3TE VOR-A in Coordination

[aterpster]

3TE is a light airplane airport near Detroit, MI. The airport will likely never have an RNAV approach because of runway and survey limitations. But, it does have a VOR-A or GPS approach. The VOR approach is lousy because of the distance from the VOR to the airport. But, the GPS overlay is, of course, consistently accurate from the VOR to the airport.

For no good reason the FAA is now planning to remove the overlay "(...or GPS) capability on this approach procedure. One comment is of limited value. Lots of comments are more seriously considered. Plus, they are required to reply to each commentator.

The comment period opened on July 23, and lasts for 21 business days. For those who don't like this type of arbitrary action on the part of the FAA I urge each and everyone to submit timely comments.

You can email them to the FAA at:

9-AMC-AEROCHART@FAA.GOV

Place the airport designator in the subject line.

Here are my submitted comments:

SUBJECT: 3TE VOR-A in Coordination

Request that you retain the GPS overlay capability on this instrument approach procedre, proposed Amendment 8. This airport does not have an RNAV IAP, thus RNAV capability on the only instrument approach to the airport is of subsstaintal benefit to the large percentage of operators who have IFR-certified GPS/RNAV capability. Because of the considerable distance from the VOR facility to the airport, safety is enhanced by greatly increased accuracy for those operators who are equipped to fly this approach procedure using RNAV equipment.

This approach procedure has had RNAV overlay capability for many years. There is no valid reason for the FAA to now deny operators that RNAV capability, especially since this is the airport's only instrument approach procedure.

 

[nosehair]

Just do the vor-a approach and use your gps as "situational awareness enhancement", and don't worry about it.

 

[John Collins]

I sent an email. I pointed out I would not object if there was a RNAV procedure with the same or lower MDA first. I also pointed out that SVM is a likely candidate for elimination with the MON.

 

[aterpster]

Just do the vor-a approach and use your gps as "situational awareness enhancement", and don't worry about it.

That's your choice.

Other pilots ***** when they lose overlays.

 

[azure]

This approach procedure has had RNAV overlay capability for many years. There is no valid reason for the FAA to now deny operators that RNAV capability, especially since this is the airport's only instrument approach procedure.

Thanks, Wally. All I can say is, good luck in this effort. The FAA recently removed the GPS overlay from the VOR-A approach into VLL, at the same time as they made both the VOR-A and the RNAV 9 approaches NA at night. But the effect is that the VOR-A is now defunct FAIAP since it is based on PSI, which is indefinitely OTS (according to rumor they have decided to just let it die). I have a feeling that removing GPS overlays is some brain-dead FAA bureaucrat's assigned project and he's gung-ho, consequences be damned.

I have never flown this approach (nor even gone near 3TE since there is always jumper activity going on there), but given that the field is 28 miles from SVM I'm sure you're right that it's a poor standalone VOR approach. I'll send an email too, for all the good it will do.

edit: thought I'd check the chart before sending an email and I note that the approach is based on CRL not SVM, only 22 nm from the field. Not as bad as 28 nm, but still not good. SVM is used for cross-radials that define fixes along the FAC.

As to whether the likely elimination of SVM will carry any weight as an argument, there are something like a half dozen or more IAPs at 3 or 4 different airports around here that use the PSI VOR to define fixes. Several local pilots wrote detailed analyses of the impact of eliminating PSI when the request for comments was alive and sent them to the FAA. A lot of good it did.

Yes, I'm a bit cynical. Sorry, it's been a bad week.

 

[Jaybird180]

Likely explanation

 

[ChrisK]

Is the reason for removing these approaches the cost of flight checking them?

 

[John Collins]

Is the reason for removing these approaches the cost of flight checking them?

It has been policy for some time to eliminate the GPS portion of the overlay approaches, but usually there are better RNAV procedures in place first. The overlay program was instituted when there were no stand alone GPS or RNAV approaches and was a good idea at the time. As long as there is a replacement RNAV procedure, they have served their intended purpose. With the phase out of VOR's coming in the near future, the only procedures at many airports will be the RNAV option.

 

[ChrisK]

Oh, I understand. Thanks for the explanation. I was confusing GPS overlay with RNAV. That's the problem with completing my IR when the only RNAV systems I will encounter are GPS based =)

 

[ChrisK]

Ok. I guess I still have the question. What is the point of eliminating GPS overlay approaches if the altitudes, courses, and procedures are exactly the same as an existing valid - for example - VOR-based approach? I guess you'd save on the cost of maintaining the procedure (and a little ink removing the word "GPS"). The only reason this would make sense is if you were eventually intending to eliminate the VOR approach. Guess that's the point, eh?

 

[somorris]

I think we need Wally's input on this. I could understand the FAA eliminating the overlay, if it was going to (or had been) replaced with an RNAV approach, with the VOR's slated for decommissioning. But, I don't know if this is the case here.

 

[aterpster]

I think we need Wally's input on this. I could understand the FAA eliminating the overlay, if it was going to (or had been) replaced with an RNAV approach, with the VOR's slated for decommissioning. But, I don't know if this is the case here.

No, it isn't. This is not for me. It's for you light airplane guys and gals who have IFR certified GPS avionics.

 

[aterpster]

Ok. I guess I still have the question. What is the point of eliminating GPS overlay approaches if the altitudes, courses, and procedures are exactly the same as an existing valid - for example - VOR-based approach? I guess you'd save on the cost of maintaining the procedure (and a little ink removing the word "GPS"). The only reason this would make sense is if you were eventually intending to eliminate the VOR approach. Guess that's the point, eh?

The VOR approach has to be flight checked annually whether or not it has a GPS overlay.

 

[ChrisK]

The VOR approach has to be flight checked annually whether or not it has a GPS overlay.

Right - so the only reason I can think of to get rid of the GPS overlay is if the VOR approach was going away.

 

[gismo]

I sent an email. I pointed out I would not object if there was a RNAV procedure with the same or lower MDA first. I also pointed out that SVM is a likely candidate for elimination with the MON.

ditto.

 

[azure]

I emailed the address in Wally's OP (unfortunately I accidentally sent my draft version - gah! - then tried to submit a correction) and received a reply telling me I had contacted the wrong address.

This concern has been closed with the following Response:



Thank you for your concern. Procedure development, amendment and cancellation is is coordinated and prioritized by the Flight Procedures Team. Please contact Deb Hogan at (404)305-5944

 

[gismo]

I emailed the address in Wally's OP (unfortunately I accidentally sent my draft version - gah! - then tried to submit a correction) and received a reply telling me I had contacted the wrong address.

Sent mine over an hour ago and it hasn't bounced yet. How long between sending and the "wrong address" reply?

 

[azure]

Sent mine over an hour ago and it hasn't bounced yet. How long between sending and the "wrong address" reply?

Definitely not immediate or even soon. There was also a "new owner notice" and a link to the "concern", which was given a number (and as might be predicted since it was all generated automatically, the link was broken).

I don't recall exactly how long before the final reply, but more than 24 hours, for certain.

 

[gismo]

Definitely not immediate or even soon. There was also a "new owner notice" and a link to the "concern", which was given a number (and as might be predicted since it was all generated automatically, the link was broken).

I don't recall exactly how long before the final reply, but more than 24 hours, for certain.

Ah. I'll keep watching for a bounce reply.

 

[gismo]

Apparently my email did get through but was rejected by an actual person with the following response:

Dear Lance:

Thank you for reporting the problem concerning:

Subject: GPS overlay approach at 3TE airport

I would like to voice my objection to the removal of the GPS overlay for
VOR-A or GPS approach (the only approach) into 3TE for safety reasons.
The VOR is more than 20 nm from the airport and this makes GPS
navigation far more accurate. This could easily make the difference
between successfully finding the airport in low visibility with GPS and
missing it entirely with VOR navigation.

Personally I'd rather see the VOR-A capability go away since I have GPS
but there may well be some users still relying on VOR navigation for
this approach. If an alternative GPS approach with equal or better
minimums was being implemented for this airport I wouldn't object to the
loss of the overlay but it's my understanding that this is not the case.


Control Number 17509 has been assigned to this issue for tracking purposes.

This concern has been closed with the following Response:

Your query has been sent to the Flight Procedures Team in Ft Worth. This is their response. The subject airport environment does not meet minimum rwy length requirements for us to amend the VOR or GPS-A procedures with a straight-in RNAV procedure. This was coordinated with MDOT program manager and it was agreed to just amend the procedure to a VOR-A and cancel the GPS procedure.

We have a criteria requirement to remove all GPS overlays from procedures.

Regards,

Jill Olson
Lead
Phone: (405) 954-0414
​

IOW, because they decided to remove all overlays and they can't build a straight-in GPS approach they're going to discard the existing GPS capability. What utter nonsense!

I replied to Jill's response with this:

Then the requirement to remove all GPS overlays needs to be reconsidered or you need to come up with a GPS equivalent to the VOR-A design. The concept of eliminating the overlays was based on the expectation that they would be replaced with a stand alone GPS (RNAV) approach with equal or better minimums and safety. Using the "requirement" that overlays be discontinued to eliminate a useful approach without a replacement is an oversight that needs to be corrected.

I understand that a straight in RNAV approach isn't appropriate, but there's no logical reason why there can't be an unaligned GPS approach (overlay or stand alone).

-lance

 

[azure]

IOW, because they decided to remove all overlays and they can't build a straight-in GPS approach they're going to discard the existing GPS capability. What utter nonsense!

What did you expect? It's the government...

Why even publish an address for comments if they've already made their minds up?

 

[masloki]

Less options != more safe. Sigh.

 

[aterpster]

What did you expect? It's the government...

Why even publish an address for comments if they've already made their minds up?

They didn't used to be so arbitrary. It is now a remote, aloof FAA department.

I am asking the right person in Flight Standards if there is a "criteria" for removing overlays from VOR IAPs where there is no RNAV IAP published.

We know they remove overlays when RNAV approaches are published.

 

[aterpster]

My organization took this one to the coordination appeal process. It now appears the VOR-A or GPS will remain unchanged until, when, or if, the airport wants an RNAV-A approach. They presently are preoccupied with the airport's marginal condition.

 

[denverpilot]

My organization took this one to the coordination appeal process. It now appears the VOR-A or GPS will remain unchanged until, when, or if, the airport wants an RNAV-A approach. They presently are preoccupied with the airport's marginal condition.

Heh. Now that's enlightening. I'm imagining a phone conversation like, "We're just trying to get the place up to bare minimum spec, and you guys are whining about what approaches it has?!"