I guess what you mean is that if the observation is made but not reported
to someone other than me (as the pilot), then the requirement is not
satisfied.
Is there documentation supporting the concept that the report has to be
made to some government facility directly, and not relayed to ATC via the
pilot?
My take on it is that the =reason= the requirement is not satisfied is
that the observation is not "official" unless it meets certain
requirments, among them being made by a suitably qualified
("certificated?") observer.
So to re-pose the question - if the observation is in fact made by an
officialy certified observer, is it sufficient =then= that the pilot
relays it to ATC, or does the report have to go through some official
channels to be usable for a contact approach clearance? I'm not (of
course) asking what pilots and controllers would actually =do= under the
circumstances, but rather, what the FAA would throw at the pilot or
controller should there be an accident (and it could be proven that the
observation was correct, made by a certfied observer, but not delivered
to ATC except via the pilot).
Jose
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