20 August 2014
Background:
When a pilot files an IFR flightplan in accordance with CFR 14 91.169, they are required to file a suitable alternate airport with the only exception being described in paragraph (b). This exception is conditional based on:
(b) Paragraph (a)(2) of this section does not apply if :
(1) Part 97 of this chapter prescribes a standard instrument approach procedure to, or a special instrument approach procedure has been issued by the Administrator to the operator for, the first airport of intended landing; and
…
This wording permits an IFR flight to an airport without an instrument approach as long as an alternate is specified. However, if the aircraft is not equipped to fly any of the Part 97 standard Instrument approaches at the first airport of intended landing, may the pilot still conduct the flight as long as they have specified a suitable alternate that they are equipped to fly. To be able to complete a landing at the first airport of intended landing requires that the aircraft be able to descend from the minimum IFR enroute altitude in VFR conditions as they are not equipped to fly any of the approaches in a similar way if they had filed to an airport without any approaches. Would this be a violation of CFR 91.205 (d)(2) as long as they filed a suitable alternate airport which has approaches that the aircraft is equipped to fly. For example would it be permissible for an aircraft to file an IFR flightplan to an airport that only had RNAV (GPS) approaches and the aircraft was only equipped with a VOR/ILS navigation equipment as long as they selected a suitable alternate airport that had VOR or ILS approaches that the aircraft could fly?