“To” & “For” Confusion in Aviation Communications

FAA recently released an update to AC 90-66 Non-Towered Airport Flight Operations (more information here at BruceAir).

That update specifically address several contentious issues, such as straight-in approaches, “the active,” and the perenially annoying and counterproductive request “any traffic in the area, please advise.”

But one section of the updated AC 90-66B also discusses the common tendency of pilots to include the words “to” and “for” in transmissions–even when not at a non-towered airport. For example:

  • Cessna 1234A: Podunk traffic, Cessna 1234A, right base for runway two.
  • Cessna 1234A: Podunk traffic, Cessna 1234A, ten miles to the south to enter downwind for runway two seven.
  • Cessna 1234: Podunk traffic, Cessna 1234, taking the active for takeoff to the south. Podunk.
  • Approach: Cessna 34A, turn right heading two five zero. Cessna 34A: Two fifty for 34A.
  • Approach: Cessna 34A, descend and maintain two thousand two hundred. Cessna 34A: Two point two for 34A.
  • Cessna 1234A: Metro departure, Cessna 1234A, one point two for two.
  • Departure: Cessna 34A, climb and maintain four thousand. Cessna 34A: Up to four for 34A. Or: Out of two for four for 34A.

You can hear many similar examples on the CTAF at any busy non-towered airport and while working with ATC. The use of “to” and “for” and abbreviated readbacks is also common in popular aviation videos on YouTube.

The use of “to” and “for” is natural in everyday communication, and perhaps it seems cool if you’re an experienced pilot who graduated from remedial ATC-speak thousands of hours ago.

But mixing words and numbers is potentially confusing in aviation, especially when the frequency is busy and workload is high. It’s also unnecessary. AC 90-66B devotes a paragraph specifically to the matter.

10.4 Confusing Language. To avoid misunderstandings, pilots should avoid using the words “to” and “for” whenever possible. These words might be confused with runway numbers or altitudes. The use of “inbound for landing” should also be avoided. For example, instead of saying, “MIDWEST TRAFFIC, EIGHT ONE TANGO FOXTROT TEN MILES TO THE NORTHEAST, INBOUND FOR LANDING RUNWAY TWO TWO MIDWEST,” it is more advisable to say, “MIDWEST TRAFFIC, EIGHT ONE TANGO FOXTROT TEN MILES NORTHEAST OF THE AIRPORT, LANDING STRAIGHT IN RUNWAY TWO TWO, MIDWEST,” so it does not confuse runway 4, runway 22, or the use of an IAP on arrival.

Rephrasing the above examples removes the unnecessary homophones:

  • Cessna 1234A: Podunk traffic, Cessna 1234A, right base runway zero two. Podunk
  • Cessna 1234A: Podunk traffic, Cessna 1234A, one-zero miles south, planning left downwind runway two-seven. Podunk.
  • Cessna 1234: Podunk traffic, Cessna 1234, departing runway two-seven, will be southbound. Podunk.
  • Approach: Cessna 34A, turn right heading two five zero. Cessna 34A: Right turn heading two five zero, Cessna 34A.
  • Approach: Cessna 34A, descend and maintain two thousand two hundred. Cessna 34A: Maintain two thousand two hundred, Cessna 34A.
  • Cessna1234A: Metro departure, Cessna 1234A, one thousand two hundred, climbing two thousand.
  • Departure: Cessna 34A, climb and maintain four thousand. Cessna 34A: Maintain four thousand, Cessna 34A.

You can find additional detailed examples in AIM Chapter 4 Air Traffic Control, Section 2 Radio Communications Phraseology and Techniques.

Of course, sometimes there’s no subtitute for using plain language. The aviation phrasebook doesn’t include standard dialog for every situation. And we all make slips of the tongue on the radio, just as in normal conversation. But remaining vigilant about the use of potentially confusing and unnecessary words and phrases is one way to reduce the potential for conflicts.

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Complex Aircraft No Longer Required for Practical Tests

FAA has published Notice N8900.463, which removes the requirement for applicants to provide a complex aircraft (i.e., an airplane with retractable landing gear, a controllable-pitch propeller, and flaps) for the commercial pilot SEL and flight instructor-airplane practical tests.

Note, however, that this change in policy affects only practical tests, not the training and experience requirements for commercial pilots and flight instructors. Those requirements, which are specified in 14 CFR Part 61, may change if an NPRM from May 2016 is enacted as a final rule. For more background on these proposed regulatory changes, see FAA Proposes Significant Rule Changes here at BruceAir.

Specifically, [this notice] outlines the policy which no longer requires applicants for a commercial pilot certificate with an airplane single-engine rating to provide a complex or turbine-powered airplane for the associated practical test and no longer requires applicants for a flight instructor certificate with an airplane single-engine rating to provide a complex airplane for the practical test…[T]here are far fewer single-engine complex airplanes available to meet the ACS/PTS requirement, and the single-engine complex airplanes that are available are older airplanes that are expensive to maintain. Additionally, the FAA finds that removing the commercial pilot ACS requirement to furnish a complex or turbine-powered airplane and removing the flight instructor PTS requirement to furnish a complex airplane will achieve the same objectives. The FAA has determined that removing these ACS/PTS requirements will significantly reduce costs for persons pursuing a commercial pilot or flight instructor certificate by allowing applicants to utilize less-expensive airplanes on the practical test that are not complex or turbine-powered.

The notice continues:

The FAA has determined that any airplane may be used to accomplish the tasks prescribed in the initial commercial pilot with an airplane single-engine rating practical test or a flight instructor with an airplane single-engine rating practical test, provided that airplane is capable of accomplishing all areas of operation required for the practical test and is the appropriate category and class for the rating sought. Therefore, the airplane used for the practical test must still meet the requirements specified in § 61.45.

However, the notice also explains that:

There is no change to the complex airplane training and endorsement requirements of § 61.31(e) or to the commercial pilot aeronautical experience requirements of § 61.129(a)(3)(ii) or part 141 appendix D.

As noted above, flight schools will still need complex aircraft so that commercial students can acquire 10 hours of complex time.

But commercial students won’t necessarily need to spend those 10 hours practicing lazy 8s, chandelles, power-off 180 landings, etc. to prepare for the practical test. Instead, they can use the complex aircraft to fly cross-countries, build night-flying hours, and so forth. They just need to log 10 hours and get the complex–and, depending on the airplane used–high-performance endorsements. They can then practice and prepare for the checkride in any aircraft that is capable of all the areas of operation in the ACS and that meets the requirements for the practical test. This change should help with the maintenance and other costs incurred when operating complex aircraft for training.

CFI candidates, who presumably have acquired the 10 hours of complex time as part of their training for the commercial certificate, can accomplish all of their training and preparation for the initial CFI-A with a SEL rating in any suitable aircraft.

This flexibility will save CFI candidates money, and it will make it much easier for flight schools to provide aircraft both for training and practical tests. Many flight schools have only one or two complex aircraft available, making scheduling difficult. And saving wear-and-tear on complex aircraft will probably improve their dispatch availability and lower maintenance costs.

Cloud Surfing

A few minutes of flying among the clouds during a couple of IFR flights in the Pacific Northwest.

More videos at my YouTube channel, BruceAirFlying.

New Equipment Required Notes

FAA has published a charting notice (PDF) that describes how equipment requirements will be noted on terminal procedure charts. This change is based on a long discussion at the Aeronautical Charting Forum (see 13-02-312: Equipment Requirement Notes on Instrument Approach Procedure).

For procedures with PBN elements, the PBN box will contain the procedure’s navigation specification(s); and, if required: specific sensors or infrastructure needed for the navigation solution; any additional or advanced functional requirements; the minimum Required Navigation Performance (RNP) value and any amplifying remarks. Items listed in this PBN box are REQUIRED. The separate Equipment Requirements Box will list ground-based equipment requirements. On procedures with both PBN elements and ground-based equipment requirements, the PBN requirements box will be listed first.

The publication of the new notes will continue incrementally until all charts have been amended to comply with the new standard.

A sample of the new notes boxes is below.

PBN Requirements Notes

Here’s an example of the requirements box on the recently updated chart for the ILS RWY 28R approach at Billings, MT (KBIL):

KBIL-ILS-PlanView

Setting the CDI on a Conventional Approach (The “Kill Switch”)

If you fly an aircraft with an IFR-approved GNSS, you probably use that “suitable RNAV system” to help you fly all types of approaches, including ILS, LOC, and VOR procedures. In fact, if your aircraft isn’t equipped with DME or ADF, using an IFR-approved GNSS system may be the only way for you to fly many conventional procedures.

“Suitable RNAV systems” based on GNSS are described in AIM 1−2−3. Use of Suitable Area Navigation (RNAV) Systems on Conventional Procedures and Routes, AC 90−100, AC 90-108, and other FAA references.

A critical step in flying conventional approaches while using GNSS to fly transitions/feeder routes is ensuring that the proper guidance is shown on the PFD/HSI as you intercept and then fly the final approach course.

For example, as shown below, when flying the LOC RWY 17 approach at Aurora, OR (KUAO), you could use the GNSS for course guidance as you fly the charted transition from the Battleground (BTG) VOR.

KUAO-LOCRWY17-Chart-01

KUAO-LOCRWY17-Transition-01

Some systems can automatically switch the CDI from the “magenta line” shown when using GNSS signals to “green needles,” usually labeled VOR/LOC, as you intercept final. But you must always monitor the avionics and, if necessary, use the CDI button (or other switch for your system) to change to VOR/LOC “green needles” before you join the final approach course.

KUAO-LOCRWY17-FinalApproach-01.jpg

For more information about guidance along the final approach course, see Use of IFR GPS on Conventional Approaches here at BruceAir.

Unfortunately, many pilots fail to confirm this critical step, which often occurs during a high-workload phase of an approach. For example, just as you are about to intercept the final approach course, ATC may issue a rapid-fire vector and approach clearance (“Fly heading 130, maintain 2,000 until established…”), you can be distracted while making a late configuration change, or while switching frequencies to the tower or CTAF.

In fact, this error is so common that many pilots and instructors call the CDI switch the “kill button” (or a similarly ominious name) to emphasize its importance.

I use a graphical reminder to help me ensure that I switch course guidance in plenty of time for a smooth intercept.

Like many pilots, I use a tablet and an aviation app (in my case, primarily ForeFlight) to display charts. Those apps typically have an annotation feature that lets you mark up charts to emphasize important information.

ForeFlightAnnotations

For example, on this chart for another approach at KUAO, I’ve noted a temporary change in minimums.

AnnotatedChart

To remind myself to switch the CDI to “green needles” on conventional approaches, I use the annotation feature to draw a transparent green line along the final approach course.

KUAO-LOCRWY17-Plan-GreenLine-01

I mark up the charts for conventional approaches during my preflight planning as I review weather, NOTAMs, procedures that I might fly, and other details.

I organize approaches that I fly often into binders in ForeFlight (other apps have a similar feature), and the markups are preserved between flights, so I don’t have to repeat this process for most of the procedures that I fly.

Because RNAV (GPS) approaches don’t require changing from GNSS guidance, I don’t highlight the final approach segment on those procedures.

To avoid cluttering charts, I also don’t mark the intial steps of a missed approach in magenta to signify that I can return to GNSS guidance to fly the miss, regardless of the type of approach. But if you’re in IFR training or new to using GNSS under IFR, highlighting the miss in magenta might be a useful reminder.

Update on ATC Phone Numbers for IFR Clearances/Cancellations

At the October 2017 meeting of the Aeronautical Charting Forum, the FAA provided an update (PDF) on its efforts to provide direct telephone numbers to ATC facilities so that pilots can receive IFR clearances and cancel IFR at non-towered airports directly with ATC rather than relay those notifications through FSS or other means.

The presentation notes that:

  • ATC phone numbers for 656 airports have been entered into the national airport database and published in the Chart Supplement.
  • Over 200 additional airports will have their Chart Supplement entries updated to include a clearance delivery phone number.
  • For all other uncontrolled airports without a GCO or radio outlet linking them to ATC or Flight Service, pilots will be able to obtain a clearance by calling the overlying ARTCC through a published phone number to that Center’s Flight Data Unit (FDU).

KTTD-AFD_07DEC2017.jpg

An update to AIM 5-2-3 Taxi Clearance is also in the works. The proposed language would read as follows:

a. Pilots departing on an IFR flight plan should consult the Chart Supplement US airport/facility directory to determine the frequency or telephone number to use to contact clearance delivery. On initial contact pilots should advise the flight is IFR and state the destination airport.

b. Air traffic facilities providing clearance delivery services via telephone will have their telephone number published in the communication remarks section of that airport’s directory entry. This same remarks section may also contain a telephone number to use for cancellation of an IFR flight plan after landing. Pilots are encouraged to use these telephone numbers at uncontrolled airports when they are published. Pilots may also contact Flight Service’s dedicated clearance delivery hotline (1-888-766-8267).

FAA also plans to move telephone relay of IFR clearance from FSS to ATC:

Preliminary agreement has been reached with Air Traffic and the Bargaining Units to move the telephone relay of all remaining IFR Clearance functions from Flight Service over to Air Traffic.

Fall 2017 Update on VOR Decommissioning

At the October 2017 meeting of the Aeronautical Charting Forum, the FAA provided an update on the program gradually to decommission about 309 VORs by 2025 as part of the switch to GNSS-based performance based navigation (PBN).

To see the full list of VORs that FAA plans to decommission, visit this post at BruceAir.

VORandMON-Overview

According to the minutes of that meeting and a presentation from an FAA representative, the switch to the mininimum operational network (MON) of about 587 VORs includes the following highlights:

Discontinued 16 VORs to date:
– [EDS] Edisto, in Orangeburg, SC – February 4, 2016
– [BUA] Buffalo, in Buffalo, SD – July 21, 2016
– [PNN] Princeton, in Princeton ME – July 21, 2016
– [PLB] Plattsburgh, in Plattsburgh, NY – September 15, 2016
– [AOH] Allen County , in Lima, OH – September 15, 2016
– [ABB] Nabb, in Nabb Indiana – January 5, 2017
– [SYO] Sayre, in Sayre Oklahoma – April 27, 2017
– [ENW] Kenosha, in Kenosha Wisconsin – June 22, 2017
– [BTL] Battle Creek, in Battle Creek, Michigan – June 22,2017
– [HRK] Horlick, in Horlick Wisconsin – June 22, 2017
– [HUW] West Plains, Missouri – August 17, 2017
– [RIS] Kansas City, Missouri – September 14, 2017
– [DDD] Port City, in Muscatine, IA – October 12, 2017
– [JKS] Jacks Creek, TN – October 12, 2017
– [MXW] Maxwell, CA – October 12, 2017
– [STE] Stevens Point, WI – October 12, 2017

Over the next six months, the following  seven VORs are scheduled to be shut down:

– [AOO] Altoona, PA
– [BRD] Brainerd, MN
– [DKK] Dunkirk, NY
– [HVN] New Haven, CT
– [PNE] North Philadelphia, PA
– [RNL] Rainelle, WV
– [RUT] Rutland, VT

You can follow the links in the list above to see the VORs on a VFR chart. Note that these navaids are not the only VORs in the vicinity. In fact, in most cases, at least one VOR is within just a few miles of the facility slated for shutdown.

HVN-VOR

Part of the switch to the MON is establishing new VOR service volumes. The FAA representative noted that upgrading and flight checking remaining VORs is one the next steps in the VOR MON program. The upgraded service volume values will be 70 nm at or above 5000 ft and 130 nm above 18,000 ft for high VORs. When the flight checks are complete, new information about VOR service volumes will be published in the Chart Supplement and the AIM.