Originally Posted by
rickair7777
Like the other guys said, the technically correct (checkride) answer is to hold at the clearance limit long enough to make your ETA at the airport match what was filed. The generally accepted real-world answer is to get out of the sky.
But if you are doing a checkride with a company (vice FAA) examiner, tell him the textbook answer so he knows that you know it, but then clarify what you would really do.
Well part of the point of this discussion is that I believe it is incorrect to hold unless, as previously stated, you were given an EFC. I understand that it has been taught over the years to "hold if early," but just because that's what CFII's have passed on to their students doesn't necessarily make it correct. (And to be fair, I've had DPE's lack critical knowledge of the PTS requirements on checkrides, so just because a DPE says so, that doesn't make it correct either.)
If you look at the wording of FAR 91.185, it states "commence descent or descent and approach as close as possible to the estimated time of arrival". That does not preclude being early, should that situation occur, it just indicates that the pilot should make a best effort attempt to meet this criterion. (i.e., that could simply mean adjusting speed if it became known that they would arrive significantly early.)
In a radar environment, there are no surprises as to where the aircraft is. The only possible surprise would be an aircraft making a seemingly (to ATC) random orbit somewhere for possibly an unknown amount of turns/time. In a nonradar environment, seperation still needs to be provided, which means I doubt ATC would clear an aircraft who may only be several miles (or minutes) ahead of you unless they were absolutely sure you were not close enough for there to be a loss of seperation. I'd imagine the seperation standards would be such that there is consideration for an aircraft being early to the airport (since, again, 91.185 simply states as close as possible to ETA), thus again holding would not be correct.
If you were making up a hold, would you utilize the MSA to maintain obstruction clearance? No. That doesn't make sense because the altitude rules do not include MSA/TAA depicted altitudes
until an aircraft is utilizing the procedure. In fact, you may be flying at an MEA or assigned altitude that is below the MSA for the procedure you intend to do... would you climb to the MSA for your made-up hold, then come back down to complete the procedure? Or do you stay at the MEA and then risk leaving the 4nm protected area for the airway during your hold? Do you then fly the OROCA for your made-up hold? You can see I'm simply pointing out obvious problems with this train of thought. The common answer does not make sense, in fact, it seems to violate IFR rules.
I'm just looking for a good answer to the "hold when early" answer.