Interpretation of 61.57 on the 6/6 IR rolling currency

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peter-h

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peter-h
Here is the reg.

(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.
[my bold]

Obviously, it is almost never the case that the cloudbase is at the DA/MDA. So if somebody is maintaining their IR currency using the 6/6 rolling concession, they would have to do it under the hood (and with a RHS pilot) practically all the time.

Yet everybody knows this is not how this reg is interpreted in reality.

I wonder if there has been any precedent in the USA on this, e.g. the METARs need to show probable IMC at the FAF, or whatever?
 
I'm not sure there is any official guidance on this but most people, including me, count it as an actual approach if they are in IMC past the FAF
 
peter-h said:
Here is the reg.

(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.
[my bold]

Obviously, it is almost never the case that the cloudbase is at the DA/MDA. So if somebody is maintaining their IR currency using the 6/6 rolling concession, they would have to do it under the hood (and with a RHS pilot) practically all the time.

Yet everybody knows this is not how this reg is interpreted in reality.

I wonder if there has been any precedent in the USA on this, e.g. the METARs need to show probable IMC at the FAF, or whatever?
Click to expand...

Show me where it says you have to keep the hood on until DA/MDA to count it as a simulated approach.
 
tonycondon said:
I'm not sure there is any official guidance on this but most people, including me, count it as an actual approach if they are in IMC past the FAF
Click to expand...

As do I.
 
If I couldnt descend to the airport without using an instrument approach, its logged.
 
If I couldnt descend to the airport without using an instrument approach, its logged.
Click to expand...

Do you mean that you log it if you would be unable to get there while maintaining VFR?
 
I'm more or less with Grant.

If I have to use the instruments to maintain control if the airplane, that's IMC, regardless of the weather.

If I have to use an instrument approach to safely get to the airport, regardless of the weather, that's a logged approach.

Normally, that works out to being in actual clouds at the Final Approach Fix. But on occasion, at night, where terrain or illusions make visual aircraft control and navigation difficult, that logged instrument approach may have been cloud-free.
 
Here's a question:

Flying VFR on a dark and high but thick overcast night... lots of moisture in the air, visibility is about 5mi. With a safety pilot. No hood on, I lower my seat back so I can't really see above the panel. I have zero horizon, all my focus is on the instruments. My safety pilot agrees that i'm 100% on the instruments. Can I log this as simulated IMC? Assuming I am not doing an approach where I can see the runway lights.

I did this awhile back and I logged it. The hood went back on before shooting the NDB approach.
 
dell30rb said:
Here's a question:

Flying VFR on a dark and high but thick overcast night... lots of moisture in the air, visibility is about 5mi. With a safety pilot. No hood on, I lower my seat back so I can't really see above the panel. I have zero horizon, all my focus is on the instruments. My safety pilot agrees that i'm 100% on the instruments. Can I log this as simulated IMC? Assuming I am not doing an approach where I can see the runway lights.

I did this awhile back and I logged it. The hood went back on before shooting the NDB approach.
Click to expand...
IIRC the regs require a "view limiting device". Perhaps one could claim that lowering the seatback enough that you cannot see anything but dark sky makes the glareshield plus undercast plus darkness a "view limiting device" (works for me).
 
From a legal standpoint, the only standard is a January 28, 1992, FAA Legal Opinion, which did not address the issue of how much of the approach must be flown in instrument conditions, only that "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." I think that the FAA Counsel who wrote that opinion deliberately omitted any mention of how much of the approach must be flown in instrument conditions because any specific standard would probably result in an approach not counting unless you were on the instruments to the MAP, in which case you could only count approaches you missed.

As for VMC/IMC per 91.155, that doesn't matter. What counts is whether or not you were in "instrument conditions," which could be simulated instrument conditions (under the hood or in the sim) or actual instrument conditions (AIC), which was defined as:

"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 [but not always], these conditions involve adverse weather conditions. ...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 judgment of the pilot.
Click to expand...
Emphasis and [] added.

So, it's possible to be in AIC while in VMC, and it's possible not to be in AIC while in IMC. For example, on a dark, moonless night over unlit featureless terrain with OVC250 and P6SM, you would probably be in AIC and able to log the approaches for currency. Likewise, it's possible to be in IMC without being in AIC -- say, flying 400 feet below the base of the overcast with clear air below. Of course, if you log actual instrument time in VMC...

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.
Click to expand...

The other question is how much of the approach must be flown in AIC, and that question has never been addressed (no less answered) by the Chief Counsel, and I hope it stays that way, because we probably couldn't stand the answer. The only other thing is that you have to fly the approach all the way to the runway, or down to the MDA/DA (unless ATC directs a restricted low approach) and all the way to the MAP if you don't land.

As a practical matter, if you ask FAA Inspectors or DPE's, you'll get varying answers ranging from counting it if any portion from IAF to MAP was flown under instrument conditions, to requiring that the entire final segment be flown on instruments. My personal standard is to count for my own currency only those approaches on which I was on instruments for some portion of the final segment, and while some have said I'm being overly restrictive, no FAA official has ever said I'm not strict enough.
 
Thanks, I am going to make a note in my logbook about the weather conditions of that particular flight. And I guess I can log that as actual too.
 
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