Logging approaches in VMC

[MachFly]

I recently heard that in order to log an approach you need to fly it either in IMC or under the hood, is this true?
I always thought that as long as you fly the whole approach you can log it regardless of weather.

 

[azure]

I recently heard that in order to log an approach you need to fly it either in IMC or under the hood, is this true?
I always thought that as long as you fly the whole approach you can log it regardless of weather.

No, it has to be flown under either actual or simulated instrument conditions. Then comes the question of just HOW MUCH of the approach has to be flown that way in order to be loggable. The consensus seems to be, as long as some part of the approach beyond the FAF (or p-FAF) is flown in actual, it's loggable. For simulated, I'd assume the same is true, but tearing off the hood 10 seconds after the FAF would probably be considered cheating. Normally you're expected (at least by a CFII) to continue down to the MDA or DA on the gauges.

 

[Captain]

That's how I do it. If I see the airport 1 second prior to the FAF it's logged as a visual. 1 second past the FAF it's an approach. Gotta draw a line somewhere.

 

[MachFly]

This sucks.
Well, thanks for clarifying.

That's how I do it. If I see the airport 1 second prior to the FAF it's logged as a visual. 1 second past the FAF it's an approach. Gotta draw a line somewhere.

What if it's perfectly VFR but you don't see it due to haze?

 

[poadeleted20]

For a full explanation, see:

http://www.pilotsofamerica.com/forum/showthread.php?p=812598#post812598

The gist of it is pretty much what Azure said. You must be in actual or simulated instrument conditions, it doesn't matter whether you're in IMC or VMC, the approach must be continued to the MDA or DH (but not necessarily all the way in instrument conditions) unless safety requires an early level-off, you must continue to the MAP or runway, and there is no official guidance on how much of the approach must be in instrument conditions. On the last point, my personal standard is that if I'm in actual instrument conditions at any point between FAF and runway/MAP, I log it, and nobody in the FAA has ever said that standard is inadequate (although some have said it's unnecessarily strict).

BTW, as an instrument instructor, I use different strategies for removing the hood depending on the type of approach. First, I brief the trainee that the s/he is in the goo as long as the hood remains on, and to take action accordingly. On a precision approach where I want the trainee to continue to land, I pull the hood 50-300 above DH (depending on stage of training). On a nonprecision approach where I want the trainee to continue to land, I pull the hood once established at MDA within appropriate distance from the runway (e.g., about 2 miles for an MDA of 500 feet -- time to to spot the airport and descend normally). Either way, if I want the missed approach executed, I leave the hood on.

Finally, while Captain is free to do as he pleases, not seeing the airport from the FAF is not necessarily being in actual instrument conditions, and it would take more than that for me to count it.

 

[Captain]

This sucks.
Well, thanks for clarifying.





What if it's perfectly VFR but you don't see it due to haze?

If I just passed he FAF and I can't see the runway then I'm guiding the plane by instruments (charted visual segment excluded) and I'm on an IAP with terminal sensitivity. That's an approach in my book.

I know guys who log an approach any time theyre cleared for an approach. I can't imagine logging an ILS and 0.0 IMC. But like Cap'n Ron said, to each their own. Who cares? I've got my IR and ATP ME. Not like I'll be showing any of it to anyone with a badge anytime soon. Plus, my currency is covered every six months in a sim.

(not bragging, just trying to head off future counterpoints that so often pop up here.)

 

[Jaybird180]

 

[Gubbins]

Interesting. I've decided to start doing my currency approaches in a simulator. It is too difficult trying to find a safety pilot when it is convenient for me, and is cheaper than flying my plane.

 

[bobmrg]

My take on it is subjective: Has the approach made you a more competent/proficient pilot, or am I just checking off a box? I ask myself this question only after having some obstruction to vision during the final approach leg. VMC? Absolutely not.

BTW, "I recently heard" is not the way to do it. Look at original source documents, where they exist. There are too many Old Wives Tales already. Ask the person you heard it from to provide documentation.

Bob Gardner

 

[poadeleted20]

Interesting. I've decided to start doing my currency approaches in a simulator. It is too difficult trying to find a safety pilot when it is convenient for me, and is cheaper than flying my plane.

Even with the cost of the instructor?

 

[weilke]

BTW, "I recently heard" is not the way to do it. Look at original source documents, where they exist. There are too many Old Wives Tales already. Ask the person you heard it from to provide documentation.

Bob Gardner

Oh, that's the perfect way to do it. Post it here with 'I have heard' and within an hour there will be an answer from you, John Collins and Ron Levy citing chapter and verse of the applicable rules

 

[Gubbins]

Even with the cost of the instructor?

I was told I don't need an instructor to log approaches in the sim. I am not logging the hours only the approaches. Is this not correct?

 

[TMetzinger]

I was told I don't need an instructor to log approaches in the sim. I am not logging the hours only the approaches. Is this not correct?

It used to be correct. There are even letters from FSDOs and DC to the folks who make the Frascas and Redbirds and such that said that flying a sim for proficiency wasn't "training" any more than going up with a safety pilot was.

Then our gloriously reigning Chief Counsel issued an interpretation that contradicted those, and that's how it stands. I believe that folks have asked for a reconsideration of that opinion but am not sure it's happened.

Ron probably has the opinion handy, I'm pretty sure it's been raised (by me) at least once here.

Also, keep in mind that the rules have changed and there's a difference between a simulator/FTD and the ATDs like the Redbird. If you use a "real" sim or FTD I believe you can just fly the same routine as in an airplane. But for the ATDs you have more strict requirements. So please go read the appropriate part of 61 - don't take this description as being complete or even terribly accurate. Just know that you need to review the regs.

 

[BillTIZ]

Even with the cost of the instructor?

Approved simulator with CFII, $130/hr.
Ability to fly almost twice the number of approaches in the sim vs. the airplane. Able to reposition the sim. Yes, fly one or two with the full published or "ATC" directed missed procedure. Not taking full time for radar downwind or vectors for the next approach. Able to complete approaches to multiple airports 100s of miles apart instead of flying the same ILS/Loc approach 6 times.

Cost of C182, $180/hr plus CFII
I'll agree that in the airplane is more realistic, but around here, you can only get "multiple practice approaches" between midnight and 6am.

 

[Gubbins]

It used to be correct. There are even letters from FSDOs and DC to the folks who make the Frascas and Redbirds and such that said that flying a sim for proficiency wasn't "training" any more than going up with a safety pilot was.

Then our gloriously reigning Chief Counsel issued an interpretation that contradicted those, and that's how it stands. I believe that folks have asked for a reconsideration of that opinion but am not sure it's happened.

Ron probably has the opinion handy, I'm pretty sure it's been raised (by me) at least once here.

Also, keep in mind that the rules have changed and there's a difference between a simulator/FTD and the ATDs like the Redbird. If you use a "real" sim or FTD I believe you can just fly the same routine as in an airplane. But for the ATDs you have more strict requirements. So please go read the appropriate part of 61 - don't take this description as being complete or even terribly accurate. Just know that you need to review the regs.

I will research this. Thank you for the heads up. But even with a cfii it will be cheaper than flying my plane.

 

[poadeleted20]

The letter is here.
http://www.faa.gov/about/office_org...nterpretations/data/interps/2010/Keller-1.pdf

And now, the rest of the story...

This specific issue is the subject of an ongoing dispute between AFS-800 and AGC-200, without what I wlould consider final resolution. AFS-800 says that under 14 CFR 61.4, they can make the rules on what you can use a sim for, and that includes allowing use for recent instrument experience without an instructor's involvement. However, AGC-200 took the position in the Keller letter that 61.51(g)(4) specifically requires an instructor's presence and signature to log anything in any sort of sim for recent instrument experience requirements, and that 61.4 does not authorize AFS-800 to essentially nullify 61.51(g)(4). Their position is that AFS-800 would have to either revise 61.51(g)(4) or go through the exemption process (which includes many of the steps of the rulemaking process, including notice in the Federal Register), but AFS-800 (which can do either) doesn't want to go through either regulatory process. Nobody with authority over both AFS and AGC has taken a position which office's position is to be adopted, but per general policy established by the Administrator and agreed to by AFS-1 as a result of the hoopla over the Part 61 FAQ file, although AFS has the final word on flight procedures, the Chief Counsel has the final word on interpretation of regulations.

As a result, I recommend abiding by the Keller letter, i.e., not logging anything in any kind of sim without an instructor present and signing, regardless of anything that comes out of AFS-800. By doing this, you are certain of not getting in trouble, even if you may be inconvenienced.

BTW, AFAIK, the only flight simulation devices for which AFS-800 has written 61.4 authorization letters allowing accomplishment of recent instrument experience are some Redbird BATD's. If you're in anything other than one of those devices for which such an authorization letter has been written, there is no question that 61.51(g)(4) applies and you must have an instructor present and signing.

 

[Sac Arrow]

My take on it is that if you cannot land VFR and you must file and do the approach, it's loggable. Seems fair to me. And 99% of the time in my area that means being in IMC well past the FAF.

 

[poadeleted20]

My take on it is that if you cannot land VFR and you must file and do the approach, it's loggable. Seems fair to me. And 99% of the time in my area that means being in IMC well past the FAF.

Once again, being in IMC has nothing to do with this -- the determining factor is whether you're in actual instrument conditions, and VMC/IMC is not deciding. As discussed above, you can be in actual instrument conditions while in VMC, and you can be in IMC without being in actual instrument conditions. That part is again straight from the Chief Counsel's office, and on this one, Flight Standards agrees with the Chief Counsel.

 

[Sac Arrow]

That's why I post by Sac Arrow and not my given name, Hugh Gnot.

 

[denverpilot]

Boy, I'm so glad leadership is strong at FAA and stepped in to decide which bureaucracy makes which rules.

And that we pay for that level of incompetent leadership...

It's cool. Our Blessed Leader (my new name for the Chief Counsel, since apparently Law is religion now) will lead if the real leadership won't.

That'll be good for the organization and its customers.

We should definitely be all fixed soon. And I'm sure it's a high priority at aviation organizations like AOPA.

They look out for problems like this and fix them quickly and efficiently through the great numbers of pilots they represent. A strong organization for sure!



(In a rant mood tonight.)

 

[MachFly]

BTW, "I recently heard" is not the way to do it. Look at original source documents, where they exist. There are too many Old Wives Tales already. Ask the person you heard it from to provide documentation.

We didn't have much time to talk so I didn't ask.
Then after I couldn't find it in the FAR I posted this thread.

 

[MachFly]

Say your flying RNAV 3L into Yuma. It's a perfect VMC day and you can see the airport from the IAF. Unless your extremely familiar with the area there is no way that you will be able to fly this approach by looking outside, so regardless of wx you will be referencing instruments. Now since your referencing instruments on this approach shouldn't you be able to log it even with 0.0 IMC or simulated instrument?


Plate: http://skyvector.com/files/tpp/1209/pdf/00511R3L.PDF

 

[TMetzinger]

BTW, AFAIK, the only flight simulation devices for which AFS-800 has written 61.4 authorization letters allowing accomplishment of recent instrument experience are some Redbird BATD's. If you're in anything other than one of those devices for which such an authorization letter has been written, there is no question that 61.51(g)(4) applies and you must have an instructor present and signing.

I've seen letters from fsdos referencing AFS800 for the GATT II device, but they were pre-Keller.

Sent from my ADR6300 using Tapatalk 2

 

[jason]

Say your flying RNAV 3L into Yuma. It's a perfect VMC day and you can see the airport from the IAF. Unless your extremely familiar with the area there is no way that you will be able to fly this approach by looking outside, so regardless of wx you will be referencing instruments. Now since your referencing instruments on this approach shouldn't you be able to log it even with 0.0 IMC or simulated instrument?


Plate: http://skyvector.com/files/tpp/1209/pdf/00511R3L.PDF

No, not unless it was done in either simulated or actual instrument conditions.

 

[MachFly]

No, not unless it was done in either simulated or actual instrument conditions.

Right I understand that but I think you really should be able to.

 

[jason]

For a full explanation, see:

http://www.pilotsofamerica.com/forum/showthread.php?p=812598#post812598

The gist of it is pretty much what Azure said. You must be in actual or simulated instrument conditions, it doesn't matter whether you're in IMC or VMC, the approach must be continued to the MDA or DH (but not necessarily all the way in instrument conditions) unless safety requires an early level-off, you must continue to the MAP or runway, and there is no official guidance on how much of the approach must be in instrument conditions. On the last point, my personal standard is that if I'm in actual instrument conditions at any point between FAF and runway/MAP, I log it, and nobody in the FAA has ever said that standard is inadequate (although some have said it's unnecessarily strict).

BTW, as an instrument instructor, I use different strategies for removing the hood depending on the type of approach. First, I brief the trainee that the s/he is in the goo as long as the hood remains on, and to take action accordingly. On a precision approach where I want the trainee to continue to land, I pull the hood 50-300 above DH (depending on stage of training). On a nonprecision approach where I want the trainee to continue to land, I pull the hood once established at MDA within appropriate distance from the runway (e.g., about 2 miles for an MDA of 500 feet -- time to to spot the airport and descend normally). Either way, if I want the missed approach executed, I leave the hood on.

Finally, while Captain is free to do as he pleases, not seeing the airport from the FAF is not necessarily being in actual instrument conditions, and it would take more than that for me to count it.

What about approaches that don't have a FAF? One would think that if an FAF is a requirement to log an approach, all approaches would have one.

Of course, having seen this discussed before I know that you probably meant final segment and not FAF. And I also know that there isn't much that can be said on the subject that would change your mind.

My personal standard isn't that far off from yours, really. I suppose that the only difference is that I wouldn't reject an approach that was flown in IMC/AIC until near the FAF. If I'm in AIC for a good portion of the approach between the IAF and the FAF, that is good enough for me. It would all depend on the specifics of the approach.

The bottom line is that the point of the rule is to keep you current enough to fly well (safely). It takes as much skill to navigate to an IAF and then from it to the FAF in AIC as it does to get dumped (radar vectored) just outside the FAF on an ILS and follow it in. That's why I'm more of an "it depends" guy when it comes to the interpretation of this rule.

 

[jason]

Right I understand that but I think you really should be able to.

Can't say I agree. There is huge difference between keeping the plane right side up by reference to the horizon (while following the approach on the instruments) and keeping the plane right side up and fully navigating all segments with no outside visual clues.

There is already enough of a difference between only flying it with foggles and then jumping to AIC. I'm not sure that lowering the bar for currency does a lot to increase safety.

 

[TMetzinger]

Back to the original question... just like logging actual instrument time, there is some judgement involved.
For logging approaches, my criteria is if I need to use the instruments to safely operate the airplane (meaning I couldn't do it just by looking out the window) during the final approach segment, I log it.

It's the same thing for logging actual instrument time - if I need the instruments to be safe, it's actual.

You may discuss the definition of "safe" among yourselves.

 

[Palmpilot]

Right I understand that but I think you really should be able to.

There was an NPRM that included a proposal to do away with the requirement for actual or simulated instrument conditions, but the comments filed were largely against it, so they didn't adopt that provision.

 

[azure]

Right I understand that but I think you really should be able to.

I disagree, at least if proficiency is the goal. I've flown dozens of practice approaches like this, just me and my lonesome with my CNX-80 in perfect VMC. Doing that is good for keeping up my familiarity with the buttonology, procedures, and radio work, but it's a totally different ball of wax from having to do all that while keeping the dirty side down without having visual cues as to which way actually IS down. I could fly approaches like that all day long for a week, and once under the hood, a whole new set of challenges is added. Even if I try to keep my eyes on the gauges (bad idea, especially in busy airspace), my peripheral vision provides enough cues that it just isn't the same thing.

The only time I'd agree that flying approaches in VMC without a hood helps proficiency is at night, away from the city. But even then, your priority should be see and avoid and I can't do that and keep my eyes on the panel long enough to NEED the gauges to control the airplane. The only way to do it safely is to take along a safety pilot. And if I'm going to do that, I might as well put on the foggles.

 

[TMetzinger]

I disagree, at least if proficiency is the goal. I've flown dozens of practice approaches like this, just me and my lonesome with my CNX-80 in perfect VMC. Doing that is good for keeping up my familiarity with the buttonology, procedures, and radio work, but it's a totally different ball of wax from having to do all that while keeping the dirty side down without having visual cues as to which way actually IS down. I could fly approaches like that all day long for a week, and once under the hood, a whole new set of challenges is added. Even if I try to keep my eyes on the gauges (bad idea, especially in busy airspace), my peripheral vision provides enough cues that it just isn't the same thing.

The only time I'd agree that flying approaches in VMC without a hood helps proficiency is at night, away from the city. But even then, your priority should be see and avoid and I can't do that and keep my eyes on the panel long enough to NEED the gauges to control the airplane. The only way to do it safely is to take along a safety pilot. And if I'm going to do that, I might as well put on the foggles.

Very well said.

 

[MachFly]

I disagree, at least if proficiency is the goal. I've flown dozens of practice approaches like this, just me and my lonesome with my CNX-80 in perfect VMC. Doing that is good for keeping up my familiarity with the buttonology, procedures, and radio work, but it's a totally different ball of wax from having to do all that while keeping the dirty side down without having visual cues as to which way actually IS down. I could fly approaches like that all day long for a week, and once under the hood, a whole new set of challenges is added. Even if I try to keep my eyes on the gauges (bad idea, especially in busy airspace), my peripheral vision provides enough cues that it just isn't the same thing.

The only time I'd agree that flying approaches in VMC without a hood helps proficiency is at night, away from the city. But even then, your priority should be see and avoid and I can't do that and keep my eyes on the panel long enough to NEED the gauges to control the airplane. The only way to do it safely is to take along a safety pilot. And if I'm going to do that, I might as well put on the foggles.

Oh yeah, I completely agree.
I just want to be able to log an approach simply to have more. As far as proficiency is concerned foggles or IMC would do a much better job.

 

[azure]

As long as you do your 6HITS in 6 months and/or an IPC, you're (legally) good to go. Why else would you need to log more (as opposed to fly more for proficiency)?

 

[MachFly]

As long as you do your 6HITS in 6 months and/or an IPC, you're (legally) good to go. Why else would you need to log more (as opposed to fly more for proficiency)?

I don't know, no real reason. Just logically it seems that I should log every approach I fly regardless of how I fly it.

 

[Palmpilot]

I don't know, no real reason. Just logically it seems that I should log every approach I fly regardless of how I fly it.

Sometimes I write VMC no-hood approaches in the remarks section, but I don't put them in the approach column.

 

[MachFly]

Sometimes I write VMC no-hood approaches in the remarks section, but I don't put them in the approach column.

Yeah that's an option.

 

[poadeleted20]

What about approaches that don't have a FAF? One would think that if an FAF is a requirement to log an approach, all approaches would have one. Of course, having seen this discussed before I know that you probably meant final segment and not FAF.

Yes, that's better phrasing.

And I also know that there isn't much that can be said on the subject that would change your mind.

Short of something from the Chief Counsel or a reg change, no, I won't change how I log it.

My personal standard isn't that far off from yours, really. I suppose that the only difference is that I wouldn't reject an approach that was flown in IMC/AIC until near the FAF. If I'm in AIC for a good portion of the approach between the IAF and the FAF, that is good enough for me. It would all depend on the specifics of the approach.

There are few I've spoken with in the FAA who would disagree with your method.

The bottom line is that the point of the rule is to keep you current enough to fly well (safely). It takes as much skill to navigate to an IAF and then from it to the FAF in AIC as it does to get dumped (radar vectored) just outside the FAF on an ILS and follow it in. That's why I'm more of an "it depends" guy when it comes to the interpretation of this rule.

I won't argue with any of that.

 

[poadeleted20]

As long as you do your 6HITS in 6 months and/or an IPC, you're (legally) good to go. Why else would you need to log more (as opposed to fly more for proficiency)?

Because you never know when you'll get your next "countable" approach and you don't want to run out of currency later on.

 

[azure]

Because you never know when you'll get your next "countable" approach and you don't want to run out of currency later on.

But if you do 6HITS today, and fly no more loggable approaches (or any more instruments period, for that matter) between now and March 31, 2013, would you really want to take off into hard IMC on April 1 based only on the non-loggable (and generally worthless-for-proficiency) approaches you might fly between now and then?

I haven't flown instruments since July 25. If I'd passed my checkride by then as I was supposed to, I'd (easily) be legally current today but probably rusty enough after 6 weeks that I wouldn't want to file IFR to KCMH without doing a little brush-up with a CFII or safety pilot first. I'd probably have gotten the visual at my destination this morning, but I think I would prefer to be ready for anything before accepting an IFR clearance.

 

[jason]

I don't know, no real reason. Just logically it seems that I should log every approach I fly regardless of how I fly it.

AFAIK there is nothing stopping you from *logging* them as approaches. You just can't count them toward your instrument proficiency requirements (which is what everybody in this thread assumed that you meant by "logging").

So if you DO log them, you'd better have a way of differentiating which count toward 6HITS and which don't. To me, it's not worth that extra effort. Just remark them and be done with it.