“Clearance on Request”

Sometimes when you call air traffic control–usually clearance delivery or ground control–for an IFR clearance based on a filed IFR flight plan, ATC responds, “Clearance on request.”

In ATC-speak, the statement means that the controller doesn’t have your clearance immediately at hand. But he or she is tapping a keyboard or calling on a landline to retrieve it from the air traffic control system. The controller will call you back when your clearance is ready. This situation can occur if you call more than 30 minutes before your proposed (estimated) time of departure, but there may be other reasons why your flight “strip” isn’t immediately available.

Flight Progress Strip from FAA JO7110.65Y

I confess that “clearance on request” never confused me, but a long thread at BeechTalk, a popular forum for Beechcraft pilots, showed that several folks found the response puzzling. They thought it meant something like, “Reply when you’re ready to copy, and I’ll read your clearance.”

The discussion got me thinking about the wording. A colleague, Jeff Van West of Pilot Workshops, agreed that it had never confused him, but as we talked, he said the phrase was like a Rubin vase, an image that can appear either as two people in profile or as a vase, depending on how you look it at. The longer you stare, the more ambiguous the scene.

To my surprise, the commonly used phrase doesn’t appear in the AIM or P/CG or in the ATC handbook, Air Traffic Control (JO7110.65Y).

So I wrote the FAA, asking that “clearance on request” be explained. Here’s the initial response:

This office has carefully reviewed the matter. Although the phrase “Clearance on request”, does not appear in FAA directives, the Aeronautical Information Manual, or other FAA standards/procedures, this is by design, as the phrase is self-explanatory.

“Clearance on request” is in response to the pilot’s request, “I’m looking for my clearance to xxx”, “Request for clearance on Nxxxxx”, “This is N12345, requesting clearance,” etc. Although not regulatory, the controller’s response, “Clearance On Request”, “On Request”, “I have your request”, “Standby”, “I’ll be right back with you”, etc., are all phrases that are self-explanatory, accomplishing the same task. The controller proceeds to process the pilot’s request as higher priority duties allow.

Accordingly, this office does not believe the phrase “Clearance on request” needs further explanation. If you wish to appeal this determination, please contact John Reagan, Manager, Terminal Standards and Procedures Team, AJV-P31

I called Reagan, who is a very responsive, understanding fellow. He said that his group will reconsider and probably change the ATC handbook to use a different phrase (e.g., “Standby”) that will reduce potential confusion.

He noted that when he was a new IFR pilot, he was initially confused by the phrase and that the wording probably has been passed along informally and adopted without careful vetting.

In the meantime, if you’re an instrument instructor, make sure your IFR students and IPC customers understand “clearance on request.”

Setting a Course v. Vectors to Final

I am not a fan of the vectors to final (VTF) option when loading instrument approaches in GPS navigators like the Garmin GNS and GTN series avionics.

As a general rule, avoid the vectors (vectors-to-final) option

Even with recent improvements to how the Garmin GTN series boxes handle VTF, it’s usually best to choose an initial fix (IF) or initial approach fix (IAF) based on the direction from which you’re arriving in the terminal environment, and then, depending on your clearance from ATC, activate a leg of the procedure or proceed direct to an IF or IAF. See the example at KMWH below.

Choosing a transition (IF) when loading an approach.

For more information about VTF, see Avoiding the Vectors-to-Final Scramble, Changes to Vectors-to-Final in Garmin GTN System 6.x, and Flying Instrument Approaches without Activating the Approach.

Occasionally, however, you may encounter an approach such as the ILS or LOC RWY 14 at Boeing Field (KBFI) (chart below).

Video of the approach described in this discussion

Knowing how to use a handy technique that straddles the line between the VTF and setting a specific course (a variation on OBS mode) can help you smoothly join the final approach course. Bear with me for a somewhat convoluted explanation.

For more information about setting a specific course to a fix and the OBS feature, search for Direct To and OBS in the pilot guide for the avionics you use.


The plan view for this approach shows two key fixes along the localizer: ISOGE and TOGAE.

Plan view

TOGAE is step-down fix with a crossing restriction and a GS intercept altitude at 1600 (the beginning of the final approach segment when you fly the full ILS with glideslope). TOGAE also serves as the FAF when you fly the LOC-only version of the procedure.

In theory, Seattle Approach could vector you to join the localizer a few miles outside TOGAE (within the approach gate; see the Instrument Procedures Handbook and the P/C Glossary).

APPROACH GATE− An imaginary point used within ATC as a basis for vectoring aircraft to the final approach course. The gate will be established along the final approach course 1 mile from the final approach fix on the side away from the airport and will be no closer than 5 miles from the landing threshold.

Definition of approach gate in the P/C Glossary

The approach also chart shows ISOGE, a fix 9 nm from the ruwnay, as an IF/IAF. (You will never fly the depicted hold/course reversal anchored at ISOGE.)

And ISOGE appears in the list of transitions when you load this approach in a GPS navigator such as a Garmin GTN 750.

If you choose either Vectors or ISOGE, the fix appears in the flight plan.

If you activate VTF for this approach, the GTN draws an extended centerline from TOGAE (the FAF) out along in the localizer course. You loose ISOGE as a reference.

VTF leaves ISOGE in the flight plan, but all distance and ETE information references TOGAE.

If you activate the approach with ISOGE as the transition, the navigator draws a magenta line from your present position to ISOGE, and if you hand-fly that course or put the autopilot in NAV mode, you will head directly to that fix.

But Seattle Approach always issues a series of vectors to sequence you into the flow of traffic for KBFI and to avoid conflicts (wake turbulence and otherwise) with airliners aiming for nearby KSEA. Regardless of the direction from which you’re arriving, ATC places you on the localizer at least a few miles outside of ISOGE.

In other words, you don’t want to go direct to ISOGE, and it’s helpful to have a reference to the localizer course as ATC vectors you into the flow.

For example, I recently flew the ILS from the area near Arlington, WA (KAWO) northeast of Seattle (video here).

Radar vectors KAWO-KBFI to the ILS or LOC RWY 14R

This typical routing from the northeast involves a long vector on a southwest heading to intercept the localizer. Even if you have the navaid tuned, you may not be able to identify it and confirm its appearance on the CDI until you are almost on top of the course. If ATC is busy or if you’re flying a fast airplane, it’s easy to blow through the localizer or be tempted to make an aggressive turn to capture it when you get the final vector from ATC.

Here’s the “trick” to help you fly a smooth intercept. It involves setting a specific course direct to a fix–in other words, it’s similar to using OBS mode:

  • If you’re using the autopilot, make sure you’re in HDG mode to follow vectors from ATC.
  • Because you’re flying vectors to join the localizer, confirm that you’re showing “green needles” on the HSI or CDI used to fly the ILS. You don’t need GPS guidance from this point on.
  • Load the approach with ISOGE as the transition (i.e., as the first fix in the procedure).
  • Confirm the list of fixes in the flight plan.
  • Select ISOGE and choose direct-to.
  • In the direct-to window, enter the course inbound to ISOGE along the localizer–135 degrees.
  • On the map, you’ll see a magenta line extending to ISOGE along the course 135 degrees–in effect, an extension of the localizer.

Here’s how that sequence looks using a GTN 750:

ISOGE selected as the transition (initial fix). ISOGE is the current direct-to fix–the approach is activated.
The GTN 750 shows guidance direct to ISOGE. But ATC is vectoring you to join the final approach course at a point outside ISOGE.

To draw an extension of the localizer from ISOGE, select ISOGE again, choose Direct-To, and enter the course 135.

Setting a specific course to ISOGE.
The GTN draws a course of 135 to ISOGE, in effect, an extension of the localizer.

Now you can monitor your progress toward the final approach course and prepare for the turn onto the localizer, even if you’re not currently receiving the signal or showing a flyable localizer CDI.

Joining the localizer.

As you join the localizer and then pass ISOGE, the GTN sequences to the next fix in the approach, TOGAE. If you used OBS mode to set a course to ISOGE, the GTN would suspend waypoint sequencing past ISOGE, but setting a direct-to course preserves that feature.

On the ILS approaching TOGAE.

A Handy Guide to Airport Markings and Lights

You can find information about runway markings and lights in the AIM, but many key details, including the lengths of runway stripes and the dimensions associated with specific types of runway lighting systems, are typically buried technical advisory circulars that are tough for pilots to parse.

Fortunately, FAA has collected valuable information in A Quick Reference to Airfield Standards, available as a PDF.

For example, here’s a table that summarizes markings for a runway served by a precision approach.

Unfortunately, this document does not describe various types of approach lighting systems. For those details, you must still wade through a publication such as JO 6850.2B.

Across the Cascades via T268

I took advantage of CAVU weather to record a flight across the Cascades from east to west via the new (as of January 2020) GPS-based T-route (T268) that offers lower MEAs than the V2 airway between the VORs at ELN and SEA. T268 won’t appear on the Seattle sectional chart until the new edition is published May 21, 2020, but it’s on the IFR chart and available for both IFR and VFR navigation.

For more information about T-routes, see New T-Routes in the PNW and AIM 5−3−4. Airways and Route Systems.

T268 will appear on new VFR charts in May 2020.
T268 on an IFR en route chart
Portions of T268 shown on the Seattle sectional published May 21, 2020

FAA plans to publish VFR charts the same 28-day cycle used for IFR charts and data beginning in 2021. For more information, see VFR Charts Moving to 56-Day Update Cycle.

Video of the route

You can see the lower lower MEAs available on T268 versus V2 on the charts below. The T-route follows a path north of the VOR-based V2 airway, with a couple of bends to keep you over lower terrain. You can fly T268 at 8000 westbound–2000 feet lower than the 10,000 altitude typically required on V2 westbound.

Lower GPS-based MEAs on T268

The early morning flight in the video begins at Ephrata, WA (KEPH), and after BANDR intersection, I turned southwest to land at Chehalis, WA (KCLS) for fuel.

Enjoy the scenery, which changes dramatically in just a short distance–only about 80 nm between Ellensburg and Seattle.

Credit for Using ATDs and AATDs

The FAA allows pilots to use flight simulators, flight training devices (FTD), and aviation training devices (ATD) to accumulate some of the aeronautical experience required in 14 CFR Part 61 for various pilot certificates and ratings.

Guidance for using ATD during training is in AC 60-136B and in the letters of authorization (LOA) issued with each ATD.


The Foundation from one-G, an AATD based on the C172, is among the newest FAA-approved ATDs.

For additional background about the types of “simulators” that the FAA authorizes, including ATDs and AATDs (advanced aviation training devices), see New AC for ATDs and Simulations, Flight Simulators, FTDs, and ATDs here at BruceAir.

Unfortunately, the regulations aren’t always easy to parse, and when pilots and instructors consider the use of ATDs and AATDs, one regulatory paragraph, 14 CFR Part 61.4(c), is often overlooked, probably because it’s the last sentence in a rule titled “Qualification and approval of flight simulators and flight training devices,” and that section doesn’t specifically mention ATD.

But 14 CFR Part 61.4(c) says: “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.” And that’s the key to understanding the credit allowed in the LOAs.

The flight school where I instruct, Galvin Flying, has several AATDs, each of which has an LOA from the FAA that describes how the devices may be used during training. The LOAs specifically note credits for tasks and for aeronautical experience associated with various certificates and ratings, in accordance with AC 60-136B and 14 CFR Part 61.

Most of the criteria are clear. But over the years, the flight school has received conflicting interpretations about how much experience in the AATDs may apply toward the aeronautical experience requirements set out in 14 CFR Part 61.

For example, 14 CFR § 61.129 [(i)(1)(i)] states that up to 50 hours of simulated flight time in a “full flight simulator” or a “flight training device” may be credited toward the 250 hrs total time required for a commercial certificate. That regulation does not specifically mention “aviation training devices” or “advanced aviation training devices,” distinctions that were made with both regulatory changes and the publication of AC 60-136B.

Now, AC 60-136B notes that the LOA associated with each approved ATD or AATD describes the device’s authorized uses and allowable credit toward specific aeronautical experience requirements. For example:

C.2 Authorized Use. Except for specific aircraft type training and testing, an AATD may be approved and authorized for use in accomplishing certain required tasks, maneuvers, or procedures as applicable under 14 CFR parts 61 and 141. The FAA will specify the allowable credit in the AATD LOA for private pilot, instrument rating, instrument recency of experience, IPC, commercial pilot, and ATP.

D.3 Logging Training Time and Experience.

Note: There are no restrictions on the amount of training accomplished and logged in training devices. However, the regulatory limitations on maximum credit allowed for the minimum pilot certification requirements are specified by parts 61 and 141 and in the LOA. No approvals or authorizations are provided for aircraft type ratings using ATDs.

Each of the LOAs for the AATDs at Galvin Flying includes the following language related to the commercial pilot certificate:

…The [model name] AATD is approved for use in satisfying the following sections of parts 61 and 141:…

§ 61.129(i)(1)(i)—Commercial Pilot Certificate: up to 50 hours;…

That language seems clear, but as I noted earlier, the fact that the regulation itself doesn’t mention ATD has led to confusion.

So I wrote the FAA asking for clarification. Here, in part, is the reply, which confirms that the language in the LOAs supplements the regulations in 14 CFR Part 61:

The rule is silent in these rule sections concerning the use of ATD’s including rule sections for Private Pilot, Commercial Pilot, and Airline Transport Pilot certificates. However, Part 61.4(c) states, “The Administrator may approve a device other than a flight simulator or flight training device for specific purposes.” All aviation training device (ATD) letters of authorization (LOA) reference §61.4(c) in the first paragraph of the letter. The maximum amount of credit for various certificates and ratings is provided in the LOA. The FAA uses the letter of authorization (LOA) to approve the use of advanced aviation training devices (AATD’s) for private pilot, commercial pilot, and ATP experience requirements utilizing the provision of 14 CFR §61.4(c). The LOA also provides credit allowances for the instrument rating and associated experience requirements.

Marcel Bernard
Aviation Safety Inspector
Aviation Training Device (ATD) National Program Manager
Federal Aviation Administration, Flight Standards Service HQ

In other words, 14 CFR Part §61.4(c) allows you to use an ATD toward the experience requirements in 14 CFR Part 61, as long as you use the ATD in accordance with its LOA.

Here’s a link to a chart from FAA that summarizes credit for use of various training devices and simulators. (But see below for additional information about using simulation devices during training.)

The reply to my query from the FAA (and the language in AC 60-136B) also emphasizes another important point: There’s no absolute limit to the amount of time you can spend using an ATD during training.

Finally, it is important to understand that you can log as much time as you want in an ATD, flight training device (FTD) or full flight simulator (FFS). Many flight instructors believe that you can only “log” what time is indicated on the LOA. This is a common misconception. “Training credit” and “logging of pilot time” are two different considerations. Proactive flight instructors will accomplish and log as much time as needed with their student in the simulator, until the student is proficient for that particular task. This usually results in the student needing far less time in the aircraft to compete the same flight tasks, saving time, money and wear and tear on the aircraft. Additionally, many emergency scenarios that can’t be safely accomplished in the aircraft, can be accomplished in a simulator without risk.

You should always practice tasks to acceptable level of proficiency (ACS standards) in the simulator first, before doing the same task in the aircraft, no matter how much time it takes in the simulator. Without this practice it defeats the advantages, logic and use of a simulator during training.

Marcel Bernard
Aviation Safety Inspector
Aviation Training Device (ATD) National Program Manager
Federal Aviation Administration, Flight Standards Service HQ

Demonstrating, Teaching, and Practicing Stalls

Debates about how to teach, practice, and demonstrate stalls continue, usually vociferously, after more than century of powered flight. In the U.S., FAA guidance on the topic has evolved to the current standards, described in the Airmen Certification Standards and the references (viz., handbooks and ACs) that expand on the tasks applicants are required to demonstrate.

Airplane Flying Handbook, Figure 4-7
Private Pilot ACS Task VII

Of course, the ACS is not a syllabus–a detailed sequence of lessons that describes the training required for a certificate or rating. The ACS is the guide examiners use during a practical test to determine whether an applicant is qualified for a new piloting privilege. The ACS samples an applicant’s knowledge and skill. It is the final exam, not the course.

The current edition of the Airplane Flying Handbook (FAA-H-8083-3B) includes detailed descriptions of the stall tasks in the ACS for private pilot and commercial pilot applicants. But that guide also offers guidance to flight instructors about how to introduce and teach stall-related skills. For example:

The practice of impending stalls is of particular value in developing the pilot’s sense of feel for executing maneuvers in which maximum airplane performance is required. These maneuvers require flight in which the airplane approaches a stall, but the pilot initiates recovery at the first indication, such as by a stall warning device activation. Impending stalls may be entered and performed in the same attitudes and configurations as the full stalls or other maneuvers described in this chapter. However, instead of allowing the airplane to reach the critical AOA, the pilot must immediately reduce AOA once the stall warning device goes off, if installed, or recognizes other cues such as buffeting. Hold the nose down control input as required to eliminate the stall warning. Then level the wings maintain coordinated flight, and then apply whatever additional power is necessary to return to the desired flightpath. (AFH FAA-H-8083-3B, 4-8)

Unfortunately, many CFIs still introduce stalls by jumping right into demonstrating the power-off and power-on stalls as described in the ACS. Those demos often confuse and frighten students, and as the Aviation Instructor’s Handbook emphasizes, if you’re scared, you can’t learn.

A previous edition of the AFH offered additional, detailed advice about how to introduce stalls:

Usually, the first few practices should include only approaches to stalls, with recovery initiated as soon as the first buffeting or partial loss of control is noted. In this way, the pilot can become familiar with the indications of an approaching stall without actually stalling the airplane. Once the pilot becomes comfortable with this procedure, the airplane should be slowed in such a manner that it stalls in as near a level pitch attitude as is possible. The student pilot must not be allowed to form the impression that in all circumstances, a high pitch attitude is necessary to exceed the critical angle of attack, or that in all circumstances, a level or near level pitch attitude is indicative of a low angle of attack. Recovery should be practiced first without the addition of power, by merely relieving enough back-elevator pressure that the stall is broken and the airplane assumes a normal glide attitude. The instructor should also introduce the student to a secondary stall at this point. Stall recoveries should then be practiced with the addition of power to determine how effective power will be in executing a safe recovery and minimizing altitude loss. (FAA-H-8083-3B, 4-5)

Here’s an example of that technique during a flight with a student in my Extra 300L, a high-performance aerobatic airplane.

I always show pilots the basic stall characteristics of the airplane before we move on to accelerated stalls, incipient spins, and the like.

You can find a series of videos that show stalls and spins at my YouTube channel, here.

If more instructors would follow that advice when introducing slow flight and stalls, perhaps we’d see fewer articles such as Be Afraid of Stalls, that advocate omitting stalls from pilot training, and more pilots would understand how best to avoid the stalls that result in accidents.

Avionics Flow Check

Here’s my latest tip for Pilot Workshops: The Avionics Flow Check.

It’s a simple way to ensure that you’ve configured the avionics before each important phase of flight. The video below shows a before-takeoff avionics flow.

Chaotic Traffic Pattern: Sedona, AZ (KSEZ)

I recently flew friends to Sedona, AZ (KSEZ) for brunch on a beautiful Sunday morning. The flight from the Las Vegas area was uneventful, but the arrival at KSEZ (video below) illustrated the need for clear communications and standard traffic pattern procedures at busy non-towered airports.

Sedona, AZ (KSEZ) on a sectional chart

KSEZ is famous for its runway located on a mesa above the town, which is surrounded by spectacular red rock formations and supposedly is home to at least one spiritual energy vortex. Some wags call KSEZ the USS Sedona, because landing there is as close as most pilots will come to landing on an aircraft carrier (the other famous candidate for landlubbers is Catalina, CA; KAVX).

Closer view of the airport on a sectional chart

The airport is at 4830 MSL elevation; traffic pattern altitude is 6003 for piston aircraft, per the remarks in the Chart Supplement. It has one runway, 3-21. Runway 3 slopes up, and it is the preferred choice for landing when winds are light. Runway 21 is usually the best choice for takeoff. Left traffic is designated for both runway ends; downwind and base west of the airport when using runway 3; downwind and base east of the airport when using runway 21.

The recently updated AC 90-66B–Nontowered Airport Operations describes the recommend procedures for entering and flying the traffic pattern at a non-towered airport, and it provides examples of best practices for communicating on the Common Traffic Advisory Frequency (CTAF) assigned to each airport.

The airport was busy on that Sunday morning, mostly with arriving traffic as we approached at about 1100 MST.

Arriving at KSEZ

But the problem during this approach and landing wasn’t really the number of airplanes trying to use the airport. Instead, it was difficult to develop a good picture of the traffic around the airport and to anticipate the actions of other pilots because:

Some pilots overflew the airport to enter the downwind directly or entered downwind directly rather than flying a 45-degree entry. Now, the 45-degree entry isn’t required, and AC 90-66B discusses two options for joining the downwind if you overfly the airport.

Traffic pattern entry after crossing overhead at midfield.

But the advisory circular also notes that:

11.3 Traffic Pattern Entry. Arriving aircraft should be at traffic pattern altitude and allow for sufficient time to view the entire traffic pattern before entering. Entries into traffic patterns while descending may create collision hazards and should be avoided. Entry to the downwind leg should be at a 45 degree angle abeam the midpoint of the runway to be used for landing. The pilot may use discretion to choose an alternate type of entry, especially when intending to cross over midfield, based upon the traffic and communication at the time of arrival. [Emphasis added.]

Note: Aircraft should always enter the pattern at pattern altitude, especially when flying over midfield and entering the downwind directly. A midfield crossing alternate pattern entry should not be used when the pattern is congested. Descending into the traffic pattern can be dangerous, as one aircraft could descend on top of another aircraft already in the pattern. All similar types of aircraft, including those entering on the 45 degree angle to downwind, should be at the same pattern altitude so that it is easier to visually acquire any traffic in the pattern.

AC 90-66B

The other issue that sunny Sunday morning was confusing or confused radio calls and position reports. Using local landmarks like “the high school” doesn’t help folks who aren’t familiar with the area. As AC 90-66B notes:

Transient aircraft may not know local ground references, so pilots should use standard pattern phraseology, including distances from the airport.

AC 90-66B

The recommendations in the AC also note that:

When referring to a specific runway, pilots should use the runway number and not use the phrase “Active Runway,” because there is no official active runway at a non-towered airport. To help identify one airport from another when sharing the same frequency, the airport name should be spoken at the beginning and end of each self-announce transmission.

AC 90-66B

Finally, some of the transmission where confusing, perhaps because the pilot simply misstated a runway number, pattern leg, or intentions. For example, one pilot said, “Cirrus xxx, on a straight-out departure runway 21, coming back for a straight-in departure runway 3.” Those were slips of the tongue, but they certainly didn’t help others understand the pilot’s plan.

Other pilots reported entering the downwind from the north, probably via a direct entry (without a 45-degree leg), but it was hard to be sure, and at least one aircraft apparently flew inside another as they entered the downwind.

As you can see in the video, I made a 360-degree turn while on the 45 leg to create more space behind the Baron that joined downwind ahead of me after crossing over the airport at midfield. We were a little too close for my comfort, and I didn’t want to extend my downwind behind the twin, which needs more room to maneuver.

In the end, we all arrived safely, but the traffic pattern was more chaotic than necessary. Flying a few extra miles to set up west of the airport for a 45-degree entry would have allowed everyone more opportunities to develop good situational awareness, to minimize last-minute maneuvering near the airport, and to adjust the pattern to accommodate arrivals and departures.

Another note for pilots: My Bonanza is equipped with an altitude-compensating fuel pump. It adjusts the mixture based on ambient pressure, so even at high-altitude airports such as KSEZ, I set the mixture to full rich for takeoff and landing, and I check for the appropriate the fuel flow based on a table in the airplane flight manual. If your aircraft doesn’t have such a system, and most don’t, you should refer to the performance data in your POH or AFM and set the mixture according the the information in that handbook when operating at high density altitudes.

AIM Update: Approach Categories

FAA has released the January 30, 2020 update to the AIM. (Link to PDF and HTML editions here. You can read the explanation of changes here.)

The update includes several items of interest to IFR pilots, but one is of particular note here:

5−4−7. Instrument Approach Procedures
This change provides pilots with additional options when it is necessary to conduct an instrument approach at an airspeed higher than the maximum airspeed of its certificated aircraft approach category. It explains the flexibility provided in 14 CFR and emphasizes the primary safety issue of staying within protected areas.

Here’s the new text in that section:

a. Aircraft approach category means a grouping of aircraft based on a speed of Vref at the maximum certified landing weight, if specified, or if Vref is not specified, 1.3Vso at the maximum certified landing weight. Vref, Vso, and the maximum certified landing weight are those values as established for the aircraft by the certification authority of the country of registry. A pilot must maneuver the aircraft within the circling approach protected area (see FIG 5−4−29) to achieve the obstacle and terrain clearances provided by procedure design criteria.

b. In addition to pilot techniques for maneuvering, one acceptable method to reduce the risk of flying out of the circling approach protected area is to use either the minima corresponding to the category determined during certification or minima associated with a higher category. Helicopters may use Category A minima. If it is necessary to operate at a speed in excess of the upper limit of the speed range for an aircraft’s category, the minimums for the higher category should be used. This may occur with certain aircraft types operating in heavy/gusty wind, icing, or non−normal conditions. For example, an airplane which fits into Category B, but is circling to land at a speed of 145 knots, should use the approach Category D minimums. As an additional example, a Category A airplane (or helicopter) which is operating at 130 knots on a straight−in approach should use the approach Category C minimums.

c. A pilot who chooses an alternative method when it is necessary to maneuver at a speed that exceeds the category speed limit (for example, where higher category minimums are not published) should consider the following factors that can significantly affect the actual ground track flown:

1. Bank angle. For example, at 165 knots ground speed, the radius of turn increases from 4,194 feet using 30 degrees of bank to 6,654 feet when using 20 degrees of bank. When using a shallower bank angle, it may be necessary to modify the flight path or indicated airspeed to remain within the circling approach protected area. Pilots should be aware that excessive bank angle can lead to a loss of aircraft control.

2. Indicated airspeed. Procedure design criteria typically utilize the highest speed for a particular category. If a pilot chooses to operate at a higher speed, other factors should be modified to ensure that the aircraft remains within the circling approach protected area.

3. Wind speed and direction. For example, it is not uncommon to maneuver the aircraft to a downwind leg where the ground speed will be considerably higher than the indicated airspeed. Pilots must carefully plan the initiation of all turns to ensure that the aircraft remains within the circling approach protected area.

4. Pilot technique. Pilots frequently have many options with regard to flight path when conducting circling approaches. Sound planning and judgment are vital to proper execution. The lateral and vertical path to be flown should be carefully considered using current weather and terrain information to ensure that the aircraft remains within the circling approach protected area.

Proposal to Change VOR Equipment Test

A pilot has proposed removing the requirement to log the results of the VOR equipment test required by 14 CFR § 91.171 for operations under IFR.

You can read the original proposal, docket FAA-2019-0739, and comments at the Federal Register, here.

The change wouldn’t repeal the test itself, only the detailed requirements for recording the results as described in paragraph (d).

AOPA filed detailed comments in support of the proposal, here. The organization notes in part that: “The logging requirement is not a positive safety argument when a failed check is what is clearly the concern. A failed check is fully and effectively mitigated by the placarding requirement of 14 C.F.R. §91.213 and the obligations under 91.171(a).”

I support the proposal, but in comments that I submitted to the docket, I suggested additional changes, viz.:

  • Expand the current 30-day limit to a more reasonable interval, such as every three calendar months or six calendar months. Using the calendar month criterion would synchronize the interval with other regulatory requirements, such as the valid periods for medical certificates, annual inspections, flight reviews, and so forth.
  • Allow the use of an IFR-approved GNSS (i.e., a suitable RNAV system, as described in AIM 1−2−3 Use of Suitable Area Navigation (RNAV) Systems on Conventional Procedures and Routes, and as defined in various ACs, including AC 90−100A) to verify the accuracy of VOR equipment.

As I explained:

For example, a pilot tracking an airway or a course to/from a VOR with an IFR-approved GNSS could confirm that the VOR course shown by a CDI or bearing pointer is within the limits specified by the regulation. As other commentators have noted, FAA is gradually decommissioning VORs, and accomplishing the VOR equipment test will become increasingly difficult as navaids are removed from the NAS. Even given the inherent differences between the courses shown by GNSS and conventional navaids, as described in the AIM (1−1−17. Global Positioning System (GPS), Paragraph k. Impact of Magnetic Variation on PBN Systems), checking the accuracy of a VOR in this manner would be well within the six-degree error long permitted for airborne checks. Using GNSS would also be in keeping with current FAA policy about PBN in general, and specifically about using GNSS to fly conventional procedures while monitoring guidance from ground-based navaids.