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

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