logging instrument approach question

[teach2fly]

can you log an instrument approach if its VMC, single pilot IFR?...assuming you're IFR current and you just shot an ILS approach down to the DH (in an IFR flight plan and cleared for the approach) and full stop landing.

 

[bigD]

Heh - I don't think so. Otherwise, maintaining my instrument currency would be SOOOO much easier!

I think the kicker here is that if it's VFR - you really should have your eyes outside the airplane instead of buried in the needles.

 

[teach2fly]

I kinda know that already...just wonderin' if there's any way around the "actual instrument conditions" phrase in the FAR

 

[JungleJetFO]

Why can't you log it? Were you IFR and did you get cleared for the approach? An instrument approach is an approach no matter what the weather. If you aren't instrument rated and flying VFR, you need a safety pilot but that is the only restriction. Now, if you shoot the approach while flying VFR, that's a different story. Don't confuse flying VMC and flying VFR. One is weather and one is rules.

 

[ArcherB]

I am pretty sure you do need to be either " IMC" or if "VMC" you need to have a saftey pilot. The reasoning is that if you are single pilot in "VMC" even though you are on a instrument flight plan you should be looking outside and maintaining visual seperation with other airplanes.

 

[JungleJetFO]

Let's be reasonable here:

I am pretty sure you do need to be either " IMC" or if "VMC" you need to have a saftey pilot. The reasoning is that if you are single pilot in "VMC" even though you are on a instrument flight plan you should be looking outside and maintaining visual seperation with other airplanes.

If you are on an IFR flight plan and you shoot a non-precision or precision approach in VMC or IMC, log it. You shot the approach, why would you not log it? Think of it this way, say you do a VOR-DME approach with a 12 mile arc, would you not log it? Who cares what the weather is? Now, when you are talking instrument currency, that's a different story, you need a certain minimum actual or simulated approaches. But in every day flying and you want to shoot an approach, it all counts toward your totals, especially if you want to put it on your resume. I get cleared for the ILS all the time at work on VMC days, but I'm logging the approach.

 

[midlifeflyer]

Re: Let's be reasonable here:

If you are on an IFR flight plan and you shoot a non-precision or precision approach in VMC or IMC, log it. You shot the approach, why would you not log it? Think of it this way, say you do a VOR-DME approach with a 12 mile arc, would you not log it? Who cares what the weather is? Now, when you are talking instrument currency, that's a different story,

I think that's the point. Logging questions =usually= (though not always) include the unstated phrase "that counts for currency or toward a certificate or rating under the FAR"

Sure you can log the approach you flew entirely in VMC. You can also log the last time you sat in Seat 33C on a 757, the drive to the airport, and the ice cream sundae you had for desert at that great restaurant last week. They just don't count for anything.

 

[bobbysamd]

Whatever floats your boat . . . .

can you log an instrument approach if its VMC, single pilot IFR?...assuming you're IFR current and you just shot an ILS approach down to the DH (in an IFR flight plan and cleared for the approach) and full stop landing.

You can log it for the sake of the approach being a detail of that flight, but unless it was in actual IMC or simulated IFR with a safety pilot, it won't count for currency.

I agree with Midlifeflyer. Most of these logging questions seem to turn on the issue of currency. The spirit of the reg is to ensure a minimum currency maintenance standard.

Another opportunity to provide my FSI Chief Pilot instrument approach logging story. Our Chief Pilot was trying to convince us instructors that we could log the approaches that our students shot as our own for the purpose of currency. I don't recall at the moment what he saw in the FARs to give him that hare-brained notion; it doesn't matter because it obviously flies in the face of common sense. Under his theory, if you're training instrument students continuously you could be perpetually current without ever executing an approach yourself! I am sure his motivation was he was too cheap to provide instructors with airplane proficiency time.

 

[A Squared]

OK, folks, here's the real answer direct from the FAA's office of chief counsel:



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).

****non-pertinent text removed***

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 1.57(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.


****non-pertinent text removed***


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

Sincerely,

Donald P. Byrne
Assistant Chief Counsel


There it is, in IMC or simulated IMC right down to the minimums, or it doesn't count. Now, if you break out 100 feet above minimums ..... well, I think that is probably close enough, but logging an entire approach flown by yourself in VMC? Where do people dream up this crap?

Speaking of dreaming up crap, there seems to be a pretty persistent notion that you can put whatever you want in your logbook, as long as you don't use it for currency, or to meet requirements for a rating....think again folks. If you put something in your logbook that ain't right, the FAA considers it falsification, regardless of what your intent is. Go take a look at the NTSB records, the FAA *does* violate pilots for falsifying thier logbooks even if they don't use the falsifications for currency or qualification. The FAA's view on this is pretty clear from the enforcement records: Don't put anything in your logbook that you're not legally entitied to log. This view has been supported on appeal to the NTSB. If the FAA thinks that you're falsifying records, any records, they *WILL* and *DO* revoke your certificates. They take this stuff seriously, very seriously. Do a search of hte NTSB opinions and orders for 61.59 (falsification) enforcement. You'll find that in *every* one the FAA went for revocation of certificates, ususally all certificates, even if they're not related to the offense. Remember folks, revocation isn't just a little 30 day vacation like a suspension. Revocation means that you aren't a pilot any more. If you want to be a pilot again you have to go through the process again.


regards

 

[Timebuilder]

Listen to Bobby and Mark here, but please ignore what Bobby's old chief pilot was saying.

Rather than just "log approaches" for their own sake, log the approaches that conform to your best reason for logging approaches at all: instrument currency.

Approaches done in VMC, where you as a single pilot have the regulatory responsibility to see and avoid other aircraft, should not be logged for currency because if you are "heads down" the whole time you are not only being unsafe, you are also breaking a regulation. Being on an IFR flight plan makes no difference if the conditions are VMC.

You are left with two ways to log for currency in an airplane: under VMC conditions with a safety pilot, while "simulating" instrument conditions, and in IMC conditions.

If pilots could log approaches done any old way, I could have logged the DME A into Teterboro three times a week!

 

[A Squared]

I'm still shaking my head about that idiot JungleJetFO shooting his mouth off about logging approaches in VMC. Ok, ignoring the obvious, that logging approaches is supposed to demonstrate experience in flying approach procedures in IMC, what if you do follow junglejetfo's advice? Say for whatever reason the FAA has aksed to review your logbook, and they're interested in your IFR currency. They notice that you're logging approaches, but no IMC time, and no saftey pilot listed. Hmmm, so they look up the weather for that airport on that day in the archives....turns out they were reporting 100 sct 10 miles vis...hmmm doesn't sound like IMC to me.....busted. Keep in mind that they *are* going to go for revocation of your certificates.

regards

 

[midlifeflyer]

Re: Whatever floats your boat . . . .

I don't recall at the moment what he saw in the FARs to give him that hare-brained notion; it doesn't matter because it obviously flies in the face of common sense.

Actually this particular harebrained notion is supported by John Lynch's sometimes harebrained FAQ. He doesn't explain why, but the best argument that I could find that supports it goes something like this:

1. The FAR for landing currency specifically says "sole manipulator"
2. The FAR for instrument currency says "performed" approaches.
3. The different wording means that you =don't= have the be the sole manipulator in order to log the approach.
4. We're left with the FAR that says that a CFI can log instrument time when teaching in IMC.

The supporting common sense arguments tend to be:

1. That the CFI who is monitoring the student's approach is not only responsible for it (the justification for CFIs logging anything while giving instruction) but is working harder by needing to stay not only ahead of the airplane but ahead of the student.
2. That the CFI who is monitoring the student's approach is definitely doing a lot more in terms of performance than the pilot who is monitoring her autopilot flying the approach and who clearly can log it.

Personally, I'm not terribly impressed. Of course in Colorado the issue is academic anyway

 

[Timebuilder]

I'm not familiar with Lynch, but if looking at the totality of regulations, I'd include the fact that an SIC in a two-crew airplane can only log instrument time at all when he is flying the airplane, not as a "condition of flight", such as "night", which can always be logged.

If you think of the CFI as a "required crew member", or a "second in command", then he would have to be flying the airplane to log the approaches. Luckily, he can still log the IMC time, unlike the SIC!

 

[flx757]

I'd include the fact that an SIC in a two-crew airplane can only log instrument time at all when he is flying the airplane, not as a "condition of flight", such as "night", which can always be logged.

I disagree. FAR 61.51(b)(3) lists "conditions of flight" as (i) Day or night (ii) Actual instrument (iii) Simulated instrument conditions in flight, a flight simulator, or a flight training device.

If you believe you can always log "night" time "as a condition of flight", then by that same logic, you can log "instument" time.

Further, FAR 61.51(g) "Logging instrument flight time" states that a person may log instrument time when the person operates the aircraft solely be reference to instruments...(note it doesn't say is the sole manipulator of the controls.)
If an SIC is required for a two-pilot aircraft, then both pilots are operating the aircraft, and both may log the instrument time.

 

[midlifeflyer]

If you think of the CFI as a "required crew member", or a "second in command"

But a CFI is neither. The CFI logging regulations don't really have anything to do with the CFI as a crewmember of any kind. I think they are pretty much a policy decision by the FAA to let CFIs log certain things simply because they are acting as an instructor. In addition to allowing career track pilots to use instruction to build time, there's probably also a general recognition that there's no better way to learn something than to teach it.

For an example, take it out of the "hot" approach issue. Think of a CFI who is giving a flight review to a pilot a week before the pilot's previous review "expires." The pilot is in all respects current and qualified to act as PIC in the airplane being used for the review. On the other hand, the CFI lost her medical 3 years earlier due to an unfortunate heart condition.

Clearly, the CFI isn't (and can't be) a required crewmember. But just as clearly, the CFI gets to log PIC. If it were an IPC in actual under similar circumstances (pilot who is qualifies to act as PIC under IFR) , the CFI could even log actual!

 

[Timebuilder]

If you believe you can always log "night" time "as a condition of flight", then by that same logic, you can log "instument" time.

Doc seems to agree with you, and his "legal definition number ten" supports the idea that a Second in Command is "operating" the airplane, by definition.

I think we are getting into an area of interpretation based on our own ideas and those of others we have asked, which is always a murky area. I was referring to Lynch (whoever he may be) making reference to some regulations when I mentioned thinking about a CFI as a required crewmember, which Mark correctly pointed out is not the case. The operative word in my supposition was "if", used for example of looking at several regulations for guidance.

I recall seeing a regulation, which I have been unable to find today, that references a SIC being able to log all of the time spent controlling the aircraft by reference to the flight instruments. If that is correct, when the PIC or the autopilot is flying the airplane, the SIC can't be controlling by reference to the flight instuments. While logical, this may not be the "letter of the law".

If this approach to logging instrument time is incorrect, then I will chalk it up to being perhaps the best example of inconsistent regulatory oversight that I have come across.

 

[Timebuilder]

Ah, here we go.

In the ATP study guide, there is a reference to FAR 61.51:

"A second in command of a two pilot flight - may log as instrument flight time all of the time the second in command is controlling the airplane solely by reference to flight instruments" (my emphasis).

To me controlling sounds a lot more specific than operating, and sounds to me like a reference to having one's hands on the flight yoke, making control inputs.

Now, I'll confess, I can't find this wording in last year's seachable CD rom of the regs, but it's there in the ATP question bank, (number 9342) and may not be correct and up to date.

From my CD:
(g) Logging instrument flight time.
(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

What a nice feeling: to know that the material I am studying for the ATP may no longer be correct. Ah, the government.

 

[flx757]

The references to 61.51 which I quoted in my post above are from the current online version of the FARs, as well as my 2003 FAR/AIM.

The gist of my original post was to point out that, according to 61.51, instrument flight is a "condition of flight", the same as "night". Therefore, I didn't understand why you have no problem logging night time "all the time", but instrument time only when you were actually flying the airplane.

I'm not sure any of this made it any clearer, but to me, it seems clear that a both pilots of a required two-pilot crew may legally log actual instrument time anytime the aircraft is in IMC regardless who is the "flying pilot".

BTW, good luck with the ATP written.

 

[Timebuilder]

Therefore, I didn't understand why you have no problem logging night time "all the time", but instrument time only when you were actually flying the airplane.

It's because I had been studying information that apparently is so old as to be incorrect. That's very frustrating, as you might imagine. The word "controlling" sure sounds like the SIC is "flying the airplane":

"A second in command of a two pilot flight - may log as instrument flight time all of the time the second in command is controlling the airplane solely by reference to flight instruments".

Nice to have up to date information to study, eh?

 

[flx757]

Don't get me wrong. I understand totally about your ATP guide using the word "controlling", which the FARs do not, and how misleading, and therefore frustrating, that can be.

Really, all I was initially doing was pointing out that the FARs consider "instrument" to be a condition of flight the same as "night". It sort of went from there into the SIC thing.

Again, I wish you good luck with the ATP written. I'm sure you'll do well in spite of your study materials.

 

[teach2fly]

wow..this turned out to be an interesting discussion.

 

[Timebuilder]

Really, all I was initially doing was pointing out that the FARs consider "instrument" to be a condition of flight the same as "night".

Yes.

I thought that this particular reg was an "exception" to the theory that both night and IMC are "conditions of flight".

Maybe I'm just too used to these regs seeming arbitrary and contradictory, such as the whole question of the difference betwen the "acting" and "logging" of PIC time. To my way of thinking, the ONLY time a reasonable person would "log" something, PIC time for instance, would be when the had "acted" as PIC for the flight in question. As we have seen, this isn't the way the regs approach this, which makes them seem very arbitrary.

 

[midlifeflyer]

I was referring to Lynch (whoever he may be)

Just an FYI for the few who don't know at this stage of the game. John Lynch is with the FAA certification branch. To the extent that there really is one, he's the author of the 1997 revisions to Part 61. In an effort to standardize the way Examiners use the rules, the FAA's Regulatory Support Division (http://afs600.faa.gov/AFS640.htm) publishes a Part 61 and Part 141 FAQ. Lynch is the "guru" who answers the questions.

Unfortunately, Lynch's interpretations are not always correct. Fortunately, some these have been corrected from time to time, usually the result of comments from the FAA Legal Counsel's office, which is the final authority on what the FAA says the FAR mean. Unfortunately, in some cases, the correction came after Lynch, with one flick of his pen (keyboard?) contradicted 20 years of consistent FAA policy. Fortunately, the FAQ itself disclaims it's own authority. Unfortunately, until corrected, the FAQ is =the= guidance relied upon by DPEs and FSDOs. Fortunately, a bad interpretation, uniformly used, can sometimes be better that every region going off half-cocked with it's own version. Unfortunately, the regions sometimes go off half-cocked anyway.

 

[Timebuilder]

I think I was able to follow that whole paragraph about FAA thoughts.

Unfortunately.

 

[JungleJetFO]

I'm still shaking my head about that idiot JungleJetFO shooting his mouth off about logging approaches in VMC.

First of all, screw you.

There it is, in IMC or simulated IMC right down to the minimums, or it doesn't count. Now, if you break out 100 feet above minimums ..... well, I think that is probably close enough, but logging an entire approach flown by yourself in VMC? Where do people dream up this crap?

So why the hell are you dreaming up you're own crap? It's talking about shooting the approach down to minimums, not the weather "idiot". If the weather is IMC, that doesn't mean it has to be "at" minimums. If it did, no one would be able to maintain their currency. Last time I checked, IMC was below 1000/3.

Section 1.57(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.

When's the last time you updated your FAR/AIM, 1991? You might want to read the latest, it's changed a bit.

If you put something in your logbook that ain't right, the FAA considers it falsification

Logging an approach in VMC and recording it as actual is falsification. Logging an approach in VMC is not falsification. Idiot.

 

[A Squared]

JungleJetFO,

>>>>>If the weather is IMC, that doesn't mean it has to be "at" minimums. If it did, no one would be able to maintain their currency. Last time I checked, IMC was below 1000/3.

We can argue about exactly what the legal interpreteion means regarding how low the IMC conditions actually has to be, but that would be beside the point.

The point is that you claimed that you can log approaches performed in VMC which is completely wrong. Remember, that's what you were saying in your earlier posts. Here's what you wrote:

>>>An instrument approach is an approach no matter what the weather.

and;

>>>If you are on an IFR flight plan and you shoot a non-precision or precision approach in VMC or IMC, log it.

and;

>>>>Who cares what the weather is

The idea that you can log approaches flown entirely in VMC is an absurd fantasy. It makes about as much sense as logging instrument time when you are in VMC on an IFR flight plan. Even ignoring the legal implications of logging it, presenting such time as a measure of your experience is dishonest.

>>>>>>When's the last time you updated your FAR/AIM, 1991? You might want to read the latest, it's changed a bit.

Read a little more carefully there ace, that's a legal interpretation which was written in 1992. They obviously quoted the regulation as it was written then. I assumed that we were all intelligent enough that the obvious didn't need to be stated. Apparently that was a bad assumption.
Anyway, I am fully aware that the regulation is worded a bit differently now and that some of the requirements have been changed. The approaches are still required to be in simulated or actual instrument conditions.


>>>>Logging an approach in VMC is not falsification.

Oh, really? Do you have anything to back this up, or do you just beleive it because you really really want to log approaches in VMC? You want to bet your certificates on this?

 

[Timebuilder]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

 

[cjh]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

And talks to himself, thereby becoming his own safety pilot.

 

[A Squared]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

Well, I suppose that is possible. However there doesn't seem to be anything in his posts which suggest that, and he appears to be contradicting a poster who is telling him that he needs to simulate IMC and have a saftey pilot, and he's certainly made no attempt to clarify that he was speaking of logging approaches in VMC with a view limiting device and a safety pilot.

 

[Checks]

Ok, I will be honest when I say I have just skimmed the responses on here.

Let us look at the pertinent part of the reg:

(1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions,

Ok, so what does this say? It says you must fly the approach under actual or simulated instrument conditions.
What are actual instrument conditions??? Here is what the FAA legal counsel wrote regarding the definition of “actual instrument conditions”(because you won’t find a definition anywhere else)
--------------------------------------------------------------------------------
-"Actual" instrument flight conditions occur when some outside conditions make it necessary for the pilot to use the aircraft instruments in order to maintain adequate control over the aircraft. Typically, these conditions involve adverse weather conditions.
-----------------------------------------------------------------------------

So can I log the approach if the visibility is 2 miles and I am operating the aircraft solely by aircraft instruments while shooting the ILS down to DH? YES! Additionally, there is a difference between IMC and actual instrument conditions. If the ceiling at the airport is 900ft OVC and 10sm vis I would be in IMC conditions but not in actual instrument conditions(anything less than VMC is IMC).

Does it matter if I break out of the overcast layer just past the FAF? NO, unless you believe that actual instrument conditions are defined as 0/0. The key point is to stay on the aircraft instruments to DH and to be in “adverse weather conditions”

Can you claim to be in "adverse weather" when it is CAVU out? NO. Which means you can not log it legally.

Just my 2 cents