Non standard phraseology: Does that bug controllers?

Palmpilot said:
Maybe they "can't," but in practice they do. For example, the regulations don't explicitly define what type of GPS receivers are "suitable" for IFR en route navigation, but the AIM says that portables and VFR panel mounted ones are not "authorized" for that purpose.

That having been said, let's try to keep this in context. I was replying to a post that suggested that the 7110.65 may define the term "appropriate clearance" that is used in the regulation. The 7110.65 is no more regulatory than the AIM; its provisions only become binding on a pilot when a controller bases a clearance or instruction on it. At that point, 91.123 becomes the operative regulation.

The reason I brought up the AIM is that unlike the 7110.65, it is a document that the FAA expects pilots to be familiar with.
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Except the regs do specify what is considered acceptable. This is where TSOs come in to play.
 
mkosmo said:
Except the regs do specify what is considered acceptable. This is where TSOs come in to play.
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Which regulation says that only TSOed avionics are suitable?

I'm not saying there isn't one, but if there is, I would like to read it.
 
Palmpilot said:
Which regulation says that only TSOed avionics are suitable?

I'm not saying there isn't one, but if there is, I would like to read it.
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Many pilots today use the Global Positioning System (GPS) for navigation. As described in AIM 1-1-19, authorization to use GPS for any IFR operation is based on several requirements. Some of these requirements are:
  • GPS navigation equipment must be approved in accordance with TSO-C129, or equivalent, and the installation must be done in accordance with Advisory Circular AC 20-138D or equivalent.

  • Aircraft using GPS navigation under IFR must have an approved and operational alternate means of navigation appropriate to the flight.

  • The GPS operation must be conducted in accordance with the FAA-approved aircraft flight manual (AFM) or flight manual supplement.
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https://www.faasafety.gov/gslac/ALC/course_content.aspx?cID=38&sID=247&preview=true
 
Everskyward said:
https://www.faasafety.gov/gslac/ALC/course_content.aspx?cID=38&sID=247&preview=true
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That document refers to the same AIM provisions that I did (although the section number has changed). Personally, I'm satisfied with the AIM as a reference for what "suitable" means, but mkosmo and others seem to want a regulatory reference for what "appropriate clearance" means in 91.129(i). That's why I was pointing out that 91.129 is not the only regulation that uses terms that are defined outside of the regulations.
 
Palmpilot said:
True, and I consider that sufficient to define what's "suitable," but that's still not a regulation.
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Maybe you have a different definition of 'regulation' than I do. I'm not sure what part of,
  • GPS navigation equipment must be approved in accordance with TSO-C129, or equivalent, and the installation must be done in accordance with Advisory Circular AC 20-138D or equivalent.
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you don't understand.
 
I do understand that statement, and I consider it sufficient to define what the regulations mean by "suitable."

The ONLY thing I'm saying is that this is an example where a term used in a regulation is being defined by a document other than a regulation, because as far as I know, neither that statement, nor the TSOs that it refers to, are themselves regulations.
 
Palmpilot said:
I do understand that statement, and I consider it sufficient to define what the regulations mean by "suitable."

The ONLY thing I'm saying is that this is an example where a term used in a regulation is being defined by a document other than a regulation, because as far as I know, neither that statement, nor the TSOs that it refers to, are themselves regulations.
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OK, aircraft certification is not something I am an expert in but try this from FAR Part 21.

Subpart O—Technical Standard Order Approvals

Source: Docket No. FAA-2006-25877, Amdt. 21-92, 74 FR 53392, Oct. 16, 2009, unless otherwise noted.
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§21.601 Applicability and definitions.

(a) This subpart prescribes—
(1) Procedural requirements for issuing TSO authorizations;
(2) Rules governing the holders of TSO authorizations; and
(3) Procedural requirements for issuing letters of TSO design approval.
(b) For the purposes of this subpart—
(1) A TSO issued by the FAA is a minimum performance standard for specified articles used on civil aircraft;
(2) A TSO authorization is an FAA design and production approval issued to the manufacturer of an article that has been found to meet a specific TSO;
(3) A letter of TSO design approval is an FAA design approval for an article that has been found to meet a specific TSO in accordance with the procedures of §21.621;
(4) An article manufactured under a TSO authorization, an FAA letter of acceptance as described in §21.613(b), or an article manufactured under a letter of TSO design approval described in §21.621 is an approved article for the purpose of meeting the regulations of this chapter that require the article to be approved; and
(5) An article manufacturer is the person who controls the design and quality of the article produced (or to be produced, in the case of an application), including any related parts, processes, or services procured from an outside source.
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That seems to be getting closer to what I'm looking for, but Paragraph (b)(4) appears to be saying that you have to look elsewhere in the regulations for something that requires the article in question to be approved.

(b) For the purposes of this subpart--...

(4) An article manufactured under a TSO authorization, an FAA letter of acceptance as described in §21.613(b), or an article manufactured under a letter of TSO design approval described in §21.621 is an approved article for the purpose of meeting the regulations of this chapter that require the article to be approved; ... [emphasis added]
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Here are a couple of examples of the type of thing I'm looking for:

- I know that FDC NOTAMS are regulatory in nature because the Pilot/Controller Glossary explicitly says so.

- I know that published instrument approaches are regulatory because Part 97 explicitly states that they are part of Part 97, even though they are not carried in the Code of Federal Regulations.
 
Palmpilot said:
That seems to be getting closer to what I'm looking for, but Paragraph (b)(4) appears to be saying that you have to look elsewhere in the regulations for something that requires the article in question to be approved.

(b) For the purposes of this subpart--...

(4) An article manufactured under a TSO authorization, an FAA letter of acceptance as described in §21.613(b), or an article manufactured under a letter of TSO design approval described in §21.621 is an approved article for the purpose of meeting the regulations of this chapter that require the article to be approved; ... [emphasis added]
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Here are a couple of examples of the type of thing I'm looking for:

- I know that FDC NOTAMS are regulatory in nature because the Pilot/Controller Glossary explicitly says so.

- I know that published instrument approaches are regulatory because Part 97 explicitly states that they are part of Part 97, even though they are not carried in the Code of Federal Regulations.
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I would say that if you are THAT interested, look through the regulations in that chapter. I don't need any further proof.

In fact, I'm not sure how we got here from talking about non-standard phraseology.
 
Everskyward said:
...In fact, I'm not sure how we got here from talking about non-standard phraseology.
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It went like this:

  • It was asserted that the regulations had not been changed to reflect the fact that the FAA started requiring runway-crossing clearances to be explicit.
  • I pointed out that they had.
  • Concern was expressed about some vagueness in the relevant regulation.
  • I pointed out that the AIM spelled it out pretty well.
  • Concern was expressed that the AIM isn't regulatory.
  • I pointed out that there are other examples where things that are vague in the regulations are spelled out in the AIM, citing the approved uses of VFR GPS receivers as an example.
  • Etc.
 
Palmpilot said:
I pointed out that there are other examples where things that are vague in the regulations are spelled out in the AIM, citing the approved uses of VFR GPS receivers as an example.
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I still maintain that the AIM is not spelling out the regulation as much as it is referencing the places to look for the regulation if for some reason you feel you need more proof. But it really doesn't matter since we know that GPSs used in IFR operations need to be approved by that TSO or equivalent.

We are both probably using phraseology that is understandable to ourselves but not the other. :confused: :p
 
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Everskyward said:
I still maintain that the AIM is not spelling out the regulation as much as it is referencing the places to look for the regulation. But it really doesn't matter since we know that GPSs used in IFR operations need to be approved by that TSO or equivalent.
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Do you feel the same about the AIM passage that says runway crossing clearances must be explicit?

We are both probably using phraseology that is understandable to ourselves but not the other. :confused: :p
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Maybe. It's probably not that important, since I was just using it as an example.
 
Palmpilot said:
Do you feel the same about the AIM passage that says runway crossing clearances must be explicit?
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If you are talking about this...

5. A clearance must be obtained prior to crossing any runway. ATC will issue an explicit clearance for all runway crossings.
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I think the AIM is expanding on 91.129 (i)

(i) Takeoff, landing, taxi clearance. No person may, at any airport with an operating control tower, operate an aircraft on a runway or taxiway, or take off or land an aircraft, unless an appropriate clearance is received from ATC.

It's telling you what you can expect from ATC.
 
I still think "ten fifty-five" is as legible as "one zero five five", but the local tower guy disagrees. Sigh.
 
Palmpilot said:
I pointed out that there are other examples where things that are vague in the regulations are spelled out in the AIM, citing the approved uses of VFR GPS receivers as an example.​
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Everskyward said:
I still maintain that the AIM is not spelling out the regulation as much as it is referencing the places to look for the regulation if for some reason you feel you need more proof.
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Boy, talk about semantics! Or is it the old blind men and the elephant? ;)

The AIM is one of a number of FAA "guidance documents." They are "non-regulatory" but all that really means is they have not gone through the hoops required to have the legal force of a regulation. Instead they sometimes have some "sort of" regulatory effect. They sometimes reflect what the regulations say in easier language. They sometimes expand on what the regulations say. They sometimes give us insight to what the FAA says the regulations mean. They sometimes even have quasi-regulatory force because a regulation tells you to look at them (look at the FAR 1.1 definition of "suitable RNAV system"). And they sometimes just provide helpful information that have no regulatory impact at all.

I think the AIM really says it best when it describes itself as the "Official Guide to Basic Flight Information and ATC Procedures."
 
midlifeflyer said:
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Boy, talk about semantics! Or is it the old blind men and the elephant? ;)

The AIM is one of a number of FAA "guidance documents." They are "non-regulatory" but all that really means is they have not gone through the hoops required to have the legal force of a regulation. Instead they sometimes have some "sort of" regulatory effect. They sometimes reflect what the regulations say in easier language. They sometimes expand on what the regulations say. They sometimes give us insight to what the FAA says the regulations mean. They sometimes even have quasi-regulatory force because a regulation tells you to look at them (look at the FAR 1.1 definition of "suitable RNAV system"). And they sometimes just provide helpful information that have no regulatory impact at all.

I think the AIM really says it best when it describes itself as the "Official Guide to Basic Flight Information and ATC Procedures."
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Time to update your sig: 1. The AIM is sort of regulatory. :)
 
This kind of thing cracks me up. Like a few have already said, I don't know why people get so worked up over this kind of stuff. I can understand controllers getting a little frustrated, but if you don't like how other pilots talk to controllers, hate to break it to you, no one cares. As long as the point gets across pretty concisely, and it doesn't jeopardize safety, it's a non-issue. I tend to be pretty by the book myself, with a small exception here and there, but it makes no difference to me if another pilot talks about his "fish finder".
 
denverpilot said:
Have you actually heard that as a command given by ATC? I haven't.

I've heard "N12345, go around" followed by vectors and an altitude to climb to if IFR, if VFR it's usually "make right crosswind pilot's discretion, enter right downwind for runway X".

The assumption if you go NORDO right when they said "go around", would be to fly the published missed if IFR, I reckon.

Never heard a controller say "go missed".
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Actually, I got that just a few days ago. IFR into Napa in VMC, all approaches have tailwinds and it's busy. Just a mile inside the FAF on the VOR 6, ATC tells me to go missed now for opposite direction traffic. Not an easy missed approach that close to the VOR.
 
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