Denver

The confusion here I imagine is because we are assuming a standard 200 and a half ILS where you are going to have visual reference if you are at or above published minimum flight visibility at DH. The geometry works out as such and they designed it this way on purpose.

So now imagine the Reno ILS when your flight visibility you have determined at DH is 6 miles and the minimums are 7 miles but you barely have the approach lights in sight and lets say this distance is 6 miles from the aircraft. The way I read 91.175 is that you cannot descend below this very high 2200 or so foot DH because your flight visibility is below that stated on the approach plate. The other side of the argument is that you can descend down to 100 feet above but just cannot continue further if it is still under 7 miles.

In other words 3(i) is simply one of the other 10 items of required visual reference but has it's separate clause about a limitation on using the approach lights. I do not read anywhere that it says you can ignore the visibility if you can see them. In other words 3(i) is not an exemption to (c)(2) but I think many read it as such.

Correct me if I am wrong but 6.2.7 just talks about the requirements to continue an approach once beyond the FAF with new weather that is now below minimums. 91.175 C2 still governs once at DH for the visual portion.


Note that between (c) (2) and (3) the word "and" exists and not the word "or"


(c) Operation below DA/ DH or MDA. Except as provided in paragraph (l) of this section, where a DA/DH or MDA is applicable, no pilot may operate an aircraft, except a military aircraft of the United States, below the authorized MDA or continue an approach below the authorized DA/DH 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, and for operations conducted under part 121 or part 135 unless that descent rate will allow touchdown to occur within the touchdown zone of the runway of intended landing;

(2) The flight visibility is not less than the visibility prescribed in the standard instrument approach being used; and

(3) Except for a Category II or Category III approach where any necessary visual reference requirements are specified by the Administrator, at least one of the following visual references for the intended runway is distinctly visible and identifiable to the pilot:

(i) The approach light system, except that the pilot may not descend below 100 feet above the touchdown zone elevation using the approach lights as a reference unless the red terminating bars or the red side row bars are also distinctly visible and identifiable.

(ii) The threshold.

(iii) The threshold markings.

(iv) The threshold lights.

(v) The runway end identifier lights.

(vi) The visual approach slope indicator.

(vii) The touchdown zone or touchdown zone markings.

(viii) The touchdown zone lights.

(ix) The runway or runway markings.

(x) The runway lights.