14 CFR 91.175 — Takeoff and Landing Under IFR (the (c) Visual References List)

What does 14 CFR 91.175 cover?

14 CFR 91.175 establishes the rules for takeoff and landing under IFR, including the visual references a pilot must acquire before descending below DA/MDA and the takeoff minimums applicable to commercial operators. It is one of the most heavily tested regulations on the instrument rating checkride oral exam because it governs the most consequential moment of any IFR flight: the decision to land or execute a missed approach.

The regulation runs from subsection (a) through (k). For instrument rating candidates, the critical subsections are:

• (b) — defines the authorized DA/DH or MDA as the highest applicable among procedure, pilot qualification, or equipment

• (c) — the three conditions and 10 visual references required to continue below DA/MDA

• (d) — landing prohibition when flight visibility is below minimums
• (e) — mandatory missed approach when (c) conditions are not met

• (f) — takeoff minimums, which apply only to Parts 121, 125, 129, and 135 operators

What is the authorized DA/DH or MDA under 91.175(b)?

The authorized DA/MDA is the highest of three values, per 14 CFR 91.175(b): the minimums prescribed by the approach procedure itself, the minimums prescribed for the PIC based on qualifications or training, or the minimums appropriate for the aircraft's available equipment. All three must be compared before beginning the approach — the most restrictive value controls.

This matters on the oral exam because many candidates assume the published procedure minimums are always the answer. They are not. A pilot who lacks the required training for a Category II approach, for example, must use Cat I minimums even if the aircraft is capable and the procedure is published.

Cross-reference 14 CFR 91.169 for alternate airport weather minimums — those are a separate set of thresholds that govern whether an alternate is required on the IFR flight plan, not whether the approach can be flown at the destination.

What are the three conditions to descend below DA/MDA under 91.175(c)?

All three conditions must be met simultaneously before any pilot may operate below DA/MDA, per 14 CFR 91.175(c):

1. (c)(1) — Position: 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.

2. (c)(2) — Flight Visibility: The flight visibility is not less than the visibility prescribed in the standard instrument approach procedure being used.

3. (c)(3) — Visual References: At least one of the visual references for the intended runway is distinctly visible and identifiable to the pilot.

Note the specific language in (c)(2): flight visibility, not reported ground visibility. AIM Chapter 5 discusses the distinction — the PIC must assess actual in-flight visibility and confirm it meets published minimums. If flight visibility is adequate but reported RVR is not, the PIC's assessment governs for Part 91 operations.

What are the 10 visual references listed in 91.175(c)(3)?

The regulation lists exactly 10 visual references enumerated as (c)(3)(i) through (c)(3)(x) in 14 CFR 91.175(c)(3). At least one must be distinctly visible and identifiable before descent below DA/MDA:

1. (i) The approach light system
2. (ii) The threshold
3. (iii) The threshold markings
4. (iv) The threshold lights
5. (v) The runway end identifier lights (REIL)
6. (vi) The visual glideslope indicator (VASI, PAPI)
7. (vii) The touchdown zone or touchdown zone markings
8. (viii) The touchdown zone lights
9. (ix) The runway or runway markings
10. (x) The runway lights

Critical limitation on (i) — approach lights only: If the approach light system is the sole visual reference acquired, descent may not continue below 100 feet above the touchdown zone elevation (TDZE). Per 14 CFR 91.175(c)(3), the pilot may not descend below that altitude using approach lights alone "unless the red terminating bars or the red side row bars are also distinctly visible and identifiable." This is one of the most commonly tested nuances on the oral exam.

A useful way to organize the list is by proximity to the runway centerline:

What must a pilot do at DA/MDA when visual references are not established?

A pilot who reaches DA or the missed approach point without the required visual references must immediately execute the published missed approach procedure, per 14 CFR 91.175(e). The regulation is unambiguous: there is no provision to circle, descend further, or hover at DA/MDA hoping conditions improve.

The AIM reinforces this requirement in Chapter 5. The missed approach procedure begins at the missed approach point (MAP) for non-precision approaches and at DA for precision approaches. The pilot must comply with the published procedure — including any climb gradient requirements and initial heading — from that point forward.

Once on the missed approach, subsequent options depend on fuel, weather trends, and alternate planning completed before departure under 14 CFR 91.169. Cross-reference 14 CFR 91.177 for minimum IFR altitudes that govern any off-procedure routing during the missed approach or divert.

What are the takeoff minimums for Part 91 operators under 91.175(f)?

Part 91 non-commercial operators have no prescribed takeoff minimums under 14 CFR 91.175(f). Subsection (f) establishes takeoff minimums exclusively for persons operating under Parts 121, 125, 129, or 135. For those operators, the defaults are 1 statute mile (1 or 2 engines) and 1/2 statute mile (more than 2 engines or helicopters), unless a higher minimum is prescribed.

Part 91 pilots may legally depart in zero-zero conditions. That said, departing in conditions below published obstacle departure procedure (ODP) or SID minimums creates real risk: a loss of situational awareness or engine failure during initial climb in IMC with no visibility and no visual terrain reference has killed pilots. The FAA Instrument Procedures Handbook (FAA-H-8083-16B) addresses ODP planning and the importance of applying takeoff minimums as a matter of sound judgment even when not legally required.

For IFR cross-country planning, compare this against the alternate and fuel requirements in 14 CFR 91.169 and minimum enroute altitudes in 14 CFR 91.177.

What is the EFVS exception to 91.175(c)?

The Enhanced Flight Vision System (EFVS) exception is not in 91.175 — it is in a separate regulation, 14 CFR 91.176. Section 91.175(c) explicitly notes that its requirements apply except as provided by 91.176.

Under 91.176, a pilot using a qualified EFVS may continue below the DA/MDA using the EFVS image in lieu of natural visual references, subject to specific equipment, training, and operational requirements. Section 91.176(b) permits descent to 100 feet above TDZE using EFVS; 91.176(a) permits descent to touchdown for operators meeting additional requirements.

For the instrument rating checkride, you are expected to know that 91.176 exists and that it provides an alternative pathway — but most candidates are not expected to know its detailed requirements. The examiner is more likely to probe the standard 91.175(c) conditions and references list.

Practice Questions

1. You are flying the ILS 24 and break out at 400 feet AGL with the approach light system clearly in view but nothing else. The DA is 325 feet MSL. Can you continue below DA? If so, to what altitude?

2. You reach the missed approach point on a VOR approach with the runway environment not in sight. Flight visibility appears to be about 1/2 mile and the approach calls for 1 mile. What must you do, and what regulation governs?

3. Your DPE asks you to recite the three conditions of 91.175(c) before shooting an approach. Give all three in the correct order.

4. You are a Part 91 pilot departing IFR in fog with 1/8 mile RVR. Is this legal? What risk considerations apply?

5. The published approach minimums for the ILS you are shooting are DA 200 feet / RVR 1800. Your aircraft's ILS receiver is inoperative and you are flying the localizer-only. What is your authorized DA/MDA and why?

6. A student tells you that once you have the runway in sight, you are cleared to land regardless of flight visibility. Is this correct? Cite the specific regulation.

7. List all 10 visual references from 14 CFR 91.175(c)(3)(i) through (x) in order.

Frequently Asked Questions

Q: How many visual references are listed in 14 CFR 91.175(c)(3)?

Exactly 10. They are: approach light system, threshold, threshold markings, threshold lights, REIL, visual glideslope indicator (VASI/PAPI), touchdown zone, touchdown zone markings, touchdown zone lights, runway or runway markings, and runway lights. At least one must be distinctly visible and identifiable to continue below DA/MDA.

Q: Can you descend below DA if you only have the approach lights in sight?

Only to 100 feet above the touchdown zone elevation (TDZE). Under 14 CFR 91.175(c)(3), you may not descend below 100 feet AGL above the TDZE using the approach lights alone unless the red terminating bars or red side row bars are also distinctly visible and identifiable.

Q: Do Part 91 general aviation pilots have prescribed takeoff minimums?

No. Under 14 CFR 91.175(f), takeoff minimums apply only to persons operating under Parts 121, 125, 129, or 135. Part 91 non-commercial operators have no regulatory takeoff minimums, though good judgment and POH performance data always govern.

Q: What is the difference between DA and MDA in the context of 91.175(c)?

A Decision Altitude (DA) is used on precision and APV approaches — you make a continue-or-miss decision at DA without leveling off. A Minimum Descent Altitude (MDA) is used on non-precision approaches — you level off at the MDA and descend further only after acquiring visual references under 91.175(c).

Q: What must you do if you reach DA or MDA without the required visual references?

You must immediately execute the published missed approach procedure. Under 14 CFR 91.175(e), no pilot may continue an approach below DA/MDA or land when the required visual references are not established. There is no provision to circle, wait, or hold at DA/MDA.

Q: What is the enhanced flight vision system (EFVS) exception to 91.175(c)?

EFVS operations are governed by 14 CFR 91.176, not 91.175. Section 91.176 permits certain operators using a qualified EFVS to continue descent below DA/MDA using the EFVS image in lieu of natural visual references, subject to equipment and training requirements.

Q: What is the authorized DA/DH or MDA under 91.175(b)?

The authorized DA/MDA is the highest of: the DA/MDA prescribed by the approach procedure, the DA/MDA prescribed for the PIC based on qualifications, or the DA/MDA appropriate for the aircraft's available equipment. All three must be considered before beginning an approach.

Q: Does 91.175 apply to all IFR approaches, including GPS and RNAV approaches?

Yes. Section 91.175(c) applies to all instrument approach procedures. Whether you are flying an ILS, VOR, RNAV (GPS), or LPV approach, you must have at least one of the 10 listed visual references and meet all three conditions of (c)(1) through (c)(3) before continuing below DA/MDA.

Sources

• 14 CFR 91.175 — Takeoff and Landing Under IFR (eCFR)
• 14 CFR 91.175 — Cornell LII (readable text)
• 14 CFR 91.176 — EFVS Operations
• 14 CFR 91.169 — IFR Flight Plan: Alternate Airport Requirements
• 14 CFR 91.177 — Minimum Altitudes for IFR Operations
• FAA Instrument Rating ACS (FAA-S-ACS-8C)
• FAA Instrument Procedures Handbook (FAA-H-8083-16B)
• Aeronautical Information Manual (AIM), Chapter 5 Section 4

This article was researched from FAA primary sources (ACS, FAR/AIM, Instrument Procedures Handbook) with citations to current 14 CFR 91.175 (Cornell LII / eCFR) by MockDPE. Last updated: May 2026. If you spot an inaccuracy, email corrections@mockdpe.org.