ZSU APCH CTLR QUESTIONED FAC'S INTERPRETATION OF REQUIRED SEPARATION BETWEEN IFR AND SVFR ACFT WITHIN CLASS C AIRSPACE.

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I INVESTIGATED A COMPLAINT FROM THE SJU TWR ABOUT SVFR OPS. THE CTLR(S) HAD IFR AND SVFR INSIDE CLASS C AIRSPACE CLRED FOR THE APCH. THERE ARE MANY INTERPS. MINE; FOLLOWING WRITTEN PORTIONS OF ORDER 7110.65S; IS THAT SEPARATION BTWN SVFR AND IFR IS 500 FT BELOW AND NON RADAR SEPARATION LATERALLY. MEANING THAT YOU CANNOT HAVE AN IFR AND AN SVFR INSIDE THE SAME SURFACE AIRSPACE AT THE SAME TIME. MGMNT INTERP IS THAT YOU CAN USE RADAR SEPARATION (3 MI) IN BTWN. IFR AND SVFR IN SEQUENCE TO LAND. SOME CTLRS THINK THAT YOU CAN EVEN TELL AN SVFR TO FOLLOW OR MAINTAIN VISUAL SEPARATION FROM ANOTHER SVFR OR IFR INSIDE THE SAME AIRSPACE (DEPENDING ON WHO IS TRAINING YOU COULD RECEIVE DIFFERENT INTERP/INSTRUCTIONS). THE INVESTIGATION IS STILL ONGOING AND I CANNOT TEACH/BRIEF THIS ITEM BECAUSE OF THE DIFFERENCE OF OPINIONS. IN REALITY; I COULD BE WRONG BUT I THINK IS UNSAFE TO HAVE FOR AN SVFR IN FRONT OF AN IFR ALIGNED TO LAND THE SAME RWY WHEN THE SVFR CAN ACTUALLY REVERSE ITS COURSE TO STAY OUT OF THE CLOUDS. UNTIL WE RECEIVE INTERP; THIS EVENT CAN OCCUR MANY TIMES OVER.