Date: 201506
Local time of day: 0601-1200
Location: SAN.Airport, CA
Flight conditions: Mixed
Weather elements / visibility: 10
Aircraft: B737 Undifferentiated or Other Model
Operator: Air Carrier
Operating under: Part 121
Flight plan: IFR
Mission: Passenger
Flight phase: Initial Approach
Airspace: Class B SAN
ATC / advisory: TRACON SCT
Reporter organization: Air Carrier
Reporter function: First Officer; Pilot Flying
Reporter qualification: Flight Crew Air Transport Pilot (ATP)
Human factors: Other / Unknown
Second reporter function: Pilot Not Flying; Captain
Anomaly: ATC Issue All Types; Deviation - Speed All Types; Deviation / Discrepancy - Procedural Published Material / Policy; Deviation / Discrepancy - Procedural Clearance
Detector: Person Air Traffic Control
When detected: In-flight
Result: Air Traffic Control Issued Advisory / Alert; Air Traffic Control Issued New Clearance; Flight Crew Returned To Clearance
Contributing factors: Airport; Procedure; Human Factors
Primary problem: Airport

Narrative: Flying into SAN on the BAYVU 3 Arrival; the weather was 1100 BKN 1500 OVC; temperature 18 and dew point 14. SAN was using LOC 27 Approaches. Once established on the final approach course; we were assigned; by ATC; 160 knots to the FAF; REEBO. We advised ATC we were unable to maintain 160 knots. ATC told us if we could not maintain 160; he would pull us off the approach. We advised him that he really gave us no choice and accepted the speed restriction. There were no complications with the approach or landing. The descent angle on this approach is 3.5 degrees into an airport where we have a high rate of unstable approaches. We should not be threatened with delay if we want to fly the approach at our reference speed within three miles of the final approach fix; which is required in the FOM.


Second narrative: Captain was PM; F/O was PF. Soon after reaching cruise altitude we began briefing BAYVU 3 and LOC 27 for a Non-Precision Vertical Speed Profile Approach into SAN. On the BAYVU 3; we were assigned 250 KIAS by Center and SoCal for spacing; descended to 15;000 ft near BAYVU; and slowed again in the descent to 210 KIAS. Downwind vectors started somewhere near LCOVE. We were slowed further to 180 KIAS; then 170. We were given a late (overshooting) vector to intercept LOC27. I could be wrong; but understood this to be intentional; for spacing. Localizer course intercept occurred just inside VYDDA. Prior to OKAIN we were 'Cleared the LOC 27 Approach; maintain 160 to REEBO.' Captain (PM) told Approach 'Unable'. ATC stated; 'If you don't accept 160 KIAS to REEBO; I will need to take you out and bring you back. Captain (PM) stated; 'Well; I guess we must accept it.' Soon thereafter; SoCal gave a breakout vector. Captain (PM) stated; 'We are established on the Localizer and will fly the approach 160 to REEBO.' ATC re-cleared us for the approach; 160 KIAS at REEBO. F/O (PF) flew a textbook approach; despite ATC. Just prior to REEBO; he immediately slowed and called for configuring to be nicely stabilized; apart from the understandable Vertical Speed deviations greater than 1000 fpm. A Company; ATC System Manager was contacted after the flight to discuss the situation. An important aspect of the successful stabilized approach was the Crew thoroughly briefing the Approach; and discussion of calling 'unable' if SoCal vectors were 'too tight' or assigned speeds negatively affecting the ability to fly a stabilized approach. Company Pilots have received frequent safety communications regarding approaches into SAN. These communications discuss limited approach continuity; poor briefings and planning; LOC 27 approach design; and SoCal's reputation of short spacing vectors and limiting speed assignments on the LOC. Flying into SAN has a greater level of risk than most Company airports. Weather and night only increase the risk of failures. Much of this risk can be mitigated. A recent 'RNAV/RNP Operations and VNAV Approaches'  briefing published by Boeing mentions that 60 percent of CFIT accidents occur on Non-Precision approaches; 47 percent during step-down NP approaches; and almost all in darkness or IMC. From the most recent Company Flight Ops Safety bulletin; SAN has twice the unstable approach rate of the system wide average. Also mentioned is the increased energy perspective; due to the FAF altitude increase at REEBO from 1800 ft to 2000 ft; causing a steeper glide path of 3.5 degrees. The article talks about the severe need for better Pilot energy planning on the arrival and with vectors; and gave an excellent discussion on energy and configuration planning. It mentions that arrivals from LYNDI on the vertical path should pass 4000 ft AGL no faster than 210 knots; that ATC may not provide spacing guidance; that ATC may attempt to 'squeeze you in' between straight-in arrivals with a turn to base; that accepting common clearances provides only five NM ground track to the final approach course; causing a turn to final inside of three NM to the threshold; resulting in a descent angle in excess of 4.5 degrees; and lastly; that stating 'Unable' to SoCal is always an acceptable response; and is the most appropriate in situations such as these. Air Traffic Control is part of the team in creating successful low risk flight operations. Company Operations Safety is working hard to mitigate unacceptable risk at SAN. Hopefully Pilots are working hard to do their part. SoCal's help is drastically needed to successfully mitigate unacceptable risk. Since our beginning; Company has a wonderful cultural reputation of doing everything we can to help ATC; system wide. Much has changed in airspace and aircraft. It is possible to continue to be on the same team; helping each other be safe and efficient. Yet; sometimes we need to mutually reassess changes that have occurred with one or both parties on the team to continue to help each other; i.e. the 'old way' may not work anymore. Equipment limitations affect how different airlines fly the LOC 27. Like it or not; Company is limited by equipment to flying LOC approaches with the autopilot in a very manual way. Some may call this procedure antiquated. Other airlines have equipment making LOC approaches simpler and far easier. Added to the equation is lack of Pilot proficiency; i.e. VOR and LOC approaches are rare. It is not unreasonable for a Company Pilot to go years without conducting such an approach; especially so for a back-course; which happens on occasion. Yet; Crews are expected [to maintain] operational proficiency. It appears Company has also removed these from simulator proficiency (waive able). Risk of failure only increases when in older equipment; weather is present; and/or at night. When Pilots already know that they are going to be pushed; then 'punished' by stating 'unable' regarding ATC speed limitations; it affects the risk they are willing to accept to get the job accomplished. In other words; Pilots willingly choose to accept the higher level of risk forced upon them by SoCal. Like it or not; fear of; or intimidation by ATC is formidable. Air Traffic Control holds a greater degree of power in the mind of the Pilot regarding approach timing and certificate action. Crews deserve to be able to have the opportunity to be fully configured; at final approach speed at least two miles prior to REEBO; to fly a stable approach. It has been said that insanity is defined by doing things the same way every time with expectation of change. Company Flight Operations Safety is 'turning blue in the face' regularly recommending Pilots change their behaviors at SAN; for the sake of decreased risk. One may safely assume that most Pilots desire to change such behaviors for the sake of decreased risk. Yet; we will never know if that is the case; at SAN; if SoCal is not willing to change their behaviors (that directly affect Pilot decisions) for the sake of decreased operational risk.1. SoCal: Please move the 'speed compression' or '160 until point' back from REEBO to a couple miles prior to CIJHI ASAP. 2. SoCal and Company Flight Operations: if possible; redesign the approach with GPS points or as an RNAV/LOC; with assigned speeds; allowing Crews the time and ability to ensure reaching stabilized criteria.  3. SoCal and Company Flight Operations: if possible; please design an RNAV approach into SAN. Similar type aircraft to SAN need to participate in flying any such approaches to ensure spacing. Having an operational RNAV approach will greatly mitigate risk; especially regarding SoCal's piece of the pie. 4. San Diego and FAA: Please consider building another runway; so that SoCal does not feel a need to increase risk to compress inbounds to such a high degree. This would also help in coordinating takeoffs; also part of the equation. 5. Company Flight Operations: If an RNAV approach is not a possibility; please consider establishing a 60 or 90 day Pilot (both seat positions) currency for these approaches.


Synopsis: B737 Flight Crew laments the speed restrictions (160 to REEBO) applied by SCT during LOC 27 approaches to SAN; believing that the speed restrictions leads to unstabilized approaches.