"Counting" approaches in visual conditions with no foggles for currency - where does this idea come from?

midwestpa24 said:
Logging actual in a flight that varies from IMC to VMC is usually just an educated guess at best. I doubt anyone is tracking the minutes or tenths of an hour they are in a cloud versus not in a cloud.
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IMC and VMC has nothing to do with logging actual. You can have instrument conditions in VMC and non-instrument conditions in IMC.
 
flyingron said:
IMC and VMC has nothing to do with logging actual. You can have instrument conditions in VMC and non-instrument conditions in IMC.
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Good example: Flying at 11,000’. Cloud deck at 11,900. Unlimited visibility below. It’s IMC,
 
KE5BM said:
But seriously, I was shocked when I finally learned what the currency requirements actually are if you follow them the way you're supposed to. Basically, for us weekenders you're relegated to IPCs as opposed to the actual instrument currencies. It's one of the reasons I put a pause on my IFR training.
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That shouldn't be a barrier. Two ways to keep current. 1. Go and fly on benign IFR days. No convective activity, no ice and reasonable ceilings. Knock off 3 or so approaches. Do that twice in 6 months and you've met the minimum (need to throw in one hold) or 2. Find someone at your airport who also wants to stay current and switch off safety piloting for each other. I'm in FL, so I do a mix of both, IFR in the winter and safety pilot in the summer when the only clouds are Cu Nims.

Should add, that's minimum for currency, I do more that the minimum to stay proficient.
 
KE5BM said:
Basically, for us weekenders you're relegated to IPCs as opposed to the actual instrument currencies. It's one of the reasons I put a pause on my IFR training.
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That’s actually a very good way to maintain instrument currency…I’ve been almost continuously current for over 35 years that way.
 
KE5BM said:
But seriously, I was shocked when I finally learned what the currency requirements actually are if you follow them the way you're supposed to. Basically, for us weekenders you're relegated to IPCs as opposed to the actual instrument currencies. It's one of the reasons I put a pause on my IFR training.
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Or you could make friends with a safety pilot and fly with a view limiting device (did that for years) or after moving what I resorted to which is buying a BATD.
 
tsts4 said:
Or you could make friends with a safety pilot and fly with a view limiting device (did that for years) or after moving what I resorted to which is buying a BATD.
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I assume you meant AATD?

Ok, did the rules change or did I always have it wrong that you needed aatd for instrument currency?
 
Salty said:
I assume you meant AATD?

Ok, did the rules change or did I always have it wrong that you needed aatd for instrument currency?
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No I meant BATD— in my case a Redbird TD. The rules didn’t change, once they changed 91.57 to allow FAA approved sims to be used without a CFII for currency BATDs and AATDs both met the requirement.
 
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Htaylor said:
A lot of less-than-honorable stuff goes on out there. As a CFI, I've been asked on more than one occasion to sign off a flight review with no actual flight review given. Last person that asked for that is now dead from a fuel exhaustion crash. His last actual FR was 4 years prior to the crash. My first PPL student was caught flying solo in a twin Comanche he had purchased before he had the rating. He later went on the kill himself and another in a hold-my-beer stupid move in said Comanche. Plenty of people flying without a medical cert. They often justify it by only doing laps in the pattern. I suspect and hope that Basic Med has reduced this somewhat. I'm sure many of us here have been given VFR traffic by ATC on a very IFR day. Happens often in the LA basin.
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Yup, I've had a couple of encounters with VFR traffic in IMC. That's one that really irks me.

Htaylor said:
More to the point re: foggles, I've lost track of how many Part 135 instrument check rides I've done. But on only one was I asked to use the foggles and then only for 1 approach.
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:o

Well, that says something about that/those operator(')s(') cultures. Yikes.

I'm starting at a new 135 soon, and I'm hoping it's not the "wild west" variety.

KE5BM said:
But seriously, I was shocked when I finally learned what the currency requirements actually are if you follow them the way you're supposed to. Basically, for us weekenders you're relegated to IPCs as opposed to the actual instrument currencies. It's one of the reasons I put a pause on my IFR training.
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It's not that hard - Once per quarter, go do three approaches with a safety pilot, and every other time make one of them a full procedure that has a HPILPT, and you're good.

Or, just get an IPC every six months... That's generally three approaches and a hold with a CFII, and well worth it if you get a CFII that's worth anything.
 
flyingcheesehead said:
Or, just get an IPC every six months... That's generally three approaches and a hold with a CFII, and well worth it if you get a CFII that's worth anything.
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The more I do, the less I am impressed with an IPC as a proficiency exercise. Time with a good instructor, absolutely.

I started asking this question based on something I heard of another CFII saying: “do you want an IPC or do you want to learn something?”
 
Htaylor said:
More to the point re: foggles, I've lost track of how many Part 135 instrument check rides I've done. But on only one was I asked to use the foggles and then only for 1 approach.
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I haven't lived in the Part 135 world, but I do live in the 121 world. There are a whole slew of exceptions to the instrument currency requirements at the end of 61.57 in section 61.57(e). These deal with pilots under Part 135/121. Basically, it says that the whole 61.57 instrument currency section doesn't apply to 121 and 135 pilots when engaged in 121/135 operations. Same with night landings. As long as you are "landing current" you are "night-landing current."

There is no way I'd be "instrument current" under 61.57 without the exception paragraphs. If nothing else, I can't remember the last time I did an actual hold. But, in my world, 75% of the time I'm flying an ILS in VMC weather. No foggles... but I guess I do have a safety pilot built in.
 
Why do they log in visual, because according to 61.57(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 VFR 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.​




Note that it doesn't say actual instrument conditions. It says actual weather. All outside weather is actual. It's not like you're flying in an atmospheric simulator. Now, there is another (electronic only ?) publication out there that says the approach must be in (simulated) instrument conditions beyond a certain point to count. But according to only the CFR's any approach you fly is loggable for currency. And a lot of pilots have no idea where to find all the non-regulatory explanations.
 
Sluggo63 said:
I haven't lived in the Part 135 world, but I do live in the 121 world. There are a whole slew of exceptions to the instrument currency requirements at the end of 61.57 in section 61.57(e). These deal with pilots under Part 135/121. Basically, it says that the whole 61.57 instrument currency section doesn't apply to 121 and 135 pilots when engaged in 121/135 operations. Same with night landings. As long as you are "landing current" you are "night-landing current."
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The exceptions in (e) only give relief for (a) and (b), but not the instrument currency section.

Under 135, instrument currency is provided by checkrides every six months for the PIC. An SIC has to be instrument current under 61.57.
 
MauleSkinner said:
The exceptions in (e) only give relief for (a) and (b), but not the instrument currency section.

Under 135, instrument currency is provided by checkrides every six months for the PIC. An SIC has to be instrument current under 61.57.
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I promise I'm not being argumentative, just trying to learn and I never really looked at the 135 stuff, since it never applied to me.

I see the first three paragraphs of 61.57(e) deal with Parts 125, 121, and 135 respectively. (e)(1) deals with part 125 and only gives relief for paragraphs (a) and (b) {takeoffs and landings and night takeoffs and landings}. Paragraphs (e)(2) and (e)(3) deal with parts 121 and 135 and seems to be the exact same verbiage in each, just switching 121 and 135.

(e)(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under part 91 or 121 for that certificate holder if the pilot in command complies with §§ 121.436 and 121.439 of this chapter.

(e)(3) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 135 when the pilot is engaged in a flight operation under parts 91 or 135 for that certificate holder if the pilot in command is in compliance with §§ 135.243 and 135.247 of this chapter.

What am I missing?

(again, it's not a huge deal since the 135 stuff doesn't apply to me, I was just always under the impressions that 135 and 121 basically had the same rules as far as currencies went).
 
Sluggo63 said:
I promise I'm not being argumentative, just trying to learn and I never really looked at the 135 stuff, since it never applied to me.

I see the first three paragraphs of 61.57(e) deal with Parts 125, 121, and 135 respectively. (e)(1) deals with part 125 and only gives relief for paragraphs (a) and (b) {takeoffs and landings and night takeoffs and landings}. Paragraphs (e)(2) and (e)(3) deal with parts 121 and 135 and seems to be the exact same verbiage in each, just switching 121 and 135.

(e)(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under part 91 or 121 for that certificate holder if the pilot in command complies with §§ 121.436 and 121.439 of this chapter.

(e)(3) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 135 when the pilot is engaged in a flight operation under parts 91 or 135 for that certificate holder if the pilot in command is in compliance with §§ 135.243 and 135.247 of this chapter.

What am I missing?

(again, it's not a huge deal since the 135 stuff doesn't apply to me, I was just always under the impressions that 135 and 121 basically had the same rules as far as currencies went).
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You are correct…I was reading too fast between stuff I’m supposed to be doing at work. ;)

Also, SIC instrument recency requirements I noted are actually based on a parallel reg in 135, not 61.57.
 
Tarheelpilot said:
How do you log it?
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Honest estimation. 2 hour flight, spent a quarter of it in the clouds, .5. If I just punched through a layer after takeoff and was clear on top, .1. I don't keep a stop watch going. Is anyone going to split hairs between .4 and .6?
 
midwestpa24 said:
Honest estimation. 2 hour flight, spent a quarter of it in the clouds, .5. If I just punched through a layer after takeoff and was clear on top, .1. I don't keep a stop watch going. Is anyone going to split hairs between .4 and .6?
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I say this tounge in cheek, but half the folks on this forum are probably now searching Amazon for a microscopic X-acto knife to begin work on splitting that hair…. ;)
 
MauleSkinner said:
You are correct…I was reading too fast between stuff I’m supposed to be doing at work. ;)

Also, SIC instrument recency requirements I noted are actually based on a parallel reg in 135, not 61.57.
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Gotcha! Thanks!
 
midwestpa24 said:
Honest estimation. 2 hour flight, spent a quarter of it in the clouds, .5. If I just punched through a layer after takeoff and was clear on top, .1. I don't keep a stop watch going. Is anyone going to split hairs between .4 and .6?
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Same here. I thought you were saying I was doing it wrong somehow.
 
KE5BM said:
But seriously, I was shocked when I finally learned what the currency requirements actually are if you follow them the way you're supposed to. Basically, for us weekenders you're relegated to IPCs as opposed to the actual instrument currencies. It's one of the reasons I put a pause on my IFR training.
Click to expand...
Option 1: Flying buddy. One day at work, I found out that one of our development contractors was a pilot. We became very close friends and for 12 years we flew together about once a month. We'd get together after work, go up and do a few approaches, and then head to a restaurant for dinner. I got luck that way but there are plenty of local formal and informal social flying groups around.

Option 2: See if there is a flight school, flying club, or FBO near you with an aviation training device. For example, the flying club I am with has a "social membership" which includes access to our Redbird BATD.
 
Salty said:
I assume you meant AATD?

Ok, did the rules change or did I always have it wrong that you needed aatd for instrument currency?
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AFAIK, you always had it wrong :D Of course, it kind of depends on what you mean by "always." Using a device for instrument currency without a CFII being present goes back to 2018. The use of a BATD goes back further than that. I have the LOA for the Elite BATD dated September 2014 which includes authorization for instrument currency, and that one refers to a previous approval (but not the date of it).
 
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jayhawk74 said:
No that’s VMC. You just can’t fly VFR that close to the clouds.
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No, it's IMC. Here's the official FAA definition:
VISUAL METEOROLOGICAL CONDITIONS- Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling equal to or better than specified minima.
Note the inclusions of "distance from cloud." VMC is everywhere it is not legal to fly under VFR due to visibility, cloud clearance, and ceiling.

IMC is defined as everywhere not VMC:
INSTRUMENT METEOROLOGICAL CONDITIONS (IMC)- Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minima specified for visual meteorological conditions.
Now instrument conditions isn't really defined anywhere but the FAA counsel has determined it means anytime when you have to use instruments in order to fly.

Thus, the @midlifeflyer is correct, flying just under the clouds is IMC, but it isn't instrument conditions as you can see the horizon, etc... You can operate visually.

The converse of this is the case that is in the counsel letter. While it's technically VMC because you're not up against the clouds and 3 mile visibility, you are forced to operate with respect to instruments due to the indefinite horizon due to haze or flying on a moonless night (without ground lights). You can log instrument time even though it is VMC.

Below is a copy of the letter to which I am referring:

Legal Interpretation # 84-29

November 07, 1984

Mr. Joseph P. Carr

Dear Mr. Carr:

This is in response to your letter asking questions about
instrument flight time.

First, you ask for an interpretation of Section 61.51(c)(4) of
the Federal Aviation Regulations (FAR) regarding the logging of
instrument flight time. You ask whether, for instance, a flight
over the ocean on a moonless night without a discernible horizon
could be logged as actual instrument flight time.

Second, you ask for an interpretation of Section 61.57(e)(2) of
the FAR, noting that Advisory Circular 61-65A, Certification:
Pilots and Flight Instructors, seems to contain advice contrary
to your understanding of the rule.

As you know, Section 61.51(c)(4) provides rules for the logging
of instrument flight time which may be used to meet the
requirements of a certificate or rating, or to meet the recent
flight experience requirements of Part 61. That section
provides, in part, that a pilot may log as instrument flight time
only that time during which he or she operates the aircraft
solely by reference to instruments, under actual (instrument
meteorological conditions (i.m.c.)) or simulated instrument
flight conditions. "Simulated" instrument conditions occur when
the pilot's vision outside of the aircraft is intentionally
restricted, such as by a hood or goggles. "Actual" instrument
flight conditions occur when some outside conditions make it
necessary for the pilot to use the aircraft instruments in order
to maintain adequate control over the aircraft. Typically, these
conditions involve adverse weather conditions.

To answer your first question, actual instrument conditions may
occur in the case you described, a moonless night over the ocean
with no discernible horizon, if use of the instruments is
necessary to maintain adequate control over the aircraft. The
determination as to whether flight by reference to instruments is
necessary is somewhat subjective, and based in part on the sound
judgement of the pilot. Note that, under Section 61.51(b)(3),
the pilot must log the conditions of the flight. The log should
include the reasons for determining that the flight was under
actual instrument conditions in case the pilot later would be
called on to prove that the actual instrument flight time logged
was legitimate.

To answer your second question, your understanding of Section
61.57(e) is correct. Section 61.57(e) provides currency
requirements for acting as pilot in command (PIC) under
instrument flight rules (IFR) or in weather conditions less than
the minimums for visual flight rules (VFR). No pilot may act as
PIC under those conditions unless she or he has, within the last
six months, logged the number of hours of instrument flight time,
including the number of approaches, indicated in Section
61.57(e)(1)(i) or (ii). When that six-month currency period
lapses, that is, on the day the pilot no longer has the required
instrument flight time within the last six months, the pilot may
in the next six months regain her or his currency simply by
logging the required instrument flight time. Note that, during
this second six-mont period, Section 61.57(e)(1) prohibits the
pilot from acting as PIC under IFR or below VFR minimums
(i.m.c.). If that second six-month period runs without the pilot
regaining currency, she or he may only again become qualified to
act as PIC under IFR or in weather below VFR minimums (i.m.c.) by
passing an instrument competency check as described in Section
61.57(e)(2).

Advisory Circular 61-65A, paragraph 15a, explained in part that a
pilot failing to meet the recency of instrument experience
requirements for a period of 12 months must pass an instrument
competency check. This simply meant that, when a pilot becomes
qualified to act as PIC under the instrument conditions
described, he or she has at least a 12-month period in which
currency may be maintained or regained by logging the required
instrument flight time. After that 12-month period, if currency
has not been maintained or regained, the pilot must pass an
instrument competency check. Advisory Circular 61-65A was not
intended to expand the second six-month "grace" period to 12
months. As you note, the Advisory Circular has been changed, and
paragraph 15 was rewritten to more accurately reflect the
requirements of Section 61.57(e)(2).

Sincerely,

John H. Cassady
Assistant Chief Counsel
Regulations & Enforcement Division
 
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midlifeflyer said:
The more I do, the less I am impressed with an IPC as a proficiency exercise. Time with a good instructor, absolutely.

I started asking this question based on something I heard of another CFII saying: “do you want an IPC or do you want to learn something?”
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Nothing says an IPC has to be the bare minimum, or that you can't do both.

My favorite CFII is the one who has given me a 3-hour ass-kicking for an IPC.
 
flyingcheesehead said:
Nothing says an IPC has to be the bare minimum, or that you can't do both.

My favorite CFII is the one who has given me a 3-hour ass-kicking for an IPC.
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This might be semantics, but I'd say if you're taking 3 hours to do an IPC, it's either:

1) Training along with the IPC so that you can complete the tasks successfully. I often encounter this. The person says "I want an IPC" and I explain that it's basically a checkride, they have to do things without assistance. They say "okay", we go up and they miss something major on the first approach (such as forgetting to turn onto final when cleared for the approach, which I have seen with a person who "just needed an IPC"). At that point it becomes "training" and perhaps only a little "training" is needed and then the IPC can resume, or perhaps they need multiple days of training to be able to pass.

2) An IPC PLUS a bunch of other good things. If the instructor is going above and beyond the tasks required of an IPC, then I would say at that point the IPC is complete and the rest is bonus. If they're withholding the IPC endorsement because you didn't successfully complete an engine-out inverted ILS (or something else in excess of the requirements), then I'd cry foul.
 
midlifeflyer said:
The more I do, the less I am impressed with an IPC as a proficiency exercise. Time with a good instructor, absolutely.

I started asking this question based on something I heard of another CFII saying: “do you want an IPC or do you want to learn something?”
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I agree with this. If a pilot is using IPCs as a way to maintain currency, they are most likely far from proficient enough to actually pass the IPC (or safely operate IFR).

Most typically, pilots who come to me for an IPC in order to be IFR current are typically so far out-of-currency that there's no way they can pass an IPC without further training.

The pilots who have no problem with IPCs are generally those who don't actually NEED the IPC for currency. One example was a professional turbine pilot (also a CFII) who also flew a Cirrus on the side. To comply with the Cirrus insurance requirements, he had to have a current IPC in the Cirrus. It was the easiest IPC I've ever signed off - as a CFII he already knew what was required, he was very current, proficient, competent with the avionics, and although I threw a few things at him, he was completely unfazed and it truly seemed like just a formality. But that's exactly how an IPC SHOULD go for some who is actually proficient.
 
Anthem said:
the honor system is kind of laughable. . we all want to believe that the pilots next to us are "honorable" or tell the truth. The reality is that they mostly arent. The honor system carries through everywhere - and there are many known pilots that are / should be medically disqualified to fly that are flying. . . or conveniently left off the medxpress because they didnt want to deal with the subsequent hassle.

You cant pick and choose where your honor system is applicable or not.
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Can’t tell you the amount of pilots that somehow ended up with 1500 hours at record times, and all without being seen in a plane.
 
Really disappointed that nobody disputed the OP. Admins must be putting saltpeter in the virtual drinking water.
 
RussR said:
2) An IPC PLUS a bunch of other good things. If the instructor is going above and beyond the tasks required of an IPC, then I would say at that point the IPC is complete and the rest is bonus. If they're withholding the IPC endorsement because you didn't successfully complete an engine-out inverted ILS (or something else in excess of the requirements), then I'd cry foul.
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This is exactly what I want. FWIW, the 3-hour one was the first IPC I did with him in a glass panel airplane. Of course he threw some of his usual fun in there, like giving me a hold with a 50-knot crosswind from the non-holding side, but he also wrung me through about every combination of failure modes he could think of on the G1000. And yes, we were pulling breakers because covers just don't give you the same experience. It was WELL worth the time.

This is the same guy that had me down to the airspeed indicator, the magnetic compass, and the #2 nav, in actual, during my instrument training. It was one of the most valuable training flights I've ever had.
 
midlifeflyer said:
Option 2: See if there is a flight school, flying club, or FBO near you with an aviation training device. For example, the flying club I am with has a "social membership" which includes access to our Redbird BATD.
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This. Our local FBO has a Redbird and the ability to put different panels in it. While their Warrior panel isn't exactly the same as our Archer, to go fly a half dozen approaches on a crappy New England winter day is actually a lot of fun and you quickly see improvement. With the ability to slew yourself out to the IAF and just fly the approach you can do them quite easily and at $75 an hour for it I can get 6 approaches in an hour and all of them to minimums with weather set to minimums. I find myself doing it every month in the winter unless the weather is good and another club guy wants to be a SP.

Is this the same as doing them in the plane? No. The sim doesn't fly exactly like the plane but it's better than not doing it and it really does help your scan. Knowing what I know now, if I didn't have one locally I'd find one and fly to it VFR for the practice. They really are worth the trip.
 
EdFred said:
Why do they log in visual, because according to 61.57(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 VFR 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.​




Note that it doesn't say actual instrument conditions. It says actual weather. All outside weather is actual. It's not like you're flying in an atmospheric simulator. Now, there is another (electronic only ?) publication out there that says the approach must be in (simulated) instrument conditions beyond a certain point to count. But according to only the CFR's any approach you fly is loggable for currency. And a lot of pilots have no idea where to find all the non-regulatory explanations.
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I honestly doubt they go in for that level of regulatory analysis.
 
flyingcheesehead said:
This is exactly what I want. FWIW, the 3-hour one was the first IPC I did with him in a glass panel airplane. Of course he threw some of his usual fun in there, like giving me a hold with a 50-knot crosswind from the non-holding side, but he also wrung me through about every combination of failure modes he could think of on the G1000. And yes, we were pulling breakers because covers just don't give you the same experience. It was WELL worth the time.

This is the same guy that had me down to the airspeed indicator, the magnetic compass, and the #2 nav, in actual, during my instrument training. It was one of the most valuable training flights I've ever had.
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That’s great, and exactly why I ask. I get pilots who want that. But it’s beyond the IPC which, under the ACS, is pretty simple stuff, tests very rudimentary avionics knowledge, and can be completed in about an hour (the flight portion) with not much more than basic competence.

I do, however, toss in at least one of my “GPS Tasks Pilots Don’t Know How to Do,” and have just begun requiring a quiz be completed as homework.
 
RussR said:
I agree with this. If a pilot is using IPCs as a way to maintain currency, they are most likely far from proficient enough to actually pass the IPC (or safely operate IFR).
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Depends. Clients who do the IPC with me every 6 months are often pilots who fly regularly in the system but rarely have a loggable instrument approach. But they are also the ones who want the “PLUS.”
 
IPC like a check ride. Sounds pretty good to me. I did my last IPC in our club twin because I wanted more twin time. The CFI kept a constant stream of instruction going and was often telling me to do something just about as I was going to. After one flight like that (and we hadn't completed the tasks through no fault of his or mine, just busy airspace and limited time), we prepared for the second flight and I asked him to not bother me with stuff unless I was going to get us killed or bend the airplane. Went much better. It's on me for not asking him to be quiet the first time. CRM and all.
 
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