61.57c approaches

[Rgbeard]

I’m beginning to have sympathy for the OP.

Seems he’s surrounded by people that do exactly this.

And we’re the people he’s reaching to for a sanity check.

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

 

[Pinecone]

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"

There is a letter of interpretation that states to log it as in actual, you must be in IMC at the FAF.

Although the comes up with an interesting question. So you are on the approach, and descend to the altitude to the FAF and you break out of the clouds, but have to level off 300 feet below the clouds. You are not VMC as you do not have the required cloud clearance. So can you log the approach?

 

[flyingcheesehead]

There is a letter of interpretation that states to log it as in actual, you must be in IMC at the FAF.

Although the comes up with an interesting question. So you are on the approach, and descend to the altitude to the FAF and you break out of the clouds, but have to level off 300 feet below the clouds. You are not VMC as you do not have the required cloud clearance. So can you log the approach?

These scenarios are when they talk about "IMC" vs "IFR Conditions" and start running around in circles.

Per 14 CFR 1.1:

IFR conditions means weather conditions below the minimum for flight under visual flight rules.​

So if you're 300 feet below the clouds at the FAF, you are in "IFR Conditions".

Now, I went looking for the LOI that you referenced, and I did not find any such thing. What I found was Murphy 2009, which states that:

The FAA previously has interpreted section 61.57(c)(1)(i) to mean that a pilot must follow an instrument approach procedure to the minimum descent altitude or decision height. See Interpretation to Timothy Slater (Jan. 28, 1992).​

Do you have a reference for a newer letter that interprets it as being IMC at the FAF? That's kind of how I've always done it, but that was due to Ron Levy's personal interpretation, not any official chief counsel interpretation. I thought there was maybe a newer letter on that, but I sure can't find it.

EDIT: Found it. It's not a LOI. It's InFO 15012. Page 2, section 5 to the end.

 

[luvflyin]

These scenarios are when they talk about "IMC" vs "IFR Conditions" and start running around in circles.

Per 14 CFR 1.1:

IFR conditions means weather conditions below the minimum for flight under visual flight rules.​

So if you're 300 feet below the clouds at the FAF, you are in "IFR Conditions".

Now, I went looking for the LOI that you referenced, and I did not find any such thing. What I found was Murphy 2009, which states that:

The FAA previously has interpreted section 61.57(c)(1)(i) to mean that a pilot must follow an instrument approach procedure to the minimum descent altitude or decision height. See Interpretation to Timothy Slater (Jan. 28, 1992).​

Do you have a reference for a newer letter that interprets it as being IMC at the FAF? That's kind of how I've always done it, but that was due to Ron Levy's personal interpretation, not any official chief counsel interpretation. I thought there was maybe a newer letter on that, but I sure can't find it.

Time again for…. substitute FAR 61 for drugs.

 

[Pinecone]

These scenarios are when they talk about "IMC" vs "IFR Conditions" and start running around in circles.

Per 14 CFR 1.1:

IFR conditions means weather conditions below the minimum for flight under visual flight rules.​

So if you're 300 feet below the clouds at the FAF, you are in "IFR Conditions".

Now, I went looking for the LOI that you referenced, and I did not find any such thing. What I found was Murphy 2009, which states that:

The FAA previously has interpreted section 61.57(c)(1)(i) to mean that a pilot must follow an instrument approach procedure to the minimum descent altitude or decision height. See Interpretation to Timothy Slater (Jan. 28, 1992).​

Do you have a reference for a newer letter that interprets it as being IMC at the FAF? That's kind of how I've always done it, but that was due to Ron Levy's personal interpretation, not any official chief counsel interpretation. I thought there was maybe a newer letter on that, but I sure can't find it.

EDIT: Found it. It's not a LOI. It's InFO 15012. Page 2, section 5 to the end.

Thanks for finding that.

I had an actual approach like that. Minimum altitude before the FAF was 1900. Cloud base was about 2100. I could see the airport from the FAF, but was IFR conditions. I did NOT log the approach. Just didn't feel right.