wrote in message
...
On Tue, 4 Jan 2005 07:40:26 -0500, "Gary Drescher"
wrote:

You're citing the rules for descending below an MDA or DA. But the
question
is about descending below an intermediate fix.

If you have the requirements for descending below the MDA, you have
the requirements for descending below any intermediate altitudes.

Yes, but the way 91.175c puts it is "no pilot may operate...below the
authorized MDA or... below the authorized DH unless--...". Technically,
that doesn't even say you can go below the MDA or DH (that would be "a pilot
may operate below... if and only if--..."), though that's obviously what the
FAA meant. So as it stands, 91.175c (presumably) is meant to waive the
MDA/DH requirement under the specified conditions, but it's not obvious that
it's meant to waive the even stricter requirement given by a step-down
altitude, at a location where the step-down altitude applies. (Is the MDA/DA
even defined to apply during the approach segment where a higher step-down
altitude applies?)

--Gary