Interesting-
Twist on the thread- how would they View an instructional flight when the CFI intends for the student to execute a go around- as there was never intent to land and that would violate the 500ft rules…
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No problem at all. Despite the lousy writing in the NTSB's Palmer decision, I don't think it has anything to do with go-arounds, low passes, or runway inspection
at an appropriate location, like a runway.
This is from the Chief Counsel's
2009 Anderson Interpretation. It's about the meaning of "congested area," but it includes this, with citations to prior interpretations and decisions.
The FAA has determined that" § 91.119 does generally not apply to aircraft operations within airport traffic patterns," and that "aircraft operating within a traffic pattern are excepted from the regulation for a considerable portion of each pattern, i.e., during climb to pattern altitude following each takeoff, and during descent from pattern altitude prior to each landing." Legal Interpretation to Frank J. Deighan, from Donald Byrne, Assistant Chief Counsel (Oct. 30, 1997).
With respect to touch and go landings, the interpretation noted that the takeoff and landing exception to § 91.119 "applies equally to all practice approaches, including repeated 'touch and go,' 'stop and go,' and 'low approach' operations ..." Id. We would like to emphasize that the NTSB has also applied the § 91.119 takeoff or landing exception to touch and go landings and other practice maneuvers. See Administrator v. McCollough, NTSB Order No. EA-4020 (Nov. 4, 1993) (stating that simulated landings fall under the section 91.119 exception); Administrator v. Johnson, NTSB Order No. EA-739 (Jul. 31, 1975) ("[T]hese practice maneuvers come within the takeoff or landing exemption to the [section 91.119] restrictions because their purpose is to improve a pilot's capabilities in those operations."). Therefore, if the operation is not within the traffic pattern, or involves the approaches noted above, the pilot must operate in accordance with §91.119. (my emphasis)