Narrative:

I was captain on air carrier X cle to dtw. We had to hold on the runway 21L localizer for some time waiting for the RVR to improve. During this time the RVR was between 1800 and 2000 ft. Finally the runway was switched and we were vectored for an ILS runway 3L. Since the RVR was so variable I decided to brief for a CAT ii approach. I instructed the copilot to inform the controller that we were going to make this a CAT ii so they would give us the necessary separation. They acknowledged this and reported that the RVR was now 1200 ft. On crosswind we were told to maintain 170 KTS to the marker. I could not accept this restriction for 2 reasons. First, this autoplt does not capture well if the speed is too high and changing. Second, whenever I am making an approach into near minimum conditions, I need to be stabilized on speed on GS at the OM. To be anything but stabilized causes an unnecessary workload when crossing the final approach fix and is not a safe operation. At about 400 ft AGL we were given a go around and turn immediately to 300 degrees. I found out later it was because of an aircraft on the runway. On the second approach when I reported the OM inbound we were told to continue, that we were #2, an aircraft was on short final, standby for landing clearance. As we approached 500 ft AGL, I put my hands in the proper position and told the so to acknowledge the landing clearance when given. This is not part of our procedures but under the circumstances I felt that it was safer than for me to be talking on the radio instead of monitoring the approach, especially so close to the ground. I feel that detroit approach control put my aircraft in an unsafe situation when they did not provide proper separation even for CAT I conditions, let alone the CAT ii conditions existing at the time. Aim chapter 1 section 10 paragraph K under radio aids GS critical area, states that 'aircraft are not authorized in the area when an arriving aircraft is between the ILS final approach fix and the airport unless the aircraft has reported the airport in sight.' this clearly prohibits the actions of the controller. On my first approach they allowed an aircraft on the runway when we were inside the final approach fix. On our second approach the aircraft ahead of us had to be in the critical area when we were inside the final approach fix. In neither case did we report the field in sight. This is especially troubling since we told the controller on downwind that we were going to make a CAT ii approach and they choose to ignore this regulation thus putting us in a potentially bad situation. We should be able to depend on the controllers following the regulations but evidently this is just another case where their procedures do not follow the FARS, the aim, or common sense.

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Original NASA ASRS Text

Title: RPTR ALLEGES NON COMPLIANCE WITH ILS CRITICAL AREA WHILE ACR X MAKING CAT II ILS APCH.

Narrative: I WAS CAPT ON ACR X CLE TO DTW. WE HAD TO HOLD ON THE RWY 21L LOC FOR SOME TIME WAITING FOR THE RVR TO IMPROVE. DURING THIS TIME THE RVR WAS BTWN 1800 AND 2000 FT. FINALLY THE RWY WAS SWITCHED AND WE WERE VECTORED FOR AN ILS RWY 3L. SINCE THE RVR WAS SO VARIABLE I DECIDED TO BRIEF FOR A CAT II APCH. I INSTRUCTED THE COPLT TO INFORM THE CTLR THAT WE WERE GOING TO MAKE THIS A CAT II SO THEY WOULD GIVE US THE NECESSARY SEPARATION. THEY ACKNOWLEDGED THIS AND RPTED THAT THE RVR WAS NOW 1200 FT. ON XWIND WE WERE TOLD TO MAINTAIN 170 KTS TO THE MARKER. I COULD NOT ACCEPT THIS RESTRICTION FOR 2 REASONS. FIRST, THIS AUTOPLT DOES NOT CAPTURE WELL IF THE SPD IS TOO HIGH AND CHANGING. SECOND, WHENEVER I AM MAKING AN APCH INTO NEAR MINIMUM CONDITIONS, I NEED TO BE STABILIZED ON SPD ON GS AT THE OM. TO BE ANYTHING BUT STABILIZED CAUSES AN UNNECESSARY WORKLOAD WHEN XING THE FINAL APCH FIX AND IS NOT A SAFE OP. AT ABOUT 400 FT AGL WE WERE GIVEN A GAR AND TURN IMMEDIATELY TO 300 DEGS. I FOUND OUT LATER IT WAS BECAUSE OF AN ACFT ON THE RWY. ON THE SECOND APCH WHEN I RPTED THE OM INBOUND WE WERE TOLD TO CONTINUE, THAT WE WERE #2, AN ACFT WAS ON SHORT FINAL, STANDBY FOR LNDG CLRNC. AS WE APCHED 500 FT AGL, I PUT MY HANDS IN THE PROPER POS AND TOLD THE SO TO ACKNOWLEDGE THE LNDG CLRNC WHEN GIVEN. THIS IS NOT PART OF OUR PROCS BUT UNDER THE CIRCUMSTANCES I FELT THAT IT WAS SAFER THAN FOR ME TO BE TALKING ON THE RADIO INSTEAD OF MONITORING THE APCH, ESPECIALLY SO CLOSE TO THE GND. I FEEL THAT DETROIT APCH CTL PUT MY ACFT IN AN UNSAFE SIT WHEN THEY DID NOT PROVIDE PROPER SEPARATION EVEN FOR CAT I CONDITIONS, LET ALONE THE CAT II CONDITIONS EXISTING AT THE TIME. AIM CHAPTER 1 SECTION 10 PARAGRAPH K UNDER RADIO AIDS GS CRITICAL AREA, STATES THAT 'ACFT ARE NOT AUTHORIZED IN THE AREA WHEN AN ARRIVING ACFT IS BTWN THE ILS FINAL APCH FIX AND THE ARPT UNLESS THE ACFT HAS RPTED THE ARPT IN SIGHT.' THIS CLRLY PROHIBITS THE ACTIONS OF THE CTLR. ON MY FIRST APCH THEY ALLOWED AN ACFT ON THE RWY WHEN WE WERE INSIDE THE FINAL APCH FIX. ON OUR SECOND APCH THE ACFT AHEAD OF US HAD TO BE IN THE CRITICAL AREA WHEN WE WERE INSIDE THE FINAL APCH FIX. IN NEITHER CASE DID WE RPT THE FIELD IN SIGHT. THIS IS ESPECIALLY TROUBLING SINCE WE TOLD THE CTLR ON DOWNWIND THAT WE WERE GOING TO MAKE A CAT II APCH AND THEY CHOOSE TO IGNORE THIS REG THUS PUTTING US IN A POTENTIALLY BAD SIT. WE SHOULD BE ABLE TO DEPEND ON THE CTLRS FOLLOWING THE REGS BUT EVIDENTLY THIS IS JUST ANOTHER CASE WHERE THEIR PROCS DO NOT FOLLOW THE FARS, THE AIM, OR COMMON SENSE.

Data retrieved from NASA's ASRS site as of July 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.