Lufty at SFO

[Request Orbit]

Originally Posted by 22/04

I think that is what happens here in the U.K.

Standard phraseology here might be aircraft requests visual approach. Aircraft cleared visual approach and requests cancellation of IFR flight plan. Controller confirms IFR flight plan cancelled at [time}.

The U.S. is very different to most places in the world as I keep saying.

You’re confusing two different things: a visual approach is still an IFR approach in the UK. An IFR approach which requires standard IFR separation. And, even if they did misspeak to begin with before later clarifying, it has been well established within this thread that DLH are not banned from doing visual approaches, it’s the standard controller-provided IFR separation that was the issue, whether they did an ILS or a visual approach. 3nm/1000ft/proper wake gap ahead.

[172_driver]

Another clarification, if you reuest a visual approach and follow traffic you are responsible maintaining visual separation with preceding, in Europe. Common in places like Rhodos.

[Request Orbit]

Haven’t checked the Greek docs, but to supply the UK reference: CAP 493

S3 Ch1 12 (Visual Approach) .3: “Within controlled airspace, standard separation shall be effected between such aircraft and other IFR and/or Special VFR aircraft.”

edit: you (theoretically at least) cannot force an IFR pilot to apply their own separation, but as long as they’re agreeable it is a perfectly valid procedure. In the US AIM it states the pilots responsibility is to inform ATC promptly (and prompt isn’t defined anywhere) if they are unable for any reason to apply visual separation. I’d tend to argue that 14,000ft before you’ve even been asked to apply it is fairly prompt notice.

[PukinDog]

Originally Posted by Request Orbit

From some of the comments in that video they're in the habit of punishing both the aircraft and themselves.

"If they request something else we should accomodate them to the best of our ability, but they may have to take a delay. They view it the same as if you flew in requesting an opposite direction landing in 10 when the active runway is 28". The underlined part is baffling. It's the air traffic equivalent of deciding you need to buy 4 new tyres because your low pressure warning came on for a just single one, which only needed pumping up anyway. Probably not a great like-for-like approximation, but it would be like resorting straight to the total electrical failure checklist because your transponder failed. A runway change is a fairly significant event that will delay multiple aircraft. A single opposite-end arrival will cause huge delays. I'm not sure why they would elect to treat it in that manner. Why make so much more work for yourself?

Another comment made in that video was that the gap behind would "have to be 5-8nm", which is again, utter rubbish. If you're applying wake separation to a light behind it, yeah you'll need 8 miles. But you're delaying it - no-one has said the DLH should have received no delay whatsoever - so why on Earth would you then choose to stick it in ahead of a light?! Secondly, even if that DID apply, as far as I can tell when you use visual separation, wake responsibility also shifts to the pilot? (Not how it would work here, it would be on the controller all the way to touchdown, regardless of the type of approach you fly). As long as the aircraft behind is happy to be visual, all you need is 3nm radar separation for standard separation to be applied to the DLH. Why would you choose to put an 8nm gap behind it? As long as it's a minimum 3nm - which being a heavy doesn't seem too far off - then as long as the aircraft behind is happy to apply visual separation, you aren't actually losing anything behind it.

Honestly, if you were to tell me the SFO perspective video wasn't a controller at all I wouldn't be surprised. The language is odd "They view it as...", why they and not we? The only provenance for it is "a guy I know from Facebook". I still find it hard to believe any practicing radar controller would seriously describe the application of headings and speeds as "adding risk".

According to the video, the notification was made at around 14,000ft, which using the 3nm/1000ft fomula would suggest at least 42nm from touchdown - however close it is to the airport itself as the crow flies. If they're 16nm from touchdown at 14,000ft you really do do some crazy stuff over there. I don't dispute if they've already been on an approach frequency for a while, it would definitely have made more sense to have told them much earlier, but 42nm from touchdown wouldn't seem insanely late to me.

If it's their peak (which again, I don't dispute in the slightest) and aircraft are holding, and you're packing planes into every gap you have, there will be another plane you can fit in with 40nm notice. If you can't, that is some exceptionally inflexible procedure design. Which leads to...

If the sequence is so un-alterable, what happens when there's a go-around? Genuine question, you obviously have experience of being there. What sort of track mileage/delay do you take at SFO before you're fitted back in again? Because all the same techniques used for that are what would be used to re-build the sequence around the DLH.

I believe there's a few significant misconceptions being made about how these particular parallel Charted Visual Procedures are handled at SFO that need clearing up.

First, SFO ATC doesn't pass responsibility for wake avoidance spacing to the pilot with the clearance for the approaches or the "maintain visual separation" instructions. That would be insane, especially if one was taking into account only the aircraft directly ahead and not with regards to the parallel ahead and abeam one's own. Leaving it up to each pilot eyeballing in-trail during the most critical phase (on final) of these extra-close, vertically staggered parallels would result in aircraft splashing in the Bay with great regularity and the objective....keeping the aircraft pairs paired until touchdown to create clean gaps through with to launch departures...would be a mostly-unrealized fantasy or matter of luck rather than what's routinely accomplished.

For example, on the night in question the wind was 290 @12, off 10 degrees right of the inbound course for both runways. The 28L glide path is set lower than the glide path on 28R. Can you imagine some guy in his Gulfstream on 28L closing to 3 miles behind a 737 directly ahead (no problem there) but a few hundred feet off that 737's right wing there's a paired, half-clean LH A350 on a higher glide path laying down some nice, leftward & downward drifting wake vortices for the hapless 28L Gulfstream to fly through? (Enormous problem, if they should be so clueless and blind).

So, rather than leaving it to luck or pilots' varying degrees of depth perception, what actually happens is the same thing as if they weren't conducting closely-spaced Visuals; SFO ATC retains responsibility for spacing by issuing speed assignments after the approach clearance and "maintain" instruction, usually 180 until 5 miles plus, for the aircraft they've positioned slightly behind the other in each pair, to "not overtake" the aircraft it has positioned just slightly ahead on the parallel. The latter instruction holds until it's necessary to stabilize at one's Final Approach speed where, of course, not all aircraft are exactly equal but by that point there's not enough difference to screw up the gaps. It's still Class B airspace, and ATC can and does issue any speed it wants at any time to adjust spacing issues it sees and these must be complied-with throughout the approach unless it's beyond the aircraft's capability.

When sequencing inbounds and during these approaches, SFO ATC provides through vectors and speed control at least the standard Wake Category in-trail spacing. I have no idea where you're coming up with 3 miles. Behind LH's Heavy A350 those minimums are; 4 miles for another Heavy/Super, 5 for a Medium, and 6 for a Light. The vast majority of aircraft using SFO are Mediums and Heavies.

When conducting the simultaneous, parallel Visuals with aircraft in pairs rather than being staggered, because the runways are so closely spaced, ATC applies the most conservative wake avoidance minimum to each pair as if they were 1 aircraft. Examples. (lead pair) M/M...3 miles....M/M (following pair). H/M.....5 mile...M/M. H/M.....5 miles.....H/M, H/M....4 miles....H/H, etc.

Because the required spacing for LH is also a function-of and must be applied-to the diagonal aircraft on the parallel, in order to maintain the side-by-side pairing gaps, the size of the gap required for LH's A350 Heavy to be sequenced into 28L's stream must take into account the S/H/M/L wake cat makeup of 28R's parallel stream. Even for an ILS with no aircraft on a visual beside him. Because LH also needs to be spaced as required in-trail of both aircraft in the pair ahead, the minimum gap ATC would need to create would be 7 miles (M/M...3...LH...4...H/H), 8 miles (M/H....4....LH..4...H/H or M/M...3...LH....5....H/M or M/M), 9 miles (M/H....4.....LH...5....H/M, M/H, M/M), or 10 miles (M/H...4....LH....6....?/L).

Let's assume ATC needed a wake cat-driven, 8 mile gap for LH.

On the night in question, LH was arriving from the NW, not on one of the established streams inbound from the E or SE landing to the west. LH was to be vectored on right downwind and base turns and plugged into an already-established 8 mile gap in 28Rs stream created by ATC for him to do so. Yes, LH crossed BDEGA @ 13K and descending to 11K (mandatory)/250 at CORKK where the downwind turn was to have occurred had he continued to 28R. He would've been about 30 - 35 miles from touchdown at that point, but the stream of aircraft sequenced for 28R extended far beyond that from the direction the vast majority of SFO traffic is arriving from. I've flown the same Arrival into SFO many times trans-Pacific routing using a different transition, but the point LH received the instructions to turn 100 at CORKK is routing common to all arriving from northerly directions.

LH's requirement for the ILS scrubbed the 28R plan and so he wasn't broken off for the downwind north of the airport. He was instead sent over the airport to the south and hold away from everyone and await sequencing into another already-existing stream for 28L where, unlike for 28R, no place at the table had already been set for him. Everyone on 28R is flying the QB Visual, which is offset for noise and is the preferred/expected Approach at SFO when VMC prevails in that East quadrant over the Bay. Also, the reason ATC asked LH if he could "maintain visual separation" even after LH said he needed an ILS was NOT (as explained) to relinquish responsibility for spacing to LH.

The reason was for ATC to know how radically he'd need to alter the spacing/sequence of the stream parallel to LH on final. SFO allows for (at least used to) an aircraft on an ILS to be paired side-by-side with an aircraft on the parallel Visual Procedure as long as both aircraft in the pair confirm the traffic is in sight and will maintain visual separation. This is essentially what an aircraft flying the Tip Toe Visual to 28L does anyway tracking the Loc inbound. LH saying that they could not "maintain vis separation" affects how many and how much the Controller needs to shuffle over on 28R for LH to be able to conduct his ILS on 28L.

LH not accepting the "maintain" instruction means that no aircraft can be paired side-by-side with him. This compounds the problem for ATC on that night because the long, existing streams extending to the E and SE for both Runways were already metered/sequenced/built for pairs of aircraft on the parallel Final Approaches since the Visuals were in use to create the gaps between the pairs for departures. It was peak hours and aircraft were already holding, waiting to be plugged in, and mostly likely were able to accept the "maintain" instruction.

Because no pairing was possible with LH's refusal of the "maintain", in addition to ATC needing to;

1) Create an 8-mile, wake cat-driven gap in 28L's already-existing stream where there was none before.
2) Create another 8-mile, Wake Cat-driven gap in 28R's already-existing stream where there also was none before, that mirrors 28L in order to preserve the gaps between arrival pairings to allow departures.

ATC must also:

3). Somehow, completely eliminate one aircraft from 28R's sequence....the one that would have flown the Visual approach to 28R side-by-side with LH flying his ILS on 28L if LH had been able to accept the "maintain" instruction. If LH could have accepted, ATC could plan for this 6-aircraft pairing and space pattern on final for the parallels (where "B" represents Medium 737s)

B....3 miles....B.......5 miles.........B
B....3 miles....LH.....5 miles.........B

However, since LH couldn't accept, the Controller had to "remove" an aircraft and plan for this 5-aircraft pattern.

B.................8 miles....................B
B....3 miles.....LH.....5 miles.......B

So on a night were they're saturated and with other aircraft already holding before LH arrived, how is that a simple task? One thing for sure, no airlines up there are holding with excessive amounts of fuel above what's required. The fact that LH was long-haul doesn't make him unique in that respect. So when the requirement to "remove" an aircraft from the other runway comes into play it's affecting others in a hold on top of already doing so to create the 2 additional 8-mile gaps to slot him in.

I obviously can't vouch for the video-maker's bona fides as a Controller, but I do know in this thread there's a ton of misconceptions bout how these particular approaches are conducted, what ATC actually does provide during these Approaches, or how easy it would have been to slot LH in on a peak hour night with extended streams and aircraft already in the hold. It's a lot more complicated than just sliding a couple aircraft a couple miles to work him in any place onto 1 runway as if nothing else needs to be taken into account.

[PukinDog]

Originally Posted by Del Prado

Pukindog, some very long posts on here. I’ve just got a couple of questions for you.

One of ATC’s primary roles is to issue accurate onward clearance/approach times or at least an accurate estimate of the delay (and an update to that as soon as possible after it’s changed) in order for pilots to adequately plan fuel.
Do you think SFO fulfilled that duty to DLH?

There are various ATCOs on here adamant that an extra 2/3 miles on the spacing was enough to accommodate DLHs requirements. Why do you think that would cause significant delays and ground stops for aircraft outside the sector? Or is the estimate of 2/3 miles wrong?

Have those ATCOs worked SFO, know the airspace, airports, airspace constraints, noise constraints, the congestion/saturation level of that night? Any other things going on that we don't know about?

How does one fit a Heavy into 2 or 3 miles of extra spacing when there is no space for them in the first place? They were outside the minimally-spaced flow. To plug them in they'd need to create 7-10 miles (depending on relative wake categories) for not 1 but 2 streams, their own and the parallel, plus 1 aircraft abeam on the parallel removed completely from the equation.

Originally Posted by 1201alarm

BS.

LH can operate 24/7, they are in business since many decades, considered one of the safest airlines.

They were on an IFR flightplan to SFO, and they asked for separation by the controller, which is THE fundamental task of the controller.

The controller was unwilling to do that, for whatever reason. That was not good show by the controller.

The reason for these routine Visual Procedures and the reason for the "maintain visual separation" instruction in conjunction with those visual procedures is not a mystery nor a whim of that particular controller. The reason/necessity for it (due to the proximity of the aircraft established abeam on the parallel visua...not for self-positioning or in-trail spacingl) has been explained on this thread numerous times.

Originally Posted by NoelEvans

What a nonsense comment!

Nobody is talking about "requesting an ILS when they've said the VOR is in use".

If an airline files an IFR Flight Plan for a flight, it should remain IFR all the way to landing unless the crew request the cancellation of IFR. If an airport cannot cope with that, that is the airport's problem to sort out, not the airline's. DLH management have not written any "stupid rules for their pilots to follow", they are entirely rational. It is coming across more and more that SFO is a "good weather airport" that does not have the capacity to deal normally with IFR traffic.

When IMC prevails with lots of arrivals, SFO uses Dependent Parallel ILS Approaches with authorisation for a reduced diagonal/adjacent separation of 1.0 mile (instead of 1.5) for the staggering with standard minimums for direct in-trails. Otherwise, depending on the inbounds and outbounds they use other parallel runway modes. In this way, they're pretty much like any other airport with parallel runways close enough to warrant specified minimums for adjacent aircraft on a parallel.

San Francisco isn't a fair weather city, which is why for awhile they had PRM approach capability. PRM allowed side-by-side pairing of aircraft in IMC at airports where the runways are too close to allow Simultaneous Independent parallel approaches. Since it's not functioning now, SFO reverted to Dependent Parallel approaches.

[Request Orbit]

I don’t have time to respond to your entire manifesto right now, but since it starts so glaringly incorrectly…

Originally Posted by PukinDog

I believe there's a few significant misconceptions being made about how these particular parallel Charted Visual Procedures are handled at SFO that need clearing up.

First, SFO ATC doesn't pass responsibility for wake avoidance spacing to the pilot with the clearance for the approaches or the "maintain visual separation" instructions. That would be insane.

I hate to be the one to break this to you… .65 reference

2-1-9 b) “The separation minima must continue to touchdown for all IFR aircraft not making a visual approach or maintaining visual separation.”

Every time you accept a visual approach in the US, you are absolving ATC of responsibility for wake to touchdown, their only responsibility is to say “caution wake turbulence” (see 2-1-20 after), and it’s on you.

What you have described as insane is the responsibility that you yourself have been taking on - albeit unwittingly - every time you accept a visual approach.

edit: 99% sure RECAT wake is in use at SFO. That puts a 3nm wake gap between two “Upper Heavys” and a 4nm for a B737-700+ behind one.

[1201alarm]

Originally Posted by MarcK

Does that include turning on approach aids that may be OTS? I think you are reaching, here.

MarcK, you are riding the wrong horse once more.

Of course you can't ask for something that is out of service. But that was not the case. The ILS was functioning. If it was switched off (which is not the same as out of service), it can be put on air within 2 minutes. A controller has to do that if an aircraft on Mayday asks for it. He can't say I have 10 other aircraft to bring in - these aircraft have to step back, unless one of them is also on Mayday.

Anyways, the discussion of this aspect is also missing the point, since Lufthansa did not ask for an ILS, but asked for separation by the controller. These are two orthogonal issues, separation and type of approach.

Originally Posted by megan

If the captain put himself into a situation where he had to declare a mayday due to fuel he should have his four stripes stripped from his body and sacked.

A bit harsh, we tend not to sack people for mistakes, but of course it would be highly unprofessional. The Lufthansa PIC was obviously a pro so did the right thing in reaction to the bad show of the controller.

Originally Posted by Del Prado

I’ve handled many fuel maydays, double figures in just one incident/closure, none of the captains were demoted or sacked.
What sort of strange blame culture do you operate under?

I think what megan was alluding to was to actively provoke a Mayday to force the unwilling controller to do his job. I agree with that, that would be unprofessional.

It's a complete different thing than running out of fuel due to sudden, unanticipated airport closure, sudden extreme weather changes or just unexpected problems at your alternate you just diverted to. Longtime professionals working at airlines with good safety departments will have read about such incidents. They are rare, but sometimes things just line up in a very bad way that could catch most pros out.

Originally Posted by Check Airman

An airplane on an IFR plan can conduct a visual approach. Do you really think we’re talking about cancelling IFR?

Check Airman, really?

A visual approach and maintaining own visual separation are two orthogonal concepts.

If you are on a visual approach, it is still up to the controller to assure separation in class B airspace.
If that is not the case in the US, I am happy to learn, but please with proper sources and without your usual chest beating.

Originally Posted by Check Airman

Is that what all the angst is about? I suppose all the wailing is starting to make sense now.

In the US, an airplane can fly a visual approach while on an IFR flight plan. There are even cases where you may be required to remain clear of clouds in an IFR flight plan.

Nobody would ever suggest DLH cancelling IFR. A visual approach is just that- navigating primarily by what’s in the window. Normal IFR flight plan.

Lufthansas issue was not the visual approach. It was that the controller wanted to put the responsibility for separation on the crew, which Lufthansa does not allow at night - at least that is what Lufthansa said on the radio.

Originally Posted by 172_driver

Another clarification, if you reuest a visual approach and follow traffic you are responsible maintaining visual separation with preceding, in Europe. Common in places like Rhodos.

Rhodos is not a class B airspace.

Originally Posted by PukinDog

The reason for these routine Visual Procedures and the reason for the "maintain visual separation" instruction in conjunction with those visual procedures is not a mystery nor a whim of that particular controller. The reason/necessity for it (due to the proximity of the aircraft established abeam on the parallel visua...not for self-positioning or in-trail spacingl) has been explained on this thread numerous times.

I am not argueing what SFO controllers try to achieve. Still they had 40 min's to make that gap. They did not, for whatever reason. They did not even give an EAT.

I read with interest what you write, but it does not convince me. I still have the feeling the controller wanted to punish Lufthansa for not playing along as the controller deemed necessary. But that would be overstepping by the controller.

I also do not understand your thing of "own visual separation" still means the controller does assume separation. Obviously something is different compared to a crew not accepting "own visual separation", otherwise Lufthansa would have been in the sequence and we would not be discussing. No need to complicate very basic things, KISS principle applies.

[galaxy flyer]

Originally Posted by 1201alarm

Check Airman, really?

A visual approach and maintaining own visual separation are two orthogonal concepts.

If you are on a visual approach, it is still up to the controller to assure separation in class B airspace.
If that is not the case in the US, I am happy to learn, but please with proper sources and without your usual chest beating.

Nowhere in FAAO 7110.65AA or the AIM is there a restriction prohibiting visual separation, once the pilot accepts. The controller is required to provide IFR separation until the pilot accepts responsibility for separation. Visual approaches are common in Class B airspace at both the primary and non-primary airports. If there were one, they wouldn’t be using visual approaches.

[Mr Albert Ross]

Originally Posted by galaxy flyer

... The controller is required to provide IFR separation until the pilot accepts responsibility for separation. ...

The pilot did not accept responsibility because, in those circumstances (night), his company did not permit him to do so. Therefore it was up to the controller to continue to provide IFR separation.

[WHBM]

Having some familiarity with SFO I find the initial issue somewhat surprising.

Regarding the "close parallel" or "side-by-side" approaches, sure I've seen them, but not that often. A little look at websites since this thread started shows that at any time of the USA day they happen, but are still not that common, maybe just one or two. And when in the usual single approach manner, they still normally use alternate runways for landing.

For those unfamiliar with the SFO runway layout, they have these two closely parallel, broadly east-west runways, commonly used for arrivals, and also two comparably close runways, broadly north-south, commonly used for departures, with the two pairs crossing at their midpoints. The approaches are not often at minimums with the aircraft ahead, because of the need to allow departures to pass between the arrivals. It does seem from observation that departures, lined up, are not given clearance until the landers have passed the intersection (this seems obvious but is relevant to the consideration). Some departures are likewise done "closely parallel", two together, with one slightly trailing the other, and fanning apart immediately after liftoff. So the concept of a constant succession of arrivals at minimum spacing doesn't seem to happen, or even be practical, as nothing could depart.

Maybe I'm missing something.

[galaxy flyer]

Originally Posted by Mr Albert Ross

The pilot did not accept responsibility because, in those circumstances (night), his company did not permit him to do so. Therefore it was up to the controller to continue to provide IFR separation.

As I was addressing how visual separation works in Class B; I am making no reference to the DLH flight. If he was prohibited by company policy not to fly night visuals, then he can’t do so,

[Check Airman]

1201alarm
The following is from section 5-4 of the FAA Airman Information Manual (AIM)

https://www.faa.gov/air_traffic/publ...section_4.html

When operating to parallel runways separated by less than 2,500 feet, ATC will ensure approved separation is provided unless the succeeding aircraft reports sighting the preceding aircraft to the adjacent parallel and visual separation is applied.

Separation Responsibilities. If the pilot has the airport in sight but cannot see the aircraft to be followed, ATC may clear the aircraft for a visual approach; however, ATC retains both separation and wake vortex separation responsibility. When visually following a preceding aircraft, acceptance of the visual approach clearance constitutes acceptance of pilot responsibility for maintaining a safe approach interval and adequate wake turbulence separation.

(As an aside, you can also be cleared for a visual approach with only the preceding aircraft, but not the airport in sight.)

For the people who insist that an IFR aircraft should always be afforded an IAP, please note what I've highlighted in bold.

When landing at airports with approach control services and where two or more IAPs are published, pilots will be provided in advance of their arrival with the type of approach to expect or that they may be vectored for a visual approach. This information will be broadcast either by a controller or on ATIS.

[Request Orbit]

Check Airman

For balance it seems worth adding the next paragraph as well (5-4-4b):

“The purpose of this information is to aid the pilot in planning arrival actions; however, it is not an ATC clearance or commitment and is subject to change. Pilots should bear in mind that fluctuating weather, shifting winds, blocked runway, etc., are conditions which may result in changes to approach information previously received. It is important that pilots advise ATC immediately they are unable to execute the approach ATC advised will be used, or if they prefer another type of approach.”

I also thank you for including the AIM reference to pilot wake responsibility on a visual. While we disagree, I respect that you at least know what you’re talking about. On which note…

“ATC doesn't pass responsibility for wake avoidance spacing to the pilot with the clearance for the approaches or the "maintain visual separation" instructions. That would be insane, especially if one was taking into account only the aircraft directly ahead and not with regards to the parallel ahead and abeam one's own. Leaving it up to each pilot eyeballing in-trail during the most critical phase (on final) of these extra-close, vertically staggered parallels would result in aircraft splashing in the Bay with great regularity and the objective....keeping the aircraft pairs paired until touchdown to create clean gaps through with to launch departures...would be a mostly-unrealized fantasy or matter of luck rather than what's routinely accomplished.”

That’s a statement by a pilot with an ATPL (apparently). Is that the level of understanding you’d expect to come across on a line check? Not trying to be snarky, but I’ve no idea if it’s common knowledge among pilots or not.

[1201alarm]

Thanks, Check Airman. This confirms my understanding.

"Own visual separation" is an add-on to a visual approach. A crew can't be expected to accept "own visual separation", so the controller needs to continue providing separation, even on a visual approach.

[172_driver]

This has become a contest about who is right so my contribution as follows ;
PANS-ATM section 6.5.3. A framework for air traffic management procedures, which I pressume may be applied somewhat differently across the world:

[172_driver]

Rhodos is not a class B airspace.

Rhodos is class D, IFR is separated from IFR, no different from class B. If you get cleared for a visual approach the maneuvering is up to the pilot. Don't request it unless you can see and follow preceding traffic. Never have I been pushed into a visual approach in Europe (many airports prohibit them due noise).

[Request Orbit]

6.5.3.1: the crew has to agree to it

6.5.3.4: as in class B, visual approach means ATC responsible for separation, which is where visual separation comes in - entirely separate to the visual approach itself

6.5.3.5: … however pilot takes responsibility for wake separation regardless, if additional spacing required, pilot to tell ATC

That is all consistent with what is published in the .65 and the AIM. There’s nothing in the published AIP that seems to contradict it.

[Del Prado]

PukinDog, thanks for your response.

You reference minimum separation/wake spacing but SFO don’t operate to minimum spacing, they provide gaps for departures from the crossing runways. Look at the landing rate, it’s 30 per hour which equates to about 5.5 mile average spacing.
A gap of 8/9/10 miles would easily accommodate 3 mile separation for the DLH (although you’d only need a 6 mile gap). All they had to do was add 3-5 miles to an existing gap.

SFO had 40 minutes to organise an extra 3-5 miles.

[PukinDog]

Originally Posted by Request Orbit

I don’t have time to respond to your entire manifesto right now, but since it starts so glaringly incorrectly…



I hate to be the one to break this to you… .65 reference

2-1-9 b) “The separation minima must continue to touchdown for all IFR aircraft not making a visual approach or maintaining visual separation.”

Every time you accept a visual approach in the US, you are absolving ATC of responsibility for wake to touchdown, their only responsibility is to say “caution wake turbulence” (see 2-1-20 after), and it’s on you.

What you have described as insane is the responsibility that you yourself have been taking on - albeit unwittingly - every time you accept a visual approach.

edit: 99% sure RECAT wake is in use at SFO. That puts a 3nm wake gap between two “Upper Heavys” and a 4nm for a B737-700+ behind one.

I'm well-aware of who has responsibility for what when accepting a Visual Approach and what my own is under FAA rules. Instrument flying 101. Thanks though , I've been aware of them for about 40 years or so. Not sure if this this is your first foray into them because...,

I hate to break it to you, but I'm not incorrect, let alone glaringly, because (from your own source) https://www.faa.gov/air_traffic/publ...section_7.html.

The generic Visual approach rule you referenced assumes the Visual approach clearance is received with no accompanying or further speed restriction issued by ATC. Speed-control restrictions are, as already mentioned, commonly re-stated/issued at SFO at the time Clearance for these 28 Visuals are issued. This restatement of a restriction is no different than for any Instrument approach when ATC desires or needs to retain positive control of spacing since issuance of any approach Clearance, Instrument or Visual, automatically cancels any previously assigned speed restriction.

Ignoring the effect that restating the speed restriction has on the Visual approach clearance when issued is not unlike ignoring that there is such a thing as a conditional clearance. For the purpose of clearing up your misunderstanding, it's not an unimportant detail.

Because details matter, ATC can and does restate/issue a speed assignment with the Visual approach clearance and it essentially becomes part of that Visual approach clearance, so the generic rule you reference does not invalidate the restated/issued speed restriction (as it does a previously-assigned one). And, for the same reason ATC restates a speed restriction for an Instrument approach Clearance when they want to retain positive control for spacing, ATC does the same when issuing a Visual approach clearance; to retain positive control of spacing.

The only difference between a Visual and Instrument approach as far as Speed control and wake is what happens within 5 miles of the runway. But the subject is creating space to plug LH into the stream and the gap ATC needs to create for wake, not something that happens within 5 miles on any approach.

But, since you keep making your assumptions and hate my Manifestos, I'll assume you enjoy your own sources, so here's an excerpt from yours in the link above. Note, especially, points #9 and #10..

Section 7. Speed Adjustment

1. APPLICATION

Keep speed adjustments to the minimum necessary to achieve or maintain required or desired spacing. Avoid adjustments requiring alternate decreases and increases. Terminate speed adjustments when no longer needed.

1. Compensate for compression when assigning air speed adjustment in an in‐trail situation by using one of the following techniques:

1. Reduce the trailing aircraft first.
2. Increase the leading aircraft first.

1. Assign a specific airspeed if required to maintain spacing.
3. Do not assign speed adjustment to aircraft:
4. At or above FL 390 without pilot consent.
5. Executing a published high altitude instrument approach procedure.
6. In a holding pattern.
8. Inside the final approach fix on final or a point 5 miles from the runway, whichever is closer to the runway.
9. At the time approach clearance or a climb via/descend via clearance is issued, previously assigned speeds must be restated if required.
10. Approach clearances or climb via/descend via clearances cancel any previously assigned speeds. Pilots are expected to make their own speed adjustments to fly the approach, SID, or STAR unless assigned speeds are restated.

So yes, ATC does require one to fly a speed so restates the restriction when issuing the Clearance in order to retain positive control for required or desired spacing. SFO does it, as per the reasons in bold, and they are not alone in doing so. They also restate speed restrictions during Visual approaches at JFK, DCA, LGA...pretty much anywhere Charted Visual approaches are conducted and for the same reason. This shouldn't come as a shock to anyone except those who refuse to believe it's not a highly unsafe, free-for-all up there with pilots jockeying for position all over the sky just because "Visual" appeared in the Approach Procedure. No, it's pretty organised, controlled, and happens hundreds of time every day where Charted Visual Procedure are in use.

On the issue of "maintain visual separation" again, excerpts from your source... https://www.faa.gov/air_traffic/publ...section_4.html

The "maintain visual separation" instruction for pilot-applied visual separation is necessary if ATC wants to have aircraft positioned 750' apart side-by-side in pairs tracking the charted Visual inbound courses. While tracking those Visual inbound courses the aircraft targets on Controller's display with touch/merge, so pilot-applied visual separation becomes necessary in order to conduct them in that manner.

If ATC decides to alternately stagger aircraft with sufficient in-trail spacing during the Visuals (which does happen during off-peak hours), there is no need for the pilots to accept and confirm they will "maintain visual separation" when positive speed control is retained and ATC provides the approved separation.

The "maintain visual separation" instruction has nothing to do with the pilot jockeying his own speed to manage the in-trail spacing between himself and the aircraft miles ahead already spaced for wake turbulence by ATC. The Controller, by restating a speed restriction issued in conjunction with the Visual Clearance, is already providing-for and maintaining the wake turbulence spacing under positive control for as long as the positive speed control is valid, That's how they do it at SFO during the paired Visuals. Please don't keep repeating how something theoretically works, or can't work, until you've done sone ride-alongs in the cockpit to see how they work the Procedures.

What ATC is unable to do is see or provide for is lateral separation between the closely-spaced (750') paired aircraft, abeam each other with a slight stagger. If pilots are flying the Charted Visuals correctly, established on the inbound courses, the lateral separation will be there because that's how the Visuals are constructed. One is straight in, the other is Offset. The pilot only need to visually ensure and maintain the separation that flying to procedure establishes. Again, nobody has gets a clearance to eyeball and fly formation with anyone. The clearance is to fly a Charted Visual Procedure that has electronic lateral guidance and fly them at the ATC-assigned speeds until within 5 miles.

The excerpt directs a Controller "Do not permit an aircraft to overtake another aircraft when wake turbulence separation is required". The Controller can only prevent what he/she can clearly determine on the display, and the only way to prevent an aircraft from overtaking is through speed control. The Controller can see and prevent this for the pairs in-trail of other pairs, but the controller cannot see that the slight stagger between the aircraft that make up each pair, where pilot applied visual separation is, is being maintained. If a high-side aircraft in a pair overtakes the other and pulls ahead far enough, wake can become an issue. Therefore, the instruction.

7-4-4

1. APPROACHES TO MULTIPLE RUNWAYS

1. All aircraft must be informed that approaches are being conducted to parallel, intersecting, or converging runways. This may be accomplished through use of the ATIS.
2. When conducting visual approaches to multiple runways ensure the following:

1. Do not permit the respective aircrafts' primary radar targets/fusion target symbols to touch unless visual separation is being applied.
2. When the aircraft flight paths intersect, ensure approved separation is maintained until visual separation is applied.

1. The following conditions apply to visual approaches being conducted simultaneously to parallel, intersecting, and converging runways, as appropriate:

1. Parallel runways separated by less than 2,500 feet. Unless approved separation is provided,an aircraft must report sighting a preceding aircraft making an approach (instrument or visual) to the adjacent parallel runway. When an aircraft reports another aircraft in sight on the adjacent extended runway centerline and visual separation is applied, controllers must advise the succeeding aircraft to maintain visual separation. Do not permit an aircraft to overtake another aircraft when wake turbulence separation is required.

7-4-5

1. CHARTED VISUAL FLIGHT PROCEDURES (CVFP)

Clear an aircraft for a CVFP only when the following conditions are met:

1. There is an operating control tower.
2. The published name of the CVFP and the landing runway are specified in the approach clearance, the reported ceiling at the airport of intended landing is at least 500 feet above the MVA/MIA, and the visibility is 3 miles or more, unless higher minimums are published for the particular CVFP.
3. When using parallel or intersecting/converging runways, the criteria specified in paragraph 7-4-4, Approaches to Multiple Runways, are applied.
4. An aircraft not following another aircraft on the approach reports sighting a charted visual landmark, or reports sighting a preceding aircraft landing on the same runway and has been instructed to follow that aircraft.

[PukinDog]

Originally Posted by Request Orbit

Check Airman


That’s a statement by a pilot with an ATPL (apparently). Is that the level of understanding you’d expect to come across on a line check? Not trying to be snarky, but I’ve no idea if it’s common knowledge among pilots or not.

Since this was directed at me and of course not trying to be snarky, I'd expect a Controller (apparently) to know what restating a speed restriction/assignment when issuing an Approach clearance does for the Controller, and why it must be restated. Or do you believe that restating/issuing a speed restriction is not authorized if the approach happens to be a Visual? If it isn't, how come I've frequently received them? Is it because the Controllers also don't know their own rules?

All these years I thought when Controllers did that it was so they could retain control over my speed while on the approach after the Clearance already automatically cancelled whatever restriction I'd been assigned before. Retain control so Controllers could ensure I'd maintain any separation they'd established for me, or establish it if it wasn't yet, or adjust my speed to tweak spacing, that sort of thing. All those years I'd been following those restated speed restrictions on Visual approaches when, apparently, I could've just ignored them and self-positioned to my heart's content as if they'd never happened..

So next time I'm line checking someone and receive a Visual Approach clearance with a restated speed restriction and we're, say 10 miles in-trail of someone, if the pilot maintains or slows to the restriction I'll tell him "No No, speed at your discretion. You're cleared for the Visual so just haul ass until 3 miles in-trail. A UK Controller educated me on the the FAA rules re Visual Approaches, and we've been doing it wrong".