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6 Answers

clearance limit

Asked by: 1162 views FAA Regulations, Instrument Rating

Last night I was flying in IMC under IFR with my CFII.  Our clearance was KHPN ESJAY V623 SAX KCDW.  After reaching ESJAY we were vectored for a bit and told to expect the LOC 22 into KCDW (http://flightaware.com/resources/airport/CDW/IAP/LOC+RWY+22/pdf).  Then ATC told us to maintain 2500 feet and fly direct DOWDY, which is an intermediate fix and the first fix on the localizer for the IAP.  This is NYC airspace, so it gets pretty busy and sometimes you can't get a word in on frequency to ask the controller for your next clearance.  We got very close to DOWDY without further clearance and the frequency was too busy to make a request.  Luckily the controller cleared us for the approach right before we hit DOWDY, but I was concerned that we would not be cleared in time.  

My question is what should we have done if we hit DOWDY without receiving further clearance?  Are we supposed to treat DOWDY as the clearance limit and hold at DOWDY with a standard holding pattern based on the heading we approached DOWDY or do we assume that the controller wanted us to intercept the localizer?  Keep in mind there is no published hold and we're at 2500 and the MSA for the area is 3000, so there may be obstructions in the area we would be holding and we can't see anything.  I'm pretty sure holding is the book answer, but is this what you would have done in this situation?

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6 Answers



  1. R. Anderson on May 23, 2017

    I did not look at the approach chart, but here is what the AIM says at paragraph 4-4-3 e. 3:

    “If no holding pattern is charted and holding
    instructions have not been issued, the pilot should ask
    ATC for holding instructions prior to reaching the fix.
    This procedure will eliminate the possibility of an
    aircraft entering a holding pattern other than that
    desired by ATC. If unable to obtain holding
    instructions prior to reaching the fix (due to
    frequency congestion, stuck microphone, etc.), hold
    in a standard pattern on the course on which you
    approached the fix and request further clearance as
    soon as possible. In this event, the altitude/flight level
    of the aircraft at the clearance limit will be protected
    so that separation will be provided as required.”

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  2. R. Anderson on May 23, 2017

    Also, if ATC told you to go direct to DOWDY and then subsequently told you to expect the LOC 22, I would be inclined to start the approach. But since ATC told you to expect the LOC 22, and then subsequently cleared you direct to DOWDY and, you could not reach ATC because of freq. congestion, holding would be my choice as noted above. It’s not entirely clear, but since ATC is watching you, it’s likely you would get a clearance even at the last minute like you did.

    Probably interesting to see what others might do.

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  3. Ben E. on May 23, 2017

    I guess I should dispense with one of my initial assumptions–that this is a clearance limit. The original clearance limit was KCDW. Did it change when I was told to go direct to DOWDY, or was that just routing? If not a clearance limit then the holding rules for clearance limits don’t apply and then I’m not sure what the textbook answer is.

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  4. Jim F. on May 23, 2017

    It may not be/probably isn’t the right answer, but I would turn inbound; that’s clearly what’s intended. This happens pretty regularly in the real world, and I guarantee you that suddenly doing a 180 and pointing towards the inbound behind you would cause more trouble than just heading towards the field, as expected. I don’t think I’ve ever gotten a true “clearance limit” included when they send me to a fix on the approach without a “join the LOC” type addition…

    Now about your concern with your altitude lower than the MSA; The 3,000′ is looking at all obstacles within that 25nm circle from TEB. If you were gonna draw your own hold over DOWDY, you can see on the chart that there are no obstacles which would be of a concern around that fix, so you’d be good, from that aspect.

    Again, I’m pretty sure this isn’t the official answer, but the real-world differs greatly from the books and sim, so that’s where ADM comes in to play.

    I’m curious to hear what your instructors answer was.

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  5. R. Anderson on May 23, 2017

    Not sure there is a textbook answer. There are surely several methods of handling your question that could be legitimately argued and supported.

    Some might argue that you should follow lost comm procedures since you’re unable to communicate with ATC. Others may say that your clearance limit has changed from the airport to DOWDY, and then since your last ATC clearance ends at DOWDY, then follow the route ATC told you to expect (FAR 91.185), fly the LOC 22 approach.

    As a side note, MSA’s are often higher than the MVA’s (minimum vectoring altitude) in certain areas, so you should be fine at 2500 since the altitude at DOWDY is 2400. But excellent situational awareness on your part.

    Again, I personally don’t think there is a perfect answer to your hypothetical. A turn in a hold on the course you are on inbound to DOWDY, or start the approach (LOC22) you were told to expect – either one seems like a reasonable and safe course of action considering your circumstances (not the least of which is that the controller is watching you and likely had your sequence and separation are determined).

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  6. John Scarry on May 24, 2017

    6−4−1. Two-way Radio Communications Failure
    a. It is virtually impossible to provide regulations and procedures applicable to all possible situations associated with two-way radio communications failure. During two-way radio communications failure, when confronted by a situation not covered in the regulation, pilots are expected to exercise good judgment in whatever action they elect to take.

    While this isn’t a communication failure, it is close and the normal procedure would be Assigned, Vectored, Expected, and then Filed. Since you were told to expect the Localizer that’s what you should fly.

    This differs from one of the sample questions on the Knowledge Test:
    You have not yet been cleared for the approach, but you are being vectored to the ILS approach course. It is clear that you will pass through the localizer course unless you take action. You should
    A) turn outbound and complete the procedure turn.
    B) continue as assigned and query ATC.
    C) turn inbound and join the final approach course.

    In this case you should continue as assigned.

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