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FAA IFR Currency - exact requirements for the 6/6 IR rolling currency (merged)

172driver wrote:

Where is yours from?

Basically everywhere on the web:

“When flying in actual conditions, you must be in IMC when you start the approach and remain in IMC until passing the Final Approach Fix for the approach to count. If you break out into the clear at any point after the FAF but before DH or MDH, the approach counts.”
https://www.flyingmag.com/technique-tip-week-logging-instrument-approaches-currency/

“the pilot may still log the IAP, provided the aircraft has passed the final approach fix (FAF).”
https://learn.fly8ma.com/can-log-instrument-approach/

“The approach can be logged if you are flying an aircraft in actual IMC, and the aircraft transitions from IMC to VMC within the final approach segment of the IAP before or upon reaching minimums […] This InFO succeeded in clarifying just what the FAA expects in order to legally log approaches. It is consistent with Office of Chief Counsel interpretations as annotated above. Better, it conforms to general common sense, as in considering an approach past the FAF in actual, sufficient to demonstrate proficiency”
https://www.ifr-magazine.com/technique/can-you-log-that/

The sentence in the InFO also could suggest that above is correct: “5. When conducted in an aircraft maneuvering in IMC, and 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”. (as it’s referring to the “final approach segment”)
https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2015/info15012.pdf

In this thread, it’s also discussed controversely (more on your side of the view): https://www.pilotsofamerica.com/community/threads/define-instrument-approach-for-currency-purposes.69912/

Here’s another controversial opinion (more on your side):

“When one talks to FAA inspectors, one finds that the lack of standardization endemic to the Flight Standards Division is as evident in this area as in many others. Some inspectors will tell you that unless the entire approach is in IMC from the IAF to the MAP, it does not count for currency. At the other extreme, others will say that if you’re in IMC at any time between IAF and MAP, it counts. And there are plenty of answers in between. What’s a pilot to do?My personal standard is as follows: If any of the following three conditions occurs, I log the approach as actual:

- I’m in actual IMC at any time from FAF to MAP.
- The airport to which the approach is being flown is reporting weather below 91.155 VMC.
- I’m flying the aircraft solely by reference to the instruments, and logging actual instrument time, regardless of the reported weather."

https://www.avweb.com/flight-safety/technique/ready-to-rumble/

IMHO, there’s no exact definition (which might be intended – imagine you’re all flight long in IMC and it just clears up before the FAF and exactly 0.2 miles before it transitions to VMC. Obviously that’d be an loggable approach). That’s why I was interested why you sounded so sure.

Last Edited by BerlinFlyer at 27 Jul 14:24
Germany

Fine, but that’s all interwebs stuff. Do you – or anyone else here – have an FAA reference for it? Serious question, as I am not aware of one. For the record, I usually fly my practice approaches (i.e. with a safety pilot) to minima. But that’s not really germane to this discussion.

As I said, the sentence in the InFO also could suggest that the FAF in IMC interpretation is correct: “5. When conducted in an aircraft maneuvering in IMC, and 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”. (as it’s referring to the “final approach segment”)
https://www.faa.gov/other_visit/aviation_industry/airline_operators/airline_safety/info/all_infos/media/2015/info15012.pdf

Germany

The wording in INFO 150/12 is imprecise in my opinion. I have discussed this with the author. IMC is Instrument Meteorological Conditions and means that 91.155 minimums are not available. These conditions include visibility and cloud separation. So if the conditions at the FAF are less than 500 feet below a ceiling, with visibility of 20 miles, it is IMC when crossing the FAF, but it is not actual instrument conditions as it is easy to control the aircraft by visual means. Similarly, if the visibility is 2 SM, the conditions are IMC but one can control the aircraft by visual means.

From the US AIM Pilot/Controller Glossary:

INSTRUMENT METEOROLOGICAL CONDITIONS (IMC)− Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minima specified for visual meteorological conditions.

VISUAL METEOROLOGICAL CONDITIONS− Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling equal to or better than specified minima.

The Info discussion begins with (my emphasis is in Bold):

Discussion: Section 61.57(c)(1-5) permits a pilot to use one of four methods to conduct and then log IAPs:
1. Actual instrument flight conditions flown in an aircraft;

Later on, the Info states in part:

A pilot may log an IAP for currency or training when the pilot accomplishes the IAP in accordance with the following conditions:

4. When conducted in an aircraft, the flight must be conducted under actual or simulated instrument flight conditions [§ 61.51(g)(1)].
5. When conducted in an aircraft maneuvering in IMC, and 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 to the final approach course, or otherwise directed through an appropriate air traffic control (ATC) clearance7 to a specific IAP, 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 would have written the last quote differently to read as (my changes are in Bold):

The FAA does not require the ceiling to be at MDA or DA/DH during a flight in IMC Actual Instrument Conditions. When an aircraft is flying an IAP in IMC Actual Instrument Conditions, two outcomes are possible:
1. The aircraft will transition from IMC Actual Instrument Conditions to visual meteorological conditions that allow a landing in accordance with § 91.175; or
2. The aircraft will remain in IMC Actual Instrument Conditions and execute a missed approach at the missed approach point (MAP) or DA/DH.
In either case, a pilot may log the IAP.

The Info requires that some flight time be logged as “Actual Instrument flight time”, but does not specify where. It also says that all the segments of the procedure must be flown except for the missed approach segment: In addition, in order for the approach to be logged for currency purposes the following is required: “When conducted in an aircraft maneuvering in IMC, and 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.”

So as the Info is written, flying an approach where one is in the clouds on the initial, or intermediate segment and breaks out below an overcast just above the FAF minimum altitude, the aircraft may remain in IMC on the final approach segment until it is 500 feet below the ceiling, even though they would be in visual conditions before crossing the FAF. So there is confusion as to when the transition from IMC to Visual conditions occurs verses actual instrument conditions to Visual conditions. I think it was the FAA intent to allow counting the approach for currency, if actual instrument conditions existed on the final approach segment, but they messed up by using the term IMC which has a different meaning and leads to other interpretations.

KUZA, United States
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