Narrative:

While conducting instrument flight training under IFR flight plan, during daytime and clear VFR WX. At opf the common procedure is to report moltz intersection 5.4 NM from threshold at 1815' after beginning descent on G/south. Approach cleared us for the approach and assigned an intercept within 30 degrees approximately 2 mi outside the approach gate, which I would estimate as being approximately 3 NM from moltz intersection. More than normal amount of time was taken to contact opf tower as I allowed the student to get established and stabilized on localizer, perform before landing checks and change radio frequency to tower. Descent on G/south was begun before contacting the tower. I heard only one other aircraft in contact with tower and the airport was not congested. Had the descent continued further I would have advised tower of our location, however student did contact tower at approximately 1600-1700' once stabilized on approach. Tower advised us we were 1 mi inside moltz intersection and that we were to contact prior to reaching moltz and entering the air traffic area. Tower used radar equipment to locate us at 1 mi inside moltz and I would estimate approximately the same. The tower implied we had entered the air traffic area west/O establishing communications. While I am aware this is required to be done, I believe sometimes flight training places strain and somewhat of possible problems which I also understand are solely the responsibility of the flight instrument and not the student. However, I believe since the flight used a filed IFR flight, traffic was light and the tower was aware of our approach (the second one at opf), it should be the pilot's first responsibility to fly the airplane, navigation, then communication. I don't believe our position posed any safety problems or potential problems to other traffic or ourselves as the area was clear of traffic. The incident was discussed with the student in post-flight and pilot responsibility to fly, navigation, communication, yet in a training flight it is the instrument's responsibility to prevent such conflicts, yet still allow the student to learn such priorities west/O the instrument doing all sensitive aspects of the flight. Thus, I feel there is a fine line between productive flight training and legality involved in training operations. In response to opf's implication of entering the air traffic area west/O proper clearance I believe technically that if we were 1 mi inside moltz (5.4 NM from threshold as reported by tower we actually had not entered the air traffic area which is 5 SM from geographic center of airport. At 1 mi inside moltz [5.4 NM] we were 5.016 SM from threshold, and as air traffic area is from center of airport this would technically place our position further outside opf air traffic area. Such a technical approach I feel is applicable only to defense of a possible violation. In practical terms I believe cooperation between controllers and pilots and consideration of the aspects associated with flight training is needed. The aircraft call sign is familiar to the tower and approach as it is operated by a very large flight school which operates at opf daily. I will, in the future training flts, make a more concerted attempt to establish or have student contact tower when appropriate to avoid such incidents. Increased diligence should prevent any further occurrences.

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Original NASA ASRS Text

Title: SMA ON IFR TRAINING FLT FAILED TO REPORT MOLTS INBOUND AS INSTRUCTED WHILE EXECUTING ILS RWY 9L AT OPF.

Narrative: WHILE CONDUCTING INSTRUMENT FLT TRNING UNDER IFR FLT PLAN, DURING DAYTIME AND CLEAR VFR WX. AT OPF THE COMMON PROC IS TO RPT MOLTZ INTXN 5.4 NM FROM THRESHOLD AT 1815' AFTER BEGINNING DSCNT ON G/S. APCH CLRED US FOR THE APCH AND ASSIGNED AN INTERCEPT WITHIN 30 DEGS APPROX 2 MI OUTSIDE THE APCH GATE, WHICH I WOULD ESTIMATE AS BEING APPROX 3 NM FROM MOLTZ INTXN. MORE THAN NORMAL AMOUNT OF TIME WAS TAKEN TO CONTACT OPF TWR AS I ALLOWED THE STUDENT TO GET ESTABLISHED AND STABILIZED ON LOC, PERFORM BEFORE LNDG CHKS AND CHANGE RADIO FREQ TO TWR. DSCNT ON G/S WAS BEGUN BEFORE CONTACTING THE TWR. I HEARD ONLY ONE OTHER ACFT IN CONTACT WITH TWR AND THE ARPT WAS NOT CONGESTED. HAD THE DSCNT CONTINUED FURTHER I WOULD HAVE ADVISED TWR OF OUR LOCATION, HOWEVER STUDENT DID CONTACT TWR AT APPROX 1600-1700' ONCE STABILIZED ON APCH. TWR ADVISED US WE WERE 1 MI INSIDE MOLTZ INTXN AND THAT WE WERE TO CONTACT PRIOR TO REACHING MOLTZ AND ENTERING THE ATA. TWR USED RADAR EQUIP TO LOCATE US AT 1 MI INSIDE MOLTZ AND I WOULD ESTIMATE APPROX THE SAME. THE TWR IMPLIED WE HAD ENTERED THE ATA W/O ESTABLISHING COMS. WHILE I AM AWARE THIS IS REQUIRED TO BE DONE, I BELIEVE SOMETIMES FLT TRNING PLACES STRAIN AND SOMEWHAT OF POSSIBLE PROBS WHICH I ALSO UNDERSTAND ARE SOLELY THE RESPONSIBILITY OF THE FLT INSTR AND NOT THE STUDENT. HOWEVER, I BELIEVE SINCE THE FLT USED A FILED IFR FLT, TFC WAS LIGHT AND THE TWR WAS AWARE OF OUR APCH (THE SECOND ONE AT OPF), IT SHOULD BE THE PLT'S FIRST RESPONSIBILITY TO FLY THE AIRPLANE, NAV, THEN COM. I DON'T BELIEVE OUR POS POSED ANY SAFETY PROBS OR POTENTIAL PROBS TO OTHER TFC OR OURSELVES AS THE AREA WAS CLR OF TFC. THE INCIDENT WAS DISCUSSED WITH THE STUDENT IN POST-FLT AND PLT RESPONSIBILITY TO FLY, NAV, COM, YET IN A TRNING FLT IT IS THE INSTR'S RESPONSIBILITY TO PREVENT SUCH CONFLICTS, YET STILL ALLOW THE STUDENT TO LEARN SUCH PRIORITIES W/O THE INSTR DOING ALL SENSITIVE ASPECTS OF THE FLT. THUS, I FEEL THERE IS A FINE LINE BTWN PRODUCTIVE FLT TRNING AND LEGALITY INVOLVED IN TRNING OPS. IN RESPONSE TO OPF'S IMPLICATION OF ENTERING THE ATA W/O PROPER CLRNC I BELIEVE TECHNICALLY THAT IF WE WERE 1 MI INSIDE MOLTZ (5.4 NM FROM THRESHOLD AS RPTED BY TWR WE ACTUALLY HAD NOT ENTERED THE ATA WHICH IS 5 SM FROM GEOGRAPHIC CENTER OF ARPT. AT 1 MI INSIDE MOLTZ [5.4 NM] WE WERE 5.016 SM FROM THRESHOLD, AND AS ATA IS FROM CENTER OF ARPT THIS WOULD TECHNICALLY PLACE OUR POS FURTHER OUTSIDE OPF ATA. SUCH A TECHNICAL APCH I FEEL IS APPLICABLE ONLY TO DEFENSE OF A POSSIBLE VIOLATION. IN PRACTICAL TERMS I BELIEVE COOPERATION BTWN CTLRS AND PLTS AND CONSIDERATION OF THE ASPECTS ASSOCIATED WITH FLT TRNING IS NEEDED. THE ACFT CALL SIGN IS FAMILIAR TO THE TWR AND APCH AS IT IS OPERATED BY A VERY LARGE FLT SCHOOL WHICH OPERATES AT OPF DAILY. I WILL, IN THE FUTURE TRNING FLTS, MAKE A MORE CONCERTED ATTEMPT TO ESTABLISH OR HAVE STUDENT CONTACT TWR WHEN APPROPRIATE TO AVOID SUCH INCIDENTS. INCREASED DILIGENCE SHOULD PREVENT ANY FURTHER OCCURRENCES.

Data retrieved from NASA's ASRS site as of August 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.