General aviation Flight Instructor and Student Pilot reported ATC instructed them to descend to traffic pattern altitude while the flight was several miles from the airport. Flight crew believed this was an unsafe instruction.
Synopsis
General aviation Flight Instructor and Student Pilot reported ATC instructed them to descend to traffic pattern altitude while the flight was several miles from the airport. Flight crew believed this was an unsafe instruction.
Narrative
Ellington Airport has a 600 feet MSL traffic pattern altitude for light aircraft. This sounds fine and probably is ok as long as the light aircraft are operating in the traffic pattern." EFD is a large field with plenty of space to make an emergency landing. There are multiple flight schools on the field. These flight school operations tend to lack the motivation to fly patterns that allow a margin in the case of an immediate emergency; such as an engine failure. Subsequently it is not uncommon to be very wide abeam the runway or on an extended downwind out over subdivisions full houses and trees or a refinery; at SIX HUNDRED FEET!This came to a head the other day when flying into EFD in a light airplane. Because EFD is under Houston's Class B; their Class D ends at 1600 feet. We were at 1500 when we checked in. Tower responded and instructed us to enter a base for Runway 17R and report two miles; which is standard and expected. Then traffic was pointed out behind us at 1000 feet and ½ mile and we were instructed to descend to 600 feet. Being based at EFD and knowing the local procedures descending to 600 feet was not a surprise but what happened next was. Tower asked us if we were descending. We said we were; albeit slowly because we were over suburbia with nothing but trees and houses below us. Tower then insisted that we get down to 600 feet due to the traffic behind us at 1000. This made no sense to me but more importantly we were at least 5 miles from the field over houses and trees; nowhere near gliding distance to anything and 600 feet was not a safe altitude to be over that kind of terrain. My expectation was to comply by entering the "pattern" at 600 feet on the base turn to 17R as instructed. Tower however seemed to get agitated and again insisted that we descend to 600 feet. At that point I took over the communication and specifically asked Tower why we needed to be that low this far from the airport and the answer again was due to the traffic ½ mile behind us at 1000 feet. I requested the 1000-foot pattern and suggested we make a 360-degree turn and let that traffic pass as we did not want to descend to 600 feet that far from the pattern. Tower then instructed us to maintain a northeast heading; and they would call our turn back to the airport; which we did. When Tower called us back; they once again seemed agitated and lectured us saying we could request the 1000-foot pattern; but they had the right to deny it. I then asked for clearance to land.Please keep in mind that we do training with the members of our organization and we have been based at this airport for years. We strive to keep a good working relationship with everyone but there is no justification for endangering anyone by instructing them to fly 600 feet 5 miles from the airport. Yes; we know the dynamics of all the diverse operations at this airport. I personally am part of that flying not just light airplanes but high performance experimental right here at EFD. As a retired airline pilot; I'm not afraid to speak up with given what I believe is an unsafe instruction from ATC. I believe the assumption was made that we were just another of the flight school airplanes and they typically don't have the experience to push back on an ATC instruction that are unsafe. I'll say it again; 600 feet 5 miles from the field over subdivisions; trees and refineries is UNSAFE. At that altitude a typical GA single has about a minute before it's landing on someone's house.There seemed to be no appreciation for the dangers of being that low that far from the airport. 600 feet over subdivisions and trees to me is a dire situation requiring emergency procedures - CLIMB! If we were on downwind within gliding distance of the runway; a taxiway; or the grass around the airport I'd never said a word. That is the normal procedure at EFD but not 5 miles from the field.I feel sorry for the flight school pilots and anyone who unwittingly follows ATC instructions that puts them into a difficult place to extract themselves if something goes wrong. Those young CFIs don't know any better and the flight schools are just interested in making money so they will do whatever it takes to keep operating. I for one believe someone needs to take an objective look at this situation and do a risk analysis of this 600-foot pattern. As long as it's within the confines of a safe landing from the pattern that's ok but the instant it's not then it's putting the occupants of the aircraft AND people on the ground in peril.I was once in very fast high performance experimental with an approach speed of 100 kt. and instructed to follow four flight school aircraft all probably 30 kt. slower; in a 600-foot pattern that they dragged out until I found myself turning a 5-mile final with nothing under me but oil refineries and I'm at SIX HUNDRED FEET!Can you imagine the headlines if my engine failed there! We're not doing it anymore and someone should look into this before an airplane lands on a house."
Second reporter narrative
Ellington Airport's published traffic pattern for light aircraft is 600 feet msl. It is safe and reasonable to fly a 600-foot pattern at EFD due to the multiple runways and grassy areas available to make an emergency landing. Once outside of the immediate traffic pattern at EFD; the environment outside of the airport makes maintaining 600 feet unsafe.My instructor and I were inbound to EFD in a light airplane from the southeast intending to make a full-stop landing. Because EFD is under Houston's Class B; their Class D ends at 1600 feet. We were at 1500 when we checked in over Kemah. Tower responded and instructed us to enter left base for Runway 17R and report two miles; which is standard and expected. Then traffic was pointed out behind us at 1000 feet and ½-mile and we were instructed to descend to 600 feet. Being based at EFD and knowing the local procedures descending to 600 was not a surprise but what happened next was.Tower asked us if we were descending. We said we were; albeit slowly because we were over suburbia with nothing but trees and houses below us. Tower then insisted that we get down to 600 feet due to the traffic behind us at 1000. This made no sense to us. More importantly; we were at least 5 miles from the field over houses and trees; nowhere near gliding distance to a safe landing spot. 600 feet was not a safe altitude to be over that kind of terrain; endangering both us pilots and people on the ground. Our expectation was to comply by entering the pattern at 600 feet on the base turn to 17R as instructed; because until we entered base; we were not in the pattern. Tower however seemed to get agitated and again insisted that we descend to 600. At that point my instructor took over the communication and specificity asked Tower why we needed to be that low so far from the airport and the answer again was due to the traffic ½-mile behind us at 1000 feet. He requested the 1000-foot pattern and suggested we make a 360-degree turn to let that traffic pass as we did not want to descend to 600 feet that far from the pattern. Tower then instructed us to maintain a northeast heading; and they would call our turn back to the airport; which we complied with. When Tower called us back; they once again seemed agitated and lectured us saying we could request the 1000-foot pattern but they had the right to deny it. My instructor then asked for clearance to land.This incident was an important lesson-learned in my flying career; as this was the first time I felt the need to push back against ATC instructions due to the hazard we would get ourselves in if we complied. I am well aware and directly involved with the diverse aircraft operations that take place at EFD - I understand why the published altitudes are what they are. However; pushing the 600 feet limit for light airplanes outside the immediate traffic pattern is dangerous due to the houses; refineries; etc. around the airport. This is especially true in the case when multiple flight school airplanes are flying wide patterns at this altitude; and when other airplanes are being sequenced in.
Source: NASA Aviation Safety Reporting System (public domain). Reports are voluntary submissions and are not verified by NASA.