What constitutes an instrument approach

yfly

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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

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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

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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

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Nothing tangible

yfly said:
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.
 

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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.
 
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mar

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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.

mar said:
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

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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.
 

Dumbledore

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avbug said:
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.

avbug said:
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.

avbug said:
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

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Dumbledore said:
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.
 

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I think this is all open to interpretation and the FAA will look the other way when accepting an approach logged for currency. For face value, it will be presumed that you have appropriately conducted an approach that meets the FAR’s requirement when it is logged in you logbook. A sort of “don’t ask, don’t tell policy.”

Remember, it's you who should really be concerned, not the FAA, about what constitutes an approach and why. The rule was put in place to provide a minimum of safety achieved through maintaining proficiency by shooting multiple approaches within a given period of time. For all intents and purposes, an approach flown down to just above minimums under IMC conditions, after breaking out can be considered an approach. It is more than likely, that you will still be following the glideslope and localizer indications while transitioning into a visual approach for the landing runway. This will entail a shift in scan for the respective indications. It can easily be agreed that the ability to successfully complete an approach under these conditions will require this visual transition. It is inherently a component of any IAP.

The purpose of this currency mandate is to provide pilots with a guideline so that they may maintain a minimum level of proficiency in conducting an approach safely under actual instrument conditions. More than six approaches in actual or simulated conditions as well as flying approaches of varying difficulty and precisions, should theoretically improve ones ability to accurately fly an approach. To merely get vectored around 6 times into an ILS at your home field does little other than to make you proficient at flying 6 ILS approaches into your home field. But it will legally make you current.

Not to lose sight of the original issue here, if you feel that you have flown what constitutes an approach and have sharpened your skills in conducting the approach, it will in practicality be an exercise in proficiency. This generally means that should you be in IMC, and have flown the approach close to the minimums, it would be acceptable to log it as an approach. As I stated before, there will inherently be a visual transition period which is part of any approach and can be considered in being classified as a component of the approach. It is also a truth, that while transitioning, you will momentarily be shifting your scan from inside to outside and back. Actual time can be logged any time the aircraft is being controlled solely by instruments. During this transition, it is and will be logged as actual. It is mere seconds from say, 150 above minimums (where you break out) to minimums. In 15 seconds you will have descended 150’ assuming a descent rate of 600 FPM at a GS of 120 knots. Within this 15 seconds which is mere fractions of a tenth of an hour, you will invariable be on instruments at least half the time, with the other half being dedicated to the visual scan and transition. This would normally constitute flying an approach.
 

mar

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I wouldn't bet my certs on it.

NYCPilot said:
I think this is all open to interpretation and the FAA will look the other way when accepting an approach logged for currency. For face value, it will be presumed that you have appropriately conducted an approach that meets the FAR’s requirement when it is logged in you logbook. A sort of “don’t ask, don’t tell policy.”

Remember, it's you who should really be concerned, not the FAA, about what constitutes an approach and why.
I'd recommend a slightly more defensive position. I worked way too hard for my certs to take such a casual attitude.

I know I can fly. The FAA doesn't. It's my responsibility to log everything I need to prove I'm legal. The burden is on me, not them.

Good luck.
 

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mar said:
I'd recommend a slightly more defensive position. I worked way too hard for my certs to take such a casual attitude.
mar said:
I know I can fly. The FAA doesn't. It's my responsibility to log everything I need to prove I'm legal. The burden is on me, not them.



Good luck.

By no means do I advocate a casual policy regarding these regs., especially one that was implemented on the basis of safety in a precarious environment such as during an instrument approach in IMC.

My intent was to illustrate that one can log an approach for currency should you execute one in IMC, down to just above minimums, as was proposed in an earlier post. The necessity of logging approaches for currency lies upon the pilot to do so in accordance within the FAA prescribed rules. If one has completed an approach as described, it is fair to log it as an approach. Once it is in the logbook, it has been recorded as a matter of fact and should indeed suffice to fulfill the currency requirements.

The determination of whether it is an approach is entirely up to you, in that you should honestly appraise whether what you executed would be considered an exercise in proficiency. This is why the rule was implemented. The execution of an approach within a specific time frame should allow you to be capable to fly one, within a 6 month period to an acceptable level of standard. Obviously, we all differ in skill level, and too many pilots go out and shoot some quick approaches under the hood just to be "legal." No where in the regs. does it say that these approaches have to be to ATP or IP standards. Sloppy or tight, you've flown 6 and so go out into low IFR. Obviously, this is not what the rules intended.

During simulated instrument conditions, it is clear-cut that they should be flown down to minimums in order to account for the currency requirement. What we have is a situation where an approach was conducted in IMC but where the aircraft broke out just above minimums. The question is, should this be logged as an approach as per the currency criteria. As I postulated in my previous post, yes, I believe it can. Normally, an approach flown from the FAF to minimums would constitute an approach. I am not saying that if you fly down to 500’ above minimums and you think you did a good job, that you should log it. But as I stated before, if it is very close to minimums and occurs under the circumstances that I outlined in my previous post, than it is acceptable to log as a currency approach. Once again, if you’ve logged it, the FAA will be apt to assume that you conducted the approach within the guidelines set forth for currency. Once this has been entered into your logbook, you have accounted for it. The logbook attests to your having established the requirements.

As described in my previous post, you will still be on the LOC and GS (albeit visually for a percentage of this time) after breaking out and RADAR will reveal that you were on the rails.
 

avbug

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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.

I can sit on the bench then, for stating the FAA Administrator's policy as prescribed by the Administrator's official mouthpiece? Let's see, this "everybody" of whom you speak, all the opinionated everyone's not sitting on the bench...which one of them was chartered by an act of congress to regulate aviation in the United States of America? Would that be you? No, no. I don't think so. Would that be me? No, not really. How about everyone? No, wrong again.

That would be the FAA Administrator, who has the power and authorization and responsibility to make regulation and enforce it, and to interpret it. Interpretations explaining the regulation and it's application are made by the FAA Chief Legal Counsel, as delegated by the Administrator. Other opinions outside of that don't really matter. Yours, included. I'm not stating my opinion, only the official stand and policy of the Administrator. On what authority do you base your comments, exactly?

Oh, that's right. Opinion. Lots of weight behind that, isn't there?

Not really. It's stuff like this that forms the basis for legal argument.
Not really. This isn't even debatable, and the Administrators interpretations are fully defensible in adminstrative court. The Administrator has clearly stipulated that an approach must be conducted in instrument conditions, simulated or actual, and must be flown to minimums, period. The administrator has made it possible for every approach to count by including the provision that simulated instrument flight is the same as actual with respect to currency and the ability to count the approach, meaning that a person in the dry desert has the same opportunity to fly in instrument conditions to minimums as someone does in the fog of marthas vineyard...no excuses for not being current, no excuses for not having available instrument conditions to minimums...nothing to debate.

I find your arguement amusing...someone who merely likes to argue. Much like putting a blotch of the color black before you, and you attempting to call it white and find a way to argue the case. There's no arguement here; the matter is very clear.

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.
Negative, and what an arrogant attitude. The regulation is applied to everyone. Further, the regulation provides that a SIC under 135 air carrier regulations must still comply with the PIC instrument currency requirements of Part 61. That, however, is not relevant to the issue, which is the clearly defined question of what constitutes a legal instrument approach for logging purposes. Again, you're attempting to cloud the issue with non-relevant information, when it's very clear cut. The approach must be conducted in instrument conditions and flown to minimums. Period.

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.
Have you? Didn't think so, as there isn't one, and there won't be. An ALJ isn't going to "overturn" regulation, and this isn't a legal rendering of judgement...there's nothing to "overturn." Do you not understand that? This is regulation, and the clarification thereof by the same person and entity chartered by an act of congress to produce and enforce the regulation. It's not done by popular vote, and it's not put up for debate before an administrative court. The ALJ will consider weather someone has met the requirements of the regulation and the guilt of violation, but not the efficacy of the regulation itself. The ALJ doesn't have the discretion to "overturn" regulation, nor is the legal interpretation, which is nothing more than an official clarification of the Administrator's policy, open to being "overturned." Again, there's nothing to argue. The approach must be flown to minimums, and must be flown in instrument conditions, per official policy.

Weather you choose to like it or adhere to it is your business, but there is no room to debate the policy of the Administrator...ie, the regulation. It's clear.

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.
You do whatever you want to do. But the forum here, and the question asked, isn't about what dumbledore's opinion is. It's about regulation, about the authoritative, official policy of the Administrator as prescribed by an Act of Congress...you do whatever you want, but it's really irrelevant to the topic, which is what constitutes a legal instrument approach for currency, to meet the requirements of the regulation. That matter, of course, is very clear, and very cut and dried...it must be conducted in instrument conditions and it must be conducted down to minimums to count...I'm sure you're getting this, by now.

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.
Now, now. Let's not make it personal. This isn't my interpretation or policy...it's that of the Administrator (remember the one given authority to do so by an Act of Congress??). Take it up with the Administrator.

We've covered this, of course. The Administrator has made it clear that anybody, anywhere, can meet the currency requirements, by clearly stating that the approach must be flown down down to minimums, and must be executed in instrument conditions. By clarifying the fact that instrument conditions are either actual or simulated, the Administrator has equally and fairly applied the regulation to ensure that everybody can complete the requisite approaches, even when it's clear and a million.
 

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What avbug states is correct, if we interpret it to the letter of the law. In order for it to "technically" count as an approach, you must fly from the FAF to the MDA/DA under actual or simulated conditions.

Just to clarify my stance as per my previous posts, should it be misinterpreted outside of these clear-cut parameters, although the ceiling or visibility precluded you from remaining on the instruments right down to minimums, for all practical purposes, you have flown the approach. This really only applies to a situation where you were just short of staying on the instruments at minimums. Although I cite an arbitray figure (150') it must be within reason that breaking out from anything much higher, might not be considered an approach for currency purposes. Anything at or below this figure may reasonable be logged in good faith to fulfill the said requirements.

Once again, I state that you as the pilot have the discretion to log what you deem appropriate as an approach. For those who are by the book, and will not log it unless they have been at the minimums on the instruments in IMC, then do so. But in keeping with this pedantic view, you will most likely be in a situation where you will be going missed if you have to go this far down before going visually. There has to be a point at where one may reasonable assume that the fulfillment of an approach has taken place. Maybe it is fair to say that at 50' above minimums would be more prudent. But this might be cheating yourself out of something more or less loggable. If you've flown the approach, you've achieved some level of practice in executing the approach, which is what the rule intended in practicality, and so to split hairs as to whether it is an apporach or not may be futile.
 

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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.

Maybe its my blonde hair, the 35+ hours of flight time in 6 days, or I am just that dense, but I dont see or get how the above paragraph states you have to fly the approach to mins ENTIRELY in IMC or Foggled. I read that as you must fly the IAP in IMC/Foggled but you must go down to MDA/DA, ie no straight and level course tracking, you must make a descent.

Maybe its just fancy twiddly winks, or the fact I cant see straight, but I dont see the requirement to be IMC to the MDA or DA.
 

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That's right. To follow an IAP is more than just being under the hood. It requires the procedures and adherence to charted numbers (alt., radials, headings, etc.). It is reasonable to assume that if you follow all of the procedures and track properly along with flying reasonable close to the minimums, you've conducted an approach. Remember, the PURPOSE of this is to ensure proficiency through mandated currency requirements. If you've accomplished all of this, log the approach.
 

avbug

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Once again, I state that you as the pilot have the discretion to log what you deem appropriate as an approach.
No, you do not have that discretion, if the logging is done for the purposes of meeting recency of experience requirments. If you chose to do so, you choose to do so...but you do not have the legal right nor discretion to do so. Do as you will, but it is not your discretion, and doing so is indeed contrary to the regulation.

For those who are by the book, and will not log it unless they have been at the minimums on the instruments in IMC, then do so.
No, this has been covered quite thoroughly so far, but IMC really has nothing to do with the question at hand. Instrument conditions, simulated, or actual.

If you've flown the approach, you've achieved some level of practice in executing the approach, which is what the rule intended in practicality, and so to split hairs as to whether it is an apporach or not may be futile.
Did you write the regulation and know that with certainty? (I once had a Director of Operations who responded that yes, he did write the regulation...). No, you didn't...don't try to clarify regulation with justification. At least you got some level of practice, and that's good enough...a little like Jack Nicolson as the President of The United States in Mars Attacks... "We've still got two out of three branches of the Federal Government...and that ain't bad!"

How about not doing night landings to a full stop? At least you get a little practice out of it. How about doing the approach proceedure turn only? At least you got a little practice out of it. How about doing landing currency by just going around each time. After all, they say a good approach equals a good landing, and you at least got a little practice out of it. Sort of like having sex by kissing and holding hands. Not quite all the way, but at least you got something.

Justification is the narcotic of the soul...but neither soul nor narcotic has any place in a discussion of legality. What you choose to do is your business, but don't justify contravention of the regulation by opinion or shades of grey. It's not grey, it's clear...you must fly the approach in instrument conditions (actual or simulated) and must fly it to minimums unless it must be abandoned for safety reasons. Period.
 

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avbug said:
No, this has been covered quite thoroughly so far, but IMC really has nothing to do with the question at hand. Instrument conditions, simulated, or actual.
I have probably reiterated the fact that it can indeed be done in both simulated and actual numerous times. I know it need not be accomplished in IMC. The question at hand referred to the situation whereas you had been in IMC, and so you have misquoted my statement out of context.


avbug said:
Did you write the regulation and know that with certainty? (I once had a Director of Operations who responded that yes, he did write the regulation...). No, you didn't...don't try to clarify regulation with justification. At least you got some level of practice, and that's good enough...a little like Jack Nicolson as the President of The United States in Mars Attacks... "We've still got two out of three branches of the Federal Government...and that ain't bad!"

How about not doing night landings to a full stop? At least you get a little practice out of it. How about doing the approach proceedure turn only? At least you got a little practice out of it. How about doing landing currency by just going around each time. After all, they say a good approach equals a good landing, and you at least got a little practice out of it. Sort of like having sex by kissing and holding hands. Not quite all the way, but at least you got something.

Justification is the narcotic of the soul...but neither soul nor narcotic has any place in a discussion of legality. What you choose to do is your business, but don't justify contravention of the regulation by opinion or shades of grey. It's not grey, it's clear...you must fly the approach in instrument conditions (actual or simulated) and must fly it to minimums unless it must be abandoned for safety reasons. Period.

Obviously not. No, I did not write the regulation. Nor do I claim to have. I am putting forth my opinion, and one that in practical terms was most likely the rational and intent for writing this rule. I'm sure you would probably agree, but I understand your need to affirm what you have stated. You may be technically correct in that one can not be presumptious. Unfortunately, these rules were written, and to be interpreted with common sense. And so yes, they were provided for these reasons I have mentioned. But I'll leave a disclaimer on that.

I am not claiming that cutting corners in an IAP will get you a loggable approach, but merely justifying ones that will. And these that I claim to qualify are quite narrow indeed.
 
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