Logging approaches

[troy]

What does it take to log an insturment approach? Is there a required mimimum time in IMC? Where is it in the FAR?

 

[avbug]

14 CFR 61.57(b). The approach must be in instrument conditions, either simulated or instrument. It must be flown completely, as backed up by legal interpretations; it must be completely flown by reference to instruments, and must be flown to minimums/MAP, as applicable.

You can log any instrument approach, but for recency of experience, the flight approach should reflect experience which is conducive to proficiency. This must include the full approach (not broken off just after intercepting the course inbound, or what is really a visual approach. It must be flown by reference to minimums. The spirit of the law fully supports this. It's all about staying current, despite the fact that the letter of the law is woefully inadequate.

 

[TDTURBO]

avbug,

Does that mean I can't log an approach I shot in IMC if I break out 100 ft above MDA or DH? Since I didn't fly it to minimums under "the hood or in actual" then it doesn't count? I bet there are allot of pilots that log otherwise! If this rule is to be interpreted literally, then 99% of approaches logged are logged under the hood since it is very rare to fly any approach in actual conditions down to minimums, agreed?

 

[avbug]

TD,

The following legal interpretation was given in response to this question, and is binding. The enumeration of the specific FAR reference has changed, but the intent of the regulation has not, nor has the efficacy of the interpretation. Note that this interpretation was written when six hours of instrument time were also required for currency. While this is no longer a regulation, and the specific currency requirement reference has changed, the interpretation is still binding.

The current reference in the FAR is 61.57(b), which requires that the approach be flown in instrument conditions, either actual or simulated.

I would postulate that while a pilot may break out 100' above minimums, he or she may still continue the approach by reference to instruments without "looking out." This is more a matter of good cockpit discipline than cheating; the PF on instruments should stay on instruments until the required reference is called. The PNF is half-in, half-out, and maintains a visual lookout until the PF identifies the runway environment. At that point a role reversal occurs with the PF looking out, and the PNF on the gages. The PF may choose to remain on instruments to minimums, rather than making a visual transition earlier, and still accomplish the intent of the FAR.

By the same token, who is to know or question the fact that the PF transitioned earlier and continued by reference to the electronic guidance? The intent is clear; that the pilot flying the approach do so by reference to instruments, and fly the complete approach.

Of course, there is no requirement for a minimum time in simulated or actual instrument conditions to qualify the approach. The entire approach must be performed by reference to instruments.

I have ommitted the non-relevant parts of the letter of interpretation, for brevity.

January 28, 1992
(no name given)

This is in response to your October 24, 1991, letter in which you asked several questions about certain Federal Aviation Regulations (FAR).

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.

Please do not hesitate to contact us if you require any further information in this regard.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel

 

[TDTURBO]

Thanks avbug,

I guess if you fly single pilot IFR allot, it could be unsafe to "stay in the cockpit" once you break out and are in VFR hence slamming into another VFR plane around the airport environment just to meet the precise defintion in the FARs to legally log the approach. If I'm alone, I am going to look out as soon as possible no matter what. I recently was cleared for a VOR approach and was told of "VFR traffic" in the vicinity. The vis was 1/2 mile and the ceiling was 600 agl, I did log the approach as would anyone else but I wasn't about to stay on the guages to MDA with other illegal traffic around. What would you do?

 

[avbug]

TD,

Anybody who knows me understands that I am a fanatic about "see and be seen;" I'll never fault a pilot for busting his eyeballs looking for traffic.

I would surmise that as you were well within the definition of instrument conditions throughout the approach, no one could fault you.

The FAA takes the viewpoint that the approach must be conducted to minimums in instrument conditions. That's the legality of it. My personal feeling is that the regulation speaks to proficiency. Did the approach make you more proficient, and did you benift from the approach? If the answer is yes, then in my opinion, that approach ought to be counted for proficiency.

On a legal basis, you must be able to defend your logging of that approach. Will the FAA ever look at your logbooks, then pull out weather reports from the time you landed and compare to see if instrument conditions existed? No. Only if there is an accident on that particular approach. That's something uniqe about aviation in the United States; we self-certify most everything. A student pilot goes on a cross country flight and logs it. How do we know he went? He says so. How do we know you flew your approaches? You say so.

Legally, that's acceptable. In fact, in strictly technical legal terms, it would appear that in many cases the FAA is more concerned that it's properly documented, than properly done. The paperwork is the thing, to butcher bill shakespeare. A private pilot flys skydivers...but doesn't take money. The private pilot gets stuck with a vioation for compensation or hire...not because of having conducted the flight, but because logging the time represents compensation. Some things make sense, others sometimes defy rational explaination.

In other countries, proof is required of training, proficiency, cross country, etc. Not here. For that reason alone, if you say you flew the approach, you flew the approach. You date the entry, but no one logs the actual time it took place. How would the FAA know what time to check the weather reports, if any were available? If there was only ASOS, how would they ever know?

There's the letter of the law, the spirit of the law, and judgement. Much like a SIC logging instrument time, it all comes down to judgement.

 

[TDTURBO]

avbug,

Thank you as usual for your incredibly articulate response and common sense approach! I was just curious as to YOUR thoughts irrespective of rote FAR interpretation.

Where do you find the time?

Thanks again!


P.S. You should change your name to avspock, I think it fits!

 

[bushman]

Somewhere in my instrument training I read how you couldn't log an approach for currency unless you have passed the FAF in simulated or IMC conditions inbound. I looked up 61.57 and couldn't find anything that said "to minimums". Can you be more specific about its location in the regs? I probably just overlooked it.

 

[avbug]

Bushman,

If you'll re-read this thread, you'll find the legal interpretation copied in my previous reply. The interpretation, given by FAA Assistant Chief Counsel Donald Byrne, is a binding interpretation of the regulations set forth by the Administrator. This interpretation is all that is required.

 

[cjh]

I don't recall ever reading anything to that effect in training manuals, but if you're a fan of "Doc's FAR Pages" there was a discussion last year on the subject. Here's the link to one specific thread:
http://www.propilot.com/doc/bbs/messages//4859.html

Also, here's another Doc reply to someone asking the same question.

"I have copied an excerpt from an FAA legal opinion on the topic. It appears that the FAA is not saying that you must be in instrument conditions all the way to the MAP, but that you must continue the approach PROCEDURE to the published minimums in order to count it for recency of experience purposes. It also appears (in other opinions) that the FAA is saying that you must be in instrument conditions at least until passing the FAF.
I think a bit of judgment comes in handy here. Do you really want to maintain your IFR recency by flying approaches that are only conducted in instrument conditions for a short period? Probably not. But the FAA has never said that you must be in instrument conditions all the way to the MAP -- otherwise you would only be logging your missed appraoches... But you DO need to conduct the approach to minimums -- e.g. as if you were trying to land from the approach -- in order to count it for recency of experience.
I hope this helps!
Regards,
Doc "
The letter he copied is the 1/28/92 document already posted elsewhere in this thread.