FAA INSPECTORS QUESTION THE VALIDITY OF AN ARPT IFR APCH PROC RESTR IN CIRCLING TO LAND AND THE ARPT REQUIRED TFC PATTERN TURNS FOR LNDG BEING IN CONFLICT.

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ATTACHED YOU WILL FIND COPIES OF 2 DOCUMENTS: 1) FAR 91.127 (B)(1) AND; 2) THE APCH PLATE FOR VACAVILLE/NUT TREE (O45). THE UNSAFE ISSUE AT HAND IS THE CONFLICT BTWN THE CIRCLING LIMITATIONS ON THE APCH PLATE AND THE OPERATING RULES AS DESCRIBED IN THE FAR. FAR 91.127 IS FOUND IN SUBPART B -- FLT RULES GENERAL OF PART 91. IT APPEARS TO REQUIRE ALL PLTS TO CONFORM TO THE ARPT DISPLAYS FOR THE LCL TFC PATTERN. IN THE CASE OF VACAVILLE/NUT TREE (O45); THE VISUAL MARKINGS REQUIRE AN AIRPLANE LNDG ON RWY 20 TO MAKE ALL TURNS TO THE R AND WHEN LNDG ON RWY 02 ALL TURNS ARE TO BE TO THE L. IN OTHER WORDS ALL TURNS; IN THE NORMAL TFC PATTERN; AT VACAVILLE/NUT TREE (O45) ARE REQUIRED TO BE ON THE W SIDE OF THE ARPT. THE APCH PLATE FOR VACAVILLE/NUT TREE (O45) SHOWS A FINAL APCH FLT PATH FROM THE FINAL APCH FIX ON THE SACRAMENTO 241 RADIAL. THIS MEANS THAT AN ACFT MAKING THIS APCH WILL BE COMING FROM THE NE. THE APCH PLATE FURTHER PROHIBITS 'CIRCLING W OF THE ARPT.' THIS REQUIREMENT IS BASED UPON TERRAIN. IN ORDER TO COMPLY WITH THE CIRCLING LIMITATION ON THE APCH PLATE A PLT TRANSITIONING FROM THE APCH TO LNDG IS REQUIRED TO MAKE ALL TURNS FOR RWY 20 TO THE L AND WHEN LNDG ON RWY 02 ALL TURNS ARE TO BE TO THE R. THIS DOES NOT APPEAR TO COMPLY WITH FAR 91.127 (B)(1). MORE IMPORTANTLY; THIS CONFLICT OF INFO HAS THE POTENTIAL TO CAUSE A MID AIR COLLISION BTWN AN INBOUND IFR AIRPLANE AND A VFR AIRPLANE IN THE TFC PATTERN. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: DISCUSSION WITH ONE OF THE RPTRS RESULTED IN THE FACT THAT NO RECOMMENDATION FOR CHANGE IS NECESSARY SINCE THE VFR TFC PATTERN TURN RULE PROVIDES RELIEF FOR THE IFR APCH INSTRUCTIONS BY STATING THAT UNLESS OTHERWISE INSTRUCTED BY ATC! THEREFORE; WHEN OPERATING ON AN IFR CLRNC; ANY INFO ON THE APCH 'PLATE' IS CONSIDERED ATC INSTRUCTIONS; WHICH WOULD BE RELIEF FROM THE FAR REQUIREMENT TO ADHERE TO THE VFR TFC PATTERN! THE APPARENT REASONING FOR THE INST APCH CHART TO INSTRUCT THAT 'CIRCLING TO THE W OF THE ARPT IS PROHIBITED;' IS THAT IN IMC THE ACFT ALT WOULD BE BELOW THE ARPT ACCEPTABLE NOISE ABATEMENT ALT OF 800 FT AGL; AND WOULD THEREFORE; NOT BE IN KEEPING WITH THE NOISE OR TERRAIN CLRNC RECOMMENDATIONS.