5
$\begingroup$

This is the VOR-A approach into KVCB:

enter image description here

The plate indicates that "Circling NA west of Rwy 2-20." But runway 2 is left traffic and runway 20 is right traffic. How is one meant to avoid the area west of 2-20 to adhere to the requirements of the plate without busting 91.126 by making turns opposite the direction of traffic?

$\endgroup$
10
  • $\begingroup$ When would you be making turns opposite the direction of traffic? $\endgroup$ May 30, 2023 at 1:11
  • 1
    $\begingroup$ @MichaelHall Right base for runway 20 and left base for runway 2 are both west of the runway, right? Maybe I'm missing something stupid. $\endgroup$
    – Chris
    May 30, 2023 at 1:15
  • $\begingroup$ Think IFR vs VFR… $\endgroup$ May 30, 2023 at 1:19
  • 2
    $\begingroup$ @MichaelHall The FAA has released several interpretations that traffic pattern directions apply to IFR circling approaches: Murphy, Collins, ... $\endgroup$
    – Chris
    May 30, 2023 at 1:31
  • 2
    $\begingroup$ Michael Hall is correct, but I think this could use some clarity. None of the turn requirements of this section (91.126) are applicable because the approach plate “requires” that a pilot not comply. The light signals or visual markings are not relevant. In other words, following a Part 97 procedure cannot cause you to violate a Part 91 requirement. $\endgroup$
    – Timbo
    May 30, 2023 at 3:45

2 Answers 2

5
$\begingroup$

IFR flying can be quite dangerous, particularly when transitioning from the airport to the enroute structure and vice-versa. This "answer" should be taken as a discussion more than a definitive statement. See also this previous discussion: Why is the VFR traffic pattern area at some airports different from its IFR circling approach area?


Per the sectional (and AFD), Runway 20 is right traffic while Runway 2 is left traffic. Thus VFR pilots operating at VCB are restricted to remain west of the airport no matter which runway they are using. The AFD further states:

No turns to crosswind below 800' MSL, remain west of interstate highway for Rwy 20, noise sensitive area west of arpt.

That noise-sensitive area appears to be the communities of Ridgeview and Browns Valley, and seems to present something of a contradiction. If there are noise-sensitive areas to the west of the airport, why should pilots be restricted to remain west? There must be a compelling reason.

As an educated guess only, that compelling reason may be Travis Air Force Base and its associated Alert Area 682. Note how close VCB is to the Travis Class D airspace: an east-of-the-airport pattern would put a VFR pilot uncomfortably close to if not solidly within the surface area, depending on the size of the pattern they flew. And note how the edge of A-682 nearly lies on top of Runway 2–20 at VCB: an east-of-the-airport pattern would be almost entirely within the alert area. Sure, it's not super likely that military trainers would be flying around right on top of another airport's traffic pattern... but if you have the chance to avoid the possiblity altogether, why not do it?

For IFR traffic, however, the calculus changes. An IFR aircraft operating in controlled airspace must be in contact with and under the control of an ATC facility—in this case Travis Approach, who is probably also talking to any military aircraft flying around in the alert area. So the question of violating the Class D is alleviated; I strongly suspect that Travis Approach has to coordinate with Travis Tower prior to clearing an aircraft for the VOR-A at VCB, and furthermore that when an aircraft has been cleared for the approach IFR traffic off of Travis is prevented from turning north- and west-bound.

Even more importantly, look at the sectional and the approach plate. Observe the rising terrain which comes to a peak only seven NM west of VCB at 2800' above field elevation; observe the obstruction only a couple of miles west of VCB at 700' above field elevation. A VFR pilot operating in the traffic pattern can easily see and avoid these obstacles. An IFR pilot executing a circling approach—with the possibility of going IMC and having to execute a missed approach—is in a much more dangerous situation.


Now for the legal aspect: in the Krug interpretation which you linked, regarding a pilot's desire to fly a circling approach contrary to the established pattern direction, the Office of the Chief Counsel said:

ATC may not issue clearance to conduct a right-hand turn at an airport without an operating control tower in Class G airspace. The Collins Interpretation notes that the circumstances under which a deviation from the left-hand turn requirement in § 91.126(b)(1) is "authorized or required" are very limited. Specifically, a deviation must be "authorized or required" by approach guidelines to a specific airport or by another FAA regulation.

(Note that ATC is not only prohibited from issuing circling instructions at Class G airports; they are prohibited from issuing circling instructions at all non-towered airports. This is not to say that pilots are prohibited from electing to circle, or not, on their own accord and to the runway of their choosing. Obviously in the case of a circling-only approach they must circle!)

To my reading of the letter, the approach plate restriction "Circling NA west of Rwy 2–20" is in fact a "requirement by approach guidelines" which supersedes not only the default left-pattern requirement for Runway 2 but also the specifically-published right-pattern requirement for Runway 20.

$\endgroup$
2
$\begingroup$

CFR 91.126 is a general rule that establishes the default of left turns in the VFR traffic pattern, unless right turns are specified. It is intended to provide safety and consistency in the flow of VFR traffic at non-towered airfields.

IFR Traffic should generally match the flow of VFR traffic when circling, but when you are operating on an IFR clearance you are expected to fly procedures as they are published. If you have been cleared for an instrument approach that contains a requirement to execute a specific circling procedure different than the VFR pattern, then that is what you are expected to fly. There is no conflict with the CFRs because you are operating under Instrument Flight Rules, which take precedence.

FAA Advisory Circular AC90-66 confirms this:

8.2.1: The FAA does not regulate traffic pattern entry, only traffic pattern flow. For example, an aircraft on an instrument approach flying on the final approach course to land would follow the requirements dictated by the approach procedure.

9.6: Pilots are reminded that circling approaches must comply with § 91.126(b) unless the approach procedure explicitly states otherwise.

How is it meant to be flown then if you cannot circle to the West? In this particular case I would enter a left base for RW 20, or a right downwind for RW 2.

Additional information can be found here: IFR Magazine Article

$\endgroup$
6
  • $\begingroup$ I'm convinced by @randomhead's argument that the requirements of this specific approach plate supersede 91.126, but saying 91.126 doesn't apply at all to IFR operations seems suspect. What do you think about the interpretations I posted in comments on the OP? $\endgroup$
    – Chris
    May 30, 2023 at 16:14
  • $\begingroup$ KVCB is a non-towered class G airport, if that changes anything. $\endgroup$
    – Chris
    May 30, 2023 at 16:15
  • $\begingroup$ @757toga, skimming again, but 8.2.1 positively leapt off the page at me: "The FAA does not regulate traffic pattern entry, only traffic pattern flow. For example, an aircraft on an instrument approach flying on the final approach course to land would follow the requirements dictated by the approach procedure." This is the entire gist of my answer, distilled right there, by the FAA. $\endgroup$ May 30, 2023 at 16:56
  • $\begingroup$ ... AND, 9.6 further backs my point! "Pilots are reminded that circling approaches must comply with § 91.126(b) unless the approach procedure explicitly states otherwise." I will admit that my answer can be improved by referencing these, and I thank you for that, but nobody I know carries a binder of Advisory Circulars for reference airborne. Fly what the plate says to do. $\endgroup$ May 30, 2023 at 17:05
  • $\begingroup$ Let us continue this discussion in chat. $\endgroup$ May 31, 2023 at 16:28

You must log in to answer this question.

Not the answer you're looking for? Browse other questions tagged .