Should you contact ATC during practice approaches?
Kent wrote me this morning asking:
While flying recently with my friend a question came up which has come up for me several times in the past. I firmly believe that while flying VFR practice approaches (as published) into an uncontrolled airport that radio communication with the controlling ATC needs to be made-I always thought the approached as published is their approach. My friend firmly believes that as long as it’s VMC and uncontrolled airspace that one does not need to be talking to ATC. I do agree that it seems to be common practice to fly these on your own without ATC but is this really appropriate/legal?
This might be one of the cases where what is legal isn’t necessarily safe. The safe thing is always to contact ATC and request flight following / radar services when practicing any kind of approach. Remember, that’s why they are there (and for now it’s still a free service). Even if you aren’t receiving radar services it would be prudent to at the very least monitor the appropriate frequency. The reasoning of course is that if an airplane comes along that really does need to shoot that approach (corporate, airline, etc), your presence on the approach might make the required IFR separation difficult if not impossible for ATC. Also, having that second (or third set) of eyes is always a good backup in case both pilots become preoccupied with the technicalities of the approach. How sad would it be if ATC could have stopped the collision of 2 VFR aircraft…if only they were talking to them! That brings up another point too, what if there is another aircraft on the same approach that has a pilot with the same mentality of your friend? Now you have 2 VFR airplanes, practicing the same approach and neither of them are talking to ATC…that’s just asking for something to happen!
However, according to the AIM Chapter 3 Section 2, in uncontrolled airspace or class E (as I’m guessing your approach is in) there is no communications requirement for VFR aircraft. I find nothing else published saying that you have to establish contact with ATC just because you are on a segment of an instrument approach. Technically your friend is right but that doesn’t mean that would be the safest operating practice (I’d rather be safe and alive then dead and right).
As a pilot (and PIC) you have every right to stand up for yourself and establish your own operating procedures. Let everyone you fly with know that your rule is to contact ATC on VFR practice approaches. Don’t let yourself be lead down the path of least resistance! A good pilot listens to his gut. If something doesn’t feel right, STOP! Don’t continue. Figure out what you don’t like about the situation and correct it. If you don’t like practicing approaches without contacting ATC, then don’t do them! There are plenty of times in my career where I’ve had to stand up for a situation I thought was unsafe, even if it was “legal” to continue.