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Which of these approaches is loggable?



 
 
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  #11  
Old August 6th 03, 11:21 PM
Robert Moore
external usenet poster
 
Posts: n/a
Default

"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)
  #12  
Old August 6th 03, 11:27 PM
John T
external usenet poster
 
Posts: n/a
Default

"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
_______________



  #13  
Old August 7th 03, 12:14 AM
Teacherjh
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Posts: n/a
Default

I would pose the following situations to Mr. Gary.

To add to that, I fly in solid IMC until shortly before the IAP, whereupon I
break out inbetween layers. I fly the approach, able to see the horizon and
200 feet above minimums go into the next layer. I break out at minimums and
land. (Or don't break out at minimums and execute a missed).

Loggable? If not, shorten the visual time until it is. How short is it?

I figure if I pretty much have to be on the gauges pretty much most of the way
(to some applicable minimum), I can pretty much log it.

Jose

(for Email, make the obvious changes in my address)
  #14  
Old August 7th 03, 01:01 AM
Mark Kolber
external usenet poster
 
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Default

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"
  #15  
Old August 7th 03, 10:34 AM
Hendrik G. Seliger
external usenet poster
 
Posts: n/a
Default

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



  #16  
Old August 9th 03, 06:44 PM
Barry
external usenet poster
 
Posts: n/a
Default

While the FAA article you quote is anecdotal, here is some precedent- please
read the following FAA Chief
Counsel Opinion about approaches for Instrument Currency. This FAA Chief
Counsel Opinion is the only official opinion I have found on
the issue. Keep in mind that a chief counsel opinion is legally binding as
to how the agancy will enforce the issue. I welcome any additional contrary
leads anyone may provide in that regard.

"January 28, 1992
(no name given)
....
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.

Donald P. Byrne
Assistant Chief Counsel"
(Source: Summit Aviation CD Chief Counsel Opinions section)

Keep in mind that a Chief Counsel Opinion is only that: an opinion. It is
not a law. You are free to argue with the FAA and an NTSB judge about it.
However, absent specific information in an FAR or information in the
Preamble to the FAR, in an enforcement proceeding against a pilot whose IFR
currency is in question, the NTSB judge would look to a Chief Counsel
Opinion to determine how the FAA wished to enforce what constitutes a
"useable" approach for currency
purposes, and follow that opinion. Rarely does an NTSB judge rule contrary
to an FAA Chief Counsel Opinion.

I neither agree with it nor like it, but it is the ONLY official legal
opinion out there on this issue. Therefore, I'm mindful of its existence
when doing my approaches for currency purposes..
Tailwinds.

"Bill Zaleski" wrote in message
...
This is the most definitive guidance that I have seen. Although not
regulatory, it is apparently FAA policy or the Feds wouldn't have
printed it. Don't slam me, I'm only the messenger.....



FAAviation News , July-Aug 1990.

"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"

The July-August 1990 issue of FAAviation News, in response to a reader
inquiry, said:

"The wording of our reply was not clear. Once you have been cleared
for and have initiated an instrument approach in IMC, you may log that
approach regardless of the altitude at which you break out of the
clouds. When doing a simulated IFR approach you should fly the
prescribed instrument approach procedure to DH or MDA to maximize the
training benefit."








On Tue, 5 Aug 2003 12:03:14 +0000 (UTC), (Paul
Tomblin) wrote:

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.




  #17  
Old August 10th 03, 01:14 AM
Ray Andraka
external usenet poster
 
Posts: n/a
Default

This says that the approach procedure must be followed to the MAP, it does not
say anything about the conditions, since you can follow the approach procedure
in visual as well as instrument conditions. I find it easier just to schedule
an IPC every 6 months, that way I get an instructor checking me for any bad
habits I might be picking up, and I get to practice stuff I might not do on my
own. The instructor I fly with puts me partial panel most of the flight, for
example.


Barry wrote:

While the FAA article you quote is anecdotal, here is some precedent- please
read the following FAA Chief
Counsel Opinion about approaches for Instrument Currency. This FAA Chief
Counsel Opinion is the only official opinion I have found on
the issue. Keep in mind that a chief counsel opinion is legally binding as
to how the agancy will enforce the issue. I welcome any additional contrary
leads anyone may provide in that regard.

"January 28, 1992
(no name given)
...
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.

Donald P. Byrne
Assistant Chief Counsel"
(Source: Summit Aviation CD Chief Counsel Opinions section)

Keep in mind that a Chief Counsel Opinion is only that: an opinion. It is
not a law. You are free to argue with the FAA and an NTSB judge about it.
However, absent specific information in an FAR or information in the
Preamble to the FAR, in an enforcement proceeding against a pilot whose IFR
currency is in question, the NTSB judge would look to a Chief Counsel
Opinion to determine how the FAA wished to enforce what constitutes a
"useable" approach for currency
purposes, and follow that opinion. Rarely does an NTSB judge rule contrary
to an FAA Chief Counsel Opinion.

I neither agree with it nor like it, but it is the ONLY official legal
opinion out there on this issue. Therefore, I'm mindful of its existence
when doing my approaches for currency purposes..
Tailwinds.

"Bill Zaleski" wrote in message
...
This is the most definitive guidance that I have seen. Although not
regulatory, it is apparently FAA policy or the Feds wouldn't have
printed it. Don't slam me, I'm only the messenger.....



FAAviation News , July-Aug 1990.

"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"

The July-August 1990 issue of FAAviation News, in response to a reader
inquiry, said:

"The wording of our reply was not clear. Once you have been cleared
for and have initiated an instrument approach in IMC, you may log that
approach regardless of the altitude at which you break out of the
clouds. When doing a simulated IFR approach you should fly the
prescribed instrument approach procedure to DH or MDA to maximize the
training benefit."








On Tue, 5 Aug 2003 12:03:14 +0000 (UTC), (Paul
Tomblin) wrote:

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.



--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email

http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759


  #18  
Old August 10th 03, 02:31 AM
Matthew Waugh
external usenet poster
 
Posts: n/a
Default

It says "actual or simulated" conditions - visual is neither.

Mat

--
Matthew Waugh
Comm. SEL MEL, CFI-AI
http://home.nc.rr.com/mwaugh/learn2fly/index.htm

"Ray Andraka" wrote in message
...
This says that the approach procedure must be followed to the MAP, it does

not
say anything about the conditions, since you can follow the approach

procedure
in visual as well as instrument conditions. I find it easier just to

schedule
an IPC every 6 months, that way I get an instructor checking me for any

bad
habits I might be picking up, and I get to practice stuff I might not do

on my
own. The instructor I fly with puts me partial panel most of the flight,

for
example.


Barry wrote:

While the FAA article you quote is anecdotal, here is some precedent-

please
read the following FAA Chief
Counsel Opinion about approaches for Instrument Currency. This FAA

Chief
Counsel Opinion is the only official opinion I have found on
the issue. Keep in mind that a chief counsel opinion is legally binding

as
to how the agancy will enforce the issue. I welcome any additional

contrary
leads anyone may provide in that regard.

"January 28, 1992
(no name given)
...
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.

Donald P. Byrne
Assistant Chief Counsel"
(Source: Summit Aviation CD Chief Counsel Opinions section)

Keep in mind that a Chief Counsel Opinion is only that: an opinion. It

is
not a law. You are free to argue with the FAA and an NTSB judge about

it.
However, absent specific information in an FAR or information in the
Preamble to the FAR, in an enforcement proceeding against a pilot whose

IFR
currency is in question, the NTSB judge would look to a Chief Counsel
Opinion to determine how the FAA wished to enforce what constitutes a
"useable" approach for currency
purposes, and follow that opinion. Rarely does an NTSB judge rule

contrary
to an FAA Chief Counsel Opinion.

I neither agree with it nor like it, but it is the ONLY official legal
opinion out there on this issue. Therefore, I'm mindful of its

existence
when doing my approaches for currency purposes..
Tailwinds.

"Bill Zaleski" wrote in message
...
This is the most definitive guidance that I have seen. Although not
regulatory, it is apparently FAA policy or the Feds wouldn't have
printed it. Don't slam me, I'm only the messenger.....



FAAviation News , July-Aug 1990.

"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"

The July-August 1990 issue of FAAviation News, in response to a reader
inquiry, said:

"The wording of our reply was not clear. Once you have been cleared
for and have initiated an instrument approach in IMC, you may log

that
approach regardless of the altitude at which you break out of the
clouds. When doing a simulated IFR approach you should fly the
prescribed instrument approach procedure to DH or MDA to maximize

the
training benefit."







On Tue, 5 Aug 2003 12:03:14 +0000 (UTC), (Paul
Tomblin) wrote:

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.


--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email

http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759




  #19  
Old August 10th 03, 05:04 AM
Ray Andraka
external usenet poster
 
Posts: n/a
Default

But it doesn't say that it has to be flown *TO* the MAP in IMC or simulated IMC.

Matthew Waugh wrote:

It says "actual or simulated" conditions - visual is neither.

Mat

--
Matthew Waugh
Comm. SEL MEL, CFI-AI
http://home.nc.rr.com/mwaugh/learn2fly/index.htm

"Ray Andraka" wrote in message
...
This says that the approach procedure must be followed to the MAP, it does

not
say anything about the conditions, since you can follow the approach

procedure
in visual as well as instrument conditions. I find it easier just to

schedule
an IPC every 6 months, that way I get an instructor checking me for any

bad
habits I might be picking up, and I get to practice stuff I might not do

on my
own. The instructor I fly with puts me partial panel most of the flight,

for
example.


Barry wrote:

While the FAA article you quote is anecdotal, here is some precedent-

please
read the following FAA Chief
Counsel Opinion about approaches for Instrument Currency. This FAA

Chief
Counsel Opinion is the only official opinion I have found on
the issue. Keep in mind that a chief counsel opinion is legally binding

as
to how the agancy will enforce the issue. I welcome any additional

contrary
leads anyone may provide in that regard.

"January 28, 1992
(no name given)
...
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.

Donald P. Byrne
Assistant Chief Counsel"
(Source: Summit Aviation CD Chief Counsel Opinions section)

Keep in mind that a Chief Counsel Opinion is only that: an opinion. It

is
not a law. You are free to argue with the FAA and an NTSB judge about

it.
However, absent specific information in an FAR or information in the
Preamble to the FAR, in an enforcement proceeding against a pilot whose

IFR
currency is in question, the NTSB judge would look to a Chief Counsel
Opinion to determine how the FAA wished to enforce what constitutes a
"useable" approach for currency
purposes, and follow that opinion. Rarely does an NTSB judge rule

contrary
to an FAA Chief Counsel Opinion.

I neither agree with it nor like it, but it is the ONLY official legal
opinion out there on this issue. Therefore, I'm mindful of its

existence
when doing my approaches for currency purposes..
Tailwinds.

"Bill Zaleski" wrote in message
...
This is the most definitive guidance that I have seen. Although not
regulatory, it is apparently FAA policy or the Feds wouldn't have
printed it. Don't slam me, I'm only the messenger.....



FAAviation News , July-Aug 1990.

"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"

The July-August 1990 issue of FAAviation News, in response to a reader
inquiry, said:

"The wording of our reply was not clear. Once you have been cleared
for and have initiated an instrument approach in IMC, you may log

that
approach regardless of the altitude at which you break out of the
clouds. When doing a simulated IFR approach you should fly the
prescribed instrument approach procedure to DH or MDA to maximize

the
training benefit."







On Tue, 5 Aug 2003 12:03:14 +0000 (UTC), (Paul
Tomblin) wrote:

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.


--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email

http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759



--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email
http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759


  #20  
Old August 10th 03, 11:34 AM
Matthew Waugh
external usenet poster
 
Posts: n/a
Default

You don't believe the 2 sentences are related? One says the instrument
approach must be actual or simulated and the other says it must be flown to
the MAP? I guess I don't get your reasoning, but it wouldn't be the first
time I've been confused.

Mat

--
Matthew Waugh
Comm. SEL MEL, CFI-AI
http://home.nc.rr.com/mwaugh/learn2fly/index.htm

"Ray Andraka" wrote in message
...
But it doesn't say that it has to be flown *TO* the MAP in IMC or

simulated IMC.

Matthew Waugh wrote:

It says "actual or simulated" conditions - visual is neither.

Mat

--
Matthew Waugh
Comm. SEL MEL, CFI-AI
http://home.nc.rr.com/mwaugh/learn2fly/index.htm

"Ray Andraka" wrote in message
...
This says that the approach procedure must be followed to the MAP, it

does
not
say anything about the conditions, since you can follow the approach

procedure
in visual as well as instrument conditions. I find it easier just to

schedule
an IPC every 6 months, that way I get an instructor checking me for

any
bad
habits I might be picking up, and I get to practice stuff I might not

do
on my
own. The instructor I fly with puts me partial panel most of the

flight,
for
example.


Barry wrote:

While the FAA article you quote is anecdotal, here is some

precedent-
please
read the following FAA Chief
Counsel Opinion about approaches for Instrument Currency. This FAA

Chief
Counsel Opinion is the only official opinion I have found on
the issue. Keep in mind that a chief counsel opinion is legally

binding
as
to how the agancy will enforce the issue. I welcome any additional

contrary
leads anyone may provide in that regard.

"January 28, 1992
(no name given)
...
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.

Donald P. Byrne
Assistant Chief Counsel"
(Source: Summit Aviation CD Chief Counsel Opinions section)

Keep in mind that a Chief Counsel Opinion is only that: an opinion.

It
is
not a law. You are free to argue with the FAA and an NTSB judge

about
it.
However, absent specific information in an FAR or information in the
Preamble to the FAR, in an enforcement proceeding against a pilot

whose
IFR
currency is in question, the NTSB judge would look to a Chief

Counsel
Opinion to determine how the FAA wished to enforce what constitutes

a
"useable" approach for currency
purposes, and follow that opinion. Rarely does an NTSB judge rule

contrary
to an FAA Chief Counsel Opinion.

I neither agree with it nor like it, but it is the ONLY official

legal
opinion out there on this issue. Therefore, I'm mindful of its

existence
when doing my approaches for currency purposes..
Tailwinds.

"Bill Zaleski" wrote in message
...
This is the most definitive guidance that I have seen. Although

not
regulatory, it is apparently FAA policy or the Feds wouldn't have
printed it. Don't slam me, I'm only the messenger.....



FAAviation News , July-Aug 1990.

"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"

The July-August 1990 issue of FAAviation News, in response to a

reader
inquiry, said:

"The wording of our reply was not clear. Once you have been

cleared
for and have initiated an instrument approach in IMC, you may

log
that
approach regardless of the altitude at which you break out of

the
clouds. When doing a simulated IFR approach you should fly the
prescribed instrument approach procedure to DH or MDA to

maximize
the
training benefit."







On Tue, 5 Aug 2003 12:03:14 +0000 (UTC), (Paul
Tomblin) wrote:

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.


--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email

http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759



--
--Ray Andraka, P.E.
President, the Andraka Consulting Group, Inc.
401/884-7930 Fax 401/884-7950
email
http://www.andraka.com

"They that give up essential liberty to obtain a little
temporary safety deserve neither liberty nor safety."
-Benjamin Franklin, 1759




 




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