Instrument Approach
- Thread starter Rodelu
- Start date
stuckingfk
Well-Known Member
I read an article by Richard Collins in his magazine about this,..........excuse me, I mean this month's Flying Magazine. Once the approach starts, if any cloud is penetrated for any amount of time, it is considered an actual approach.
EatSleepFly
Well-Known Member
The FAA's opinion is that you must be inside the final in IMC for the approach to be counted.
EatSleepFly
Well-Known Member
Sure do...This is a link to the 61/141 FAQ site:
http://av-info.faa.gov/data/640otherfaq/pt61-18.doc
And this is the question/answer that deals with it:
[ QUOTE ]
QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?
ANSWER: §61.51(g)(1) and §61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach that would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is NO.
{Q&A-291}
[/ QUOTE ]
Now, this site is not regulatory, but it does show the way the FAA interprets things. Good reference, really.
http://av-info.faa.gov/data/640otherfaq/pt61-18.doc
And this is the question/answer that deals with it:
[ QUOTE ]
QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?
ANSWER: §61.51(g)(1) and §61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach that would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is NO.
{Q&A-291}
[/ QUOTE ]
Now, this site is not regulatory, but it does show the way the FAA interprets things. Good reference, really.
Visceral
Well-Known Member
"As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach that would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate."
This says that to log an actual instrument approach, you have to go down to the DH or MDA. So, if you broke out (insert number here) feet above the DH, you couldn't log it? I don't believe that at all. Also, what if you started in VMC until 1 mile inside the FAF where you have to descend all the way in solid clouds? Some airline pilots might be lucky enough to not have to go to absolute mins in some parts of the country. This would mean they might have currency issues. This topic occupies a huge thread at Flightinfo.com where they bring up outdated material (logging 6 hours instead of 6 approaches) and FAA legal counsel briefs. I still don't know the correct, updated answer to this. So goes the old adage, "get what you can, log what you need."
This says that to log an actual instrument approach, you have to go down to the DH or MDA. So, if you broke out (insert number here) feet above the DH, you couldn't log it? I don't believe that at all. Also, what if you started in VMC until 1 mile inside the FAF where you have to descend all the way in solid clouds? Some airline pilots might be lucky enough to not have to go to absolute mins in some parts of the country. This would mean they might have currency issues. This topic occupies a huge thread at Flightinfo.com where they bring up outdated material (logging 6 hours instead of 6 approaches) and FAA legal counsel briefs. I still don't know the correct, updated answer to this. So goes the old adage, "get what you can, log what you need."
EatSleepFly
Well-Known Member
I agree Visceral.
Personally-
When I'm single-pilot, IFR: I log the approach if, due to weather, a visual approach is out of the question. If that means there's a thin overcast and 2 miles vis. at 2100 ft., but I'm in the clear at the MDA of 1700, I'm still logging the approach.
When I'm giving instrument instruction: I log the approach if we're inside the final and still in IMC (as per a different question on the same link above).
Personally-
When I'm single-pilot, IFR: I log the approach if, due to weather, a visual approach is out of the question. If that means there's a thin overcast and 2 miles vis. at 2100 ft., but I'm in the clear at the MDA of 1700, I'm still logging the approach.
When I'm giving instrument instruction: I log the approach if we're inside the final and still in IMC (as per a different question on the same link above).
mtsu_av8er
Well-Known Member
I log the approach as an actual approach if I'm IMC after being established on "...a published portion of the approach...", either on the final approach course inbound, or procedure turn inbound. If I break out on a 3 mile final, so be it. It's still an actual approach, and I had no way of doing a visual.
I actually had a situation once where it was severe clear, 10+ miles of visibility, but there were just enough clouds on the final approach course (about 3 miles from the runway) to make it hard-core IMC. So, instead of taking the visual, I requested vectors for the ILS, and got to log an actual approach (turned out to be bumpa-licious clouds that day...should have taken the visual!!!).
I actually had a situation once where it was severe clear, 10+ miles of visibility, but there were just enough clouds on the final approach course (about 3 miles from the runway) to make it hard-core IMC. So, instead of taking the visual, I requested vectors for the ILS, and got to log an actual approach (turned out to be bumpa-licious clouds that day...should have taken the visual!!!).
EatSleepFly
Well-Known Member
[ QUOTE ]
turned out to be bumpa-licious clouds that day
[/ QUOTE ]
bumpa-licious.....thats a new one! I like that!
turned out to be bumpa-licious clouds that day
[/ QUOTE ]
bumpa-licious.....thats a new one! I like that!
MidlifeFlyer
Well-Known Member
This is a wonderful topic. Opinions vary considerably. The following (from my personal FAQ) is more of a history lesson than a definitive answer to the question:
If you look at 61.57(c) (instrument currency) you'll see that the 6 instrument approaches that have to have been done in the prior 6 months must be "performed and logged under actual or simulated instrument conditions..." Some of the other requirements have changed through the years, but this one has been with us for a while.
Sounds pretty simple, doesn't it? Except some idiot thought to ask, "How much actual is actual?" What if you pass through a single scattered cloud on the way down for a total of 5 seconds of "actual"? Can you count the approach?
Sometime in 1989 or 1990, it seems FAAviation News ran an article that said that you had to fly the approach to minimums in IMC in order for it to count. Someone wrote in pointing out the illogic of a rule that meant that a very experienced pilot who flew hard IMC all the time would probably not be able to log the approaches, since most approaches don't involve breaking out at minimums.
In the July/August 1990 issue, FAAAviation News replied to the writer:
"Once you have been cleared for and have initiated an approach in IMC, you may log that approach for instrument currency, regardless of the altitude at which you break out of the clouds"
Problem is that this answer doesn't work either. Now, you're on a feeder route to the IAF above the cloud deck when you're cleared for the approach. You fly the full approach, enter the clouds just above glideslope intercept and break out at 200 AGL with 1/4 mile visibility. Oops! Sorry! You were not "cleared for and have initiated an approach in IMC".
(You're starting to see why I called the person who asked the "How much" question for the first time an idiot.)
In 1992, the FAA legal counsel chimed in:
"Second, you questioned how low a pilot must descend (i.e., minimum descent altitude or decision height or full stop landing) on the six instrument approaches he must log to meet the recent IFR experience requirements specified in FAR Section 61.57(e)(1)(i) (14 CFR Sec. 61.57 (e)(1)(i)). You also asked if an instrument approach "counts" if only part of the approach is conducted in actual IFR conditions. Section 61.57(e)(1)(i) states that:
No pilot may act as pilot in command under IFR, nor in weather conditions less than the minimums prescribed for VFR, unless he has, within the past 6 calendar months - (i) In the case of an aircraft other than a glider, logged at least 6 hours of instrument time under actual or simulated IFR conditions, at least 3 of which were in flight in the category of aircraft involved, including at least six instrument approaches, or passed an instrument competency check in the category of aircraft involved.
For currency purposes, an instrument approach under Section 61.57(e) (1)(i) may be flown in either actual or simulated IFR conditions. Further, unless the instrument approach procedure must be abandoned for safety reasons, we believe the pilot must follow the instrument approach procedure to minimum descent altitude or decision height."
Uh-oh! If you take the opinion at faces value, there's that reasoning again that essentially says that if you don't go missed, you can't log it.
There is a strong school of thought out there that says that what it "looks like" the FAA Counsel said is not what they meant. Note that despite the question, although the answer says that you have to follow the procedure all the way (unless it's not safe), it does not say that you have to follow the procedure all the way "in actual IFR conditions."
(You can see where his is much better fodder for arguments than anything else in the logging arena.)
The camp that says that the legal counsel didn't mean all the way in IMC (call them the "Rule of Reason" school) are essentially saying that "How much" is one of those undefined terms. Not everthing is susceptible to precise definition. Try to thing of all of the scenarios and come out with a rule that covers every probably (let alone possible) approach scenario. How many pages did you use?
When Part 61 was revised in 1997, there was a proposal to write the rule so that, in order to count, approaches had to be flown to MDA or DA to count. They got a lot of comments, including one that said,
"One commenter suggests revising the definition to permit the pilot to terminate the approach prior to DH or MDA for safety reasons. Another commenter proposes to define "instrument approach" as " * * * an approach procedure defined in part 97 and conducted in accordance with that procedure or as directed by ATC to a point beyond an initial approach fix defined for that procedure." The commenter explains that this definition would allow for logging instrument approaches that require some portion of the published approach procedure to be followed in order for the pilot to establish visual references to the runway"
The FAA decided against the new requirement.
Some point to the fact that the FAA posted this comment as support for the rule of reason approach.
Whew!
If you look at 61.57(c) (instrument currency) you'll see that the 6 instrument approaches that have to have been done in the prior 6 months must be "performed and logged under actual or simulated instrument conditions..." Some of the other requirements have changed through the years, but this one has been with us for a while.
Sounds pretty simple, doesn't it? Except some idiot thought to ask, "How much actual is actual?" What if you pass through a single scattered cloud on the way down for a total of 5 seconds of "actual"? Can you count the approach?
Sometime in 1989 or 1990, it seems FAAviation News ran an article that said that you had to fly the approach to minimums in IMC in order for it to count. Someone wrote in pointing out the illogic of a rule that meant that a very experienced pilot who flew hard IMC all the time would probably not be able to log the approaches, since most approaches don't involve breaking out at minimums.
In the July/August 1990 issue, FAAAviation News replied to the writer:
"Once you have been cleared for and have initiated an approach in IMC, you may log that approach for instrument currency, regardless of the altitude at which you break out of the clouds"
Problem is that this answer doesn't work either. Now, you're on a feeder route to the IAF above the cloud deck when you're cleared for the approach. You fly the full approach, enter the clouds just above glideslope intercept and break out at 200 AGL with 1/4 mile visibility. Oops! Sorry! You were not "cleared for and have initiated an approach in IMC".
(You're starting to see why I called the person who asked the "How much" question for the first time an idiot.)
In 1992, the FAA legal counsel chimed in:
"Second, you questioned how low a pilot must descend (i.e., minimum descent altitude or decision height or full stop landing) on the six instrument approaches he must log to meet the recent IFR experience requirements specified in FAR Section 61.57(e)(1)(i) (14 CFR Sec. 61.57 (e)(1)(i)). You also asked if an instrument approach "counts" if only part of the approach is conducted in actual IFR conditions. Section 61.57(e)(1)(i) states that:
No pilot may act as pilot in command under IFR, nor in weather conditions less than the minimums prescribed for VFR, unless he has, within the past 6 calendar months - (i) In the case of an aircraft other than a glider, logged at least 6 hours of instrument time under actual or simulated IFR conditions, at least 3 of which were in flight in the category of aircraft involved, including at least six instrument approaches, or passed an instrument competency check in the category of aircraft involved.
For currency purposes, an instrument approach under Section 61.57(e) (1)(i) may be flown in either actual or simulated IFR conditions. Further, unless the instrument approach procedure must be abandoned for safety reasons, we believe the pilot must follow the instrument approach procedure to minimum descent altitude or decision height."
Uh-oh! If you take the opinion at faces value, there's that reasoning again that essentially says that if you don't go missed, you can't log it.
There is a strong school of thought out there that says that what it "looks like" the FAA Counsel said is not what they meant. Note that despite the question, although the answer says that you have to follow the procedure all the way (unless it's not safe), it does not say that you have to follow the procedure all the way "in actual IFR conditions."
(You can see where his is much better fodder for arguments than anything else in the logging arena.)
The camp that says that the legal counsel didn't mean all the way in IMC (call them the "Rule of Reason" school) are essentially saying that "How much" is one of those undefined terms. Not everthing is susceptible to precise definition. Try to thing of all of the scenarios and come out with a rule that covers every probably (let alone possible) approach scenario. How many pages did you use?
When Part 61 was revised in 1997, there was a proposal to write the rule so that, in order to count, approaches had to be flown to MDA or DA to count. They got a lot of comments, including one that said,
"One commenter suggests revising the definition to permit the pilot to terminate the approach prior to DH or MDA for safety reasons. Another commenter proposes to define "instrument approach" as " * * * an approach procedure defined in part 97 and conducted in accordance with that procedure or as directed by ATC to a point beyond an initial approach fix defined for that procedure." The commenter explains that this definition would allow for logging instrument approaches that require some portion of the published approach procedure to be followed in order for the pilot to establish visual references to the runway"
The FAA decided against the new requirement.
Some point to the fact that the FAA posted this comment as support for the rule of reason approach.
Whew!
Rodelu
Well-Known Member
I contacted Aopa and this is what I got... hope it helps...
Thank you for contacting AOPA. There are no official guidelines as to how much of an approach needs to be in actual conditions for it to be logged as such. A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC.
If the approaches are simulated, we have a letter of interpretation from the FAA that states the approach be flown to the DH/MDA for it to be logged.
Please contact me with any further questions you may have.
Ian Twombly
Aviation Services Department
Aircraft Owners and Pilots Association
1-800-872-2672
Thank you for contacting AOPA. There are no official guidelines as to how much of an approach needs to be in actual conditions for it to be logged as such. A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC.
If the approaches are simulated, we have a letter of interpretation from the FAA that states the approach be flown to the DH/MDA for it to be logged.
Please contact me with any further questions you may have.
Ian Twombly
Aviation Services Department
Aircraft Owners and Pilots Association
1-800-872-2672
E_Dawg
Moderator
[ QUOTE ]
A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC. [/i]
[/ QUOTE ]
The approach can be logged, or the approach can be logged as 'actual'?
A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC. [/i]
[/ QUOTE ]
The approach can be logged, or the approach can be logged as 'actual'?
Visceral
Well-Known Member
[ QUOTE ]
I contacted Aopa and this is what I got... hope it helps...
Thank you for contacting AOPA. There are no official guidelines as to how much of an approach needs to be in actual conditions for it to be logged as such. A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC.
If the approaches are simulated, we have a letter of interpretation from the FAA that states the approach be flown to the DH/MDA for it to be logged.
Please contact me with any further questions you may have.
Ian Twombly
Aviation Services Department
Aircraft Owners and Pilots Association
1-800-872-2672
[/ QUOTE ]
Thanks for the information. I plan on using that interpretation until the FAA gets clearer guidance published. Skyguyed, I don't think understand your question. I don't have a block in my logbook that lets me sort approaches into actual or simulated. I guess that information can be inferred.
I contacted Aopa and this is what I got... hope it helps...
Thank you for contacting AOPA. There are no official guidelines as to how much of an approach needs to be in actual conditions for it to be logged as such. A letter published in an FAA magazine in July of 1990 says that if you are cleared for the approach in actual conditions, the entire approach can be logged as actual from that point on, even if you come into VMC.
If the approaches are simulated, we have a letter of interpretation from the FAA that states the approach be flown to the DH/MDA for it to be logged.
Please contact me with any further questions you may have.
Ian Twombly
Aviation Services Department
Aircraft Owners and Pilots Association
1-800-872-2672
[/ QUOTE ]
Thanks for the information. I plan on using that interpretation until the FAA gets clearer guidance published. Skyguyed, I don't think understand your question. I don't have a block in my logbook that lets me sort approaches into actual or simulated. I guess that information can be inferred.
MidlifeFlyer
Well-Known Member
[ QUOTE ]
The approach can be logged, or the approach can be logged as 'actual'?
[/ QUOTE ]I think you can safely assume that when AOPA says something can be logged, there are referring to being able to legitimately log it for the purposes of counting toward currency or the requirements for a certificate or rating.
An approach not in actual or simulated conditions can't be logged for currency purposes at all.
The approach can be logged, or the approach can be logged as 'actual'?
[/ QUOTE ]I think you can safely assume that when AOPA says something can be logged, there are referring to being able to legitimately log it for the purposes of counting toward currency or the requirements for a certificate or rating.
An approach not in actual or simulated conditions can't be logged for currency purposes at all.