seagull
Well-Known Member
Thanks for your comments. As I said, I don't know all the internal workings of the Chief Counsel office, and I never implied or meant to imply that the RC was the last word. Perhaps I'm wrong, but I would think that the RC would forward anything like this to the Chef Counsel, at which time the CC could disagree with the position, but, perhaps not, I'm only speculating at this point.
In regards to this particular subject, I doubt anyone would ever be violated for not including a PAPI as a visual reference. I also think that relying on information from the RC's office, who works for the CC, would have some mitigating influence on any violation.
I'm not implying that you or anyone has to accept the letter, I just passed it on because another poster asked for it. Beyond that, I have no interest.
As somebody who DOES know how much of the internal FAA working are, I can tell you that you are incorrect that the RC would forward this to the AGC office. It might happen, but I wouldn't count on it. Even if they do, unless the AGC issues an interp IN WRITING, it is worthless if you have some incident and they decide to enforce.
On the second point, you can doubt it all you want, but it is a very subjective call. If you blow a tire and the touchdown point was before the VASI aim point, they can pin that on a higher than normal rate of descent leading to that tire failure (just an example). Falls under 91.13 as well.
Oh, and 91.129 looks to me like it applies in entirety to large and turbine powered, but 91.13 still applies if anything goes wrong. You might look for interps here
http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/interpretations/
Regardless, you need to be very careful. This is not too far different than the issue of people thinking that they are assured a 3 degree path from MDA to the runway on non-precision approaches to runways not served by an ILS...