I don’t understand the applicability of the above to the topic.
Well if you always interrupt an ILS or LPV at 1000ft agl as your minima and join overhead above visual circuit, the FAA will not be very impressed, I would not even call that “IR currency” and inclined to think it does not count for 6/6 approaches, you have to go near the ground to “practice a bit”…
The visual circuit height in some airports is at 1200ft-1500ft agl, practicing an ILS/LPV without ATC there in good weather days is pretty useless
Can you find FAA reg which supports that?
One of the hallmarks of the FAA system is the pragmatic and not too prescriptive nature. That is not the “European way” but America has 10x more experience of safety regulation than Europe (in GA) and they have found over many decades what works.
Sounds like it’s OK under FAA rules to deviate from final segment to join the pattern for safety reasons…
A couple of points to clarify. First I did not do my flight test at LFFK I just gave it as an example. Although I did do my test where the RNAV approach was to an AFIS field where the AFIS went to lunch.
Over the years what used to be called circle to land has now evolved in the AIP to what is currently there. It makes perfect sense to me but YMMV.
At LFFK and at most other French airfields the VFR circuit is 1000’ agl. For a VFR pilot who arrives with no information (parameter) as quoted in the AIP would make an overhead join at a minimum of 1500ft
For the instrument approach non ATS and without knowledge of the parameters but with knowledge of the QNH you follow the procedure.
On final you descend as on the procedure to 670ft minimum (not below) if necessary, before checking the parameters. However, the AIP now includes the bit that Ibra has underlined in red. AIUI it is a fairly new insertion. However what it means is that you descend on the final approach course still following the IAP until (on a blue sky day) 1000ft agl (note not 1500’ as one would for a VFR join). In practical terms this does not pose any problems. The other change is that in practical terms on a gin clear day there may also be vfr traffic from which you can garner the parameters and make if the procedure allows a straight in landing.
I can not comment on the FAA rules and as Peter has said the currency requirements are different under EASA. However, as you have flown a procedure you log it as a procedure in the procedures column of log book and the time taken to fly the procedure under IFR time. I do not understand why this is not possible under FAA rules for currency, unless you can only record IFR time when in actual IMC which would seem a bit crazy to me as you are still flying to IFR regs.
Can we at least agree that at LFFK you don’t descend to circling MDA when weather is good? the same applies for every airport in France without ATS, you simply can’t fly circling MDA or straight-in DA, you have to join circuit either on overhead without parameters or downwind if you know the runway in-use, this has to be done above VAC visual circuit heights, 1000ft agl is the default (I can quote chapters and verses on this)
It’s very obvious to me…it has lot of implications for legal flight planning, you can’t depart with ceiling bellow 1000ft to non-ATS airports in France !!!
Again, it’s a crappy rule that no one seems to understand very well or apply in real flights (including me) but if one is doing an EASA IRT or FAA IPC they are expected to show high standards? at least when deciding on legal planning minima and alternates selection (even if the examiner does not care, the DGAC & BGTA likes to see 1000ft agl ceiling in the “briefing packs” for planning IFR to non-ATS airports when something bad happens), how you actually fly on the day: no one gives a hoot, you can land straight-in without ATS in 250ft ceiling, you declare mayday in your head or on Auto-Info frequency…
What does it mean during an FAA IPC to fly 1100ft amsl instead of 670ft one need to check with their CFII if that is OK? same during an EASA IRT? for 6/6 FAA currency flights, I think it counts, anyway, only the PIC knows what happened and he can decide to log it or not (FAA system for IR currency is very pragmatic and not too prescriptive nature as Peter said, in the other hand, my nearby ATO nearby is very prescriptive: IFR training require an AFIS as minimum ! )
@Ibra I do not understand the points you are trying to make. Maybe training has changed since I did my CBIR.
I can only say that I respected that both my instructors and my examiners had and have a really good grasp of the rules to high standards.
And as @Peter has posted the training environment is very different to the question that the OP asked.
I do not know the FAA regs on currency and what FAA IR pilots can and cannot log.
I do know what I log and it has never presented a problem with examiners when revalidating or the DGAC. I do know there are different regulations for revalidation between EASA and FAA
However, I believe Peter is saying that if you fly a published IAP even in Europe you can log it towards currency for the FAA IR revalidation/continuation (or whatever they call it under FAA). Unless of course the FAA rules say that you cannot fly an IAP without ATS.(I don’t know)
In France there are many published approaches which end at a field with no ATS, especially as RNP approaches are on the increase.
I am really asking simple questions, can you descend bellow 1000ft agl on RNP without ATS in good weather? the answer is fairly obvious, legally it’s STRICT NO according to French rules, even if your instructor or examiner thinks it does not apply to them during training and tests !
Now if you interrupt the approach at 1000ft agl, does it count for EASA IRT? or FAA IPC? that is when things are grey…
From what I understand, it’s fine for EASA IRT, apparently you have done load of RNP without ATS that stop at 1000ft agl and your EASA examiner was happy with that, so he did sign you off for another 12 months?
For FAA rules, I need to check with CFI-I if he is happy with logging during an IPC? and FAA DPE if he is happy with checkride? we really don’t know the answer, only some CFI or DPE based in France would know the answer (maybe @NCYankee can give an opinion if an RNP that is interrupted at 1000ft agl counts for IPC with CFI-I or Checkride with DPE)
For FAA IR currency, yes as Peter said there is not much debate: you log what you think should be logged, the point is very moot as IR currency is based on self declaration anyway and besides anyone who flies IFR regularly tend to be north of 10 approaches every month…
Why would you want to go lower than 1000ft in good weather unless you are in training or being tested?
Most instructors and examiners seem to agree certain manouvers with ATS, which of course covers everything except the non ATS airfield itself. For that I would be amazed if the DGAC didn’t make some allowances for the training environment just as it does in the case of training for an emergency landing in the country, and just as an examiner will talk to ATS to break off from an IFPL in order to do some instrument failure or stall exercises.
I may be wrong to, but I accept that regulations as written can not cover every eventuality and sometimes one needs to think for oneself whilst following what you believe to be the spirit of the law.
In the case of this thread, it is the FAA regulations which seem to be in question and not those in Europe. I leave others with experience of FAA Instrument requirements to answer that.
gallois wrote:
unless you are in training or being tested?
Why ‘unless’? it’s illegal to go bellow 1000ft agl on RNP in good weather during training & testing without ATS !
That is where we have misunderstanding? while some freelance instructors & examiners may feel sloppy about it (anyway no one cares), I would be curious to see an ATO MANEX approved by DGAC that allows it? let alone accepting it during an initial IRT test in non-ATS airports?
PS: I asked one UK CFI, he told me it should be ok for FAA IPC to fly RNP at Calais down to 1000ft agl but he added, he prefer to avoid mixing IFR & VFR in “FR Only” without AFIS in LFAC, LeTouquet would be way more appropriate for him 
