61.57c approaches

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Dave S.

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thetexan
This is a simple question....

Must the approaches used to comply with 61.57c IFR currency be in actual or simulated IFR conditions....or...may they be done in VMC conditions?

I’m interested in what you guys think and why you think that. In other words, whatever you think, what is your justification for coming to that conclusion.

tex
 
Wait, you’re a CFII and asking this question? Ok what’s the catch?
 
Dave S. said:
Where is the reg your referring to?
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61.57(c). The reg that you mentioned in your initial question. I assumed you read it. It couldn't be clearer (the relevent phrase is

(c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for IFR only if:

(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following -

(i) Six instrument approaches.

(ii) Holding procedures and tasks.

(iii) Intercepting and tracking courses through the use of navigational electronic systems.​
 
Plus 61.57(c)(2) which goes into approved Sim use to obtain said currency.
 
At the college where I am on faculty there is a raging debate among several students and even faculty about this....not about what the right answer is but about WHY the right answer is.

I’m curious what many of you think is the specific WHY behind the right answer. That’s all

Tex
 
I don’t understand what the debate is about— 61.57 is crystal clear on the subject. I’ve logged approaches using all 3 legal methods— IFR in IMC on a clearance (under the criteria spelled out in INFO15012), simulated under the hood VFR in VMC with a qualified safety pilot, and simulated by using both an approved AATD (with a CFII) and approved BATD (without A CFII).

Can you elaborate more on what the debate is about?
 
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Dave S. said:
At the college where I am on faculty there is a raging debate among several students and even faculty about this....not about what the right answer is but about WHY the right answer is.

I’m curious what many of you think is the specific WHY behind the right answer. That’s all

Tex
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Because it says so? Color me confused. What would be the alternative?
 
They may be done in VMC with a view limiting device. If they are saying that you cannot do them at all in VMC conditions, they are wrong and need to prove their case. After all, there is really no need for a view limiting device if they are in actual meteorological conditions.
 
“, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following—

First, you don’t need to go any farther than this.

But the debate is over whether or not it has something to do with Training and the training reg for IFR, or logging IFR time, or the InFO clarification on .57c, etc. The authority is in paragraph c, period. It has nothing to do with training, or logging IFR time.

Tex
 
Well, it’s not a training issue. It is strictly a currency issue and the approaches must be logged to show currency. Outside if that, there really isn’t anything to debate.
 
No. I’m wondering how many have the right answer for the right reason. I would have thought the answer was obvious but some instructors and students ( who really don’t have the expertise even though none is really required but yould think they could read plain English) seem to have some odd ideas as to what is the governing authority.

Tex
 
Dave S. said:
No. I’m wondering how many have the right answer for the right reason. I would have thought the answer was obvious but some instructors and students ( who really don’t have the expertise even though none is really required but yould think they could read plain English) seem to have some odd ideas as to what is the governing authority.

Tex
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Not an unusual situation at all...most instructors and pilots choose to believe that the regs say what they seem to remember their instructor’s instructor saying rather than reading the reg.
 
Ok this has been a strange thread since you kinda veered off from your original post. I’ve had a lot of regulatory discussions over the years, usually dealing with trying to interpret poor FAA wording, but I’ve never been part of a governing authority debate.

So are they saying that some other paragraph or reference outside of 61.57 determines currency requirements?
 
Dave S. said:
No. I’m wondering how many have the right answer for the right reason. I would have thought the answer was obvious but some instructors and students ( who really don’t have the expertise even though none is really required but yould think they could read plain English) seem to have some odd ideas as to what is the governing authority.

Tex
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61.57c is clearly spelled out, but your concern is unclear. What exactly are the "odd ideas" you are referring to?
 
Dave S. said:
At the college where I am on faculty there is a raging debate among several students and even faculty about this....not about what the right answer is but about WHY the right answer is.

I’m curious what many of you think is the specific WHY behind the right answer. That’s all

Tex
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There's a raging debate about why approaching to land in completely CAVU conditions from 10 miles out doesn't count for as an instrument approach for bottom line base currency?
 
Dave S. said:
This is a simple question....

Must the approaches used to comply with 61.57c IFR currency be in actual or simulated IFR conditions....or...may they be done in VMC conditions?

I’m interested in what you guys think and why you think that. In other words, whatever you think, what is your justification for coming to that conclusion.

tex
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Ok, you have to clarify a point. What do you mean by VMC conditions?

If the argument is that you cannot maintain IFR currency by doing approaches in VMC because the regulation does not specifically say you can, that defies logic. After all, if you are in IMC conditions, actually IN the clouds, it is pointless to put on a view limiting device. And if you do, you cannot log it as actual IMC conditions.
 
I’m sure I must not be making myself clear so I’ll try this. Remember I’m not looking for an explanation here.

If I print out all of part 61 and ask you to draw a circle around the sentence that requires a person to fly the approaches in IMC or simulated UMC where would you draw the circle?

Tex
 
Dave S. said:
I’m sure I must not be making myself clear so I’ll try this. Remember I’m not looking for an explanation here.

If I print out all of part 61 and ask you to draw a circle around the sentence that requires a person to fly the approaches in IMC or simulated UMC where would you draw the circle?

Tex
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You are, it just wasn't clear in your first post. Since we here are all in violent agreement about 61.57(c), what are the folks you are debating with saying? I'd be interested in hearing their take since this is about as clear cut as an FAA reg gets.
 
Dave S. said:
I’m sure I must not be making myself clear so I’ll try this. Remember I’m not looking for an explanation here.

If I print out all of part 61 and ask you to draw a circle around the sentence that requires a person to fly the approaches in IMC or simulated UMC where would you draw the circle?

Tex
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Well there is no regulation which requires IMC or simulated IMC to fly an instrument approach. You are certainly free to ask ATC to clear you for an IAP on the clearest of days and keep your eyes wide open. And such a reg, if it existed, would be a Part 91 IFR operational reg, like the ones which require using an IAP to get down in conditions below VMC, not a pilot certification reg.

But if you are looking to count them for instrument currency, I would point to this from 61.57(c)
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Well to play devil's advocate that doesn't say "actual instrument conditions", but "actual weather conditions." Anything out side of a climate controlled environment is "actual weather", no?

Or is clear skies and sun fake weather? trump.gif

"actual weather" is not defined in 1.1 and other parts of 61 say "actual [or simulated] instrument conditions" not "actual weather"

;)
 
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Dave S. said:
If I print out all of part 61 and ask you to draw a circle around the sentence that requires a person to fly the approaches in IMC or simulated UMC where would you draw the circle?

Tex
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Neither. Because there is no REQUIREMENT to do it one way or the other. It’s left to the discretion of the pilot
 
EdFred said:
Well to play devil's advocate that doesn't say "actual instrument conditions", but "actual weather conditions." Anything out side of a climate controlled environment is "actual weather", no?

Or is clear skies and sun fake weather? trump.gif

"actual weather" is not defined in 1.1 and other parts of 61 say "actual [or simulated] instrument conditions" not "actual weather"

;)
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Probably. You want to file a petition for rulemaking? I did it to get night fixed.
 
Exactly. That’s all it takes to light a fire in a school full of new IFR student who think they are expert on the rules. And many of them are fairly expert.

The FAA InFO which “clarifies” the subject ...

“...A pilot may log an IAP for currency or training when the pilot accomplishes the IAP in accordance with the following conditions:
1. When conducted in an aircraft, flight simulator, flight training device, or aviation training device, the pilot must operate that aircraft or authorized training device solely by reference to instruments [§ 61.51(g)(1)];...”

The debate is about the 61.57c phrase... “...in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions...”.

Now, in a FAA world where they take particular interest in distinguishing between phrases like “...in IFR conditions...” and “...under IFR...” they clearly know when to use the correct phrase when they need to distinguish between the meaning of the two. The lack of the letters “IFR” in 61.57c is conspicuously absent. So much so that it seems to either be an error in editing or intentional. If an error then the reg takes on a different regulatory meaning; if intentional then the reg does not specify IMC as the InFO insists. In either case it provides grist for the student/instructor mill around the lounges and hallways.

Tex
 
So is the confusion about what “actual weather conditions” is? IMC doesn’t necessarily qualify for “actual.”
 
In the regular 61.51 logging definition, instrument time is just "time under actual or simulated instrument conditions." No "weather" or "meteorlogical". An FAA clarification says that "actual instrument conditions" are any time you HAVE to fly by reference to instruments. So a "moonless night" or "heavy haze, while still legal VFR" would both count.

IMC is defined elsewhere as weather worse than the legal VFR minimums. So IMC and "acutal instrument conditions" are seperate concepts.

The problem as pointed out by Ed is that 61.57 is sloppily written (I can almost guess by who and what he'd say if I pointed that out, but at least he's gone from the FAA now). I suggest that to be consistent with 61.51 and presumably the intent of the FAR, that they change WEATHER to INSTRUMENT in this phrase.
 
Greg Bockelman said:
Neither. Because there is no REQUIREMENT to do it one way or the other. It’s left to the discretion of the pilot
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So you say there is no stipulated requirement for IMC or simulated IMC for the 6 required currency approaches...is that correct?

tex
 
I hope he was saying you have the choice to do it either simulated OR actual. None of the above is not an option.
 
Dave S. said:
So you say there is no stipulated requirement for IMC or simulated IMC for the 6 required currency approaches...is that correct?

tex
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No, it’s got to be one or the other.

I hate it when people want to play word games. Not directed at you, Dave.
 
If there were no stipulation for either condition, then what would be the point in doing the approaches, holding and tracking at all? Might as well not have any currency requirements then.
 
Dave S. said:
Exactly. That’s all it takes to light a fire in a school full of new IFR student who think they are expert on the rules. And many of them are fairly expert.

The FAA InFO which “clarifies” the subject ...

“...A pilot may log an IAP for currency or training when the pilot accomplishes the IAP in accordance with the following conditions:
1. When conducted in an aircraft, flight simulator, flight training device, or aviation training device, the pilot must operate that aircraft or authorized training device solely by reference to instruments [§ 61.51(g)(1)];...”

The debate is about the 61.57c phrase... “...in an airplane, powered-lift, helicopter, or airship, as appropriate, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions...”.

Now, in a FAA world where they take particular interest in distinguishing between phrases like “...in IFR conditions...” and “...under IFR...” they clearly know when to use the correct phrase when they need to distinguish between the meaning of the two. The lack of the letters “IFR” in 61.57c is conspicuously absent. So much so that it seems to either be an error in editing or intentional. If an error then the reg takes on a different regulatory meaning; if intentional then the reg does not specify IMC as the InFO insists. In either case it provides grist for the student/instructor mill around the lounges and hallways.

Tex
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Oh, so it's the "jailhouse lawyer" thing. That explains it.
 
This is the
flyingron said:
In the regular 61.51 logging definition, instrument time is just "time under actual or simulated instrument conditions." No "weather" or "meteorlogical". An FAA clarification says that "actual instrument conditions" are any time you HAVE to fly by reference to instruments. So a "moonless night" or "heavy haze, while still legal VFR" would both count.

IMC is defined elsewhere as weather worse than the legal VFR minimums. So IMC and "acutal instrument conditions" are seperate concepts.

The problem as pointed out by Ed is that 61.57 is sloppily written (I can almost guess by who and what he'd say if I pointed that out, but at least he's gone from the FAA now). I suggest that to be consistent with 61.51 and presumably the intent of the FAR, that they change WEATHER to INSTRUMENT in this phrase.
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This is the answer. Came looking for this... and it isn't just semantics. I have more than once logged instrument approaches and instrument time in VFR because while it wasn't IMC it was "actual instrument conditions." I had to fly only by reference to the instruments—on moonless nights or in bad haze facing into the sun with no horizon.
 
View limiting? Does a Sectioned Chart propped in the windshield count? Asking for a friend.
 
bonefishpete said:
View limiting? Does a Sectioned Chart propped in the windshield count? Asking for a friend.
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The FAA doesn't define it. Anything that makes it so you have to use the instruments rather than looking out would qualify. The problem with propping stuff up int he window is that it may impact the safety pilot who is required to have an adequate visual lookout.
 
flyingron said:
The FAA doesn't define it. Anything that makes it so you have to use the instruments rather than looking out would qualify. The problem with propping stuff up int he window is that it may impact the safety pilot who is required to have an adequate visual lookout.
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I was thinking they were joking. OTOH, you never know.
 
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