance limit.​

c. Radial, course, bearing, track, azimuth, airway, or route on which the aircraft is to hold.​

d. Leg length in miles if DME or RNAV is to be used. Specify leg length in minutes if the pilot requests it or you consider it necessary.​

e. Direction of holding pattern turns only if left turns are to be made, the pilot requests it, or you consider it necessary.​

PHRASEOLOGY-
HOLD (direction) OF (fix/waypoint) ON (specified radial, course, bearing, track, airway, azimuth(s), or route.)

If leg length is specified,

(number of minutes/miles) MINUTE/MILE LEG.

If direction of turn is specified,

LEFT/RIGHT TURNS.​

NOTE-
It is mandatory for the controller to issue left or right turns every time a holding pattern is issued for MLS.​

f. Issue maximum holding airspeed advisories when an aircraft is:​

1. Approved to exceed the maximum airspeed of a pattern, and is cleared into a holding pattern that will protect for the greater speed; or​

2. Observed deviating from the holding pattern airspace area; or​

3. Cleared into an airspeed restricted holding pattern in which the icon has not been published.​

EXAMPLE-
Due to turbulence, a turboprop requests to exceed the recommended maximum holding airspeed. ATCS may clear the aircraft into a pattern that protects for the airspeed request, and shall advise the pilot of the maximum holding airspeed for the holding pattern airspace area.​

PHRASEOLOGY-
"MAXIMUM HOLDING AIRSPEED IS TWO ONE ZERO KNOTS."​

 

[Vastly Underemp]

To the best of my recollection.....

Cleared to ABCDE, hold 50 miles N of ABCDE on the 030 rad XYZ, maintain FL200. Expect ABCDE at 1500 Z, time now 1430. Ten mile legs approved.

The clearance limit was an intersection with a depicted hold (and stack)
The hold point was 50 miles northeast of ABCDE (the clearance limit)
The EFC statement led us to believe we would hold again at ABCDE (which we did)

So was this a legal clearance? I'll admit it was a bit unusual, and hasn't happened since. Thanks for your input. Also, what would you expect us to do in the event of radio failure?

 

[Hold West]

To the best of my recollection.....

Cleared to ABCDE, hold 50 miles N of ABCDE on the 030 rad XYZ, maintain FL200. Expect ABCDE at 1500 Z, time now 1430. Ten mile legs approved.

The clearance limit was an intersection with a depicted hold (and stack)
The hold point was 50 miles northeast of ABCDE (the clearance limit)
The EFC statement led us to believe we would hold again at ABCDE (which we did)

So was this a legal clearance? I'll admit it was a bit unusual, and hasn't happened since. Thanks for your input. Also, what would you expect us to do in the event of radio failure?

Not correct or legal. It fails the basic logic test - if you are cleared to ABCDE, why are you in hold 50 NM away? I am a believer in standard procedures and phraseology, which keeps me out of trouble, and you from being confused.

The correct phraseology (and a non-ambiguous clearance) would be, "Cleared to the ABCDE 030 radial 50 mile fix, hold north-east on the 030 radial, ten mile legs, maintain FL200, expect further clearance 1500, time now 1430. Anticipate additional 30 minute (or whatever) delay at ABCDE."

With the clearance you were given, in the event of radio failure, there's nothing to do but leave holding at 1500 and proceed to destination via the last routing you had. In my example above, being told to anticipate additional delay is just for your fuel planning purposes, not a clearance to hold at the next fix: "Additional delay information is not used to determine pilot action in the event of two-way communications failure. Pilots are expected to predicate their actions solely on the provisions of 14 CFR Section 91.185."

Take care.

 

[Vastly Underemp]

ok, here was our plan. We entered holding 30 NE of ABCDE. We did 2 circuits in the hold and were then cleared to ABCDE where we held in the stack until descent allowed an approach. If we had radio failure at the 30m fix, we would have left the hold to arrive at ABCDE at the EFC time, then begin an approach from there. The problem was we were at FL200, and descent on an approach segment would have been difficult, but we certainly could not descend prior to ABCDE because we knew there were aircraft stacked in the hold. We figured worse case scenario we'd fly the full procedure turn approach and if we couldn't get glide slope we'd just fly the missed and go to our alternate.

We knew this was a messed up scenario. I could only imagine that someone in the stack was slow to descend so he didn't have room ahead, and there was following traffic behind at the same altitude, and he didn't want us to stay at the 30m fix if we had radio failure.

Thanks for the clarification. I hadn't realized that you cannot have a clearance limit beyond your holding point. If the NTSB asks, can I tell them some guy on the internet told me (LOL)?