AGC Opinion-ARC IAFs 1994

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Nov. 28, 1994

Mr. Tom Young, Chainnan

Charting and Instrument Procedures Committee

Air Line Pilots Association

535 Herndon Parkway

Herndon, VA 22070

T>ear Mr. Young This is a clarification of our response to your letter of August 23, 1993. In that lettu you requested an interpretation of Section 91.175 of the Federal Aviation Regulation (FAR)( 14 CFR Section 91.175). You address the necessity of executing a complete Standard Instrument Approach Procedure (SlAP) in a non-radar environment while operating under Instrument Flight Rules (JFR). Our response assumes that each of th•; specific scenarios you pose speaks to a flight conducted under IFR in a non-radar environment.

Section 91.175(a) provides that unless otherwise authorized by the Administrator, when an instrument letdown to a civil airport is necessary, each person operating an aircraft, except a military aircraft of the United States, shall use a standard instrument approach procedure prescribed for the airpm:.t in Part 97.

First you ask whether an arriving aircraft must begin the SIAP at a published Initial Approach Fix (IAF). A pilot must begin a SIAP at the IAF as defined in Part 97. Des;:ent gradients, communication, and obstruction clearance, as set forth in the U.S. Standard for Terminal Instrument Approach Procedures (TERPs), cannot be assured.ifthe entire procedure is not 11own.

You also ask whether a Distance Measuring Equipment (DME) arc initial approach segment can be substituted for a published IAF along any portion of the published ar.;. A DME arc cannot be substituted for a published IAF along a portion of the published <ire. If a feeder route to art IAF is part of the published approach procedure, it is considerc·d a mandatory part of the approach.

Finally, you ask whether a course reversal segment is optional "when one of the conditions ofFAR section 91.175(j) is not present• Section 91.175(j) states that in tLe case of a radar vector to a final approach course or fix, a timed approach from a hold ng fix, or an approach for which the procedures specifies "no procedure turn," no pilot may make a procedure turn unless cleared to do so by ATC.

Section 97.3(p) defines a procedure turn, in part, as a maneuver prescribed when it is necessary to reverse direction to establish the aircraft on a intenuediate or final appr' ach course. A SIAP may or may not prescribe a procedure tum based on the application <•f certain criteria contained in the TERPs. However, if a SIAP does contain a procedure: tum and ATC has cleared a pilot to execute the SIAP, the pilot must make the procedure 1urn when one of die conditions of Section 9 l. ! 75(i) is not present.

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If you have any questiQns regarding this matter, please contact Patricia R. Lane, Manager, Airnpace and Air Traffic Law Branch, at (202) 267-3491.

Sincerely,

Isl

Patricia R. Lane

for Donald P. Byrne

Assistant Chief Counsel

Regulations Division

March 11, 1994