I'm with you on this one Frank. On a circling or straight in
approach, I dont see how a pilot can descend below the mda, to 100 ft
above the airport, level off, and still claim he is "continuously" in
a position from which a descent can be made "at a normal rate". Who
"normally" makes a descent to land at less than, say, 2 1/2 degrees?
The far could be better worded, I admit. However, I've never seen
anyone descend at say 1 degree, which an early descent well prior to a
VDP would entail.

91.175(c)Operation below DH or MDA. Where a DH or MDA is applicable,
no pilot may operate an aircraft ... at any airport below the
authorized MDA ... unless

(1) The aircraft is continuously in a position from which a descent to
a landing on the intended runway can be made at a normal rate of
descent using normal maneuvers...

my ramblings, Stan




On 18 Nov 2003 16:47:32 -0500, (Frank Ch. Eigler)
wrote:


"John Clonts" writes:

[...] 1) Does "having the runway environment in sight...make a
normal landing" in 91.175 mean its ok to descend below MDA, fly a
couple more miles to the airport and then fly the pattern (circle to
land), as long as the runway is still in sight. [...]

One thing that troubles me about this is your reference to
circling-to-land. Up here in Canada, the IFR rules say that a descent
from the MDA for circling can only be done at the "final descent for
landing" - basically for the final approach. (I believe there is a
similar restriction for straight-in landings too.)

Look at it another way. If there was no prohibition against
descending below the MDA in this circumstance, what would keep a pilot
from going to 100 AGL at the earliest hole through the clouds, and
skirting the ground all the way to the airport? You are obviously
leaving all the IAP obstruction clearance margins, but are not making
that explicit by requesting a contact approach. That doesn't sound
right.

- FChE