If this becomes law, it will be fairly easy to stay current with an ATD (Aviation Training Device) without an instructor present: https://bruceair.wordpress.com/2016/05/13/faa-proposes-significant-rule-changes/
I have more or less this stuff in a corner at home, but from Saitek and without “Hobbs meter”; I wonder if it would be possible to get it up to “ATD standard”.
An FAA approved ATD is a bit more than FSX and a yoke/pedals/throttle quadrant….for one thing it requires that the aircraft systems and controls can all be operated without need of the mouse or keyboard….
http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_61-136A.pdf
This FAA document is from 2015.
So they want to see IMC on the final descent leg of the IAP.
I have just realised the above doc was posted in 2015, but had been missed by people asking later because it was in a different thread.
Question remains if that means you have to be in clouds at the FAF or just closer to clouds than you would be legally allowed in VFR in the given airspace.
Latter one would make sense legally (as at least in EASA land it’s clearly not VMC if you are not able to maintain required cloud clearance and there is no thing between VMC and IMC) but would lead to the “interesting” situation that it would depend on the airspace if an approach counts towards currency or not.
Most pilots I know feel this area is best left undisturbed. The FAA system has an excellent safety record – at least as good as the European one.
One can well debate why this is so; no doubt a bit of risk compensation comes into it, but also the 6/6 requirement forces FAA pilots to seek out IAPs and fly them at every opportunity regardless of wx based need. I know the latter factor is real because I have known FAA IR holders who complained about the 6/6, saying that since their home airport has no IAPs, they have to fly elsewhere to do them, which is a hassle because it interferes with their right to fly almost no hours each year 
Anyone who goes places and flies say 50+ hrs/year should have no difficulty maintaining the 6/6. I do 100-150hrs and usually manage it several times over, even though I don’t do any extra flights for it.
And looking at this whole thing in the context of the sort of planes which people actually fly IFR “for real” which are mostly modern aircraft, these are flown mostly on autopilot, so flying IAPs with the automation is as much a systems management task, which is equally well practiced in VMC as in IMC. It may be that the FAA’s avoidance of making some tight ruling on the required wx conditions is a tacit recognition of this, together with the already excellent FAA IR safety record which does not need disturbing.
Peter wrote:
the 6/6 requirement forces FAA pilots to seek out IAPs and fly them at every opportunity regardless of wx based need.
Are you supposed to record them in any way? Or do you just get to the end of the time period and say to yourself “I did them”.
Yes, you log every one. FAA logbooks have a column for IAPs.
Malibuflyer wrote:
there is no thing between VMC and IMC
I fully agree.
I have always seen the clarification in InFO 15012 (linked above) to clearly mean that between the FAF and the MDA/DA/DH once must experience non-VMC i.e. IMC at some stage to log the IAP for currency.
There is an interesting twist when one uses foggles and have a Safety Pilot since FAR 91.109 (c) 1(i) refers to him/her possessing a private pilot certificate with category and class ratings appropriate to the aircraft flown. In the UK does this mean an IR or would an IR(R) suffice in certain airspaces?
Peter wrote:
FAA logbooks
I didn’t even know there were special FAA logbooks!
What do you do if you flew an IAP but it was severe CAVOK? Is there a second column for ‘qualifying’ IAPs?
In the UK does this mean an IR or would an IR(R) suffice in certain airspaces?
An IMCR holder can definitely maintain the 6/6 currency by flying IAPs under IMCR privileges. The obvious example is if flying a G-reg in Class D, in which the FAA IR confers no IFR privileges because they are limited by the ANO to OCAS (well, that’s the last ANO I remember).
What do you do if you flew an IAP but it was severe CAVOK?
You don’t log it.
