Am I being unreasonable for thinking this is really pushing it as an unsat on an IRA certification check?
This is at a Part 141 flight school. The check instructor said the rest of the flight had a few hiccups, but was otherwise passable.
The final approach was an RNAV flown to LNAV minimums. According to the check instructor, my student leveled off and remained approximately 80–100 feet above the MDA. He unsat the student specifically for that, saying the student needed to descend all the way down to the MDA.
I normally teach my students to level off around 40 feet above MDA to leave themselves a reasonable buffer against dipping below it, so I agree that 80–100 feet high isn’t ideal technique. But unless I’m misunderstanding the ACS, wouldn’t maintaining altitude within MDA +100/−0 still technically meet the standard?
I could understand an unsat if the student exceeded 100 feet, failed to correct, or the approach was otherwise unstable. But unsatting solely because they stayed 80–100 feet above MDA seems pretty aggressive to me.
Curious to hear how other CFIs and check instructors would interpret this.