Narrative:

I was performing on-line training of a new hire preparing for his first part 135 check ride. This was our second day flying together. We were flying ZZZ to onp. Onp was reporting broken 100; 3 mi and mist. At the time of the error; we were VMC above the broken layer. Runway 16/34 was notamed closed due to painting; leaving runway 02/20 as the only available runway. Trainee was in the left seat flying without a hood. This was his first time flying this approach. ZSE gave us vectors to the ILS runway 16; from which we planned to circle for runway 2. Ground winds were calm. We were being vectored toward boilr intersection located 16 DME on the localizer; and had been descended to 5000 ft when controller said 'turn left to 190 degrees to intercept the localizer; descend and maintain 4000 ft; and report established.' the trainee started to turn and descend; and then things got very busy. First; the trainee was late with his stage cooling and I was encouraging him to catch up so that he could slow down by the FAF for gear deployment (which is SOP). Secondly; the trainee hadn't yet briefed how he would circle; so I was also asking him about that. Finally; he was also nervous about descending into the clouds because he hadn't flown actual IFR for 2 yrs. He said; 'you're gonna back me up aren't you? 'Cuz I'm feeling kind of nervous.' I reassured him; and reminded him that he should continue his descent down to 2100 ft once he was cleared for the approach; which is GS intercept altitude once inside of boilr. In the midst of all this; trainee intercepts the localizer and immediately notices that the GS indicator is flagged. The GS is obviously inoperative; as it often has been during the past month at onp. On this day; though; it was not notamed OTS. Trainee asks; 'should I go missed?' I said; 'no. We're circling to runway 2 anyway; let's just revert to the localizer approach.' this is all happening in the quick span between 5000-4000 ft (at about 1500 FPM); and trainee forgot to tell controller that he was established on the localizer; but he continued to descend past 4000 ft toward 2100 ft. I didn't catch this right away and reminded him to call ATC. He did; and the controller immediately cleared him for the approach. A few seconds after that; the controller asked our altitude; to which the trainee says 2800 ft. Controller asks; 'are you on the GS?' which was confusing since we were still above and outside of GS intercept/FAF (had it been working); we were on a published segment; and we were already cleared for approach. Trainee said no; and then controller admonished us about descending below 4000 ft until cleared for the approach. Trainee apologized and we continued the localizer approach down to circling minimums while switching to CTAF as instructed. There was no time to explain to the controller that the GS was OTS and that we were actually flying the localizer approach; but that shouldn't have mattered because all approach altitudes were the same including FAF altitude and the circling MDA. At MDA; we were in the broken clouds and only saw the runway when we were directly over the airport at the missed approach; so we started a missed approach. Informed controller of the missed approach and asked for the approach again. Then the controller asks; 'is this your regular run?' which was very odd. What difference did that make? Was he challenging our decision to go missed? Anyway; with all the tension and workload on the trainee; and with me trying to keep him up with the airplane; I took the microphone and said that we were doing on-line training. 'Training?' he asked; sounding surprised; but I ignored him in favor of focusing on the trainee's flying. We flew a second localizer approach; this time informing the controller that the GS was OTS; and successfully circled to land on runway 2. Though the controller was miffed that we descended below 4000 ft a few seconds before he actually cleared us for the approach; I estimate that we only made it to about 3500 ft when we received his approach clearance -- there were mitigating factors here. Aside from my workload dealing with a nervous trainee who was behind the power curve and the unexpected situation of finding the GS OTS (all of which is my responsibility to handle as PIC); the controller; in part; set us up for this mistake. I fly this approach into onp almost daily; and the usual instruction approaching boilr is to first descend to 4000 ft and then 'turn left to 190 degrees to intercept the localizer; maintain 4000 ft until established; cleared ILS runway 16 approach.' in other words; it is very unusual for the controller to ask that we report established prior to receiving approach clearance. Thus; with everything that was going on; I probably reverted to what I was used to; ie; being cleared for the approach prior to localizer intercept; becoming established before reaching 4000 ft; and continuing the descent down to 2100 ft without leveling off at 4000 ft. Had there been a radar problem; then I could understand the change; but the controller obviously had us radar idented or he wouldn't have known that we descended below 4000 ft. Anyway; we were on a published approach segment authority/authorized for 2100 ft when we went below 4000 ft; and there was no other traffic (ZSE never handles more than 1 IFR at a time in onp's class east surface area). I later learned that controller called company about the mistake. Controller confirmed during that call that there was no separation issue; low altitude warning; etc. Although; technically this was a pilot deviation because we descended before receiving approach clearance; I am surprised that the controller made as much out of it as he did; rather than just accepting our apology for starting the descent before actually cleared. There was no real safety hazard in this particular instance. For example; had we gone lost communication when intercepting the localizer; our continued descent to 2100 ft would (properly) have been the same. Anyway; my fault -- I'll do better next time.

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Original NASA ASRS Text

Title: PA31 PLT TAKES EXCEPTION TO ATC HANDLING OF APCH CLRNCS TO ONP.

Narrative: I WAS PERFORMING ON-LINE TRAINING OF A NEW HIRE PREPARING FOR HIS FIRST PART 135 CHK RIDE. THIS WAS OUR SECOND DAY FLYING TOGETHER. WE WERE FLYING ZZZ TO ONP. ONP WAS RPTING BROKEN 100; 3 MI AND MIST. AT THE TIME OF THE ERROR; WE WERE VMC ABOVE THE BROKEN LAYER. RWY 16/34 WAS NOTAMED CLOSED DUE TO PAINTING; LEAVING RWY 02/20 AS THE ONLY AVAILABLE RWY. TRAINEE WAS IN THE L SEAT FLYING WITHOUT A HOOD. THIS WAS HIS FIRST TIME FLYING THIS APCH. ZSE GAVE US VECTORS TO THE ILS RWY 16; FROM WHICH WE PLANNED TO CIRCLE FOR RWY 2. GND WINDS WERE CALM. WE WERE BEING VECTORED TOWARD BOILR INTXN LOCATED 16 DME ON THE LOC; AND HAD BEEN DSNDED TO 5000 FT WHEN CTLR SAID 'TURN L TO 190 DEGS TO INTERCEPT THE LOC; DSND AND MAINTAIN 4000 FT; AND RPT ESTABLISHED.' THE TRAINEE STARTED TO TURN AND DSND; AND THEN THINGS GOT VERY BUSY. FIRST; THE TRAINEE WAS LATE WITH HIS STAGE COOLING AND I WAS ENCOURAGING HIM TO CATCH UP SO THAT HE COULD SLOW DOWN BY THE FAF FOR GEAR DEPLOYMENT (WHICH IS SOP). SECONDLY; THE TRAINEE HADN'T YET BRIEFED HOW HE WOULD CIRCLE; SO I WAS ALSO ASKING HIM ABOUT THAT. FINALLY; HE WAS ALSO NERVOUS ABOUT DSNDING INTO THE CLOUDS BECAUSE HE HADN'T FLOWN ACTUAL IFR FOR 2 YRS. HE SAID; 'YOU'RE GONNA BACK ME UP AREN'T YOU? 'CUZ I'M FEELING KIND OF NERVOUS.' I REASSURED HIM; AND REMINDED HIM THAT HE SHOULD CONTINUE HIS DSCNT DOWN TO 2100 FT ONCE HE WAS CLRED FOR THE APCH; WHICH IS GS INTERCEPT ALT ONCE INSIDE OF BOILR. IN THE MIDST OF ALL THIS; TRAINEE INTERCEPTS THE LOC AND IMMEDIATELY NOTICES THAT THE GS INDICATOR IS FLAGGED. THE GS IS OBVIOUSLY INOP; AS IT OFTEN HAS BEEN DURING THE PAST MONTH AT ONP. ON THIS DAY; THOUGH; IT WAS NOT NOTAMED OTS. TRAINEE ASKS; 'SHOULD I GO MISSED?' I SAID; 'NO. WE'RE CIRCLING TO RWY 2 ANYWAY; LET'S JUST REVERT TO THE LOC APCH.' THIS IS ALL HAPPENING IN THE QUICK SPAN BTWN 5000-4000 FT (AT ABOUT 1500 FPM); AND TRAINEE FORGOT TO TELL CTLR THAT HE WAS ESTABLISHED ON THE LOC; BUT HE CONTINUED TO DSND PAST 4000 FT TOWARD 2100 FT. I DIDN'T CATCH THIS RIGHT AWAY AND REMINDED HIM TO CALL ATC. HE DID; AND THE CTLR IMMEDIATELY CLRED HIM FOR THE APCH. A FEW SECONDS AFTER THAT; THE CTLR ASKED OUR ALT; TO WHICH THE TRAINEE SAYS 2800 FT. CTLR ASKS; 'ARE YOU ON THE GS?' WHICH WAS CONFUSING SINCE WE WERE STILL ABOVE AND OUTSIDE OF GS INTERCEPT/FAF (HAD IT BEEN WORKING); WE WERE ON A PUBLISHED SEGMENT; AND WE WERE ALREADY CLRED FOR APCH. TRAINEE SAID NO; AND THEN CTLR ADMONISHED US ABOUT DSNDING BELOW 4000 FT UNTIL CLRED FOR THE APCH. TRAINEE APOLOGIZED AND WE CONTINUED THE LOC APCH DOWN TO CIRCLING MINIMUMS WHILE SWITCHING TO CTAF AS INSTRUCTED. THERE WAS NO TIME TO EXPLAIN TO THE CTLR THAT THE GS WAS OTS AND THAT WE WERE ACTUALLY FLYING THE LOC APCH; BUT THAT SHOULDN'T HAVE MATTERED BECAUSE ALL APCH ALTS WERE THE SAME INCLUDING FAF ALT AND THE CIRCLING MDA. AT MDA; WE WERE IN THE BROKEN CLOUDS AND ONLY SAW THE RWY WHEN WE WERE DIRECTLY OVER THE ARPT AT THE MISSED APCH; SO WE STARTED A MISSED APCH. INFORMED CTLR OF THE MISSED APCH AND ASKED FOR THE APCH AGAIN. THEN THE CTLR ASKS; 'IS THIS YOUR REGULAR RUN?' WHICH WAS VERY ODD. WHAT DIFFERENCE DID THAT MAKE? WAS HE CHALLENGING OUR DECISION TO GO MISSED? ANYWAY; WITH ALL THE TENSION AND WORKLOAD ON THE TRAINEE; AND WITH ME TRYING TO KEEP HIM UP WITH THE AIRPLANE; I TOOK THE MIKE AND SAID THAT WE WERE DOING ON-LINE TRAINING. 'TRAINING?' HE ASKED; SOUNDING SURPRISED; BUT I IGNORED HIM IN FAVOR OF FOCUSING ON THE TRAINEE'S FLYING. WE FLEW A SECOND LOC APCH; THIS TIME INFORMING THE CTLR THAT THE GS WAS OTS; AND SUCCESSFULLY CIRCLED TO LAND ON RWY 2. THOUGH THE CTLR WAS MIFFED THAT WE DSNDED BELOW 4000 FT A FEW SECONDS BEFORE HE ACTUALLY CLRED US FOR THE APCH; I ESTIMATE THAT WE ONLY MADE IT TO ABOUT 3500 FT WHEN WE RECEIVED HIS APCH CLRNC -- THERE WERE MITIGATING FACTORS HERE. ASIDE FROM MY WORKLOAD DEALING WITH A NERVOUS TRAINEE WHO WAS BEHIND THE POWER CURVE AND THE UNEXPECTED SITUATION OF FINDING THE GS OTS (ALL OF WHICH IS MY RESPONSIBILITY TO HANDLE AS PIC); THE CTLR; IN PART; SET US UP FOR THIS MISTAKE. I FLY THIS APCH INTO ONP ALMOST DAILY; AND THE USUAL INSTRUCTION APCHING BOILR IS TO FIRST DSND TO 4000 FT AND THEN 'TURN L TO 190 DEGS TO INTERCEPT THE LOC; MAINTAIN 4000 FT UNTIL ESTABLISHED; CLRED ILS RWY 16 APCH.' IN OTHER WORDS; IT IS VERY UNUSUAL FOR THE CTLR TO ASK THAT WE RPT ESTABLISHED PRIOR TO RECEIVING APCH CLRNC. THUS; WITH EVERYTHING THAT WAS GOING ON; I PROBABLY REVERTED TO WHAT I WAS USED TO; IE; BEING CLRED FOR THE APCH PRIOR TO LOC INTERCEPT; BECOMING ESTABLISHED BEFORE REACHING 4000 FT; AND CONTINUING THE DSCNT DOWN TO 2100 FT WITHOUT LEVELING OFF AT 4000 FT. HAD THERE BEEN A RADAR PROB; THEN I COULD UNDERSTAND THE CHANGE; BUT THE CTLR OBVIOUSLY HAD US RADAR IDENTED OR HE WOULDN'T HAVE KNOWN THAT WE DSNDED BELOW 4000 FT. ANYWAY; WE WERE ON A PUBLISHED APCH SEGMENT AUTH FOR 2100 FT WHEN WE WENT BELOW 4000 FT; AND THERE WAS NO OTHER TFC (ZSE NEVER HANDLES MORE THAN 1 IFR AT A TIME IN ONP'S CLASS E SURFACE AREA). I LATER LEARNED THAT CTLR CALLED COMPANY ABOUT THE MISTAKE. CTLR CONFIRMED DURING THAT CALL THAT THERE WAS NO SEPARATION ISSUE; LOW ALT WARNING; ETC. ALTHOUGH; TECHNICALLY THIS WAS A PLTDEV BECAUSE WE DSNDED BEFORE RECEIVING APCH CLRNC; I AM SURPRISED THAT THE CTLR MADE AS MUCH OUT OF IT AS HE DID; RATHER THAN JUST ACCEPTING OUR APOLOGY FOR STARTING THE DSCNT BEFORE ACTUALLY CLRED. THERE WAS NO REAL SAFETY HAZARD IN THIS PARTICULAR INSTANCE. FOR EXAMPLE; HAD WE GONE LOST COM WHEN INTERCEPTING THE LOC; OUR CONTINUED DSCNT TO 2100 FT WOULD (PROPERLY) HAVE BEEN THE SAME. ANYWAY; MY FAULT -- I'LL DO BETTER NEXT TIME.

Data retrieved from NASA's ASRS site as of May 2009 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.