"Sydney Hoeltzli" wrote in message
...

Yes, it does. Why would you think it doesn't?
[14CFR 91.129
does not specify that the pilot must establish or maintain
communications with the control tower, simply with "the ATC
facility providing air traffic services". ]

14CFR 91.126d as referenced in 14CFR 91.129a?


A radar facility
which provides approach services to a class D airport certainly
counts.

According to whom? I see several references to the "ATC facility having
jurisdiction over the Class D airspace area." Can there be more than one
facility with that authority?