I was flying the RNAV (GPS) RWY 33 approach into KFNL during instrument meteorological conditions. The plate identifies a non-standard 6 NM racetrack reversal at IMOMY:

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Denver approach cleared me direct to IMOMY. I was approaching from the Southwest, but NOT from HYGEN. Thus, I began a circuit around the depicted procedural track. I was cleared for the approach and approved to change to advisory frequency.

At about 4 NM outbound, ATC contacted me* and asked when I planned to turn inbound. I advised that I could begin inbound immediately, which they then asked (not cleared) me to do, in order to avoid encroaching on departing traffic from KDEN.

During VFR practice approaches (not under ATC), we always shortened the course reversal on this particular approach to save time. When doing the real thing, it was always my understanding that the depicted track had to be flown EXACTLY as published. Per the FAA Instrument Procedures Handbook:

A holding pattern in lieu of procedure turn may be specified for course reversal in some procedures. In such cases, the holding pattern is established over an intermediate fix or a [final approach fix]. The holding pattern distance or time specified in the profile view must be observed. For a hold-in-lieu-of PT, the holding pattern direction must be flown as depicted and the specified leg length/timing must not be exceeded. (Page 4-53)

Now, I was also taught that if you have to perform a teardrop or parallel entry, that completed your reversal and no circuits are necessary:

The holding pattern maneuver is completed when the aircraft is established on the inbound course after executing the appropriate entry. (Ibid.)

Question 1: Was it appropriate for me to attempt to fly the 6NM circuit?

Question 2: Am I allowed to choose an arbitrary leg distance (or time), as long as the 6NM limit is not exceeded?

*I was already switched over to the CTAF, but still monitoring approach control on the second radio which I always do just in case. Something I picked up from my flight instructor who flew larger planes for a living...

up vote 9 down vote accepted

Unless you were "cleared straight-in" for the approach, when IMOMY is your IAF (as it was in this case) you are required to fly the course reversal, even if you can execute a direct entry. This is because the approach does not have terminal arrival areas labeled NoPT. So, yes, it was appropriate to fly the 6nm reversal.

That said, no, you cannot choose a different course reversal, even a shorter distance hold. When a hold is depicted in lieu of a procedure turn (HILO) you are required to fly the hold as shown.

AIM 5-4-6 (4) states:

If proceeding to an IAF with a published course reversal (procedure turn or hold­in­lieu of PT pattern), except when cleared for a straight in approach by ATC, the pilot must execute the procedure turn/hold­in­lieu of PT, and complete the approach. [emphasis mine]

The IFH that you cited in your question has similar wording:

For a hold-in-lieu-of PT, the holding pattern direction must be flown as depicted [emphasis mine]

Occasionally ATC will act surprised or get frustrated with you for flying a reversal when you're within a 90° turn of the initial segment's course, but unless they specify straight in you're doing the right thing.

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