What constitutes an instrument approach

[yfly]

Can anyone tell me what the parameters need to be in order to log an instrument approach? My boss says we need to log 2 approaches every 30 days to stay ahead of currency requirements. Can anyone tell me where I can verify what constitutes a "loggable" approach. If I am in severe clear tracking the localizer (without foggles) can I log that approach? I would like to have something tangible ( in writing) to go on, no opinion or urban legend.

 

[NYCPilot]

Off hand, I'd have to say any time you are in actual or under the hood and fly an approach down to minimums as sole manipulator. As far as the full approach or vectors to final, I don't think it matters.

 

[avbug]

If you're strictly under Part 91, then the instrument currency requirements are clear. To log the approach, you must be in instrument conditions (actual or simulated), and the approach must be flown to minimums. Regulation and FAA Chief Legal Counsel Opinion (legal interpretation) to follow:

§ 61.57 Recent flight experience: Pilot in command.
c) Instrument experience. Except as provided in paragraph (e) of this section, no person may act as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR, unless within the preceding 6 calendar months, that person has:
(1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or flight training device that is representative of the aircraft category for the instrument privileges sought -
(i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of navigation systems.


Note: I have deleted the non-relevant portions of this legal interpretation, as they don't apply to the question at hand. Note also that the codification and specific requirements for the regulation have changed since this interpretation; no longer are 6 hours of instrument time required. This does not change the basis for the interpretation, nor it's specific application...the approach must be flown in actual or simulated instrument conditions and must be flown to minimums:

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

 

[mar]

Nothing tangible

If I am in severe clear tracking the localizer (without foggles) can I log that approach? I would like to have something tangible ( in writing) to go on, no opinion or urban legend.

You need to go to Doc's FAR BBS www.propilot.com

I remember someone asking a similiar question a couple years ago. If I get bored enough, later tonight, I'll go look it up but if you beat me to it that's fine too.

Basically I remember him saying there's nothing in black and white about this issue but naturally, as with everything else, you're better off treating it was if you had to defend it in front of a judge.

His advice, which I remember quite distinctly, was don't log it unless you've actually navigated from the FAF to some point towards the MAP under IMC.

It doesn't need to be the full approach to mins but it can't just be turning onto the procedure turn and breaking out either.

Good luck.

 

[Dumbledore]

I read a very different legal interpretation quite a number of years ago (perhaps 16) that basically stated that If you conduct any portion of a Part 97 approved instrument approach procedure in IMC then you've conducted an insturment approach suitable for currency requirements.

To certain extent I think this actually makes sense. Theoretically, any segment of an IAP flown in IMC is absolutely necessary for a letdown into an airport if that's the way you're cleared. Therefore the procedure you follow must be flown in an appropriate fashion that should keep the rust from forming on your mental hull.

Now, I realize that many approaches become more challenging in that they require a more rapid crosscheck as you get closer to the airport and that, presumably, is the reason that the interpretation above syas what it says about descending to MDA or DH (decision height - their term not mine - and valid at the time). However, this is not always the case. Take an approach that proceeds outbound from a VOR 12 to 20 miles to get to the airport. The needles become LESS sensitive and while one could suggest that greater care is required to keep the needle in the middle for accuracy's sake, the fact is that the needle won't move from the center as rapidly as it would if one were approaching the VOR.

I think it's also important to recognize that the opinion already cited here answers a particular question - and a loaded one, if you ask me. The question was how low a pilot has to fly on an approach in order to count it for currency purposes. A question formulated this way will never be answered in anything less than a 100% conservative way by ANYONE at the FAA.

The net effect of this interpretation is that if I go and shoot an approach to an altitude of 300’ AGL and break out, but the ILS plate says I can go down to 200’ AGL, then officially I haven’t conducted an approach to the level required to meet currency requirements. I think we can all agree that this is simply hogwash.

In another example of the flawed nature of this interpretation, suppose an airport is below even special VFR minimums. In this case there would be no legal way to be navigating except by some sort of approach procedure (assuming you’re landing of course). You wouldn’t have to get to MDA or DH to do that either and yet that wouldn’t qualify as a currency-maintaining procedure under this interpretation.

A FAR better question might be, "When is a pilot considered to have executed an instrument letdown in accordance with a Part 97 procedure?" Note the emphasis on the past tense of "executed." I have a feeling that this question might be answered differently. It would be hard for the FAA to suggest that you HAVE executed letdown in accordance with Part 97 and also say that you HAVE NOT done an instrument approach.

I dunno. As others have said the best thing is to use common sense. If you used some or all of the sum total of your skill in instrument flying to get where you wanted (or needed) to be then I think you count the approach.

 

[mar]

I found it and guess what?

http://www.propilot.com/doc/bbs/messages/4880.html

It cites the same legal opinion that Avbug posted.

Let me rephrase my quote below.

It doesn't need to be the full approach to mins but it can't just be turning onto the procedure turn and breaking out either.

It should read: "It doesn't need to be the full approach--but it *must* be continued to mins--even if you break out early. Breaking out on the procedure turn and then making a visual pattern does *not* count. You need to pass the FAF in IMC."

 

[avbug]

I think we can all agree that this is simply hogwash.

I certainly wouldn't agree it's hogwash, but then you've been given the interpretation by the FAA Chief Legal Counsel, and it defines the regulation as put forth by the Adminsitrator. What anybody "agrees" on is irrelevant to the issue, and only serves to cloud the matter.

The approach must be flown in intrument conditions to minimums to be counted toward currency. Period.

 

[midlifeflyer]

There's a bunch of different views on this one and somehting to support them all.

FWIW, most of them are summarized in my FAQ on "How Much Actual Is Required to Log an Instrument Approach?"

http://www.midlifeflight.com/faq/faq.php?s=2#4

 

[Dumbledore]

I certainly wouldn't agree it's hogwash...

Okay, everyone but YOU agrees that flying an approach to within seconds of its terminus as charted but not being able to count it as one click towards currency is hogwash. You can sit on the bench.

What anybody "agrees" on is irrelevant to the issue, and only serves to cloud the matter.

Not really. It's stuff like this that forms the basis for legal argument. All that's needed is a case. Unfortunately there'll probably never be one. Those most inclined to fight an action against them by the FAA are those who use their license as a meal ticket and are exempted from Part 61 IFR currency by their air carrier proficiency checks. They probably have the money to spend on an artful defense while the poor sap who falls out because he logged approaches that didn't conform to the interpretation you offered is gonna take the suspension. Besides, just because you haven't located a ruling that overturns this opinion it doesn't mean that it doesn't exist. It just means that you haven't found it.

The approach must be flown in intrument conditions to minimums to be counted toward currency. Period.

Not so fast. They did say unless safety precluded it. But okay, I'll tell you what. I'll do it my way and you do it yours. If you're as worldly as you claim to be then you also know that there are very few places where you genuinely need to fly all the way to miniums on a regular basis. If you happen to be located in one more power to you but if you're not you're screwed. As usual, the FAA's made their rules unusable in the real world - and you're right there with them to make sure it's to minimums.

Good job there buddy.

 

[midlifeflyer]

Not really. It's stuff like this that forms the basis for legal argument. All that's needed is a case. Unfortunately there'll probably never be one.

Actually, the absence of a case is a pretty good indication of the real handling of the rule. There are plenty of certificate actions that involve pilots who are not except from currency-based-on-actual. Almost every incident involves a logbook review and falsification is treated very seriously by the FAA.

All that was needed was an incident involving an instrument flight. Under the "IMC all the way to minimums" interpretation, just about any approach other than a missed approach doesn't count for currency.