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Removal of ATP VMC Circle Limitation

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Old 12-01-2022, 05:24 PM
  #11  
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Originally Posted by QRH Bingo View Post
Alrighty, this is going down a rabbit hole and I'm sorry. For clarification, I am speaking about the ATP certificate (and privileges), not my first type. The first type has not changed.
As Rickair7777 stated, the maneuver was not performed on the ATP ride itself so therefore, not included. And that makes sense.

Where this became a question and made me start asking around, is when two separate individuals I spoke to had different thoughts to this. One of them, who is an APD, believes that if the circling maneuver was already demonstrated on a previous type, it should count as demonstrated for the new ATP cert. The other instance is what I stated in the OP.

I called Airmen Certification and one of the options from the phone tree was "speak to a DPE" so that seemed like the logical selection to me.

At this point, I am just going to let the paperwork work its way through the system and see what comes on the permanent cert and I thank you all for your input.



Splitting hairs here I guess since circling approaches usually have ceilings less than 1,000' and/or visibility requirements less than 3sm which would make it IFR conditions over the field. Therefore, not VFR weather. But yes, it is an instrument approach combined with a visual maneuver to a different runway.
The limitation says VMC not VFR. Those are not the same things.
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Old 12-01-2022, 05:48 PM
  #12  
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Originally Posted by Myfingershurt View Post
The limitation says VMC not VFR. Those are not the same things.
If it is not legal to be VFR (i.e. vis and cloud clearance requirements) then you are in IMC.
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Old 12-01-2022, 06:18 PM
  #13  
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Originally Posted by flydrive View Post
If it is not legal to be VFR (i.e. vis and cloud clearance requirements) then you are in IMC.
Wrong. Thanks for playing. You don’t have to have the same cloud clearances and vis to be vmc. Just have to have adequate visual references. And technically if you’re shooting an approach in IMC you better be on and IFR clearance. VFR is regulations. VMC shut means you can see things outside to fly the plane by. You can very much be in vmc on an IFR flight plan and only be 50 ft below the clouds.
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Old 12-01-2022, 06:31 PM
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Originally Posted by Myfingershurt View Post
Wrong. Thanks for playing. You don’t have to have the same cloud clearances and vis to be vmc. Just have to have adequate visual references. And technically if you’re shooting an approach in IMC you better be on and IFR clearance. VFR is regulations. VMC shut means you can see things outside to fly the plane by. You can very much be in vmc on an IFR flight plan and only be 50 ft below the clouds.
"Visual Meteorological Conditions (VMC). Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling meeting or exceeding the minimums specified for VFR."

Straight out of the Instrument Flying Handbook Glossary. Thanks for playing.
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Old 12-01-2022, 06:38 PM
  #15  
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Originally Posted by flydrive View Post
"Visual Meteorological Conditions (VMC). Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling meeting or exceeding the minimums specified for VFR."

Straight out of the Instrument Flying Handbook Glossary. Thanks for playing.
For the purposes of shooting a circling approach those do not apply. Many circling approaches have ceiling minimums that don’t allow you to maintain VFR but you can continue the approach in VMC.
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Old 12-01-2022, 10:15 PM
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Originally Posted by flydrive View Post
We are in agreement. My only addition to your analysis is that a circling limitation on an ATP rating and a circling limitation on a type rating are two different things. In OP's scenario, a circling limitation on the ATP certificate (ATP CIRC. APCH. - VMC ONLY) is appropriate, but a circling limitation on the pre-existing type rating is not. My next question would be if OP is certain that the circling limitation has actually been placed on his pre-existing type rating. What does the back of his certificate actually say?
There's no such thing as an "ATP rating."

The FAA issues a pilot certificate, and it may be issued at various levels: student, recreational, sport, private, commercial, ATP. The circling limitation is not found on the ATP certificate. It's applicable to a type rating. The ATP pilot certificate does not have a circling limitation. A restricted ATP may be issued, annotated with the statement that the bearer does not meet the pilot in command aeronautical experience requirements of ICAO, but there is no provision to issue a circling limitation on the ATP certificate. A circling limitation is applicable to a type rating, not to a pilot certificate issued at the ATP level.

You can verify this by reviewing the FSIMS on the DRS as noted before, in this case 8900.1 Chg451, Volume 5, Section 18, Conduct an Airline Transport Pilot Certification, Including Additional Category/Class Ratings: https://drs.faa.gov/browse/excelExte...40068A05A.0001

You'll note that there is no provision for adding a circling limitation to the ATP. That only applies to type ratings that may be placed on the ATP certificate.

Originally Posted by QRH Bingo View Post
Splitting hairs here I guess since circling approaches usually have ceilings less than 1,000' and/or visibility requirements less than 3sm which would make it IFR conditions over the field. Therefore, not VFR weather. But yes, it is an instrument approach combined with a visual maneuver to a different runway.
Well, no.

Circling approaches are for approaches not aligned with the landing runway; a turn in excess of 30 degrees to line up with the runway, or in other words, when the approach is not a "straight in," will have circling minima prescribed. It is, therefore, not necessarily to a "different runway," but may often be to the same runway designated for an appproach. It's not uncommon for Part 121 operators to have operational limitations that are well above procedural minimums; a circle is an instrument maneuver. It is simply the portion of the approach used to line up with the runway at minimums, when the landing environment is in sight. I have worked for several operators that limited circling to 1000/3 or better.

A visual approach, including other than straight-in, does not terminate in a published missed approach, whereas an instrument approach with a circle to land does include the published missed approach procedure, because the circle is part of an instrument procedure.

Last edited by JohnBurke; 12-01-2022 at 10:25 PM.
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Old 12-02-2022, 06:10 AM
  #17  
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Originally Posted by Myfingershurt View Post
For the purposes of shooting a circling approach those do not apply. Many circling approaches have ceiling minimums that don’t allow you to maintain VFR but you can continue the approach in VMC.
Yes they do. The definition flydrive gives is also in the Pilot/Controller Glossary. VMC and IMC have nothing to do with how you navigate the aircraft, they are categories of weather. If you are making a circling approach you are looking out the window to navigate the aircraft but still on an IFR flight plan. If you’re not doing an auto land you look out the window to flare. Are you saying RVR 2000 is VMC in that case?
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Old 12-02-2022, 06:16 AM
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Originally Posted by JohnBurke View Post
The ATP pilot certificate does not have a circling limitation. A restricted ATP may be issued, annotated with the statement that the bearer does not meet the pilot in command aeronautical experience requirements of ICAO, but there is no provision to issue a circling limitation on the ATP certificate. A circling limitation is applicable to a type rating, not to a pilot certificate issued at the ATP level.
From ATP/Type Rating ACS (FAA-S-ACS-11), Appendix 5:
Circle-to-Land Limitation on an ATP Certificate or Type Rating

A pilot may receive a circle-to-land limitation through an approved air carrier training and checking program restricting a circling approach in the specified airplane type to visual meteorological conditions (VMC) only. An example of the certificate notation would be: “CL-65 CIRC APCH VMC ONLY.” This restriction may be removed when the applicant receives training in the circling maneuver in the same type of airplane for which he or she has the limitation and satisfactorily demonstrates a circling approach and landing in that same airplane type with an appropriately qualified evaluator.

If as part of the approved air carrier training and checking program a pilot’s initial ATP certificate is issued concurrently with an airplane type rating and the circling maneuver is not checked, the ATP certificate would also have a circling limitation. For example, the certificate notation would be: “ATP CIRC APCH VMC ONLY, CL-65 CIRC APCH VMC ONLY.” This restriction may be removed from the ATP certificate upon completion of an evaluation of the circling maneuver tasks in an airplane representative of the class held on the applicant’s ATP certificate. The airplane used does not have to be type-specific, but should reflect a class of airplane for which the pilot has ATP privileges. Depending upon the airplane used, training may be required. The applicant must satisfactorily demonstrate a circling approach and landing to an appropriately qualified evaluator. However, if a CL-65 was not used for the circling evaluation, the limitation would be removed from the ATP certificate only and would remain for the CL-65 type rating. Removal of that limitation would require demonstration of the circling maneuver in type as described in the previous paragraph.
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Old 12-02-2022, 07:06 AM
  #19  
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Originally Posted by JohnBurke View Post
The ATP pilot certificate does not have a circling limitation.
My ATP most certainly does, you had me questioning if I knew what was on my own pilot cert so I got it out to check.

I'm looking right at it:

Lims:
English Prof.
ATP CIRC. APPCH. - VMV ONLY.

Then it lists my types, also with the VMC restriction.
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Old 12-02-2022, 07:11 AM
  #20  
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Originally Posted by flydrive View Post
From ATP/Type Rating ACS (FAA-S-ACS-11), Appendix 5:
As stated above by Flydrive, straight off the temporary certificate: “ATP CIRC. APCH. - VMC ONLY; ERJ-170; ERJ-190 CIRC. APCH. - VMC ONLY”. The limitations are independent of each other.
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