JasonC wrote:
Indeed. Needs to be in real IMC until some substantial way into the approach (during the final approach segment) or simulated with safety pilot.
While this looks good on paper it really doesn’t mean much. You don’t need much skill or practise to fly an IAP accurately up to the FAF/FAP, which is all that the FAA requires. It is after that FAF/FAP that the fun begins.
Yes and no. Maybe this was the case when we still had lots of NDB/VOR/DME approaches and so on.
Nowadys, it is mostly only ILS and LPV, and it is dead simple for an IR rated pilot to ride down one of those once you are established. All the way to the minimum. Even more so with more an more GA aircraft having autopilots whch follow these as if on rails. But even without.
I think the challenges in flying instrument approaches lie more in properly briefing the approach (possibly whilst hand-flying), setting up the navigator and other avionics correctly, flying holds, as well as general descent/speed/power management on the initial and intermediate approach.
Yes; exactly. Also nobody is out there, flying right behind you, watching the actual wx. Tafs and Metars are available historically but even CAVOK doesn’t mean there wasn’t IMC at the FAF (which was the long standing FAA opinion). It is a very good pragmatic regulation which keeps many thousands of pilots safe, by ensuring a certain level of currency and that currency is much better than what is needed (and often practiced) under the EASA system with its annual test which creates very little incentive to remain current.
On the subject of the thread, I think the biggest objective – for those who want this – is to fly an N-reg on EASA papers and specifically an EASA medical. The BFR can be hard for some to do but contrary to popular anti-N-reg folklore the FAA medical is harder if you’ve had anything “happen”, and if you had some issues you will be on Special Issuance for ever which is a hard area which very few FAA AMEs in Europe want to get involved in (hassle, and lack of expertise resulting in applications rejected on a small detail). The FAA is really anal about processing these; I know of cases where someone waited for a year or more for his while his European CAA gave him a medical right away (at a cost of a few k however). The FAA will chuck an application out if say some blood test data is in European units and not US units (they won’t convert it themselves, on principle).
A lot of people solve this one by having a 61.75 FAA PPL which then allows them to fly worldwide with an EASA medical only, and given the availability of this route I would have expected not many wanting to test the legal hypothesis in this thread 
OTOH the EASA FCL attack on N-regs and its dual papers requirement probably leads many (who are not using a derogation route) to wonder if they could avoid the FAA stuff altogether. But the above 61.75 route gets pretty close.
Interpretation given 28 Jan 1992 to Timothy Slater by Donald P Byrne, Assistant Chief Counsel (link). Para 4:
For currency purposes, an instrument approach under Section
61.57(e)(1)(i) may be flown in either actual or simulated IFR
conditions. Further, 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.
Interpretation given 30 Jun 2009 to Daniel Murphy by Rebecca B MacPherson, Assistant Chief Counsel for Regulations. Penultimate para:
The FAA previously has interpreted section 61.57(c)(1)(i) to mean that a pilot must follow
an instrument approach to the minimum descent altitude or decision height. See
Interpretation to Timothy Slater (Jan. 28, 1992). The FAA has not previously interpreted to
what point an instrument approach must be followed under section 61.65(d)(2)(iii)(B).
However, because of the similarities between the two instrument approach requirements, an
instrument approach under that section also must continue to the minimum descent altitude
or decision height.
boscomantico wrote:
Nowadys, it is mostly only ILS and LPV, and it is dead simple for an IR rated pilot to ride down one of those once you are established. All the way to the minimum. Even more so with more an more GA aircraft having autopilots whch follow these as if on rails. But even without.
Of course with autopilots the FAA requirement is more or less pointless. But personally I’ve always felt that the real challenges of hand-flying an IFR approach start at about 1000 ft AAL. Above that it’s a piece of cake.
Qalupalik wrote:
we believe the pilot must follow the instrument approach procedure to minimum descent altitude or decision height.
Yes, but you don’t need to be in IMC after the FAF/FAP to make the approach to count for currency. That makes all the difference.
But personally I’ve always felt that the real challenges of hand-flying an IFR approach start at about 1000 ft AAL. Above that it’s a piece of cake.
Quite the contrary, IMHO. My workload really starts going down once I am fully established. It‘s before this that things are busy and sometimes challenging.
we believe the pilot must
follow the instrument approach procedure to minimum descent
altitude or decision height.
Yes; you have to fly it all the way down. You can’t just fly to the FAF and break off, etc
There was another ruling which required IMC at the FAF.
you don’t need to be in IMC after the FAF/FAP
Indeed; if that was required (e.g. IMC all the way to MDA) almost nothing would count.
It is interesting discussion what is “IFR/IMC currency”, most it is about terminal IFR flying (e.g. approach in IMC) rather than en-route IFC/IMC which is typically done 95% in VMC for GA aircraft
Yes, the difficult bits are indeed 1/ hand flying decent while briefing plates and 2/ hand flying the last 1000agl plus go-around, but these tend to get easy when they are done in nearby airfield 6 times in 6 months? even harder is going IFR/IMC to unfamiliar airports in windy days of marginal ceiling & visibility, this would seems to completely resets the “currency counter” and may double/triple one’s minima
Also, how about one go about measure en-route IFR/IMC currency? (apart from avoiding any sort of en-route weather: icing, thunderstorms, turbulence, stretch of rain/clouds…)
Peter wrote:
Curiously, I can’t find anything in that reg here. I read both 49-page PDFs.
Peter,
Sorry, I made a wrong reference, this INFO was what I should have referred to.
