Legal Interpretations
Gretsch-AJW-33 2012
Summary
The Question
Must part 135 pilots demonstrate a circling approach on a 14 CFR 135.297 instrument proficiency check if their company is not authorized to conduct circling approaches?
Background
The FAA's Flight Inspection Operations Group (AJW-33) asked whether an August 11, 2011 interpretation on instrument proficiency checks affects circling approach demonstrations, citing a company not authorized to conduct IFR circle-to-land maneuvers.
The FAA’s Interpretation
No. Although 14 CFR 135.297(b) calls for one straight-in, one circling, and one missed approach for each procedure demonstrated, FAA policy in FAA Order 8900.1 does not require pilots to demonstrate a circling approach when their certificate holder is prohibited from circling with a ceiling below 1,000 feet and visibility less than 3 miles. The August 11, 2011 interpretation did not change that policy.
- Requester
- Gretsch
- Organization
- AJW
- Issued
- February 6, 2012
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
Page 1
Federal Aviation
Administration
Memorandum
Date:
To:
From:
Prepared by:
Subject:
FEB - 8 20 ~~
Peter W. Gr~::~light Inspection Operations Group,AJW-33
~l.MacPherson, Assistant Chief Counsel for Regulations, AGC-200
Dean E. Griffith, Attorney, Regulations Division, AGC-220
Demonstration of Circling Approaches
This memorandum is in response to your October 13, 2011 letter regarding whether the legal interpretation issued by this office on August 11, 2011 to theFAA's Flight Standards Service, applies to demonstration of circling approaches during part 135 competency checks and instrument proficiency checks. In your letter you mention a company that is not authorized to conduct airplane IFR circle-to-land approach maneuvers.
The August 11, 2011 interpretation addresses the instrument procedures that a pilot must demonstrate during an instrument proficiency check. It states that the instrument proficiency check, required by§ 135.297, need only include the standard instrument approaches involving navigational facilities which the pilot is to be authorized to use in.part 135 operations. Section 135.297(b) requires that a pilot qualifying to use an instrument approach procedure must perform "one straight-in approach, one circling approach, and one missed approach" for each procedure demonstrated.
As a.matter of FAA policy, pilots for part 135 operators are not required to demonstrate a circling approach if the certificate holder for whom they work is prohibited by the FAA from conducting such maneuvers with a ceiling below 1,000 feet and a visibility of les·s than 3 miles. FAA Order 8900.l, Vol. 5, Ch. 3, Sec. 2, Para. 5-832(c) (authorizing waiver of circling maneuvers); FAA Order 8900.1, Vol. 3, Ch. 19, Sec. 7, Table 3-70 (allowing waiver of instrument procedures). This policy was not changed by the August 11 interpretation. Because the company in your letter is not authorized by the FAA to conduct circling instrument approaches with a ceiling below l,000 feet and a visibility of less than 3 miles, it follows that its pilots are not required to demonstrate a circling approach to satisfy the requirements of § 135.297.
This response was prepared by Dean E. Griffith, Attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the Air Transportation Division of Flight Standards Service. Please contact us at (202) 267-3073 if we can be of further assistance.
Regulations Referenced
Snapshot retrieved August 6, 2026.