Date: 202010
Local time of day: 1201-1800
Location: ZZZ.Tower, US
Aircraft: Light Sport Aircraft
Flight phase: Final Approach
Airspace: Class D ZZZ
ATC / advisory: Tower ZZZ
Reporter organization: Government
Reporter function: Other / Unknown
Reporter qualification: Air Traffic Control Fully Certified
Human factors: Communication Breakdown; Confusion; Situational Awareness
Anomaly: ATC Issue All Types; Deviation / Discrepancy - Procedural Published Material / Policy
Detector: Person Air Traffic Control
When detected: In-flight
Result: General None Reported / Taken
Contributing factors: Human Factors; Procedure
Primary problem: Procedure

Narrative: This is now the 4th Practice Approach (PA) issue we have documented in the past 30 days. ZZZ1 (TRACON) continues to not coordinate PA according to our LOA. They are introducing risk to the NAS by leading pilots to believe they are cleared for a PA and creating uncertainty. LC (Local Control) would have time to anticipate and better accommodate this pilot if ZZZ1 would have simply coordinated this procedure. Due to ZZZ1 not following their requirement in the LOA they are jeopardizing safety and not providing a good service to the flying public. We must get the answers to the following questions before we can move forward. Why did ZZZ1 issue a Practice Approach Letter to Airmen (PALTA) about 3 years ago? What are the reasons for it not reinstating the PALTA? Why was the workforce not briefed or trained on this change? What are the pros and cons of not having a PALTA?On (date); our General Manager signed the now expired PALTA in question. There were many requests from HQ for PA clarification and interpretations on this very topic throughout the past decade.Since the LTA expired on date; we have gradually started to see a thread of confusion among pilots and controllers. The very purpose of having a PALTA was to prevent this from happening. This has led to misinterpretations of many rules within the 7110.65 and the 7110.3. ZZZ ATCT has compiled over 10 falcon replays over the past 10 months that references this very trend and ZZZ2 ATCT has been experiencing similar issues as well. I would like those who review those replays to listen to the disappointment and frustration from the pilots. We are wasting their valuable time and not providing them with the best possible service. It must be clear there are only 3 possible separation rules that can be applied when handling a PA request. These rules are not to be applied by CPC choice at any given moment. 2 out of the 3 rules are defined on whether or not there is an effective LTA that lists your facility. With that being said; CPC and pilots must be trained and aware of these differences. Separation Rules (7110.65) a.1 [states that] IFR aircraft practicing instrument approaches must be afforded approved separation in accordance with Chapter 3; Chapter 4; Chapter 5; Chapter 6; and Chapter 7 minima until the aircraft lands; and the flight is terminated; or the pilot cancels the flight plan. For this argument we have not discovered any issues when complying.[Section] a.2 [states that] where procedures require application of IFR separation to VFR aircraft practicing instrument approaches; IFR separation in accordance with Chapter 3; Chapter 4; Chapter 5; Chapter 6; and Chapter 7 must be provided. Controller responsibility for separation begins at the point where the approach clearance becomes effective. Except for super or heavy aircraft; 500 ft. vertical separation may be applied between VFR aircraft and between a VFR and an IFR aircraft.The issue we have is some CPC are still following a.2 and some a.3. We must train our workforce on which they are to follow; which is dictated on whether or not we have an LTA. We can't allow them to apply a mixture of both these rules. For 2 years our effective LTA has dictated and conditioned pilots; instructors; students; examiners; and CPC that we must follow a.2. This basically implied to all users that they were going to be treated as if they were IFR doing a VFR PA. This was implemented to give VFR pilots and instructors the full experience so they can perfect the instrument approach procedures they are trying to practice. Various air traffic incidents have indicated the necessity for adoption of measures to achieve more organized and controlled operations where practice instrument approaches are conducted. Practice instrument approaches are considered to be instrument approaches made by either a VFR aircraft not on an IFR flight plan or an aircraft on an IFR flight plan. To achieve this and thereby enhance air safety; it is company policy to provide for separation of such operations at locations where approach control facilities are located and; as resources permit; at certain other locations served by ARTCCs or parent approach control facilities.We need to understand that a.2 is simple for all users involved and reduces risk to the NAS. Not to mention it provides a great and safe service to the flying public. The experience we afford the users when utilizing a.2 enhances safety; achieves a more organized and controlled operations where practice instrument approaches are conducted.[Section] a.3 [states] where separation services are not provided to VFR aircraft practicing instrument approaches; the controller must instruct the pilot to maintain VFR; advise the pilot that separation services are not provided; and provide traffic information or advise the pilot to contact the appropriate facility.The implementation of a.2 and the LTA requirement was to detour facilities from using this rule if they have existing resources. This rule creates confusing and is why we are now seeing unsafe trends since our LTA expired about a year ago. Some CPCs are following this rule and are lead to believe that no coordination is needed because they are not clearly them for the approach as they would when utilizing a.2. Some CPCs are still following a.2 and some are doing a mixture of both. We must train our workforce on which procedures must be followed when handling PA. We also need to brief the flying public as well. If ZZZ1 is not going to reinstate the LTA; all the LOAs with the towered airports listed in the LTA must be amended with detailed procedures on dealing with PA approaches; which include coordination requirements. I'm certain Mission Support would support my argument that we should follow a.2 and reinstate our LTA to achieve more organized and controlled operations where practice instrument approaches are conducted. The volume of VFR traffic in the ZZZ1 is on an upward trend and the last thing we need is uncertainty. We also must ask ourselves; why do most all other major approach control facilities in the NAS choose to issue a PALTA to enhance safety? Having the ability to issue a PALTA was given to us to migrate the very issue we are now having. By not choosing to issue a PALTA; ZZZ1 is jeopardizing safety by not creating a more organized environment where PA are being conducted. We understand that the approach control ATM has the discretion on whether or not they need to issue a PALTA however it is important that the workforce understands why they are making this decision. Especially when the data shows that we are now having mass confusion among pilots and CPC. A PALTA will mitigate this confusion immediately. Choosing to not reinstate an LTA on the sole purpose of pilot and CPC complaints is ludicrous and negligent. We did not see this chaos when the LTA was effective.   Over the past 2 years ZZZ ATCT has noticed and documented a trend with PA and other facility are starting to notice as well. Our workforce and all the users involved deserve the best possible service and training. Why are we choosing not to provide pilots with a.2 service and waste their valuable time with a subpar service (a.3) instead? I'm asking that the national recurrent training team design a course on this very argument.




Synopsis: Tower Controller reported miscommunication with TRACON concerning practice approaches.