Which of these approaches is loggable?

"David Brooks" wrote in message


I had thought that was what John Lynch meant, but now I read this
extract again I'm not so sure.

What he actually says is that you fly all the way to the conclusion
of the approach, not that you fly to the conclusion in IMC. His
reference to "fly to the FAF and break it off" seems gratuitous
otherwise. I don't think anyone is actually asking that, so he may
be, in his mind, answering a slightly different question.

The question he's answering is not whether the approach can be logged at
all, but whether it can be logged as an approach in actual conditions (see
the phrase ["actual" approach]).

--
John T
http://tknowlogy.com/tknoFlyer
_______________

Hi David,
I tend to agree with your assessment.
This seems like another one of Lynch's "non" answers. Read the Part 61
FAQ's close enough and you'll find he seems to contradict himself several
times on different issues by answering a question other than the one that
was asked. I believe the question becomes "at what designated point in
space on an IAP does an instrument approach become "loggable" when the pilot
is either in IMC or conditions that require flight by sole reference to
instruments." Because the FAR's do not define this point in space precisely
it is purely a judgment call on the part of the pilot. I think that
simulated instrument flight demands that you fly to the minimums or fly the
missed to be loggable.

Let's take it to the extreme but don't judge the idiocy of any pilot that
might try this, just look at the "loggable vs non-loggable" argument. Let's
say you're solid hard core IMC hand flying a DME arc to an off field NDB in
a mountain pass with a mean crosswind correction dialed in, moderate
turbulence, pounding rain which is turning to ice, you're sweating bullets
and praying to God that you survive. Low and behold you break out either
one foot above your MDA or 1/16 mile before your MAP.

Find me a FSDO inspector that would say "Oh crap, we broke out too soon,
since we can't log it, let's go up and shoot it again, maybe next time we
won't break out before the MAP". I'd bet Lynch would log it. To think that
every IMC approach needs to be flown all the way the MAP or DH in IMC before
it is loggable is simply not practical. I believe that the FAR's state that
an instrument pilot must "complete" 6 approaches within 6 months. I would
argue that an instrument approach can not begin until you are cleared and
establish yourself on a published portion of the IAP. I would also argue
that an instrument approach has been "completed" when the pilot either
arrives at the MAP or breaks out into VMC from IMC. I would call that a
loggable event if in the pilots good judgment he feels he has completed an
approach. I personally wouldn't log a vectors to final approach from clear
on top through a thin layer to a point outside the FAF. I don't think that
constitutes being established on the approach. I would however log an
approach where I descend into IMC, establish myself outbound, fly a
procedure turn inbound, joined the localizer, captured the glideslope and
arrived at the FAF.

--
Jim Burns III

Remove "nospam" to reply

"Jim" wrote
To think that every IMC approach needs to be flown all
the way the MAP or DH in IMC before it is loggable is
simply not practical.

I would agree, not practical at all.

I would pose the following situations to Mr. Gary.

1. Wx is 200x1/2...I break-out of the ILS at 200',
can I log it? What if I was using CAT II mins?
Same ILS, same instruments, but I broke out 100'
above minimuns...can I log an approach?
2. Same approach except on the final vector, I engage
the autopilot and do not touch the controls again
untill minimums. Can I log it?
3. Same approach except that the Wx is reported as
visibility 1/4 in ground fog. I engage the autopilot
and auto-land and sit back and enjoy the ride. Can
I log it as an approach???...a landing????
4. Same approach except the Wx is now CAVU, I program
the autopilot the same as in number 3. Did I fly an
ILS? You bet I did. Did I log a landing? You bet!

It ain't as cut-and-dried as Mr. Gary would have it be.

Bob Moore
ATP B-727 B-707 L-188
CFII
PanAm (retired)

Nothing in writing or offical. The local FSDO agrees with Mr Lynch's
opinion in the FAQ that you must be IMC from the IAF to the MAP. I
wouldn't log any of the ones you mentioned. I only log them if I just
see the runway at minimums. Log what you want, fly what you need.

-Robert


(Paul Tomblin) wrote in message ...
1. Vectored for the VOR 27 at Oshkosh in pouring rain, broke out and saw
the runway after I got established but before I started my descent,
cancelled IFR to help the guy behind me, did a visual descent and landed
on the green dot.

2. Vectored for the ILS 24(?) at Muskegeon, descended on the glide slope,
saw the runway almost as soon as I started descending, but did the ILS on
the gauges all the way down for practice (not wearing foggles).

3. Vectored for the ILS 22 at Rochester, was in the soup at 2500 feet at
the top of the glideslope, broke out on the glide slope just above traffic
pattern altitude (1400), asked for and got right traffic to runway 25.

I fail to understand the logic of your statement, Robert. I am not
slamming or bashing, but just trying to understand.

If you "must be IMC from the IAF to the MAP" then legally, you must
have missed on the approach, since you have stated that you are in
"IMC at the MAP". Surely, one must not miss an aproach in actual in
order to use it for legal currency. This subject should have been
addressed in a more definitive policy statement or legal opinion a
long time ago.



On 5 Aug 2003 20:18:53 -0700, (Robert M. Gary) wrote:

Nothing in writing or offical. The local FSDO agrees with Mr Lynch's
opinion in the FAQ that you must be IMC from the IAF to the MAP. I
wouldn't log any of the ones you mentioned. I only log them if I just
see the runway at minimums. Log what you want, fly what you need.

-Robert


(Paul Tomblin) wrote in message ...
1. Vectored for the VOR 27 at Oshkosh in pouring rain, broke out and saw
the runway after I got established but before I started my descent,
cancelled IFR to help the guy behind me, did a visual descent and landed
on the green dot.

2. Vectored for the ILS 24(?) at Muskegeon, descended on the glide slope,
saw the runway almost as soon as I started descending, but did the ILS on
the gauges all the way down for practice (not wearing foggles).

3. Vectored for the ILS 22 at Rochester, was in the soup at 2500 feet at
the top of the glideslope, broke out on the glide slope just above traffic
pattern altitude (1400), asked for and got right traffic to runway 25.

Bill Zaleski wrote in message . ..
I fail to understand the logic of your statement, Robert. I am not
slamming or bashing, but just trying to understand.

If you "must be IMC from the IAF to the MAP" then legally, you must
have missed on the approach, since you have stated that you are in
"IMC at the MAP". Surely, one must not miss an aproach in actual in
order to use it for legal currency.

Well, you could break at at the MAP (I actually have) but it is true
that you could have to get pretty lucky to get that weather. However,
that is what the Sacramento FSDO says and Mr. Lynch as well. So you
are correct, a successful approach in actual conditions would almost
never be loggable in their view. For me personally, I log the approach
if I encounter any IMC between the IAP and MAP. However, since I'm a
CFI and I'm flying around with students (sometimes in the clouds) and
often with my wife and small kids, I do an IPC with our local DE every
6 months.

On 14 Aug 2003 09:58:16 -0700, (Robert M. Gary)
wrote:

Bill Zaleski wrote in message . ..
I fail to understand the logic of your statement, Robert. I am not
slamming or bashing, but just trying to understand.

If you "must be IMC from the IAF to the MAP" then legally, you must
have missed on the approach, since you have stated that you are in
"IMC at the MAP". Surely, one must not miss an aproach in actual in
order to use it for legal currency.

Well, you could break at at the MAP (I actually have) but it is true
that you could have to get pretty lucky to get that weather. However,
that is what the Sacramento FSDO says and Mr. Lynch as well. So you

OTOH Ask the FAA, or one of the columns in one of the magazines
sometime in the last couple of years did a clarification as the way it
was written virtually no real approach that could result in a landing
could have been counted for currency.

are correct, a successful approach in actual conditions would almost
never be loggable in their view. For me personally, I log the approach
if I encounter any IMC between the IAP and MAP. However, since I'm a

That was a general interpretation in the magazine. If you ended up in
actual for any part of the approach then the approach counted.

As to practice approaches they had to be flown to the MAP, or to a
landing and you could take the foggles off once close enough to make a
landing.

CFI and I'm flying around with students (sometimes in the clouds) and
often with my wife and small kids, I do an IPC with our local DE every
6 months.

As I recall the IPC a number of the instructors use here is a cross
country to an ILS with a miss and the published hold, then to a
second airport for a VOR and circle to land (depending on the runway)
with a missed. Then on north to an NDB that is also an LOM with a
circle to land...then back home with the VOR and circle to land, or a
GPS approach if you got it.

Roger Halstead (K8RI EN73 & ARRL Life Member)
www.rogerhalstead.com
N833R World's oldest Debonair? (S# CD-2)

Time to pull out my handy-dandy personal FAQ on the issue. You'll note
that it gives a bit of history surrounding this stupid controversy,
but leaves the decision to you.

Me? I agree with Bob Gardner.

When can I log the approach? A historical perspective:


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:

==============================
"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:

==============================
"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 face 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,

==============================
"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!



Mark Kolber
APA/Denver, Colorado
www.midlifeflight.com
======================
email? Remove ".no.spam"

Hi!

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.

Actually, when I read this it says "IFR conditions", not IMC. IFR conditions
means less than VFR conditions. So if I shoot a non-precision approach (MDA
is 500ft AGL) on a field (assume E airspace) with a ceiling of 900ft AGL,
when I break out I will be 400ft above MDA but still in IFR conditions (less
than 500ft. below the ceiling). With this reasoning, I anything where I
break out less than 500ft. above MDA/DH would be in IFR conditions, hence
loggable.

Any comments on that spin?

Cheers,
Hendrik

There are too many contradictory opinions on what it means to perform or log
approaches under actual or simulated instrument conditions. John Lynch
carefully avoids the issue in the FAQs, saying only that in order to log
instrument flight time you must fly the aircraft solely by reference to the
instruments and that if you want to log an approach you must fly it at least
beyond the FAF; you can't just fly to the FAF and call it an approach.

Well, fine. If you fly an approach solely by reference to the instruments
until you are at least beyond the FAF, then it seems to me that you should
be able to log it as an instrument approach.

Requiring the flight to be IMC all the way to the MAP seems to have too many
problems. For one thing, the vast majority of approaches are not flown all
the way to the MAP. You have to take over visually at some point and land or
go missed. If you are flying a typical non-precision approach and can't see
the runway until you reach the MAP, then odds are you don't have the
visibility minimums to land. Also, flying all the way to the MAP is
discouraged at many airports. Similarly, it is rare to fly the full approach
before the FAF. You frequently get vectors to final, omit the procedure
turn, etc.

The regulations should be interpreted in such a way as to make it possible
to comply with them; otherwise there is no point in even having the
regulation.

I tend to be rather conservative and don't log all the approaches I probably
could.