Descent Below VASI on Approach

[meritflyer]

Originally Posted by BajtheJino

To make a closer taxi way.
I used to land at night at this particular field with great vis, no obstacles yada yada yada. I would come down on the Vasi all red. No problems, no near collisions. Touched down just past the white line and was off on the nearest taxi way. The next one was about 2000 feet down which would mean an extra mile of taxi. F that.

All to save what, 60 seconds of Hobbs time?

[BajtheJino]

Originally Posted by meritflyer

All to save what, 60 seconds of Hobbs time?

I could give a crap about hobbs time. Its all about block. And saving what little drops of fuel I could (can).
Besides, its not dangerous, tough on the brakes or anything else.

[ppragman]

Originally Posted by BajtheJino

I could give a crap about hobbs time. Its all about block. And saving what little drops of fuel I could (can).
Besides, its not dangerous, tough on the brakes or anything else.

Kinda hard to prove that you're descending below glideslope without a Fed on board.

[400A]

Originally Posted by ppragman

Kinda hard to prove that you're descending below glideslope without a Fed on board.

Doesn't matter. Integrity and professionalism is more about what you do when nobody is watching not what can or cannot be proven.

note
This isn't saying baj is dangerous or unprofessional.

[Stone Cold]

Originally Posted by ppragman

Kinda hard to prove that you're descending below glideslope without a Fed on board.

Unless you brag about it on an aviation web site!

[ghogue]

Originally Posted by Zero1Niner

Curious if this is one of those 'opinion varies by FSDO' interpretations. Seems like every POI on the planet, let alone each FSDO has a different interpretation of the regs.

I'm not sure of the office politics involved, however the address is from the Northwest Mountain Regional Counsel. It looks to me like the RC's office handed the task to the Flight Standards Regional Office, and I don't think this is a FSDO. I believe the Flight Standards and the Regional Counsel are both part of the Regional Administrator's office. Someone correct me if I'm wrong. Flight Standards answered the question and the RC accepted their response and sent it out. I doubt the RC's answer every question themselves, and rely on different staff persons to handle specific subject areas. From where I sit, this represents the RC's position and not just a FSDO answer.

You'll have to judge the letter as you read it, but for me, unless the Chief Counsel overturns it, it seems official enough for me, however I'm open to other ideas.

[deadstick]

Originally Posted by ppragman

Kinda hard to prove that you're descending below glideslope without a Fed on board.

Unless there is only 10 feet of a 20 ft tree left standing and the other 10 is on the ground next to the wing.

[minitour]

Originally Posted by calcapt

Just asking the question: Why would you want to descend below the VASI? Do you need a rule to say that?

There's nothing wrong with asking for clarification and a solid reference, which is what the OP did.

-mini

[seagull]

Originally Posted by ghogue

I'm not sure of the office politics involved, however the address is from the Northwest Mountain Regional Counsel. It looks to me like the RC's office handed the task to the Flight Standards Regional Office, and I don't think this is a FSDO. I believe the Flight Standards and the Regional Counsel are both part of the Regional Administrator's office. Someone correct me if I'm wrong. Flight Standards answered the question and the RC accepted their response and sent it out. I doubt the RC's answer every question themselves, and rely on different staff persons to handle specific subject areas. From where I sit, this represents the RC's position and not just a FSDO answer.

You'll have to judge the letter as you read it, but for me, unless the Chief Counsel overturns it, it seems official enough for me, however I'm open to other ideas.

If the Chief Counsel disagrees, and you followed that interp, you WILL be violated. PERIOD. The region does NOT have legal authority for regulatory interps. PERIOD. So, carry that "RC position" with you all you want. Watch the ALJ and NTSB rule in favor of the chief counsel, though. Sure you want to bet your ticket on that still?

[ghogue]

Originally Posted by seagull

If the Chief Counsel disagrees, and you followed that interp, you WILL be violated. PERIOD. The region does NOT have legal authority for regulatory interps. PERIOD. So, carry that "RC position" with you all you want. Watch the ALJ and NTSB rule in favor of the chief counsel, though. Sure you want to bet your ticket on that still?

Thanks for your comments. As I said, I don't know all the internal workings of the Chief Counsel office, and I never implied or meant to imply that the RC was the last word. Perhaps I'm wrong, but I would think that the RC would forward anything like this to the Chef Counsel, at which time the CC could disagree with the position, but, perhaps not, I'm only speculating at this point.

In regards to this particular subject, I doubt anyone would ever be violated for not including a PAPI as a visual reference. I also think that relying on information from the RC's office, who works for the CC, would have some mitigating influence on any violation.

I'm not implying that you or anyone has to accept the letter, I just passed it on because another poster asked for it. Beyond that, I have no interest.

[Zero1Niner]

Originally Posted by seagull

If the Chief Counsel disagrees, and you followed that interp, you WILL be violated. PERIOD. The region does NOT have legal authority for regulatory interps. PERIOD. So, carry that "RC position" with you all you want. Watch the ALJ and NTSB rule in favor of the chief counsel, though. Sure you want to bet your ticket on that still?

This is how I understood things as well. Whenever I see something that is not from the Chief Counsel, its hard to take it to the bank. CC or bust!

[Blackhawk]

91.129 (e) only applies to large or turbine powered airplanes:
"[(e) Minimum altitudes when operating to an airport in Class D airspace. (1) Unless required by the applicable distance-from-cloud criteria, each pilot operating a large or turbine-powered airplane must enter the traffic pattern at an altitude of at least 1,500 feet above the elevation of the airport and maintain at least 1,500 feet until further descent is required for a safe landing.
(2) Each pilot operating a large or turbine-powered airplane approaching to land on a runway served by an instrument approach procedure with vertical guidance, if the airplane is so equipped, must:"
Yada, yada, yada.
While I don't know of it being done yet in the US there were/are? some Canadian cities where your company will get a letter in the mail... along with a fine... if you descend below a certain glidepath.
Now personally, I don't think descending below glidepath at night is a really good habit to develop.

[calcapt]

Originally Posted by Realms09

....I find it useful to descend below the VASI on very short final. The aiming point provided by the VASI can be relatively far down the runway, with a resulting touchdown point even farther down. Shifting the aiming point closer to the threshold results in a lot less "runway behind you."

I completely agree with you. The FAA seems to allow for this when they say: "......at or above the glide path until a lower altitude is necessary for a safe landing."

Originally Posted by BajtheJino

.......I would come down on the Vasi all red. No problems, no near collisions. Touched down just past the white line and was off on the nearest taxi way.......

I completely understand your focus on expediting your landing. What I don't understand is how you know when low is too low? A red over red VASI looks the same if you are airborne or driving by the end of the runway in your car. I better understand a PAPI with 3 red and a white as it tells you something meaningful but the only thing an all red PAPI or a red over red VASI tells you is that you are too low. Just how low is anybody's guess. I am talking more about flying at night obviously since you could use other visual clues without VASI during the day.

I think it is important for new pilots to realize that routinely flying below the VASI is not the preferred method for most operations.

[calcapt]

Originally Posted by minitour

There's nothing wrong with asking for clarification and a solid reference, which is what the OP did.

-mini

No issue with the question as I found the answer and reference enlightening as well. I was simply asking philosophically why you would need someone to tell you that you couldn't do something that on the surface seems basically unsafe. I would never discourage anyone from asking a question on any topic. Sorry if my response seemed anything other than light chatter.

[Blackhawk]

Originally Posted by calcapt

No issue with the question as I found the answer and reference enlightening as well. I was simply asking philosophically why you would need someone to tell you that you couldn't do something that on the surface seems basically unsafe. I would never discourage anyone from asking a question on any topic. Sorry if my response seemed anything other than light chatter.

It seems as if most of part 91 is common sense. This should tell us something.

[Doug Taylor]

Well, if you dive below the VASI on a regular basis and end up running into something, you *might* make the local news broadcast if there's enough fire and smoke.

If you dive below VASI on a regular basis under part-121 and run into something, there's going to be a "Go Team", congressional hearings, lawsuits, breaking news, yadda yadda yadda.

Part 121 rules and Part 91 rules are different for a variety of reasons. Just like rules about driving a Pinto are a lot different than the rules for driving tractor-trailers, school buses and well, even the Schwann's frozen food truck.

[MikeD]

Originally Posted by Zero1Niner

Seem to recall a discussion with someone telling me that it was in the FAR's or AIM that it is not permitted to descend below VASI at night on an approach.

I cant find any reference to this in either the FAR or AIM. Anyone have any idea what the deal is with this? Is this a fact or fiction?

To answer the OP. At night I wouldn't descend below the VASI. Daytime, it depends on the particular runway I'm using and if there's any operational need for me to do so. If it's severe clear, I have a short runway, and I'm sure there are no obstructions in the approach path, I may consider shifting my aimpoint a little short when I have the runway made in order to not touchdown too far down the runway. This wouldn't be a regular thing, but would be another available item in my bag of tricks if and when necessary.

[minitour]

Originally Posted by Blackhawk

91.129 (e) only applies to large or turbine powered airplanes:
"[(e) Minimum altitudes when operating to an airport in Class D airspace. (1) Unless required by the applicable distance-from-cloud criteria, each pilot operating a large or turbine-powered airplane must enter the traffic pattern at an altitude of at least 1,500 feet above the elevation of the airport and maintain at least 1,500 feet until further descent is required for a safe landing.
(2) Each pilot operating a large or turbine-powered airplane approaching to land on a runway served by an instrument approach procedure with vertical guidance, if the airplane is so equipped, must:"
Yada, yada, yada.

Close.

That's for entering the traffic pattern and for an instrument approach procedure with vertical guidance.

The applicable section is...

91.129(e)(3)

You just got to sections 1 and 2.

(e)(3) states...
(3) Each pilot operating an airplane approaching to land on a runway served by a visual approach slope indicator must maintain an altitude at or above the glide path until a lower altitude is necessary for a safe landing.

No mention of large or turbine power.

-mini

[seagull]

Originally Posted by ghogue

Thanks for your comments. As I said, I don't know all the internal workings of the Chief Counsel office, and I never implied or meant to imply that the RC was the last word. Perhaps I'm wrong, but I would think that the RC would forward anything like this to the Chef Counsel, at which time the CC could disagree with the position, but, perhaps not, I'm only speculating at this point.

In regards to this particular subject, I doubt anyone would ever be violated for not including a PAPI as a visual reference. I also think that relying on information from the RC's office, who works for the CC, would have some mitigating influence on any violation.

I'm not implying that you or anyone has to accept the letter, I just passed it on because another poster asked for it. Beyond that, I have no interest.

As somebody who DOES know how much of the internal FAA working are, I can tell you that you are incorrect that the RC would forward this to the AGC office. It might happen, but I wouldn't count on it. Even if they do, unless the AGC issues an interp IN WRITING, it is worthless if you have some incident and they decide to enforce.

On the second point, you can doubt it all you want, but it is a very subjective call. If you blow a tire and the touchdown point was before the VASI aim point, they can pin that on a higher than normal rate of descent leading to that tire failure (just an example). Falls under 91.13 as well.

Oh, and 91.129 looks to me like it applies in entirety to large and turbine powered, but 91.13 still applies if anything goes wrong. You might look for interps here

http://www.faa.gov/about/office_org/...terpretations/

Regardless, you need to be very careful. This is not too far different than the issue of people thinking that they are assured a 3 degree path from MDA to the runway on non-precision approaches to runways not served by an ILS...

[minitour]

Originally Posted by seagull

Oh, and 91.129 looks to me like it applies in entirety to large and turbine powered...

If it did, the language for large and turbine powered wouldn't be under (e)(1) and (e)(2). It would be right there under 91.129 or at the very least under (e) itself or (a) would be applying it to turbine or large........as other regulations do.

It's listed under (e)(1) and (e)(2) for a reason. (e)(3) says "an airplane" for a reason.

-mini

[ghogue]

Originally Posted by seagull

As somebody who DOES know how much of the internal FAA working are, I can tell you that you are incorrect that the RC would forward this to the AGC office. It might happen, but I wouldn't count on it. Even if they do, unless the AGC issues an interp IN WRITING, it is worthless if you have some incident and they decide to enforce.

On the second point, you can doubt it all you want, but it is a very subjective call. If you blow a tire and the touchdown point was before the VASI aim point, they can pin that on a higher than normal rate of descent leading to that tire failure (just an example). Falls under 91.13 as well.

Oh, and 91.129 looks to me like it applies in entirety to large and turbine powered, but 91.13 still applies if anything goes wrong. You might look for interps here

http://www.faa.gov/about/office_org/...terpretations/

Regardless, you need to be very careful. This is not too far different than the issue of people thinking that they are assured a 3 degree path from MDA to the runway on non-precision approaches to runways not served by an ILS...

Again, thanks for the information, however, from the way you have responded, it seems to me that you are a bit irritated at my responses. I tried to make it clear that I wasn't sure how the system worked and was giving my opinion on it. I appreciate the information you have provided, but, not the tone. If I am wrong about that, I apologize. Perhaps, you're just very passionate about this.

I agree that the RC is subject to the AGC's interpretations. I guess my question in this case is what purpose is the RC if only the AGC can respond to questions such as these? I'm merely curious how it works. I would think that the CC would inform the RC's to cease responses like the one I posted if they had no authority to do so.

On your response to my second point, I want to be clear that I was not advocating ignoring the VASI and descending below it. I was referring to the RC's comment that a PAPI could not be substituted for a VASI and that a person would not be violated for not including a PAPI as a visual reference. I doubt that would ever be an issue anyway.

I didn't make the comment about about 91.129 in reference to large and turbine-powered airplanes. That was from a different poster.

Again, thanks for the response.

[ppragman]

Originally Posted by 400A

Doesn't matter. Integrity and professionalism is more about what you do when nobody is watching not what can or cannot be proven.

note
This isn't saying baj is dangerous or unprofessional.

I guarantee you'd do the same thing if you were going to the same 10,000' runway everynight and would have to taxi an extra mile as baj said. Guarantee it. You might not do it the first night, you might not do it the second, but eventually you will, probably just from mind numbing boredness if not something else.

Originally Posted by Stone Cold

Unless you brag about it on an aviation web site!

I try not to say "I" on this site for that reason, but really, I don't think there's much wrong with this sort of thing.

Originally Posted by deadstick

Unless there is only 10 feet of a 20 ft tree left standing and the other 10 is on the ground next to the wing.

You don't do this sort of thing unless you know the terrain. Then you'd be an idiot. This is the sort of thing you do when you are comfortable with the airport, or know what's going on around you.

[400A]

Hold on there hoss. Don't for one second think you can know what I would or would not do. My performance is never dictated by needing to get something done quickly.

[minitour]

Originally Posted by ppragman

I guarantee you'd do the same thing if you were going to the same 10,000' runway everynight and would have to taxi an extra mile as baj said. Guarantee it. You might not do it the first night, you might not do it the second, but eventually you will, probably just from mind numbing boredness if not something else.

Our landing distance performance is based on Vref and crossing the threshold at 50'. If the numbers say I need 3200' on a 10,000' runway the only difference is I probably don't brake as agressively as I would on a 3,500' runway. If that means a 6,000' taxi, then that's fine...but landing long to make a taxiway is not excusable regardless of how many times you've landed at an airport.

You don't do this sort of thing unless you know the terrain. Then you'd be an idiot. This is the sort of thing you do when you are comfortable with the airport, or know what's going on around you.

Complacency kills, chief.

-mini

[ppragman]

Originally Posted by 400A

Hold on there hoss. Don't for one second think you can know what I would or would not do. My performance is never dictated by needing to get something done quickly.

This is the internet, and everyone is always incredibly cautious and never does anything outside of the ordinary. BTW, this isn't about speed, this is about efficiency. If I can operate the aircraft more efficiently without jeopardizing safety, I'm going to. Am I going to do this into places I'm unfamiliar with? No. Am I going to do things that are unsafe? No. But I am going to try to maximize the efficiency on every flight. Period.

Originally Posted by minitour

Our landing distance performance is based on Vref and crossing the threshold at 50'. If the numbers say I need 3200' on a 10,000' runway the only difference is I probably don't brake as agressively as I would on a 3,500' runway. If that means a 6,000' taxi, then that's fine...but landing long to make a taxiway is not excusable regardless of how many times you've landed at an airport.


Complacency kills, chief.

-mini

You guys probably wouldn't like my short approach and long landing so I can touch down slightly before echo, and roll out to exit at charlie, still with more than 1000' remaining past charlie so I don't have to taxi for 5 minutes and can speed up my turn.

As for complacency, yeah, it does kill, but landing long, or landing short to save time isn't complacency, its being efficient. Don't fly outside the envelope, but don't waste time. Being complacent is not doing flows properly, or not checking the weather before you go, or forgetting notams cuz' ehh, what could have changed. Landing extra short to get a taxi way isn't complacency. Landing long because you're landing a 207/210/Cherokee 6/Caravan/310/ or even the 1900 on a 10,000' runway isn't necessarily complacent. Its complacent if you do it without thinking yes, but not necessarily complacent in general. It comes down to your judgment on the touchdown. Am I going to have adequate runway to stop if something goes wrong now? Most of the time, on an airplane that big, the answer is yes. Its when the answer is "no" and you do it anyway that you'll get in trouble.

What are the three biggest wastes in aviation, the fuel at home, the runway behind you, and the altitude above you. If I can touch down in the first inch of the runway safely, I'm going to because if its icy, or blowy, or something jumps onto the field in front of my, my velocity will be lower if I impact something/slide off the end/etc. If I can clear the runway quicker, I'm going to, god only knows who or what might try to land on me, the quicker I'm off the runway the better.

Do you do a runup before every takeoff when flying a piston engine airplane? If not you're complacent! And complacency kills!!!



Oh, and also, 91.129 is for Class D, so if its the middle of the night, and the tower is closed, you're in class e, and it no longer applies, so this whole argument only applies to the cases where its night, and the tower is still open. And on top of that, you have to have a long enough runway so that you couldn't easily argue that it was required for safety to get off early. And the VASI has to be working. So if I'm going into a 5000' runway or less, I'm going to touch down as quickly as possible and clear the runway in the interests of safety if I have an extended threshold.