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Is a CVFP in Part 97?
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Not that I can tell.
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Sec. 91.175 Takeoff and landing under IFR.
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One potential loophole is " Unless otherwise authorized by the
Administrator", the same escape clause for vectors to final, visual
and contact approaches.
Another out is that as long as the aircraft maintains the 91.177
obstacle clearances, there is arguably no "letdown" in progress. ATC
can tell you to intercept a radial and give you a descent, but I infer
that isn't a "letdown" until descending below the 91.177 altitudes.
The above seems unlikely, given the terrain in the area.
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