Hold/PT approach procedures

It is best, though, if everyone is on the same page. According to the rules, the HILPT is mandatory for the pilot if not cleared straight-in, even if coming from the NW, when cleared to a fix (as opposed to VTF). Unless you tell him, the pilot has no way of knowing that you don't care whether he goes straight in or not.

If I was coming from the NW on this approach, cleared direct CIPEX and for the approach, I'd ask the controller if I could go straight in. I certainly wouldn't assume that he doesn't care.

Is it good for the controller and pilot to be on the same page, usually in most cases. And I never have a problem when someone tells me they are going to start a turn out-bound, change altitudes VFR or whatever else they want to say (time permitting of course). The controller vectoring to airports like this one is not the same controller running the final at the busy class B airport. With that said, I'm not going to over-control a pilot when it's not necessary.

If there is a sequence into that airport, I will not allow you to do a hold or PT, you will get a straight-in approach (legally and specified if required) so as not to delay others behind you. If you are the only one for that airport and traffic doesn't preclude, I will clear you and let you ask for what you want or in most cases, do what you want. I have a radar so if you turn out, I know you're going for the turn. If you turn in, you're heading towards the final.

I quoted earlier from the 7110.65 giving the controller direction on when to say straight-in. As a pilot (very active IMC/VMC) where does it say that I'm required to do a PT or HILPT? It sounds like your saying if my course to the IAF is the same exact course as the final I'm required to do the turn because they didn't say straight-in. If that's true, can you provide the regulation that requires that? I learn something new everyday but this isn't how I do it as a pilot and funny enough, I just got off position (ATC) where I ran 2 of these exact approaches without specifying straight-in and they both did it without question. I've honestly ran hundreds of these approaches and may have had 1 person verify the straight-in and none attempt the HILPT. Being a pilot I almost never just clear someone to a fix from a heading that would require the hold or PT...simply because I don't like doing them for no reason so why would I make someone else.

To reiterate, I did say this controller that started this thread was wrong on several levels.
 
...I quoted earlier from the 7110.65 giving the controller direction on when to say straight-in. As a pilot (very active IMC/VMC) where does it say that I'm required to do a PT or HILPT? It sounds like your saying if my course to the IAF is the same exact course as the final I'm required to do the turn because they didn't say straight-in. If that's true, can you provide the regulation that requires that?....
It's in the AIM.


5−4−9. Procedure Turn and Hold−in−lieu of
Procedure Turn

a. A procedure turn is the maneuver prescribed
when it is necessary to reverse direction to establish
the aircraft inbound on an intermediate or final
approach course. The procedure turn or
hold−in−lieu−of−PT is a required maneuver when it
is depicted on the approach chart, unless cleared by
ATC for a straight−in approach. Additionally, the
procedure turn or hold−in−lieu−of−PT is not
permitted when the symbol “No PT” is depicted on
the initial segment being used, when a RADAR
VECTOR to the final approach course is provided,
or when conducting a timed approach from a holding
fix.
The altitude prescribed for the procedure turn is
a minimum altitude until the aircraft is established on
the inbound course. The maneuver must be
completed within the distance specified in the
profile view. For a hold−in−lieu−of−PT, the holding
pattern direction must be flown as depicted and the
specified leg length/timing must not be exceeded.

NOTE−
The pilot may elect to use the procedure turn or
hold−in−lieu−of−PT when it is not required by the
procedure, but must first receive an amended clearance
from ATC. If the pilot is uncertain whether the ATC
clearance intends for a procedure turn to be conducted or
to allow for a straight−in approach, the pilot must
immediately request clarification from ATC (14 CFR
Section 91.123).

[Emphasis added]
As for the regulatory basis, I'm not sure, but my guess is that it's in 91.175(a), which says that when an instrument approach is needed, you have to use one that's published in Part 97, and if you don't do what the approach chart says, you're not really 'using' it.
 
I quoted earlier from the 7110.65 giving the controller direction on when to say straight-in. As a pilot (very active IMC/VMC) where does it say that I'm required to do a PT or HILPT? It sounds like your saying if my course to the IAF is the same exact course as the final I'm required to do the turn because they didn't say straight-in. If that's true, can you provide the regulation that requires that? I learn something new everyday but this isn't how I do it as a pilot and funny enough, I just got off position (ATC) where I ran 2 of these exact approaches without specifying straight-in and they both did it without question. I've honestly ran hundreds of these approaches and may have had 1 person verify the straight-in and none attempt the HILPT. Being a pilot I almost never just clear someone to a fix from a heading that would require the hold or PT...simply because I don't like doing them for no reason so why would I make someone else.

Not anywhere in the FARs. FAR 91.175(j) says when a procedure turn may not be flown:

(j) Limitation on procedure turns. In the case of a radar vector to a final approach course or fix, a timed approach from a holding fix, or an approach for which the procedure specifies “No PT,” no pilot may make a procedure turn unless cleared to do so by ATC.

The AIM tells pilots, in paragraph 5-4-9.a., "The procedure turn or hold−in−lieu−of−PT is a required maneuver when it is depicted on the approach chart, unless cleared by ATC for a straight−in approach." That statement is not supported by the FARs, and is in conflict with the preceding statement in that paragraph; "A procedure turn is the maneuver prescribed when it is necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course."
 
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It's in the AIM.


5−4−9. Procedure Turn and Hold−in−lieu of
Procedure Turn

a. A procedure turn is the maneuver prescribed
when it is necessary to reverse direction to establish
the aircraft inbound on an intermediate or final
approach course. The procedure turn or
hold−in−lieu−of−PT is a required maneuver when it
is depicted on the approach chart, unless cleared by
ATC for a straight−in approach. Additionally, the
procedure turn or hold−in−lieu−of−PT is not
permitted when the symbol “No PT” is depicted on
the initial segment being used, when a RADAR
VECTOR to the final approach course is provided,
or when conducting a timed approach from a holding
fix.
The altitude prescribed for the procedure turn is
a minimum altitude until the aircraft is established on
the inbound course. The maneuver must be
completed within the distance specified in the
profile view. For a hold−in−lieu−of−PT, the holding
pattern direction must be flown as depicted and the
specified leg length/timing must not be exceeded.

NOTE−
The pilot may elect to use the procedure turn or
hold−in−lieu−of−PT when it is not required by the
procedure, but must first receive an amended clearance
from ATC. If the pilot is uncertain whether the ATC
clearance intends for a procedure turn to be conducted or
to allow for a straight−in approach, the pilot must
immediately request clarification from ATC (14 CFR
Section 91.123).

[Emphasis added]
As for the regulatory basis, I'm not sure, but my guess is that it's in 91.175(a), which says that when an instrument approach is needed, you have to use one that's published in Part 97, and if you don't do what the approach chart says, you're not really 'using' it.
Here is the 1994 FAA legal interpretation, which resulted in the AIM language you cite. Legal interpretations are generally held to be law, unless superseded by a related, but different letter of interpretation.
 

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Here is the 1994 FAA legal interpretation, which resulted in the AIM language you cite. Legal interpretations are generally held to be law, unless superseded by a related, but different letter of interpretation.

"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."

Well, that certainly clears things up. To illustrate, let's use the RNAY RWY 27 approach to Wittman Field. An aircraft twenty miles east of PEENA is issued the clearance; "Proceed direct PRIMO, cleared straight-in RNAV RWY 27 approach." Upon reaching PRIMO the pilot begins the HILPT because none of the conditions of Section 91.175(j) is present.
 
"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."

Well, that certainly clears things up. To illustrate, let's use the RNAY RWY 27 approach to Wittman Field. An aircraft twenty miles east of PEENA is issued the clearance; "Proceed direct PRIMO, cleared straight-in RNAV RWY 27 approach." Upon reaching PRIMO the pilot begins the HILPT because none of the conditions of Section 91.175(j) is present.

The letter was written long before ATO devised the RNAV IAP direct-to-the-IF option. I would consider that procedure the equivalent of vectors to final. You might view it differently.
 
The letter was written long before ATO devised the RNAV IAP direct-to-the-IF option. I would consider that procedure the equivalent of vectors to final. You might view it differently.

The office of the chief counsel might view it differently as well. Perhaps someone should ask them for an interpretation.
 
"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."

Well, that certainly clears things up. To illustrate, let's use the RNAY RWY 27 approach to Wittman Field. An aircraft twenty miles east of PEENA is issued the clearance; "Proceed direct PRIMO, cleared straight-in RNAV RWY 27 approach." Upon reaching PRIMO the pilot begins the HILPT because none of the conditions of Section 91.175(j) is present.

This example doesn't play at all.

First off, if the controller says, "Straight in", that means NoPT. Secondly, the example you use has a TAA coming from the east, so the controller would not need to specify straight in, because coming from the east the TAA clearly specifies NoPT.
 
This example doesn't play at all.

First off, if the controller says, "Straight in", that means NoPT. Secondly, the example you use has a TAA coming from the east, so the controller would not need to specify straight in, because coming from the east the TAA clearly specifies NoPT.
Good point. Besides within an NoPT (straight-in) TAA sector all the controller need say is, "Cleared for the RNAV 27 approach."
 
This example doesn't play at all.

First off, if the controller says, "Straight in", that means NoPT. Secondly, the example you use has a TAA coming from the east, so the controller would not need to specify straight in, because coming from the east the TAA clearly specifies NoPT.

Sure does, right there on the 30 mile arc. Missed it, bad example. Let's try another one, the RNAY RWY 32 to Clintonville Municipal. An aircraft twenty miles southeast of ONECO is issued the clearance; "Proceed direct GIGKE, cross GIGKE at or above 3000, cleared straight-in RNAV RWY 32 approach." Upon reaching GIGKE the pilot begins the HILPT because none of the conditions of Section 91.175(j) is present.

That covers your NoPT objection. The controller said "straight-in" but that is not one of the conditions of Section 91.175(j).
 
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The FAA published the straight-in exception in the AIM well after that Chief Counsel opinion was written, IIRC. Yeah, I know, the AIM is not regulatory, but neither are Chief Counsel opinions.
 
The FAA published the straight-in exception in the AIM well after that Chief Counsel opinion was written, IIRC. Yeah, I know, the AIM is not regulatory, but neither are Chief Counsel opinions.

I read recently, somewhere, that legal interpretations are generally held to be law, unless superseded by a related, but different letter of interpretation. If you're right, and given that the AIM is not regulatory, then there exists no requirement to fly a procedure turn when it is not necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course.
 
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Fortunately, I'm not an authoritative source on anything.
 
then there exists no requirement to fly a procedure turn when
it is not necessary to reverse direction to establish the aircraft inbound on an intermediate or final approach course.
This is my understanding and the understanding of what a very large portion (essentially 99+%) of the GA aircraft that come into our airspace where they don't ask or conduct the course reversal and conduct the straight-in.
 
This is my understanding and the understanding of what a very large portion (essentially 99+%) of the GA aircraft that come into our airspace where they don't ask or conduct the course reversal and conduct the straight-in.

So if we don't utilize a common source of info/"regulations" (AIM for example), who determines whether to fly a course reversal or not? The pilot or controller? In other words, if the pilot decides it's in his/her best interest to fly a course reversal, what ensures that the controller is thinking the same?
 
So if we don't utilize a common source of info/"regulations" (AIM for example), who determines whether to fly a course reversal or not? The pilot or controller? In other words, if the pilot decides it's in his/her best interest to fly a course reversal, what ensures that the controller is thinking the same?

By confirming the clearance with the controller (91.123).

HILPT execution has always been clear as mud on both sides of the radio. :confused:

https://asrs.arc.nasa.gov/publications/callback/cb_363.html
 
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So if we don't utilize a common source of info/"regulations" (AIM for example), who determines whether to fly a course reversal or not?
Controller's don't necessarily know the regulations under which you operate or the capabilities/requirements of your airplane (although they should know this). If they want you to do something that you can't do, or aren't authorized to do, tell them "unable" and request a clearance that you can do.

i.e. 'unable straight in, request procedure turn'. or '...request direct XYZAB'
 
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Am I missing something here? Other than, if in doubt, just confirm expectations? And it may not be by the book, but if I actually get ". . . .cleared straight in", I think the controller and I are on the same page, and that's what I would do.
 
Am I missing something here? Other than, if in doubt, just confirm expectations? And it may not be by the book, but if I actually get ". . . .cleared straight in", I think the controller and I are on the same page, and that's what I would do.

Well, no argument with a straight-in if 90 degrees or less to the IAF. Nothing preventing the controller from issuing that and overriding a HILPT requirement. If you can't comply and want to do the HILPT vs the SI, you can always say "unable."
 
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So if we don't utilize a common source of info/"regulations" (AIM for example), who determines whether to fly a course reversal or not? The pilot or controller? In other words, if the pilot decides it's in his/her best interest to fly a course reversal, what ensures that the controller is thinking the same?

The issue is those situations where it is not necessary to reverse direction to establish an aircraft on the intermediate approach segment or final approach course. Can you, as a pilot, think of an example where it is in your best interest to execute a maneuver that upon completion puts you in the same position in space that you were in just a few minutes earlier?
 
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The issue is those situations where it is not necessary to reverse direction to establish an aircraft on the intermediate approach segment or final approach course. Can you, as a pilot, think of an example where it is in your best interest to execute a maneuver that upon completion puts you in the same position in space that you were in just a few minutes earlier?
I wish the Chief Counsel and the authors of the AIM were able to think that logically.
 
I wish the Chief Counsel and the authors of the AIM were able to think that logically.

Well, they are not. The FAA is essentially no different than the IRS, or you name it.

I was involved with the 1994 legal interp. Chief Counsel first wrote a response, if left standing, would have disassembled the IFR system in the U.S. That was challenged by ALPA, so the second time the FAA attorney got an FAA TERPS expert to advise her, rather than an ATC know-nothing that advised her on the first response. I believe that first response is not available anywhere.
 
Well, they are not. The FAA is essentially no different than the IRS, or you name it.

I was involved with the 1994 legal interp. Chief Counsel first wrote a response, if left standing, would have disassembled the IFR system in the U.S. That was challenged by ALPA, so the second time the FAA attorney got an FAA TERPS expert to advise her, rather than an ATC know-nothing that advised her on the first response. I believe that first response is not available anywhere.

That explains a lot.
 
I was involved with the 1994 legal interp. Chief Counsel first wrote a response, if left standing, would have disassembled the IFR system in the U.S. That was challenged by ALPA, so the second time the FAA attorney got an FAA TERPS expert to advise her, rather than an ATC know-nothing that advised her on the first response. I believe that first response is not available anywhere.

A shame that first response is not available. It would be interesting to see how advice from an ATC guy would have disassembled the US IFR system. Odd that advice was then sought from a TERPS guy on an issue where TERPS is not a factor.
 
A shame that first response is not available. It would be interesting to see how advice from an ATC guy would have disassembled the US IFR system. Odd that advice was then sought from a TERPS guy on an issue where TERPS is not a factor.
The questions ALPA asked were indeed about the intent of TERPs designs as it applied to pertinent FARS and, to a lesser extent, ATC procedures. For instance, one of the questions ALPA asked was whether a DME ARC initial segment could be intercepted inside the IAF in a non-radar environment. The TERPS expert struggled with that until he found a location where an airway passing through an ARC inside the IAF would result in exceeding descent gradient limitations. The ATC guy didn't have a clue about any issues of that nature.
 
The questions ALPA asked were indeed about the intent of TERPs designs as it applied to pertinent FARS and, to a lesser extent, ATC procedures. For instance, one of the questions ALPA asked was whether a DME ARC initial segment could be intercepted inside the IAF in a non-radar environment. The TERPS expert struggled with that until he found a location where an airway passing through an ARC inside the IAF would result in exceeding descent gradient limitations. The ATC guy didn't have a clue about any issues of that nature.

There were no TERPS issues in Tom Young's questions.
 
Whenever I am cleared for an approach that I need to do a procedure turn to get inbound I respond with n756xx cleared approach, will report inbound. If I want to go straight in and the plate isn't clear to me I say, cleared approach, straight in ok?
Never had a moment of confusion doing that
 
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