When can I log instrument approaches for currency?

[rheise]

I am a new IR pilot and have the question about when an instrument approach can be logged to satisfy the currency requirements? I am talking about non-simulated approaches.

Almost all the cross-country flights I have taken in the last few months since getting my rating have been on instrument flight plans, and I have been even able to log a couple of hours of actual IMC, but it has been primarily at altitude.

I always ask for an instrument approach into the destination instead of a visual approach, but if I am in VMC, I don't think it can be logged as satisfying currency.

I have had one pilot tell me I need to be in IMC at least until the FAF to be able to log the approach, but is there any rule that specifies when a non-simulated approach can be logged?

Thanks for any responses!!

Robert

 

[KennyFlys]

Hey Robert, Welcome to the board!

Per 61.57(c), the only requirement is they must be under actual or simulated conditions (view limiting device). There's nothing regarding approaches acceptable in actual or simulated being down to only the FAF. Fly it to minimums or slightly above at the very least to give you the most realistic experience. You can also log them on an approved flight training device.

If you haven't had much experience flying in actual, I'd suggest getting with a good CFII and flying approaches in actual instrument conditions for a couple flights.

 

[rheise]

Thanks Ken for the response and welcome. It is nice to find an active community of pilots to talk with.

I guess it then begs the question, do most pilots have to do simulated approaches with a safety pilot to keep current?

My own personal minimums for now are 500 ft above minimums and 2 miles, so for a 200 ft ILS, that would be 700 ft AGL.

If I fly an approach where I would break out at 700-1000 ft, or even 1500 ft above the ground, but on an ILS the glideslope intercept is say at 2000 ft, would that approach suffice as one of the six needed and be logged as such?

I hope to do much more than six approaches in six months to stay current and safe, and I am sure some of those will continue to be with an instructor or safety pilot down to minimums, but just was wondering what the FAA said if they were to check on other approaches logged.

Robert

 

[ScottM]

Robert welcome aboard. Where do you fly out of? I am based up north of you at 10C (Galt). There are a bunch of PoAers in the Chicago area. Hopefully we will get to meet up with you.

 

[TMetzinger]

There is some debate on how low the clouds have to be to log an approach conducted in actual conditions for instrument currency.

One opinion was that you had to be in actual crossing the FAF, and another was that you had to have IMC all the way to the MDA/DA.

I don't know if there's been a definitive opinion issued by an FAA counsel on the matter.

My personal opinion (which is worth diddly or squat depending if it's an odd or even day) is that if you're in actual IMC when you commence the final approach segment, then the approach should count. But since I don't get enough actual time that low to meet the requirements, I've just gotten in the habit of doing 6 approaches with a safety pilot regardless.

 

[ScottM]

There is some debate on how low the clouds have to be to log an approach conducted in actual conditions for instrument currency.

One opinion was that you had to be in actual crossing the FAF, and another was that you had to have IMC all the way to the MDA/DA.

I don't know if there's been a definitive opinion issued by an FAA counsel on the matter.

My personal opinion (which is worth diddly or squat depending if it's an odd or even day) is that if you're in actual IMC when you commence the final approach segment, then the approach should count. But since I don't get enough actual time that low to meet the requirements, I've just gotten in the habit of doing 6 approaches with a safety pilot regardless.

I do not believe you have to IMC all the way to the MDA/DH at all, but you do have to fly the approach to the MDA/DH for it to count. There are a few threads already on the site about this.

I would say that by the time you are at the FAF and are out of IMC that you should not count it at all. But if a protion of the decent is in IMC and you break out and continue to fly the procedure you can count it. Although the FAA will allow you to deviate for safety reasons sooner than MDA/DH and still count the approach.

 

[KennyFlys]

Thanks Ken for the response and welcome. It is nice to find an active community of pilots to talk with.

I guess it then begs the question, do most pilots have to do simulated approaches with a safety pilot to keep current?

Yes, to log them while flown in VMC, you must do them with a safety pilot.

My own personal minimums for now are 500 ft above minimums and 2 miles, so for a 200 ft ILS, that would be 700 ft AGL.

If I fly an approach where I would break out at 700-1000 ft, or even 1500 ft above the ground, but on an ILS the glideslope intercept is say at 2000 ft, would that approach suffice as one of the six needed and be logged as such?

Those are good starting numbers as long as there are no terrain issues in the area which isn't likely in your region, towers excepted. Such an approach would qualify but please don't make that your minimum goal.

With those higher numbers, obviously that limits things on your own and that's a good plan for the time being until skill and experience improve. The most important factor is you're flying the procedures, meaning you're setting up as required and briefing the approach to know what to expect at a given point.

I hope to do much more than six approaches in six months to stay current and safe, and I am sure some of those will continue to be with an instructor or safety pilot down to minimums, but just was wondering what the FAA said if they were to check on other approaches logged.

Definitely do more than the required six approaches. There are far too many instrument rated pilots who do the very minimum for currency only to get themselves in trouble somewhere down the road. I don't think doing a couple a month with a safety pilot is an unreasonable goal and it's all the better if you can spend some of those times in actual with a qualified CFII.

Even when flying in VMC, you can still request and fly an approach. That alone will keep up your skill in reading the plates, doing a proper brief and instrument set up even if you can't log it. It's all part of remaining proficient.

 

[airdale]

I guess it then begs the question, do most pilots have to do simulated approaches with a safety pilot to keep current?

Yes, but when ceilings are only slightly above the lowest MDA for my home airport I try to get the guy that I did my training with and go out to shoot approaches for an hour or two sans autopilot. With luck, this happens a couple of times a year. IMHO I don't get enough solid IMC approaches in my normal flying & I don't think enroute IMC really is much value as practice.

I also try to satisfy the FAA requirements using a three month window, not six.

 

[rheise]

I appreciate all the response. I will look for the opportunity to fly with a CFII when weather is at minimums. Unfortunately, I missed one a few weeks ago. Winter in Chicago is going to bring up a whole other set of issues flying IMC, so may not be many more chances until next year.

I am glad to hear from the Chicago area pilots. I did most of my PP training at ARR 15 years ago, but completed the instrument and working on the commercial at DPA. I love cross-countries and the opportunity the instrument rating has given me to make them. I made two trips in September, one to Northern Wisconsin and the other to OSU in Columbus, that I wouldn't have made just VFR.

Happy flying!

Robert

 

[gprellwitz]

Welcome, Robert!
I'm one of the Chicago area fliers, based at Clow.
You'll need to join us at some of our get-togethers in the midwest, and you can fly with a safety pilot!

 

[midlifeflyer]

I have had one pilot tell me I need to be in IMC at least until the FAF to be able to log the approach, but is there any rule that specifies when a non-simulated approach can be logged?

Thanks for any responses!!

Robert

This is one of "those" questions. FWIW, I try to cover the controversy on my web site:

How Much Actual Is Required to Log an Instrument Approach? http://www.midlifeflight.com/faq/faq.php?s=3

 

[KennyFlys]

This is one of "those" questions. FWIW, I try to cover the controversy on my web site:

How Much Actual Is Required to Log an Instrument Approach? http://www.midlifeflight.com/faq/faq.php?s=3

Mark, I had seen that opinion once before. Thanks for the reminder.

 

[rheise]

Mark, thanks for the link. I was hoping that common-sense would apply, but I know that is not always the FAA's "style". I was looking for some other guidelines to you and from all the comments, I got them.

Thanks!

Robert

Tomorrow looks like an instrument day!

 

[poadeleted20]

I do not believe you have to IMC all the way to the MDA/DH at all, but you do have to fly the approach to the MDA/DH for it to count.

If you change "IMC" to "actual instrument conditions" (the two are by no means the same), that statement is consistent with the FAA Chief Counsel opinion on the subject. The only exception in that opinion is that if ATC issues a safety restriction (e.g., "restricted low approach not below 500 AGL for personnel and equipment on the runway"), you do not have to go all the way to MDA/DH if it's lower than 500 AGL.

I would say that by the time you are at the FAF and are out of IMC that you should not count it at all.

While I agree with Scott, you will find some FAA Inspectors who say it's OK to count it as long as you were in actual instrument conditions at some point in the approach. You will also find others who agree with Scott and me. Of course, Inspectors statements aren't legally binding interpretations, so take that for what you will.

 

[poadeleted20]

As a legally critical point of semantics, let's not forget the definitions of VMC, IMC, simulated instrument conditions (which for brevity I'll call SIC here), and actual instrument conditions (AIC).

VMC is flight conditions in which VFR flight is permitted under 14 CFR 91.155. These conditions change depending on altitude and airspace.

IMC is flight conditions in which VFR flight is not permitted under 14 CFR 91.155.

From the 1984 Carr letter of interpretation:

"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.

Note in particular the "typically," as oppose to "always" in the AIC definition.

Thus, you can be in AIC in VMC -- say, between layers at night with several thousand feet between the layers and miles of visibility, but no visible ground or horizon references for navigation or control. Likewise, you can be in IMC without being in AIC, say, when you're 1500 feet laterally from the only cloud in a clear blue sky.

This may seem silly, but it's an important point to remember when discussing these rules, particularly since there are times you can be legally logging approaches for currency in VMC, and there are also times you cannot legally log them for currency when in IMC.

 

[steingar]

I used to fly safety pilot for a friend to do his IFR currency. He stayed under the hood and I made certain the airplane stayed shiny side up. Hopefully you can find a pilot buddy who wouldn't mind sitting in while you do yours.

 

[rheise]

Ron, thanks for the definitions. I never thought about it in the way you presented it. I would have said IMC and actual were the same before your post.

I hope to fly to Waukesha tomorrow and am keeping an eye on the weather. They are forecasting 1500 ovc out of Dupage late morning and that weather should be coming up to Waukesha later in the day. May be a good IFR day...

 

[midlifeflyer]

Thus, you can be in AIC in VMC -- say, between layers at night with several thousand feet between the layers and miles of visibility, but no visible ground or horizon references for navigation or control.

I disagree with you on one point, Ron. I read the Carr as dealing exclusively with aircraft control ("adequate control over the aircraft") - keeping the shiny side up - and not at all with navigation.

 

[poadeleted20]

I disagree with you on one point, Ron. I read the Carr as dealing exclusively with aircraft control ("adequate control over the aircraft") - keeping the shiny side up - and not at all with navigation.

I believe you're right. But the fact that in that between-layers case you have no navigational references, either, makes it even more compelling in arguing that you are in AIC even though you're in VMC.

 

[ScottM]

I believe you're right. But the fact that in that between-layers case you have no navigational references, either, makes it even more compelling in arguing that you are in AIC even though you're in VMC.

No visual reference to the horizon either. I have been in between layers where one layer was 'tilted' it was hard to fly and look outside, even a glance away form the panel and I wanted to align the wings with the sloping cloud deck. Was harder to fly than when in the soup. IMHO that was IMC and I logged it as actual. That would seem to be in agreement with the Carr letter..

 

[poadeleted20]

No visual reference to the horizon either. I have been in between layers where one layer was 'tilted' it was hard to fly and look outside, even a glance away form the panel and I wanted to align the wings with the sloping cloud deck. Was harder to fly than when in the soup. IMHO that was IMC and I logged it as actual. That would seem to be in agreement with the Carr letter..

As regards logging "actual instrument" experience under 14 CFR 61.51(g)(1), the fact that it is (or is not) IMC is not relevent to determining whether you can log actual instrument time -- only whether you are in "actual instrument conditions" as defined in the Carr letter, and that could be in either VMC or IMC as defined by 14 CFR 91.155.

 

[gprellwitz]

As regards logging "actual instrument" experience under 14 CFR 61.51(g)(1), the fact that it is (or is not) IMC is not relevent to determining whether you can log actual instrument time -- only whether you are in "actual instrument conditions" as defined in the Carr letter, and that could be in either VMC or IMC as defined by 14 CFR 91.155.

If I read your response correctly,
IMC = IFR != Actual Instrument Conditions.

I think Scott's contention was:
IFR != Actual Instrument Conditions = IMC

Where is Instrument Meteorological Conditions (IMC) defined, and is it the same as Actual Instrument Conditions or Instrument Flight Rules, or is it yet a third animal? I was thinking like Scott, but based solely on belief, not any research, so that doesn't count!

 

[midlifeflyer]

If I read your response correctly,
IMC = IFR != Actual Instrument Conditions.

I think Scott's contention was:
IFR != Actual Instrument Conditions = IMC

Where is Instrument Meteorological Conditions (IMC) defined, and is it the same as Actual Instrument Conditions or Instrument Flight Rules, or is it yet a third animal? I was thinking like Scott, but based solely on belief, not any research, so that doesn't count!

They are defined. You can check the AIM, a couple of regs, and the Carr letter.

==============================
INSTRUMENT METEOROLOGICAL CONDITIONS- Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minima specified for visual meteorological conditions. (AIM P/CG)
==============================

==============================
INSTRUMENT FLIGHT RULES- Rules governing the procedures for conducting instrument flight. Also a term used by pilots and controllers to indicate type of flight plan. (AIM P/CG)
==============================

Actual Instrument Conditions is defined in the Carr letter.


So if you are, say, flying above 10,000 msl, 900' below a cloud deck with CAVU below and 100 miles visibility, you are in "IMC" and should be on an "IFR" flight plan, but are most definitely not in "Actual Instrument Conditions".

 

[gprellwitz]

They are defined. You can check the AIM, a couple of regs, and the Carr letter.

==============================
INSTRUMENT METEOROLOGICAL CONDITIONS- Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minima specified for visual meteorological conditions. (AIM P/CG)
==============================

==============================
INSTRUMENT FLIGHT RULES- Rules governing the procedures for conducting instrument flight. Also a term used by pilots and controllers to indicate type of flight plan. (AIM P/CG)
==============================

Actual Instrument Conditions is defined in the Carr letter.


So if you are, say, flying above 10,000 msl, 900' below a cloud deck with CAVU below and 100 miles visibility, you are in "IMC" and should be on an "IFR" flight plan, but are most definitely not in "Actual Instrument Conditions".

<Self-administered dope-slap>
IFR != IMC != AIC
</Self-administered dope-slap>

 

[poadeleted20]

<Self-administered dope-slap>
IFR != IMC != AIC
</Self-administered dope-slap>

They are three, independent, separate issues, defined by different standards, and having different impacts on different aspects of what what is legal or not to do.

 

[pocat]

a friend and I swap out. We fly 2 or 3 approaches in his plane one weekend and in mine the next weekend. We miss a weekend here or there because of family or work. But we usually manage to get 4-6 approaches a month. Mostly simulated.
Just don't forget it's just as i'mportant to do and log holds, I believe tracking a vor is also a requirement this is a given an a vor approach. But what about a GPS approach? thoughts?

thanks

 

[midlifeflyer]

a friend and I swap out. We fly 2 or 3 approaches in his plane one weekend and in mine the next weekend. We miss a weekend here or there because of family or work. But we usually manage to get 4-6 approaches a month. Mostly simulated.
Just don't forget it's just as i'mportant to do and log holds, I believe tracking a vor is also a requirement this is a given an a vor approach. But what about a GPS approach? thoughts?

VOR tracking is not a requirement. "Intercepting and tracking courses through the use of navigation systems" is. VOR, NDB, GPS are all "navigation systems."

To maintain technical legal currency, I do something similar to you. A friend and I go up together 1-2X a month. He does a couple of approaches from the left seat and I do them from the right. We toss in a hold now and then.

 

[flyingcheesehead]

Welcome aboard, Robert!

I guess it then begs the question, do most pilots have to do simulated approaches with a safety pilot to keep current?

I *try* to do enough approaches in actual that I don't have to, but it only seems to work about half the time. To even get that much, I have to just wait for the really good actual days (low ceilings, thick layer, light or no precip, no ice) and then I pick the worst weather around and go there. I've shot a lot of ILS's to 300 feet, about 3 to 200 feet, only ever missed one.

However, if I can't stay current by going up and shooting approaches in actual, I just go ahead and get an IPC instead of just going up with a safety pilot. I figure that the CFI is gonna throw stuff at me and really work me, and that can't be anything but good.

My own personal minimums for now are 500 ft above minimums and 2 miles, so for a 200 ft ILS, that would be 700 ft AGL.

Hmmm. I am of the opinion that personal minimums of this sort have no place in IFR flying, except maybe with respect to staying on the ground if it's forecast below a certain amount. Even so, IMHO if you (and that's an ambiguous you) aren't confident that you are proficient enough to fly an ILS all the way to minimums every single time, you shouldn't even take off IFR. Here's a couple of good examples why:

We called DSM approach and reported the miss, and they put us on vectors for the ILS 13.

Weather at DSM when we went missed at Ames, Information Foxtrot, KDSM 310454Z 09007KT 10SM FEW065 BKN090 OVC150 16/14 A2995. Piece of cake.

When we reached our assigned altitude of 3,000: "Des Moines information Golf now current, wind 090 at 10 knots, visibility 7, scattered at 500, overcast niner thousand." Okay, we should still make that.

Just a few minutes later... "Des Moines information Hotel now current, wind 090 at 10, visibility 2 miles, ceiling broken 500. Arrow 27M, turn left heading 150, maintain 2,600 until established, cleared ILS 13 approach." OK, yikes! Weather's coming down awful fast here, I'm still unsure if the glideslope problem was an airplane problem or an Ames problem... I'm suddenly very glad I asked for the plane to be topped off before departure even though Kate had only burned off an hour on the way to get me.

We intercept the localizer and truck along to the glideslope. It's showing 2600 at the marker, just as it should good, and down we go.

"Des Moines Information India now current, wind 090 at 9, visibility 2, Overcast 300 feet." "Arrow 27M, contact tower."

So, we ducked back into the bottom layer of clag at about 2500. It was VERY bumpy, unlike the rest of the flight. I had to fight it the whole way down. Bank angles of around 20 degrees due to turbulence. The glideslope looked very solid (phew!) and after a few minutes of high-pucker-factor flying, we spotted the rabbit at about 160 feet above minimums.

On that flight, forecasts were for ceilings to be between 1,000 and 2,000 AGL at our destination. In reality, we missed the ILS and you'll note that in the time it took us to fly 30 miles to the alternate, the weather dropped rapidly from ceilings of 9,000 feet and unlimited visibility down to 300 feet and 2 miles.

Here's another one:

An instrument pilot, minted about 8 months ago and with a couple hundred hours total time, was flying a glass-cockpit turbo 182 into a Class C airport. His current personal minimums in that airplane include 400 feet on an ILS. The weather was forecast to be 1000 feet, and his departure airport was about 1.5 hours away. Departure was good VFR. He was flying with his wife and <2-year-old son.

As they approached the airport he found the weather was much worse than forecast, and ATIS was reporting a 500 foot ceiling. I don't recall the reported visibility. He flew the ILS, but did not have the field at 400 feet, and so he went missed. For whatever reason, his son started screaming at that point, either because the go-around attitude scared him or he wanted to land, or he could detect the pilot's anxiety. Dunno. The pilot asked for vectors for another try, and this time broke out at about 600 feet and proceeded to land. Problem was, he mistook a newly paved taxiway that ran parallel to the runway for the runway itself, and landed on the taxiway. Fortunately there were no airplanes in the way, although there was an airliner holding short that was on the perpendicular connector and was not in danger.

He blames the distraction caused by his son's angst as a primary cause, along with the fresh pavement that made the taxiway prominent in his vision.

Just a word of warning. Manage distractions. Identify AND verify before you take action. This could have been very, very bad.

If this pilot had simply continued the first approach to the published minimums, it would have been a non-event.

If I fly an approach where I would break out at 700-1000 ft, or even 1500 ft above the ground, but on an ILS the glideslope intercept is say at 2000 ft, would that approach suffice as one of the six needed and be logged as such?

Like many others here, I log the approach if I'm in IMC inside the FAF.

 

[gismo]

Welcome aboard, Robert!

Ditto.

I *try* to do enough approaches in actual that I don't have to, but it only seems to work about half the time.

To even get that much, I have to just wait for the really good actual days (low ceilings, thick layer, light or no precip, no ice) and then I pick the worst weather around and go there.

Not quite ditto. I rarely (but occasionally) make a flight in IMC just for currency purposes and it seems like I average 3-4 approaches every six months flying 150-180 hours per year.

I've shot a lot of ILS's to 300 feet, about 3 to 200 feet, only ever missed one.

I don't think I've ever missed on an ILS but I've flown down to about 100 AGL with just approach lights in sight) a couple times and then spotted the runway and made it in.

However, if I can't stay current by going up and shooting approaches in actual, I just go ahead and get an IPC instead of just going up with a safety pilot. I figure that the CFI is gonna throw stuff at me and really work me, and that can't be anything but good.

I've been in the habit of doing practice approaches with a SP or CFII to stay current but have done one IPC in the airplane as well. For the last several years I've been going to SimCom in Florida once a year with a group of Baron pilots and getting an IPC there which covers half the year.

Hmmm. I am of the opinion that personal minimums of this sort have no place in IFR flying, except maybe with respect to staying on the ground if it's forecast below a certain amount. Even so, IMHO if you (and that's an ambiguous you) aren't confident that you are proficient enough to fly an ILS all the way to minimums every single time, you shouldn't even take off IFR.

I'm pretty much with Kent on this one with a couple differences. One is that I do believe in the notion that a newbie or barely current IR pilot can safely plan and fly in benign IMC (i.e. MVFR) but the flight needs to be conducted with the understanding that this involves keeping abreast of developing conditions along the route and treating having an out if things get worse than forecast. It also means abandoning the flight before takeoff if such "outs" don't exist and anywhere along the route if the outs dissappear. While this is slightly less conservative than strictly VFR/VMC flight I believe it can be done as or even more safely than sticking to VFR minimums.

For example, say that the current and forecast weather calls for a 1500 ft ceiling and good visibility at the departure airport giving way to scattered clouds between 2000 AGL and 5000 AGL along the route with clear skies at the destination. A legal but marginally competent IR pilot can easily cope with this but should strongly consider landing short if the weather at the destination looks like there's much chance it will be worse than the takeoff weather when he arrives. This also implies that reasonable attention is paid to the probable accuracy of the forecasts just like you would for a VFR flight. Where I think such pilots get into trouble is when they plan a flight based on an acceptable forecast and then continue the flight when things change for the worse, either because they fail to continuously check for weather updates enroute and/or they learn about the actual or newly forecast potential deterioration and choose to ignore it.

Like many others here, I log the approach if I'm in IMC inside the FAF.

Ditto.