Private Checkride Fail

[poadeleted20]

Forget rules for just one second and show me an example of an 800' AGL pattern that cannot be flown safely at 1000' AGL.

They got some bridge or obstruction hovering in the air out there somewhere I don't know about?

How about airliners going in and out of Washington National flying overhead? That's the situation at Freeway. And no, they are not going to raise that particular bridge just to accommodate the light planes operating at Freeway.

 

[poadeleted20]

Ron uses Freeway (W00 I presume) as an example, but even there a 1000' would work, being 300' below the overlaying Bravo.

300 below the Bravo doesn't provide the controllers the 500 foot separation they need. There would be nonstop alarms both in the TRACON and in the airliner cockpits.

You can grumble all you want, but one-size-fits-all isn't a workable solution to this problem. If the FAA could make that work, they would have done so decades ago.

 

[LDJones]

Give me a better solution. Perhaps closing all airports where a 1000 TPA doesn't work?

Sorry, LD -- this cigar is just a cigar. It's about failing to understand and meet the standards I the PTS, and from what you've written here, I am beginning to believe the failure to understand is entirely your fault since you don't seem to understand them yourself..

Your experience doesn't match mine -- not even close.

Not if you look in the right place.

No, I understand them completely....just don't think it makes much sense as currently conceived and could be simplified significantly, as pointed our previously.

And I still haven't seen one where 1000' wouldn't work.

 

[LDJones]

300 below the Bravo doesn't provide the controllers the 500 foot separation they need. There would be nonstop alarms both in the TRACON and in the airliner cockpits.

You can grumble all you want, but one-size-fits-all isn't a workable solution to this problem. If the FAA could make that work, they would have done so decades ago.

So now you must maintain 500' below a Class B shelf to avoid setting off alarms??

 

[Z06_Mir]

DPE's are specifically prohibited from giving applicants a second bite at any given apple.

She didn't prioritize. If she had, she would have circled while she looked up the necessary information. Instead, she just went ahead and entered the pattern minus some important information.

I get it Ron, you live by the rulebook. That's fine until reality sets in and you need to make real choices in real environments. But what SAFETY hazard does flying 200ft above TPA create? If an airplane descends on top of another airplane, wouldn't those airplanes have just collided at the same altitude?
The fact that there have been two midairs in the Phoenix practice areas (where there are several uncontrolled airports that students use for 'diversions' and practice approaches) tells me my head needs to be OUTSIDE every moment possible, not reading the tiny print about a tiny airport in the AFD... Spending 30 seconds heads down hunting for first the airport and secondly the TPA is just too much time heads down when it could be safely and effectively flown at 1,000AGL.

 

[Tarheelpilot]

Nevertheless, it is a necessary part of satisfactory performance as defined by the PTS.

the DPE could have used her traffic patterns anywhere else on the ride to check the box you quoted. I agree that if she were off during a normal pattern, fine bust her. Busting for the emergency divert is bull****. Its supposed to be handled like an emergency. There is not a requirement in the PTS to check TPA during the emergency divert. Also in real life you don't have time for crap like that and the examiner is sending the wrong message to applicants IMO.

I just finished reading the rest of the posts on this thread.

Ron you are wrong this time. Not often I have read your posts and found you to be wrong. I will never teach my applicants to circle a diversion field to check TPA. This bust was bull. Frankly I believe you are teaching a poor habit pattern to always and forever check the book before landing unless life and limb is in immediate danger. Sometimes lesser emergencies turn into big one if you stay up too long.

 

[MarkZ]

So now you must maintain 500' below a Class B shelf to avoid setting off alarms??

No.

Well, not exactly.

When an aircraft flies less than 500 feet below the Bravo shelf, we still turn participating (aircraft cleared into the Bravo) away to maintain at least 1 1/2 NM separation. Purely a safety measure.

I'm not sure why some airports TPA drop to 800ft AGL. I can see the reasoning when conflicting airspace, like Bravo or Charlie, are involved.

 

[redtail]

I get it Ron, you live by the rulebook. That's fine until reality sets in and you need to make real choices in real environments. But what SAFETY hazard does flying 200ft above TPA create? If an airplane descends on top of another airplane, wouldn't those airplanes have just collided at the same altitude?
The fact that there have been two midairs in the Phoenix practice areas (where there are several uncontrolled airports that students use for 'diversions' and practice approaches) tells me my head needs to be OUTSIDE every moment possible, not reading the tiny print about a tiny airport in the AFD... Spending 30 seconds heads down hunting for first the airport and secondly the TPA is just too much time heads down when it could be safely and effectively flown at 1,000AGL.

Having made my only emergency/precautionary landing (low oil pressure indication), at East Hampton airport a few years ago, I have to agree.

I had a general idea of the airport elevation, knew the layout of the terrain and I was too focused on scanning for traffic (there was none), monitoring my engine instruments and preparing for an engine out landing. I entered the pattern at 1000 MSL or a little higher (can't recall the exact altitude) and landed without incident.

At that point, I could care less what the published TPA was

EDIT: I just saw this statement...

And I'll say that if the examiner had (in what would be a rather unusual move) made this a "your oil pressure just went to zero" or other distress condition rather than the more typical "weather ahead -- what will you do now?" non-distress situation, then I'd find fault with the examiner for this bust since checking for TPA in that situation would not, to my thinking, be worth delaying that emergency approach and landing -- and I'd expect my trainee to tell the examiner that, too.

Thanks Ron

 

[JB1842]

So many people on here say to "fly the plane" when in an emergency, which I agree with. Checkride or not, fly the plane. To worry about finding the TPA seems to me to go against that train of thought.

 

[Sam D]

Just for clarity, the PTS task is a diversion -- no mention of "emergency".

 

[timwinters]

Hey, Jonesy,

Have you confirmed that he busted her for the TPA in the A/FD and NOT the one listed in ForeFlight or Garmin Pilot or WingXPro?

I'm curious since I found so much conflicting information in your area just like there is in mine. It would be pretty embarrassingly hilarious for the DPE if he used the wrong info.

What I found interesting in your area, is that the A/FD listed a few pattern altitudes that were 1,000' AGL. Two over on the Wisconsin side; New Richmond and Simenstad IIRC. And one down south...Mankato or LeSueur...maybe?

I've slept since then.

Why list TPA's that are 1,000' AGL?

 

[poadeleted20]

So now you must maintain 500' below a Class B shelf to avoid setting off alarms??

You always have. If you're that close to the altitude of the airliners overhead, TCAS alarms are likely, and they don't use any buffer above the floor of the B-space.

 

[poadeleted20]

I get it Ron, you live by the rulebook. That's fine until reality sets in and you need to make real choices in real environments. But what SAFETY hazard does flying 200ft above TPA create? If an airplane descends on top of another airplane, wouldn't those airplanes have just collided at the same altitude?
The fact that there have been two midairs in the Phoenix practice areas (where there are several uncontrolled airports that students use for 'diversions' and practice approaches) tells me my head needs to be OUTSIDE every moment possible, not reading the tiny print about a tiny airport in the AFD... Spending 30 seconds heads down hunting for first the airport and secondly the TPA is just too much time heads down when it could be safely and effectively flown at 1,000AGL.

No, you don't get it. Practical tests must be conducted by a specific set of standards, and examiners cannot be given latitude to deviate from them.

Back when I started flying, we had no such standards, only the Practical Test Guides, which weren't mandatory and didn't really set requirements or parameters. The result was major problems when one examiner required things others did not, or one examiner allowed things others did not. Instructors and applicants never new exactly what would be required or what would be allowed on practical tests. It was not good.

As a result, the FAA created the Practical Test Standards, and required examiners to operate by them. The result is a much more (although not entirely) uniform testing process. You are suggesting a reversion to the old way of doing things, and my experience tells me that's not what we want.

 

[poadeleted20]

Just for clarity, the PTS task is a diversion -- no mention of "emergency".

Glad someone's reading the PTS before firing away.

 

[MAKG1]

Glad someone's reading the PTS before firing away.

My one real-life diversion had nothing to do with an emergency.

ATIS was wrong at KMRY. A visual sighting showed the field was actually IFR (or quite close to it) with marine layer. ATIS reported scattered at 2000, but the view from 2000 differed substantially; it was a LOT lower and more than half the field was obscured. I could have landed safely (the numbers were visible from above), but a safe go-around was not possible, nor would I be able to take off again, probably until the following day.

So I diverted. KSNS was 8 miles away in the clear and easily in sight, so the "calculations" were trivial. I asked Approach for the diversion and got handed off to Salinas Tower right away and made a safe and uneventful landing.

Not anywhere near an emergency. I had 3 hours of fuel and everything was working fine.

You could also divert because your passenger has to pee or is hungry or just because you change your mind. Heck, I've "diverted" to KSTS because a steak sounded really good at that moment (and it was).

 

[Z06_Mir]

No, you don't get it. Practical tests must be conducted by a specific set of standards, and examiners cannot be given latitude to deviate from them.

Back when I started flying, we had no such standards, only the Practical Test Guides, which weren't mandatory and didn't really set requirements or parameters. The result was major problems when one examiner required things others did not, or one examiner allowed things others did not. Instructors and applicants never new exactly what would be required or what would be allowed on practical tests. It was not good.

As a result, the FAA created the Practical Test Standards, and required examiners to operate by them. The result is a much more (although not entirely) uniform testing process. You are suggesting a reversion to the old way of doing things, and my experience tells me that's not what we want.

I stopped talking in context of the PTS awhile ago. I never disagreed with what the PTS had in written, I do disagree with how the examiner handled it however. We all know that examiners do exercise discretion, and I think most of us are in agreement that this was a little bit on the crazy-trying-to-fail-an-applicant side of things. If the applicant demonstrated TPA in another way, like during the oral or back at home-base, which I'm guessing she did, this shouldn't have happened.


My question to you want posted above

But what SAFETY hazard does flying 200ft above TPA create? If an airplane descends on top of another airplane, wouldn't those airplanes have just collided at the same altitude?

 

[poadeleted20]

I stopped talking in context of the PTS awhile ago. I never disagreed with what the PTS had in written, I do disagree with how the examiner handled it however. We all know that examiners do exercise discretion, and I think most of us are in agreement that this was a little bit on the crazy-trying-to-fail-an-applicant side of things. If the applicant demonstrated TPA in another way, like during the oral or back at home-base, which I'm guessing she did, this shouldn't have happened.

If we're speaking about this particular bust, the fact that she can maintain altitude within parameters does not change the fact that she failed to determine the correct altitude at which to fly when there was no overriding emergency preventing her from doing that. That alone is sufficient for disapproval. IOW, it wasn't being 200 feet off the correct altitude which was the biggest issue, it was not checking what the correct altitude was in the first place. No different than failing to ID a VOR -- even if it was the right VOR and it was working properly, the failure to check is the unsatisfactory action.

As for your other question about safety:

But what SAFETY hazard does flying 200ft above TPA create? If an airplane descends on top of another airplane, wouldn't those airplanes have just collided at the same altitude?

...it's a lot easier to see a plane at the same altitude as you than directly above or below you. That's why the FAA wants everyone at the same altitude in the traffic pattern.

 

[tehmightypirate]

Here Ron, I'll help you out. Here's my homebase airport of Bangor, Maine. It's a class C airport with pretty much the standard shelf configuration. However, note the little bump out for the tiny gravel strip of 0B2 in the 42/SFC center of the class C.

This area is listed as 42/07. Now, don't look at the A/FD or anything else. What's the traffic pattern? Is it 1000 ft AGL? That's in the class C and right in an approach path for runway 33 at Bangor (like literally right in the path, not 500 feet below or anything). So what is it?







The answer is 600 ft per the A/FD. Also, approaches and departures are to be done to the east of the field the traffic is left hand to runway 19 and right to runway 1 (which is shown on the sectional as RP 1).

Thus, if you took your little cub with no radio into 0B2 and you couldn't maintain the PTS standards then you just busted a class C airspace and could have been VERY much at risk of colliding with an aircraft on approach into Bangor.

So, yes, traffic pattern altitudes are important and busting them in the wrong place can hurt you. However, I still think it was a douche move on the DPE but not wrong or improper.

 

[poadeleted20]

Here Ron, I'll help you out. ...
So, yes, traffic pattern altitudes are important and busting them in the wrong place can hurt you.

Thanks for the example.

However, I still think it was a douche move on the DPE but not wrong or improper.

You make a great point and then say you don't think it's correct? The PTS requires that you determine the proper altitude to fly, and then fly it within certain tolerances. You have to do both to achieve satisfactory performance. The applicant in the original post failed to do the first, making then second issue moot.

 

[tehmightypirate]

My beef is the unexpected diversion, emergency or not, and the testing scenario seems to be inappropriate for calling the TPA a bust in a real world application. However, this is so specific to her case that I don't think it warrants an exception of any kind, but is definitely grounds for grumbling.

First let me state that she failed for a valid reason (and again during the steep turns) and I don't think anything should be changed with anything. However, if it was my flight and the DPE failed me for that I would have been ****ed but only at the testing environment and not the rules.

The reason being that I consider traffic pattern altitude to be something you look up prior to the flight always. Then, if you divert you obviously have a reason for it, this is what the test fails to adequately simulate. If it was an emergency then as long as I'm being safe I'm not going to bother looking up TPA (though I would definitely consult a chart to see if there is any airspaces or other reasons to be lower than 1000 AGL, such as my example above).

Now, if it was a non-emergency then I would say it depends on the situation. Huge storm rolling in, PAX comfort, fuel minimal but not really low; for these I would say that learning the TPA is required and the proper course.

For other things I would say it's important but not something that I would say is critical. Oil pressure indicator (could be false), weird sounds from the plane (what's that rattling?), PAX sick (could be serious?), bird strike but still controllable, etc. These could or could not be emergencies and so I would say expediency is required. In that case it would be improper to delay your landing for something that 90% of the time wont cause any issues.

SO! In conclusion, yes she failed, yes she should have failed, yes the DPE was right with failing her. Nothing should be changed but it is still unfair because the testing environment is such and I see no easy way to fix that. Yes, she could have asked why she had to divert and adjusted her mental attitude appropriately but we've all been there. If the DPE says "divert to XYZ" you're going to do what he says and not question it because it's a stressful test and you have a lot on your mind already.

Now, the real question is would she have done anything different if the DPE specified the reason for the diversion and given her the option of a farther away airport? If not then no grumbling allowed.

 

[txflyer]

..tech needs to jive with A/FD

How about airliners going in and out of Washington National flying overhead? That's the situation at Freeway. And no, they are not going to raise that particular bridge just to accommodate the light planes operating at Freeway.

O.k. got it. I was omitting airspace overhead because it is not an obstacle or something solid, as idiotic as that sounds, that anyone must worry about overhead. So technically, it is not 'unsafe' to fly any pattern at 1000 AGL. It just puts you in closer proximity to traffic. It is 'less safe' for lack of better summation.

I like to think that in or under class bravo, my brain might be telling me to maintain 500' below any airspace, but maybe not, especially if I have transitioned off FF, and I'm relying on data, and then paper. If I terminated radar service from ATC to VFR, and entered the pattern, it would follow what's in the 430w and 696 or my last assigned altitude to 1000 AGL. I probably would not have confirmed it with the A/FD if the examiner was allowing all avionics. I may start doing it again if I'm unfamiliar, since discrepancies are being pointed out between formats.

But if I'm in contact with traffic, and looking, it shouldn't kill anything but a rule if we're 200' over. Which is a bust on a test, and maybe a controllers board, but no physical harm can come from busting it, provided everyone is flying correctly. Good luck to us all with that.

 

[MAKG1]

What if the weather is less than CAVU?

What if you're landing SVFR and there is a cloud between you and the traffic?

My own airport has a missed approach hold for another airport (KSJC) over the bayside downwind. It's a real low hold because the KSFO ILS approaches are above that at 4500.

This is really hard to figure out without specifically looking in detail, especially for a VFR student pilot. So, know your TPAs.

http://155.178.201.160/d-tpp/1313/00693VD30L.PDF

At KHWD, if you screw up their bayside downwind, you'll be eating wake turbulence from KOAK's 30 ILS, which is directly overhead and quite low. That TPA is only 600.

 

[kgruber]

Same Boeing Field and Sea-Tac.

 

[tehmightypirate]

Re: ..tech needs to jive with A/FD

But if I'm in contact with traffic, and looking, it shouldn't kill anything but a rule if we're 200' over. Which is a bust on a test, and maybe a controllers board, but no physical harm can come from busting it, provided everyone is flying correctly. Good luck to us all with that.

See my example on the last page. Class C shelf is 100 ft above TPA of 600 ft with aircraft right above them on an approach around 1000 ft. If the guy on approach is 200 ft low and you're 200 ft high then you guys just hit. Bonus points if you're on downwind to runway 19 as you'll be low and slow with what could be a C-5 galaxy bearing down on you with no way for you to see them. Here's to hoping they see you or their TCAS goes off.

So, no, as Ron has said (and I agree) it is not "always safe". It can be safe or it can be really unsafe.

 

[EdFred]

This could have all been avoided by flying a straight in.

 

[tehmightypirate]

This could have all been avoided by flying a straight in.

Non-standard pattern entry. I assume you're being sarcastic but (in case you're not) that would fail you (right?).

 

[poadeleted20]

My beef is the unexpected diversion, emergency or not, and the testing scenario seems to be inappropriate for calling the TPA a bust in a real world application. However, this is so specific to her case that I don't think it warrants an exception of any kind, but is definitely grounds for grumbling.
...
The reason being that I consider traffic pattern altitude to be something you look up prior to the flight always

The FAA does not see it that way. They think that being at the correct TPA for the airport you are approaching is a safety issue, and the DPE acted as required by that position. If you don't like that, you need to raise that issue with the FAA Flight Standards Service (HQ office, not your local FSDO), because that's from whence this direction comes. And I think the reasoning you'll hear from them for not accepting your idea will be much the same as what I mentioned above.

 

[poadeleted20]

Re: ..tech needs to jive with A/FD

O.k. got it. I was omitting airspace overhead because it is not an obstacle or something solid, as idiotic as that sounds, that anyone must worry about overhead.

Reminds me of Spock's remark to Kirk about Khan: "He is intelligent, but not experienced. His pattern indicates two-dimensional thinking."

So technically, it is not 'unsafe' to fly any pattern at 1000 AGL. It just puts you in closer proximity to traffic. It is 'less safe' for lack of better summation.

...and absent a good reason for accepting that lower level of safety (and it will have to be a really good one given the history of traffic pattern midairs), the FAA is likely to stand by their position on this.

I'd like to reemphasize what I said above about why this happened -- a misplaced sense of urgency on the applicant's part. She apparently felt that it was more important to arrive quickly than to make sure she arrived safely (or was never taught not to think that). Granted, it's very easy for us to get into that mindset. One reason is the very popular old adage that "landings mandatory but takeoffs are optional." While that's good advice for pre-takeoff go/no-go decisions, it's not as good when making inflight decisions.

The truth is that a landing is never mandatory unless environmental conditions or an inflight emergency make continued flight impossible, or you have lost (or are about to lose) propulsion (or you're flying a glider -- see the discussion about the then-brand-new Tower at Frederick MD gelling a glider to go around for a Cirrus on the crossing runway ). If neither is the case, then you have time to do it right, and check the pubs you have on board for the information necessary for that safe arrival.

 

[tehmightypirate]

The FAA does not see it that way. They think that being at the correct TPA for the airport you are approaching is a safety issue, and the DPE acted as required by that position. If you don't like that, you need to raise that issue with the FAA Flight Standards Service (HQ office, not your local FSDO), because that's from whence this direction comes. And I think the reasoning you'll hear from them for not accepting your idea will be much the same as what I mentioned above.

Well, as I stated, I don't see any better way than the current situation and checkride method. I just feel it's a limit of the testing environment vs real-life. It just sucks that he had to call her out on it, it would be "nice" if the DPE could give people farther diversions but, as it's a good test of dealing with rapid decision making, I understand not fixing something that is a good test for other reasons.

In the end, it wasn't wrong or bad, simply unfair. But who said that checkrides or life ever had to be fair?

 

[EdFred]

Non-standard pattern entry. I assume you're being sarcastic but (in case you're not) that would fail you (right?).

Nope, I did a straight in on my private check ride. There is no "standard" pattern entry. On my various rides we entered from all the legs. There the recommended, but dumb as **** 45° entry, if that's what you are referring to as standard. What a great ****ing idea there FAA. Find the airport, and then turn your back to it, blinding yourself to any other traffic. Good thinking, not.

 

[tehmightypirate]

No kidding, I've lost track of how many times I've been slapped on the wrist for suggesting a straight-in by instructors over the course of my PPL as it's not in line with the AIM. Though, I suppose now that I think of it does it violate any FAR?

(Attempting not to derail this thread too much.)

 

[EdFred]

No kidding, I've lost track of how many times I've been slapped on the wrist for suggesting a straight-in by instructors over the course of my PPL as it's not in line with the AIM. Though, I suppose now that I think of it does it violate any FAR?

(Attempting not to derail this thread too much.)

Next time they do ask them how it can violate a FAR when there's a FAR written saying you have to give way to traffic on final? If there was a FAR then everyone would be required to enter the pattern at point x and play follow the leader, and the FAR regarding traffic on final wouldn't be necessary. Keep in mind there are some airports where the 45 isn't going to work due to airspace or obstacles.

 

[poadeleted20]

Well, as I stated, I don't see any better way than the current situation and checkride method. I just feel it's a limit of the testing environment vs real-life.

I guess I just don't see any difference between the two. Whether it's a checkride or real life, if you're making a diversion to an unplanned airport and there's no distress condition requiring landing ASAP, I think that checking the pubs for the correct TPA is a requirement for a safe arrival.

It just sucks that he had to call her out on it, it would be "nice" if the DPE could give people farther diversions but, as it's a good test of dealing with rapid decision making, I understand not fixing something that is a good test for other reasons.

In the end, it wasn't wrong or bad, simply unfair. But who said that checkrides or life ever had to be fair?

How can you say it was "unfair"? Were the standards not available for her to review? Was she judged other than by those standards? Did the DPE somehow pressure her into skipping this part of the arrival process? I'm just not seeing any unfairness here.

 

[EdFred]

What I'm surprised about is that they actually went to the diversion airport. On my private and commercial, once I got a heading and time to the airport that was pretty much the end of the diversion task.

 

[Ghery]

I can count on one hand the number of current AF/Ds I've seen in cockpits over the last 35 years. The digital revolution is helping this situation, but as has been pointed out there's conflicting info being presented there.

Come fly with me. I'll add to your list. There is ALWAYS an up-to-date AF/D in the plane with me.

My beef is the unexpected diversion, emergency or not, and the testing scenario seems to be inappropriate for calling the TPA a bust in a real world application. However, this is so specific to her case that I don't think it warrants an exception of any kind, but is definitely grounds for grumbling.

Unexpected? It's part of the test. I had a diversion during my PPL ride years ago. I expected it to happen. It's part of the PTS, so how could it have been unexpected?

 

[Skyscraper]

Given that the airport directory is not organized in geographical order, you wind up doing a lot of page turning when finding info for multiple airports, I also find the font a little small to read while flying(and I have 20/20). I like to copy down that info (runway info, freq's, and TPA) for relevant airports in the area on a piece of paper and keep it on my knee board.

 

[poadeleted20]

What I'm surprised about is that they actually went to the diversion airport. On my private and commercial, once I got a heading and time to the airport that was pretty much the end of the diversion task.

Some examiners (many, in my experience) use that diversion as a way of getting to somewhere to do the various takeoffs and landings when the departure airport is too busy for that to be comfortable for more than one arrival and full-stop at the end. I know the two examiners at Easton MD (KESN) do that routinely to use Cambridge (KCGE) for the takeoffs and landings, especially on weekends. The XC goes south, and about 20 miles out, they divert to CGE. Of course, every instructor in the Baltimore District knows this, so there is little surprise to the applicant when it happens, but it is a popular technique in many other locations, too.

 

[poadeleted20]

Given that the airport directory is not organized in geographical order, you wind up doing a lot of page turning when finding info for multiple airports,

If you're on a diversion, you only need data on one airport, and the name of the airport is right there on the chart. Unless you're saying you don't know what state you're in?

I also find the font a little small to read while flying(and I have 20/20).

Perhaps it's time for a pair of reading glasses? Nothing says you can't wear them without a prescription or a requirement on your medical certificate if that's what you need to get the job done. And if you have ForeFlight, you can expand it to readability with just two fingers. :wink2:

I like to copy down that info (runway info, freq's, and TPA) for relevant airports in the area on a piece of paper and keep it on my knee board.

That's all well and good, but things don't always go as planned, and this Task is there specifically to test your ability to handle that safely.

 

[LDJones]

You always have. If you're that close to the altitude of the airliners overhead, TCAS alarms are likely, and they don't use any buffer above the floor of the B-space.

So where's the reg that says you need to stay 500' below the shelf? I'm not finding it.

 

[poadeleted20]

So where's the reg that says you need to stay 500' below the shelf? I'm not finding it.

No such reg to my knowledge, and I never said otherwise.