Logging approaches in IMC

This is from the old Q&A of Part 61:

QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?

ANSWER: Ref. § 61.51(g)(1) and § 61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an “actual” approach, it would presume the approach to be to the conclusion of the approach that would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is no.
{Q&A-291}
 
What it does NOT say is that the approach must be conducted in IMC all the way to the MAP/DH. If any portion of the approach is conducted in IMC, and the approach is flown to MAP/DH, the brain trust has said you are good to log it.
 
My personal standard is similar to what Greg describes. I have to be "on instruments" crossing the FAF inbound, and I have to fly the approach to the MAP if practicing, or to a landing or missed approach if doing it for real. I know some folks will log it if they're in "Actual" anywhere on the initial approach segment and don't disagree with them, but for my own personal proficiency I want to be on instruments all the way to the FAF (at which point if I've done everything properly I should be well established and stable).
 
And before someone questions the legal force of that Q&A file R&W quoted, the Chief Counsel said pretty much the same thing in an official legal interpretation (but, being a lawyer, in a lot more words).

Personally, like Tim, I don't count it unless some part of the final segment was done in actual instrument conditions, but that's just me being conservative, because I think the part that really matters is the final segment. Others count it if any part (even the first 100 feet of descent from the IAF) was in actual instrument conditions, and I've never heard anyone from the FAA say that's not legal, but I personally don't think that provides sufficient proficiency to consider myself current, and YMMV.
 
Ron Levy said:
And before someone questions the legal force of that Q&A file R&W quoted, the Chief Counsel said pretty much the same thing in an official legal interpretation (but, being a lawyer, in a lot more words).

Personally, like Tim, I don't count it unless some part of the final segment was done in actual instrument conditions, but that's just me being conservative, because I think the part that really matters is the final segment. Others count it if any part (even the first 100 feet of descent from the IAF) was in actual instrument conditions, and I've never heard anyone from the FAA say that's not legal, but I personally don't think that provides sufficient proficiency to consider myself current, and YMMV.
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And I would second what Mr. Levy says here. Hood time is one thing, flying some of the approach in IMC is one thing, but flying down close to minimums in IMC is the real deal. Log how you may, legally, but know what the reality is.
 
Rotor&Wing said:
QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?

ANSWER: Ref. § 61.51(g)(1) and § 61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an “actual” approach, it would presume the approach to be to the conclusion of the approach that would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is no.
{Q&A-291}
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I'll note that the answer doesn't actually address the question it purports to answer. I've never seen anything from an official source that did.

The question was "how far do I need to be in IMC", while the answer actually answers the question "how far do I need to keep flying".
-harry
 
mantakos said:
I'll note that the answer doesn't actually address the question it purports to answer. I've never seen anything from an official source that did.

The question was "how far do I need to be in IMC", while the answer actually answers the question "how far do I need to keep flying".
-harry
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And even then the FAQ varies slightly (to me) from the definition of IMC. "Actual" IMC in my mind is when the instruments are the ONLY way to reliably keep the airplane upright, as opposed to when a pilot chooses to fly soley by reference to instruments.

Taking it to an extreme, according to the FAQ R&W quoted I could log actual instrument time whild flying on a CAVU day as long as I kept my head down and focused on the panel. No hood, no safety pilot, no see and avoid(!), but by god I'm operating soley by reference to instruments. That's not "actual" in my book.

When you get down to the hair-splitting level the whle "actual" definition is almost as useless as the "high performance" definition.
 
TMetzinger said:
And even then the FAQ varies slightly (to me) from the definition of IMC. "Actual" IMC in my mind is when the instruments are the ONLY way to reliably keep the airplane upright, as opposed to when a pilot chooses to fly soley by reference to instruments.
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Per the Chief Counsel, what you are describing is "actual instrument conditions," not IMC. IMC is conditions which do not meet the requirements for VMC given in 91.155, thus requiring that you be operating under IFR to be legal. This could mean being 1999 feet from the cloud off your wingtip on an otherwise clear day. The Chief Counsel has made clear that you must be in "actual instrument conditions," not just "IMC," in order to log instrument time and currency events. The Chief Counsel also made clear that determination of "actual instrument conditions" is a "somewhat subjective" judgement. Here are the Chief Counsel's complete words on the subject in a 1984 interpretation:
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 (imc)) 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 judgment 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.
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And yes, that means you could be legally logging actual instrument flight time in VMC!
 
Ron Levy said:
Per the Chief Counsel, what you are describing is "actual instrument conditions," not IMC. IMC is conditions which do not meet the requirements for VMC given in 91.155, thus requiring that you be operating under IFR to be legal. This could mean being 1999 feet from the cloud off your wingtip on an otherwise clear day. The Chief Counsel has made clear that you must be in "actual instrument conditions," not just "IMC," in order to log instrument time and currency events. The Chief Counsel also made clear that determination of "actual instrument conditions" is a "somewhat subjective" judgement. Here are the Chief Counsel's complete words on the subject in a 1984 interpretation:

And yes, that means you could be legally logging actual instrument flight time in VMC!
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Yes, but, as I noted, only if the meteorological conditions FORCED you to use the instruments to maintain control, as opposed to you CHOOSING to use the instruments instead of the 2000-mile wide horizon out your window.

You're correct, the term IMC is irrelevant to IFR currency, all that matters is actual or simulated instrument conditions.
 
As Tim points out using the instruments on a sunny day is not IMC...

It is really simple: Did you need an IFR clearance for the approach and landing because the field was below VFR minimums? (That is the legal definition of IMC, btw)
If the answer is yes, it was an actual IMC operation and needs to be logged as such Needing the instruments for only 60 seconds or not, using them all the way to DH/MAP or not, does not change the fact that it was an IFR operation in legal IMC...

denny-o
 
Dr. O said:
It is really simple: Did you need an IFR clearance for the approach and landing because the field was below VFR minimums? (That is the legal definition of IMC, btw)
If the answer is yes, it was an actual IMC operation and needs to be logged as such Needing the instruments for only 60 seconds or not, using them all the way to DH/MAP or not, does not change the fact that it was an IFR operation in legal IMC...
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True, and in this case, you almost certainly were in actual instrument conditions on the final segment. But it is those actual instrument conditions, not the IMC, which makes it legal to log the actual instrument time and the approach for currency. OTOH, if the reason the field was IMC was a fog bank around the ASOS while the runway and approach were clear, you could not legally log the time or approach since you were never in actual instrument conditions.
 
Ron Levy said:
True, and in this case, you almost certainly were in actual instrument conditions on the final segment. But it is those actual instrument conditions, not the IMC, which makes it legal to log the actual instrument time and the approach for currency. OTOH, if the reason the field was IMC was a fog bank around the ASOS while the runway and approach were clear, you could not legally log the time or approach since you were never in actual instrument conditions.
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Or, symbolically:

IMC <> Actual Instrument Conditions
IMC != Actual Instrument Condtions

Here are a couple examples where I don't log the approaches:
1. I was in and out of clouds at the IAF, but clear of them by the time I reached the FAF.

2. The Field was reporting IFR (visibility) but I was able to fly the approach and land without HAVING to use the instruments to keep the airplane upright.
 
Sac Arrow said:
Good point and and an important distinction. But, I think though, in the scenario where you were in IMC and on an IFR flight plan due to cloud clearance issues when you began the approach and crossed the FAF, but you otherwise were not in actual conditions and did not need to control the airplane solely by reference to instruments you could log the approach (right?) but not the flight time, (right?)

FAR Part 61.51 (g) (1)

"A person may log instrument time only for that flight time when the person operates the aircraft soley by reference to instruments under actual or simulated instrument flight conditions."
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I don't think you can count the approach unless you were in actual or simulated insttrument flight conditions which, as noted, are different then IMC.

So I wouldn't log the approach unless you were actually required to fly on the gauges for a portion of the approach, regardless of the type of flight plan you were on or the weather out the window.
 
Sac Arrow said:
I think though, in the scenario where you were in IMC and on an IFR flight plan due to cloud clearance issues when you began the approach and crossed the FAF, but you otherwise were not in actual conditions and did not need to control the airplane solely by reference to instruments you could log the approach (right?) but not the flight time, (right?)
FAR Part 61.51 (g) (1)

"A person may log instrument time only for that flight time when the person operates the aircraft soley by reference to instruments under actual or simulated instrument flight conditions."
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Not the way the Chief Counsel interprets it. You must be in actual or simulated instrument flight conditions to count the approach, not just in IMC, since you can be in IMC without being actual instrument conditions (e.g., 1999 feet laterally from the only cloud in the sky during the approach). Ref: Legal Interpretation #92-5. And "actual instrument conditions" are, per the Carr letter, "when some outside conditions make it necessary for the pilot to use the aircraft instruments in order to maintain adequate control over the aircraft." No necessity for instruments = no "actual" instrument flight conditions = no counting for currency unless you're using the hood (thus making it "simulated instrument conditions", not actual).
 
Sac Arrow said:
Okay, I misunderstood what you guys were saying. I do in fact apply the criteria that I be in actual instrument conditions at some point in the approach to log it. But it's a little ambiguous based on FAR 61.57 alone.
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You do have my sympathy, as it's a bit of a slippery fish you're trying to grasp. Careful reading of both the Carr and Slater interpretations is necessary to get a grip on the issue. Consider it another one of those things the FAA does like the three different definitions of night (depending on context -- lighting, logging, or landing) or the seven different types of cross-country flight time.
 
If I am in instrument conditions at any point after the IAF I log it.
 
Hmmm.....

IMC (on gauges, no outside reference -- and peeks straight down from time to time isn't a "visual reference") at least to the FAF for me... though I only log approaches that land or go missed near the DA or MDA.

:dunno:
 
EdFred said:
If I am in instrument conditions at any point after the IAF I log it.
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...and there's nothing that says you can't. However, there's also nothing to prevent anyone from applying more stringent standards to what they log -- simply a matter of choice and assessment of the effect on one's own proficiency.
 
dmccormack said:
IMC (on gauges, no outside reference -- and peeks straight down from time to time isn't a "visual reference") at least to the FAF for me...
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Being on the gauges with no outside visual reference doesn't necessarily mean you're in IMC, and being in IMC doesn't necessarily mean you're in "actual instrument conditions" ("actual instrument conditions" being equivalent to "on gauges, no outside visual reference"), and being in "actual instrument conditions" is required for logging the time and approaches (other than with a vision restricting device). To avoid confusion over this issue, it's very important that instrument instructors accurately convey these concepts to their trainees correctly, including correct definition and use of the terms IMC, IFR, and "actual instrument conditions." Sloppy semantics only make it harder for our trainees to get this right.
 
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Ron Levy said:
Here are the Chief Counsel's complete words on the subject in a 1984 interpretation...
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Ron,

Since the FAA's search site only goes back to 1990, is there a link for that 1984 interpretation?

Thanks,
 
kinoav8r said:
Since the FAA's search site only goes back to 1990, is there a link for that 1984 interpretation?
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Not to my knowledge. I believe I extracted it from the FAQ file R&W mentioned earlier, and that file is no longer publicly available.
 
Ron Levy said:
Being on the gauges with no outside visual reference doesn't necessarily mean you're in IMC, and being in IMC doesn't necessarily mean you're in "actual instrument conditions" ("actual instrument conditions" being equivalent to "on gauges, no outside visual reference"), and being in "actual instrument conditions" is required for logging the time and approaches (other than with a vision restricting device). To avoid confusion over this issue, it's very important that instrument instructors accurately convey these concepts to their trainees correctly, including correct definition and use of the terms IMC, IFR, and "actual instrument conditions." Sloppy semantics only make it harder for our trainees to get this right.
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Good grief -- and that was supposed to be "explanatory?" :rolleyes2:

If I have no outside visual references -- guess what? I'm on the gauges and that's instrument flight.

What's unclear about that?
 
dmccormack said:
Good grief -- and that was supposed to be "explanatory?" :rolleyes2:

If I have no outside visual references -- guess what? I'm on the gauges and that's instrument flight.

What's unclear about that?
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You could have no outside visual references and still be in VMC, thus while it would be instrument flight, it's not VMC.
 
TMetzinger said:
You could have no outside visual references and still be in VMC, thus while it would be instrument flight, it's not VMC.
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Hunh??

I understand the difference between "VMC" and "IMC" -- but if you can't see due to whatever.... does it matter?

"Reported visual meteorological conditions" is moot once you're airborne -- various obscurants can force gauges-only flight during otherwise visual conditions.
 
dmccormack said:
... I understand the difference between "VMC" and "IMC" -- but if you can't see due to whatever.... does it matter?...
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Just a terminology issue, one that matters because the regs use these terms, so we have to know what they mean in order to know the rules. It's noteworthy because people do tend to use these incorrectly, per the textbook definitions.
-harry
 
mantakos said:
Just a terminology issue, one that matters because the regs use these terms, so we have to know what they mean in order to know the rules. It's noteworthy because people do tend to use these incorrectly, per the textbook definitions.
-harry
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I think it's an interesting fact, but not for the purposes of this discussion.

If I am flying an approach and my visual references are limited to instruments, it's an instrument approach.

I only count approaches to the MAP if I go around -- FAF isn't really enough, IMHO.
 
To summarize:

  • In VMC but also "Actual Instrument":

  • Dark night, no horizon, no visual references, but no clouds and excellent visibility. Generally over open water or North Dakota
  • Log the approach because you're forced to fly by reference to instruments
  • In IMC, but not in "Actual Instrument":
    • You're 200' below a cloud layer in Class C-D-E. No clouds, 10+ SM visibility in all directioins but up
    • Don't log the approach unless you're under a hood
 
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