APCH CTLR COMPLAINT ABOUT A MEMO FROM THE AIRSPACE AND PROCS OFFICE OF THE TRACON SPECIFYING ALTERNATE CLBOUT PROC WHEN DPK VOR IS OTS.

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TODAY I WAS INFORMED OF A MEMO DATED SEP/XA/97 FROM THE AIRSPACE AND PROCS OFFICE OF THE NY TRACON; SUBJECT: CLBOUT INSTRUCTIONS FOR ILS RWY 4R (JFK). THIS MEMO STATES: DURING OUTAGES OF THE DPK VOR THE FOLLOWING CLBOUT INSTRUCTIONS MAY BE ISSUED BY APCH CTL WHEN USING THE ILS RWY 4R/CAT II/CAT III. 'CLB TO 500 FT THEN CLBING R TURN TO 4000 FT VIA HDG 100 DEGS AND JFK R078 TO 23 DME AND HOLD. HOLD NE ON JFK 078 DEG RADIAL 23 DME; L TURNS.' TO SAY THAT SUCH INSTRUCTIONS; WHICH WOULD HAVE TO BE ISSUED TO EACH AND EVERY ACFT PRIOR TO ISSUING THE ILS RWY 4R APCH CLRNC ARE INANE WOULD BE GENEROUS. THE JFK INTL ARPT IS THE PREMIER INTL ARPT IN THE UNITED STATES EASTERN REGION; HANDLING OVER 1000 ACFT MOVEMENTS DAILY. THE ILS RWY 4R CAT II/CAT III APCH IS USED PRIMARILY DURING PERIODS OF POOR WX. TO EXPECT FLCS TO COPY DOWN THESE 'CLBOUT INSTRUCTIONS' (WHICH; FOR MODERN FMS EQUIPPED ACFT; WOULD HAVE TO THEN BE PROGRAMMED INTO THE FMC) AS THEY ARE VERBALLY ISSUED; WHILE THE ACFT IS BEING VECTORED FOR THE APCH AND THE FLC IS ALSO TRYING TO COMPLETE THEIR REQUIRED PRE LNDG CHKLISTS; IS QUITE OBVIOUSLY LUDICROUS. THE FREQ CONGESTION ALONE COULD CAUSE SUCH MASSIVE DELAYS THAT IT COULD IMPACT THE ENTIRE UNITED STATES NORTHEASTERN SEABOARD. THE FACT THAT THE MEMO IS NOT REGULATORY IN NATURE; THAT THE TERM 'CLBOUT INSTRUCTIONS' IS USED IN LIEU OF 'ALTERNATE MISSED APCH INSTRUCTIONS' (WHICH ARE WHAT IS CLRLY REQUIRED IN THIS CASE); AND THAT THE MEMO CONTAINS SUCH PHRASES AS '...MAY BE ISSUED...;' DOES LITTLE TO MAKE SUCH GUIDANCE LESS UNSATISFACTORY. FURTHER; THESE 'CLBOUT INSTRUCTIONS' MAY NOT BE IN ACCORDANCE WITH FAA ORDER 8260.3B; THE UNITED STATES STANDARD FOR TERPS; FAA ORDER 8260.40A 'FMS INST PROCS DEVELOPMENT;' ADVISORY CIRCULAR 120-29; 'CRITERIA FOR APPROVING CAT I AND CAT II LNDG MINIMA FOR FAR 121 OPERATORS;' ADVISORY CIRCULAR 120-28C; 'CRITERIA FOR APPROVAL OF CAT III LNDG WX MINIMA;' OR EVEN FAR PART 97. AN INST APCH PROC ASSURES FULL VERT AND LATERAL OBSTACLE CLRNC WHEN FLOWN IN ITS ENTIRETY. ATC HAS NO AUTH TO MODIFY OR DELETE ANY SEGMENT OF AN INST APCH PROC WITH 1 EXCEPTION: APPROPRIATE RADAR VECTORS TO A SEGMENT OF THE INST APCH PROC OR ARR RTE. AS A PROPOSED SOLUTION; I SUBMIT THAT STANDARDIZED ALTERNATE MISSED APCH INSTRUCTIONS IN ACCORDANCE WITH TERPS BE ISSUED FOR THE JFK ILS RWY 4R CAT II/CAT III IAP.