what counts as an approach?

Z

ZUM

New Member
If on an IFR flight plan in VMC would an approach count if it is being flown without foggles if flight is solely by reference to instruments? if not could you just fly it with foggles? The probem I see with this, is that in VMC it is the pilots responsibility to see and avoid traffic. Basically, how do you all stay current? Is a safety pilot the easiest answer?

Also, at what point does an approach count? Is it true that it counts as soon as the final approach fix is passed?

Thanks
 
I count approaches if I'm still on the gauges after the final approach fix.

Grab a saftey pilot, that's the only way you can count the approach if you're in VMC.
 
[ QUOTE ]
If on an IFR flight plan in VMC would an approach count if it is being flown without foggles if flight is solely by reference to instruments? if not could you just fly it with foggles? The problem I see with this, is that in VMC it is the pilots responsibility to see and avoid traffic.

[/ QUOTE ] It would count if you =had to= fly solely by reference to instruments, whatever the weather conditions are. Do a black hole approach over water in 3.5 NM visibility and you will probably work as hard to keep upright as if you were in the clouds.

But you can't "just not look". FAA legal opinions tell us that " 'Simulated' instrument conditions occur when the pilot's vision outside of the aircraft is intentionally restricted, such as by a hood or goggles."

And you absolutely can =not= fly with foggles or another view limiting device without a safety pilot. 91.109.

So I guess most of us who live in areas of minimal IMC use a safety pilot to maintain technical currency.

[/ QUOTE ]Also, at what point does an approach count? Is it true that it counts as soon as the final approach fix is passed?

[/ QUOTE ]Yes. No. Maybe. There are at least 3 and maybe more different answers to this one. Maybe my personal FAQ will put it in some kind of context.

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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:

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"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 below 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:

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"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 this 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 everything is susceptible to precise definition. Try to think of all of the scenarios and come out with a rule that covers every probable (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 to specifically say that approaches had to be flown to MDA or DA to count. They got a lot of comments, including one that said,

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"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!
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Thanks for the reply. That's kind of what I figured. When flying with a safety pilot, how is it logged in terms of PIC?
 
Much easier to just have to deal with the instrument competency check....
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Move to FL, I've gotten jack loads of actual in the past three days and had to divert twice due to t-storms popping up in the area. Although in all of that I have acutally logged only TWO approaches since I broke out of the clouds before the FAF. I use the same rule for logging approaches as CFII use. If you're IMC after the FAF, log it. I shoot appraoches with a safety pilot about once or twice a month to maintain currency, though. That way I don't get burned by my own rules.
 
[ QUOTE ]
Thanks for the reply. That's kind of what I figured. When flying with a safety pilot, how is it logged in terms of PIC?

[/ QUOTE ]
Depends. All a safety pilot needs to have are a private pilot certificate with the applicable aircraft category and class ratings and a current medical.

Beyond that, the FAR gives a few options for the safety pilot (SP)logging time =while the flying pilot (FP) is under the hood=. Although these flights tend to be in VMC and under VFR, you mentioned the possibility of doing this on an IFR flight, so here's the full range of options. Choose your poison
wink.gif


==============================
Standard safety pilot logging scenarios

Terminology and assumptions:
VFR and IFR refer to the rules of the flight. VMC and IMC refer to the visual conditions of the flight
FP is shorthand to refer to the Flying Pilot, the only one who is actually manipulating the controls. SP is the Safety Pilot
Both pilots are current and qualified to perform the duties asked of them.
No one in these scenarios is an instructor.

Scenario 1: Under VFR (FP under the hood):
1. Nobody has to be instrument rated and it doesn't matter if someone is.
2. FP logs PIC because she is the "sole manipulator of the controls of an aircraft for which the pilot is rated" 61.51(e)(1)
3. FP logs "simulated instrument time" for the time she is under the hood, because 61.51(b) requires that a log entry include the conditions of flight and one of those conditions is "simulated instrument" along with day and night.
4. SP may log PIC if SP is acting as PIC for the flight because he "is acting as pilot in command of an aircraft on which more than one pilot is required under ... the regulations under which the flight is conducted. 61.51(e)(1). Flight in simulated IMC is an operation that requires more than one pilot. 91.109(b). If SP is not acting as PIC, he may log SIC. 61.51(f).

Scenario 2: Under IFR in VMC (FP under the hood). FP is not instrument rated; SP is instrument rated:
1. Someone must be instrument rated since the flight is under IFR. SP must be acting as PIC because he's the only one who is legally capable of acting as PIC under IFR.
2. FP logs PIC because she is the "sole manipulator of the controls of an aircraft for which the pilot is rated" 61.51(e)(1)
3. FP logs "simulated instrument time" for the time she is under the hood, because 61.51(b) requires that a log entry include the conditions of flight and one of those conditions is "simulated instrument" along with day and night.
4. SP may log PIC because he is "is acting as pilot in command of an aircraft on which more than one pilot is required under ... the regulations under which the flight is conducted. 61.51(e)(1). Flight in simulated IMC is an operation that requires more than one pilot. 91.109(b).


Scenario 3: Under IFR in VMC (FP under the hood). FP is instrument rated; SP is not instrument rated:
1. Someone must be instrument rated since the flight is under IFR. FP must be acting as PIC because he's the only one who is legally capable of acting as PIC under IFR.
2. FP logs PIC because she is the "sole manipulator of the controls of an aircraft for which the pilot is rated" 61.51(e)(1)
3. FP logs "simulated instrument time" for the time she is under the hood, because 61.51(b) requires that a log entry include the conditions of flight and one of those conditions is "simulated instrument" along with day and night.
4. SP may log SIC because he is not acting as PIC but is performing pilot duties on a flight on which "more than one pilot is required under ... the regulations under which the flight is being conducted" 61.51(f)(2). Flight in simulated IMC is an operation that requires more than one pilot. 91.109(b).

Scenario 4: Under IFR in IMC. (No hood) FP is not instrument rated; SP is instrument rated:
1. Like Scenario 2, SP must be acting as PIC because he's the only one who is legally capable of acting as PIC under IFR.
2. FP logs PIC because she is the "sole manipulator of the controls of an aircraft for which the pilot is rated" 61.51(e)(1).
3. FP logs "actual instrument time" for the time she is under the hood, because 61.51(b) requires that a log entry include the conditions of flight and one of those conditions is "actual instrument" along with day and night.
4. SP logs nothing countable. (This is different in other countries)
a. Yes, he is =acting= as PIC, but hasn't fulfilled =any= conditions for logging it. There is no rule anywhere that says that one gets to =log= PIC by =acting= as PIC without there being some other condition. 61.51 gives you the universe of when you can log something. "Acting as PIC" standing alone, is not one of them.
b. This flight doesn't fit into the 61.51 "more than one pilot required" rule. Unlike simulated instrument flight which under 61.109 requires more than one pilot, there is no FAR that requires "more than one pilot" on a flight under IFR. True, the SP is required for the flight since he's the instrument-rated one, but he's the =only= one that's required.

Scenario 5: Under IFR in IMC. (FP under the hood) FP is not instrument rated; SP is instrument rated:
There's no clear answer from the FAA on this one. Some say that since it's actual IMC, it can't be simulated IMC. Therefore, no safety pilot is necessary and we apply the rules from Scenario 4.
Others argue that purpose of a safety pilot is to fulfill "see and avoid" responsibilities. Those obligations exist even in IMC and the FP is in no position to meet them even if she temporarily flies out of a cloud. So, even in IMC, if FP is hooded, the SP is required and the rules from Scenario 2 apply.

Scenario 6: Under IFR in IMC. FP under the hood. FP is instrument rated; SP is not instrument rated:
Same argument as Scenario 5. If you view the SP as required, we're under the same logging rules as Scenario 3. If you view the SP as not required, then we just have a flight by an instrument-rated pilot in IMC and the SP logs nothing.
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One important thing that should be understood but often isn't: In order for the SP to act as PIC, the FP must be qualified to do so (currency, all necessary endorsements, etc)
 
Good lord it actually makes sense now. So, I could go out with my buddy in an Arrow with him as FP and myself as SP. He has a complex sign-off, but I do not. Therefore, I could ACT as PIC, but not LOG as PIC since I don't have the endorsements to LOG PIC normally. However, I could log SIC since I am acting as a required crewmember. I can log that as Total Time,but not PIC time.
 
[ QUOTE ]
Good lord it actually makes sense now. So, I could go out with my buddy in an Arrow with him as FP and myself as SP. He has a complex sign-off, but I do not. Therefore, I could ACT as PIC, but not LOG as PIC since I don't have the endorsements to LOG PIC normally. However, I could log SIC since I am acting as a required crewmember. I can log that as Total Time,but not PIC time.

[/ QUOTE ]Not quite. Yes, you can go flying with your buddy in the Arrow. Yes, he can be the FP and you the SP. However, you can NOT ACT as PIC. In order for you to qualify to ACT as PIC, you must have all of the necessary endorsements, including the complex endorsement. Therefore, the best you can do as SP in the situation you described is LOG SIC time, during the time he is under the hood.

However, if you had the complex endorsement (and were current, etc.) to ACT as PIC ~and~ you and your buddy agree that you will be ACTING PIC, then you could LOG PIC when he is under the hood (ACTING PIC/Required Crewmember Rule) and he could also LOG PIC for the entire flight (Sole Manipulator Rule).
 
[ QUOTE ]
Good lord it actually makes sense now. So, I could go out with my buddy in an Arrow with him as FP and myself as SP. He has a complex sign-off, but I do not. Therefore, I could ACT as PIC, but not LOG as PIC since I don't have the endorsements to LOG PIC normally. However, I could log SIC since I am acting as a required crewmember. I can log that as Total Time,but not PIC time.

[/ QUOTE ]Not quite. Based on your final conclusion, I think you probably do understand it (it only makes sense if you break it down to components), but hit the trigger too quickly. Maybe still a bit of confusion with that always difficult separation between "acting" and "logging"

In order to ACT as PIC, you =must= always have the proper endorsements. So, in your scenario, since you do not have the necessary endorsements, you may not ACT as PIC.


Rewriting what you said, it ends up as
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So, I could go out with my buddy in an Arrow with him as FP and myself as SP. He has a complex sign-off, but I do not. Therefore, I could not ACT as PIC, [and can] not LOG as PIC since I don't have the endorsements to ACT as PIC.. However, I could log SIC since I am acting as a required crewmember. I can log that as Total Time,but not PIC time

==============================
 
Yeah, next time I'll say what I mean, not mean what I say.
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Too many SIC PICs in there and I got confused.
 
Yeah...just be smart and keep your local friendly instructor's piggy bank full. Get an IPC every 6 months.

I'm honestly blown away that the government hasn't required a more restrictive IPC requirement to tell you the truth. You try flying with someone that hasn't flown instruments in 13 months. You'll be glad you spent 2 hours with an instructor getting your stuff back together.

Remember...bad habits come from someone not beating them out of you...
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