Counting instrument approaches

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ultraturtle
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Re: Counting instrument approaches

Post by ultraturtle »

blsewardjr wrote:In 2015 the FAA legal counsel issued a letter addressing logging instrument approaches -- https://www.faa.gov/other_visit/aviatio ... O15012.pdf
My takeaway is that, “...the aircraft transitions from IMC to visual flight conditions on the final approach segment...” means that IMC must exist somewhere along the final approach segment in order to log it as an approach in actual IMC.

That’s how I log it.
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Re: Counting instrument approaches

Post by ultraturtle »

Remember that IMC does not necessarily mean "in the soup". While it kind of does in Class B airspace, outside of Class B, cloud clearance rules come into play.

The definition of IMC is "not VMC", so for a typical instrument approach where the Final Approach Segment begins at 1,500' AGL, you would not be VMC at that point with a 1,900' broken ceiling (again not in Class B), and therefore IMC. You would transition from IMC to "visual flight conditions" after descending 100' along the final approach segment, and therefore could log it.

Similarly, if during the Final Approach Segment (not in Class B) you do not maintain 2,000' clear of clouds horizontally while descending through a scattered layer, you are technically IMC and can log it.

These conditions are quite common in the Southeast, so it is pretty easy to stay current.
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Re: Counting instrument approaches

Post by ultraturtle »

Exception to the above would be daytime in Class G below 1,200' AGL, where you'd have to either nick a cloud or be in <1 sm visibility to be considered IMC.
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Steven
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Re: Counting instrument approaches

Post by Steven »

Well, that's yet another interpretation. If cloud clearance rules come into play, then if the FAF is at 1700' then it is "loggable" if at the FAF the clouds are anything below 2200' (Class C, D, E). That starts to sound a lot more practical for logging approaches.

This would be an easy rule to follow. But I must say I've never heard anyone say before that 500' above the FAF is a good rule for counting an approach or not (ignoring visibility and horizontal clearance for now).
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Re: Counting instrument approaches

Post by blsewardjr »

Under this interpretation, you would be in the interesting position of being able to log an instrument approach but not instrument time. To log instrument time, under FAR Section 61.51(g)(1) "[a] person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions." According to a November 7, 1984 FAA legal opinion "'[a]ctual' 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." In the scenario posed, flying in clear air 400 feet under the cloud ceiling would qualify as IMC for purposes of logging the approach, but would not qualify as actual instrument flight conditions for purposes of logging as instrument time because the conditions did not require the use of instruments to maintain adequate control over the aircraft. Conversely, the opinion admits that "actual instrument conditions may occur in the case [of] a moonless night over the ocean with no discernible horizon, if use of the instruments is necessary to maintain adequate control over the aircraft." Thus, you could log instrument time, but not an instrument approach under certain conditions. Personally, I log only those approaches in which I'm in actual instrument flight conditions, as defined above, at some point after the FAF.
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Re: Counting instrument approaches

Post by Steven »

I'm glad there's some difference of opinion here. Makes me feel less ignorant.

Seems like if I'm "in the soup" at FAF or at any point on the final approach segment, it's a loggable instrument approach. If I'm not in soup, but yet not maintaining VFR cloud clearances, it's ambiguous whether that is a loggable approach. If however I maintain VFR all the way from FAF to MAP, it doesn't count as an instrument approach.
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Re: Counting instrument approaches

Post by Rick »

I agree with Steven's interpretation, and I've always been fuzzy on the ambiguous part, too, so I decide to re-read the document. Here are the applicable statements from this document, edited to remove all the simulator and view-limiting-device parts:
The FAA, in InFO 15012, wrote:A pilot may log an IAP for currency or training when the pilot accomplishes the IAP in accordance with the following conditions:
1. ... the pilot must operate that aircraft ... solely by reference to instruments [§ 61.51(g)(1)];
2. ... the pilot must be established on each required segment of the IAP to the minimum descent altitude (MDA) or decision altitude/decision height (DA/DH);
4. ... the flight must be conducted under actual ... instrument flight conditions [§ 61.51(g)(1)].
NOTE: A pilot cannot log an IAP for currency in an aircraft without also logging ... instrument time.
5. ... the aircraft transitions from IMC to visual flight conditions on the final approach segment of the IAP prior to or upon reaching MDA or DA/DH.
NOTE: Except when being radar vectored ... or otherwise directed by ATC ..., pilots must execute the entire IAP commencing at an initial approach fix or associated feeder route and fly the initial segment, the intermediate segment, and the final segment of an IAP [AIM 5-4-7 (e)]. If the pilot completes these segments, or receives vectors to the final approach course, he or she may log the IAP.

The FAA does not require the ceiling to be at MDA or DA/DH during a flight in IMC. When an aircraft is flying an IAP in IMC, two outcomes are possible:
1. The aircraft will transition from IMC to visual meteorological conditions that allow a landing in accordance with § 91.175; or
2. The aircraft will remain in IMC and execute a missed approach at the missed approach point (MAP) or DA/DH.
In either case, a pilot may log the IAP.
I note that nowhere in this document does it make any distinction between IFR and VFR - only between IMC and VMC. So I don't see how the argument that you can log an approach if you are in VMC but do not meet VFR minimums is supported by this document. But then, I'm not a lawyer, and I am still confused by other wording. Item 1 (must operate the aircraft solely by reference to instruments) seems to imply you must be in IMC, and item 4 ("the flight" must be conducted under IMC) reinforces this. But how much of "the flight"? Are they just referring to the approach? Or, if ANY part of the flight is in IMC? Surely they don't mean the entire flight? Item 5 above clearly says you need to break out of IMC on the final approach segment. But then the last section seems to imply that if you break out of IMC anywhere on the approach, you can count it.
Roanoke, VA (KROA)
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Re: Counting instrument approaches

Post by Steven »

Thanks for extracting the relevant parts of the letter. It feels like the ambiguous part is still ambiguous, but the definitely-counts and definitely-does-not-count parts I feel more confident about now.
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Re: Counting instrument approaches

Post by ultraturtle »

The flight must be conducted in actual instrument flight conditions (in our example, penetrating the 1,900' AGL layer enroute to the final approach segment would suffice), but the requirement to transition from IMC to visual flight conditions on the final approach segment is a separate one.

I agree that if actual instrument flight conditions are never encountered during the flight, the IAP cannot be logged, but (except in Class B) there is no requirement to encounter them during the final approach segment.
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Re: Counting instrument approaches

Post by ultraturtle »

To simplify, in order to log the approach in an aircraft without a licensed pilot safety observer, both requirements must be satisfied. They are separate and should not be confused with each other:
  • 1. The flight must be conducted in instrument flight conditions ("soup" at some point, arguably on a portion of either the published procedure or vectors to final)

    2. Lack of VMC (to include both cloud clearance and visibility requirements) at some point along the final approach segment.
Back to our example of an approach outside of Class B airspace with the final approach segment beginning at 1,500' AGL, ceiling of 1,900' and visibility greater than 3 sm:
  • A pilot descending through the deck enroute to the final approach segment experiences instrument flight conditions until 1,900' AGL satisfying the first condition, then IMC (not yet 500' below clouds) until 1,400' AGL, satisfying the second. This pilot can log the approach.

    A pilot takes off, climbs to 1,500' AGL and takes vectors to final for the approach, never entering the clouds. While the second condition has been satisfied, the first has not, therefore this pilot cannot log the approach.
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