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How to do a circling approach to a runway where the only authorized direction is against the normal traffic pattern direction

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Instrument Rating

Allentown Queen City airport (KXLL) has 2 instrument approach procedures both approaching the airport from the west (RNAV 7 and VOR B).  Since the prevailing wind is from the west, the most preferred landing runway (by a great deal) is 25.  There is a ridge line running parallel to 7-25 so  even if the wind might be acceptable for runways 15-33, the ridge makes landing to runway 33 essentially unusable, and the climb-out directly into the ridge on a balked landing to runway 15 is less than optimal.  Taken together, these factors mean that except for the rare cases when the wind favors runway 7, the only really safe runway to land is 25.

The problem as I see it is that KXLL has left traffic to all runways, yet both approach plates say that circling over the ridge line to the south of 7-25 is not authorized.  Then the only way to circle to 25 would be right traffic north of the runway.  But I thought that circling approaches must be done in the direction of the prevailing traffic pattern at an airport.  So right traffic to 25 would be prohibited, as well.  I don't see a legal way to fly those approaches into what is almost always the safest runway at that airport.

What am I missing?  How can they safely and legally be flown into 25?

12 Answers



  1. Matt R. on Feb 27, 2018

    This is a great question and one that DE’s love to ask.

    Take a look at this excerpt from AIM 5-4-20f(1) & (2):

    “1. Maneuver the shortest path to the base or downwind leg, as appropriate, considering existing weather conditions. There is no restriction from passing over the airport or other runways.”

    “2. It should be recognized that circling maneuvers may be made while VFR or other flying is in progress at the airport. Standard left turns or specific instruction from the controller for maneuvering must be considered when circling to land.“

    It’s basically a judgement call based on the factors present as you’re flying the circle to land. So, a slight side-step to the left to fly a right downwind for landing on runway 25 is perfectly legal.

    Again, nice job thinking about things like this on the ground. Safe flying.

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  2. Mark Kolber on Feb 28, 2018

    Given your local knowledge, it looks like whe whole Airport is unusable at night since the only authorized runway is 7.

    I should leave this one for John Collins. He wrote to the Chief Counsel about this issue. One of the bases fir a deviation is when “‘‘authorized or required’ by the approach guidelines of a specific airport.” Or an emergency.

    At least arguably, if you cannot circle in the “correct” direction, and there are no other safe landing options, it is “authorized by the approach guidelines.”

    Keep in mind, though, that the purpose of the rule is safety. The airport is Class G below 700 AGL, so there could theoretically be traffic flying a correct VFR pattern below circling minimums. And, if the weather is good enough, a “safe landing option” is cancelling IFR. IOW, in case a problem arose, I would not bet on using the “unless authorized” language as a defense if the weather was CAVU.

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  3. Best Answer


    John D Collins on Feb 28, 2018

    I have never bought the argument that it is safer to fly the circle in the same direction of potential VFR traffic unless one is at the same altitude as the VFR traffic. I would be more worried about a mid air if circling is accomplished on the same side as the VFR pattern but at a different altitude than VFR traffic.

    That said, in my discussions with the attorney who drafted the opinion, this would be a case where the direction of circling is authorized by the approach procedure and the wording of 91.126 allows for it “Unless otherwise authorized or required”. This is a distinction that would not apply to the case where the weather on the circling side would prohibit circling in the pattern direction. However, the approach chart is also a regulation and goes thru the regulatory process under part 97. So the chart authorizes and requires circling to the north and opposite side of the pattern.

    So unless you cancel IFR before circling, my take is you are required to circle to the north of runway 7 and 25. If you are flying a practice approach under VFR, then the chart does not apply and you should follow the pattern direction. I would also recommend that you circle at pattern altitude in the practice case.

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  4. John D Collins on Feb 28, 2018

    Matt,

    Read these FAA General Counsel opinions:

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2013/collins-2%20-%20(2013)%20legal%20interpretation.pdf

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2014/krug%20-%20(2014)%20legal%20interpretation.pdf

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  5. Barry on Feb 28, 2018

    Thanks, all. John, the opinion letter is the clincher. I had my IR checkride out of that airport and at the time (several years ago), I couldn’t get or find a good answer. Not knowing the examiner, I was afraid to ask for his input. I had decided to fly a mid-field crosswind entry to left traffic on 15 and do a there with a right crosswind (lame, but legal and in the VFR conditions of a simulated IFR checkride, safe). Yours is a much better response.

    By the way, the winds on the day of my checkride were unusually from the east with runway 7 preferred. The examiner accepted the circling VOR-B approach for the circling approach requirement and all was easy.

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  6. Matt R. on Feb 28, 2018

    John,

    I don’t want to thread jack from the original poster but please summarize the letters if you don’t mind.

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  7. R. Anderson on Feb 28, 2018

    I totally agree with John C.

    Since the approach plate DOES NOT say “Circling NA to Rwys 7 and 25” but it DOES SAY “Circling NA south of rwys 7 and 25,” it follows that circling would therefore be authorized, by the design of the FAR Part 97 approach regulatory criteria (i.e. “authorized”), north of rwys 7 and 25 (i.e. right traffic).

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  8. Barry on Mar 01, 2018

    At first I was happy with John’s guidance and documentation that the regulations allowed for flying right traffic to circle to runway 25. The approach charts provide for circling minimums, and they do not prohibit circling to 25. And they prohibit circling on the left traffic side of 25. So by elimination they must allow for circling on the right traffic side of 25 based upon the “Unless otherwise authorized or required…” exclusion of 91.126.

    But as I have thought more about this question, I am having 2nd thoughts. This situation is set up for the FAA having 20/20 hindsight in the event of an accident or incident. I can practically write the decision. “Both 14 CFR 91.126 and the Collins letter of April 2013 require that a pilot have clear justification for circling contrary to the guidelines of 91.126, such as the emergency provisions of 91.3(b).” “Prohibition of circling south of 7-25 is not affirmative authorization of circling north of that runway under 14 CFR 91.126.” “Just because one thing is prohibited does not mean that its opposite is allowed.” “The fact that circling minimums are provided does not infer that circling is allowed to runway 25, as circling left traffic to runway 15 is available.”

    I think that, unless there is unambiguous guidance saying that a limitation against complying with the circling direction requirement of 91.126 provides authorization to circle otherwise, I will not consider circling right traffic to 25. What I should have been prepared to tell my examiner if he directed me to do a circling approach to landing on 25 is, “I am unable to do that because of the requirement for left turns and the prohibition of circling south of 7-25.” If faced with this situation in IMC, I would divert to KABE, ca. 10 miles to the north. For the sake of the practical test, I would recommend that we fly to a nearby airport, such as Braden airpark, and conduct the circling procedure there. I would have to trust that this response would have exhibited sufficient knowledge of the regulations, good ADM, and provided for the opportunity to display the necessary flying skill. If he had failed me for giving it, then so be it.

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  9. John D Collins on Mar 01, 2018

    If you want additional clarification, draft and send a question to the FAA General Counsel. It is very difficult to get definitive answers from them even if you draft an unambiguous question. The lawyers tend to answer the question they wish to answer and not necessarily the one that is drafted. Even a direct question may not get the desired response, but it is worth a try. I would suggest asking if circling is permitted to XX runway on that specific procedure by circling opposite the direction of the pattern.

    PS, it seems to take a good part of a year to get a response.

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  10. Barry on Mar 01, 2018

    Thanks, John. Now that I have my own plan crystallized, I am probably not going to poke the FAA hornet’s nest by asking this question. But thank-you and the others for helping me work through the issues.

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  11. R. Anderson on Mar 01, 2018

    Barry, I think you make some excellent points in your last post. The central point of your argument is the well written phrase: “Prohibition of circling south of 7-25 is not affirmative authorization of circling north of that runway under 14 CFR 91.126.”

    However, here are a few other considerations that I personally think supports the legality of circling to rwy 25 via right traffic:

    1. It is agreed that circling south of rwy 25 to enter left traffic is “NA” (not authorized as shown on the approach plate). Therefore, in order to circle and land on rwy 25 right traffic is “required” by the FAR Part 97 procedure. To me, this satisfies the exception allowed under 91.126 (a) “Unless otherwise authorized or required…”

    2. If you circled and made right traffic to rwy 25, what regulation would be violated? 91.126 (b) (1) could not be violated because in order to specifically comply with that regulation you would have to knowingly violate FAR Part 97 (i.e. circling south of rwys 7 and 25 which is not authorized). I think this is a compelling point supporting both “authorized” (because circling north it is not prohibited by the approach plate) and/or “required” (because circling south is prohibited by the approach plate).

    3. Lastly, what safety issue has been created because you are circling north using right traffic? In fact, you would arguably be creating a safety (and regulatory) issue if you circled south (otherwise it would not be prohibited by the approach plate).

    I think it would be a stretch too far to assume that you could not land at all on rwy 25 because both left and right traffic are prohibited. It’s absolutely clear left traffic is prohibited (see the plate). Right traffic, however, seems to comfortably fit within the “unless otherwise authorized or required…” wording (even if that phrase is narrowly construed).

    Remember, regulations are supposed to make flying safer, not prohibit safe operations because of a regulatory conundrum.

    You made some good points, but I think it would be legal and safe to circle north for rwy 25.

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  12. Mark Kolber on Mar 02, 2018

    Matt R – you can read a summary of the letters in this article from IFR Magazine

    Which Way to Turn?

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