Practice IAPs

[tmmorris]

What makes an IAP a practice one? I know that for a practice IAP in VMC you need a safety observer (your 'granny' will do) but if you carry one out in IMC you don't. But what if you are flying solo and elect to fly IFR: can you then carry out an IAP in VMC, or do you have to go for a visual approach?

Tim

[Chilli Monster]

If you're IFR, solo and you go for the IAP in VMC then that's no problem. However, in this scenario no view limiting devices can be used and you would conduct the approach as if you would in IMC - occasionally checking to see whether you'd gone visual. Nothing wrong with taking the approach down to DA/MDA but you have a responsibility to other airspace users to keep the scan going outside as well as in - which would detract from the normal training process of "head in" until the relevant point of the approach.

[yawningdog]

Actually your granny won't do. Your safety pilot needs to be a ppl or someone with enough flying experience to easily anticipate and recognise any potential conflict.

Someone without this experience is much less likely to spot any potential traffic problems.

[tmmorris]

Not so, yawningdog...

7 (1) Within the United Kingdom an aircraft shall not carry out instrument approach practice
when flying in Visual Meteorological Conditions unless:
(a) the appropriate air traffic control unit has previously been informed that the flight is
to be made for the purpose of instrument approach practice; and
(b) if the flight is not being carried out in simulated instrument flight conditions, a
competent observer is carried in such a position in the aircraft that he has an
adequate field of vision and can readily communicate with the pilot flying the aircraft.

You are confusing this with the rules for 'view-limiting devices', which I never mentioned...

Thanks, Chilli - that's what I suspected. I wasn't planning on foggles &c.

Tim

[DodgyFlyer]

I must admit to getting myself very confused. If under 7(1) an aircraft shall not carry out an instrument approach practice when flying VMC unless (a) and (b) are complied with. How is this different to flying IFR in VMC and carrying out a IAP?

[IO540]

an aircraft shall not carry out an instrument approach practice

What defines "practice"? How can they tell?

A landing is a landing. Does a missed approach constitute "practice"? Surely not otherwise commercial traffic carrying passengers would never be allowed to do one :O

[Pierre Argh]

Does a missed approach constitute "practice"? I believe it would IF it were your original intention... but the practice IAP to land when IFR, but not IMC is obviously woollier... self-discipline maybe?

[IO540]

The obvious Q is how can anybody tell your "intention"?

Seems a bizzare area to legislate in.

If "practice" was defined as a flight on which an instructor is present and - if G-reg - implicitly PIC that would be something else.

[slim_slag]

My understanding......

If it's practice you are still under VFR and you are responsible for your own separation, the controller isn't.

If it's not practice, you will get a proper clearance, the controller has to separate you, (but if you are in VMC you do too).

How do you tell the difference? If it's a practice approach, you request a practice approach.

[IO540]

What is the advantage of telling the controller it is "practice"?

How does this apply to outside the UK?

A part of the point I am trying to make is that the IMC Rating or the JAA IR does not require the pilot to maintain any currency whatsoever.

The FAA IR does, but most pilots will log the six approaches as part of normal flying. Also, most FAA pilots fly outside the UK.

[slim_slag]

As I understand it, if it's practice, the controller doesn't have to separate you from other airborne VFR traffic, so it makes his life easier and you are more likely to get your request approved.

I'm not sure many people shoot their six approaches as part of normal flying. If you are flying IFR, when can you log an approach? Do you have to be in cloud all the way from the IAF to minimums for it to count?

[IO540]

The prevailing wisdom in FAA land appears to be that the approaches have to be in real IMC.

I'd say that *most* FAA IR pilots over here are aircraft owners, not renters. And if you have a plane, you will be flying it all over the place :O

Whereas a JAA IR holder complained to me the other day that the FAA IR is "really hard to keep" - because you have to keep flying a plane.........

[slim_slag]

In that case I disagree with the prevailing wisdom. If you want to keep your IR current under 61.57 by flying six actual IMC approaches in six months, you need to descend to DH or the MAP/MDA in actual conditions. I doubt most people do that in normal flying, it must be even more difficult if you are UK based because it will have to be on a published approach to count under the FARs. Most FAA people remain instrument current by flying with a safety pilot under the hood on practice approaches (or they should do legally, I know plenty of people who don't)

[Spitoon]

Just to give a view from a UK ATC perspective - and I stress it's my view because there is just as much confusion and differing opinions amongst controllers as there seems to be amongst pilots.

If a pilot asks for a practice approach I will clear him/her for an approach. I will provide standard separation between the 'practice' aircraft and all other IFR traffic. I will give traffic info on VFR traffic to the 'practice' aircraft - and traffic info on the 'practice' aircraft to other aircarft in the area. So the fact that it's a practice approach makes absolutely no difference to me - I treat it like a proper one! (For the record - the exception to this is practice Cat II/III approaches but I guess that's not really what we're talking about here)

I don't know whether this is right or wrong because I can't get my head around the law on this topic but it is safe. But like I said earlier, ask a different controller and there's every chance you'll get a different answer.

I would normally refer anyone to the guidance and procedures in the Manual of Air Traffic Services. But I don't think there's anything in it on this!

[Keef]

Couple of points:

1. My (very wise) instrument instructor warned me that in Europe I must inform ATC and request a "practice" approach if it's not real IMC/IFR. I don't know where/whether this is in the rules, but home base certainly insists on ILSes being "booked" in advance if it's VMC.

2. The FAA IR can be kept up to date with approaches flown under the hood to minima, with a safety pilot. Or that's what I told the examiner when I did mine, and he didn't tell me I was wrong. How else would you keep your IR current in the "clear" parts of the USA?

[IO540]

in Europe I must inform ATC and request a "practice" approach if it's not real IMC/IFR. I don't know where/whether this is in the rules, but home base certainly insists on ILSes being "booked" in advance if it's VMC.

It's nonsense. A suitably rated pilot is entitled to fly IFR the whole way. VMC has nothing to do with it. Most commercial traffic is required to. A well planned IFR flight will be in VMC much of the time anyway :O

Anyway, let's say the weather is poor or marginal and then improves. You aren't required to cancel IFR just because it's improved.

There is no such thing as "IMC/IFR" except that flight in IMC has to be IFR. An IR/IMCR can fly IFR anytime he chooses. Abroad, or in Class A, it just gets more regulated (mandatory flight plan, IFR clearance).

As for booking an ILS, that may be the individual airfield rule, for a "training" flight, if they have half a dozen twins doing IR training in the circuit. A lot of airfields around Europe have restrictions, often a total ban, on "training" flights. But a pilot can still do a fully IFR flight and the destination has to fit him in. That's the ATC job. He may have to hold, etc.

For example Cranfield has a lot of IR training traffic and tries to discourage people going in there IFR if the conditions are OK for a VFR arrival. But you can just do it and they can't stop you. Especially if they have the flight plan.

[Keef]

You miss my point. I said for a "practice" approach. If it's IMC, or if I'm on an IFR flight plan, I would expect to be asked what approach I want and may well choose an ILS.

If I'm on a VFR flight plan (or no flight plan at all) but want an ILS for practice (which I often do), then I book it first and tell them it's for practice. If I'm "under the hood" (cos it's nice VMC outside) then I take a safety pilot, too.

That's what I was taught, and that's what I do.


If I'm "practising" but it's IMC and I'm under IFR, then I don't "book" it. That's what I meant by "IMC/IFR" above.

Don't be so pesky aggressive! Nonsense it ain't. What my IFR instructor taught me, it is.

[IO540]

Keef

I do see your point. What I don't see is how a *UK* airfield can legally insist on what is effectively a PPR for an IFR approach, given that:

1) A suitably rated pilot is entitled to arrive IFR (with or without an IFR flight plan)

2) Instructor absent, there is no practical difference that I can see between me choosing to fly an ILS to land because I feel like it, and me choosing to fly an ILS to land because I feel I need the practice (but not telling ATC anything different).

Flying is a constant learning / currency rebuilding process and unless one is flying A-B on business (or some other real purpose) every flight, including the landing, could be regarded as a practice flight.

[slim_slag]

Spittoon, what you have described seems totally reasonable and safe. What happens in my neck of the woods is I request the practice approach, what I hear from the controller is something like

'Cleared for the ILS 30 practice approach, maintain VFR, VFR separation services not provided' (or similar) .

Then I fly the approach as normal, but I am not cleared to fly the missed

Speaking with controllers in a less formal setting, I am told that although the controller will not provide legal IFR separation to me, they always try to. The main difference to the controller, from what I hear, is that in a practice approach they do not have to deconflict the missed approach procedure. As there may be IFR arrivals in that airspace that makes it a lot easier for them to keep the flow rate up.

[Chilli Monster]

It might be worth going back to the original post here before everyone gets themselves tied in knots:

But what if you are flying solo and elect to fly IFR: can you then carry out an IAP in VMC, or do you have to go for a visual approach?

He's IFR - it has nothing to do with flight conditions - he's IFR, end of story. Quite entitled therefore to fly that IAP no matter what the number of people on the flight deck.

Now follow this reasoning. If someone is ostensibly VFR but asks for an approach for training then effectively they are putting themselves IFR.

Reason?

Either you're going to vector them or they're going to follow a laid down procedure. Either way they stand the risk of going inadvertant IMC due to the nature of the task. On that basis they effectively become IFR, and therefore get treated and handled as such. The term VFR implies the guy can deviate from track and level at will to remain VMC - this has no place in the scenario so far, so isn't applicable. Telling that person to remain VFR defeats the object of the exercise.

As for the missed approach scenario - there would be nothing wrong with the phrase "In the event of a missed approach turn left/right into the visual circuit VFR". That removes the ambiguity as to what rules you're on during the approach, but provides a non-separation required solution at the end of it.

[slim_slag]

Chilli,

When you say 'effectively putting themselves IFR' do you mean from a controller's point of view or the pilot's? I cannot speak for controller, but from a pilot I remain 100% VFR effectively and legally. For example, I am responsible for visual separation, and following visibility/cloud clearance regs. If a radar vector in Class B given by a controller in a windowless room in a different county takes me towards cloud, I would simply aviate navigate and communicate. No different from what I would do on a practice approach.

I think the 'maintain VFR' phrase is there to make sure there is no doubt that I am VFR, that should be a given, but no harm in reinforcing the fact.

The controller will always ask how the approach will terminate, then the pilot can state his intentions.

[Fuji Abound]

IO540

"I do see your point. What I don't see is how a *UK* airfield can legally insist on what is effectively a PPR for an IFR approach, given that:"

I raised this issue some while back.

http://www.pprune.org/forums/showthread.php?threadid=71642&highlight=approach

[Chilli Monster]

When you say 'effectively putting themselves IFR' do you mean from a controller's point of view or the pilot's?

Both - so if you're a VFR only pilot don't ask for an IAP.

[Pierre Argh]

Aside from all the semantics about confusing regulations relating to practice IAPs... let me invite you to consider the reason we exercise such evolutions... to remain current and to maintain good practice.

IMHO the regulations are written from a common-sense perspective... to achieve the objective of a practice approach it may be beneficial to have the oversight of a qualified instructor. The regulations are not about the pilot who wishes to grab an opportunity for a bit of practice... but about training and currency.

Finally, the posts about the level of separation/information you receive is worrying... it has nothing to do with whether you are practise or not... in Class G airspace it depends on what type of service you ask for (FIS/RIS/RAS)!!!

[slim_slag]

Ok chilli, we will have to agree to differ on that one.

Pierre, you don't need a qualified instructor to learn something. Sometimes it's better not to have an instructor on board, they can often get in the way. Not sure what you mean about your class G comment.

[bookworm]

Ok chilli, we will have to agree to differ on that one.

This is just a US vs UK difference of convention, probably resulting from the differences in airspace system.

In the US, where any practical IFR flight requires an ATC clearance, it's usual to practise IAPs in VMC while maintaining VFR. That relieves ATC of the responsibility of separation from IFR flights, and the aircraft of some of the requirements of IFR flight. US ATS philosophy, built around class E where IFR is assumed to be able to see and avoid random VFR traffic, is comfortable with that.

In the UK, the operational difference between IFR and VFR in class G is less starkly defined, and tends to revolve around participation in a service. Placing yourself under the control of an Approach Control Unit by requesting practice approaches is taken as an implicit request for participation in (at least) procedural separation from other flights. While it's possible for practice approaches in VMC to be conducted under VFR, it's neither usual nor the default.

[tmmorris]

Sorry I've not had time to come back in on this since I started it...

My experience at Oxford certainly was that ATC would enquire when I was inbound whether I was VFR or IFR. If I was solo I would say IFR (so I didn't need an observer) and they would separate me; if I had someone with me I would say VFR and they would explicitly state that I was responsible for my own separation. In fact as Oxford is in class G I was responsible for my own separation (see and avoid) in either case in VMC, but at least it made it clear. I'm now operating out of Benson where they are happy to accept me for an ILS/PAR on request, if I'm inbound from somewhere else and either genuinely in need or they can fit me it (e.g. I did an ILS when the viz was 4500m - not legally required but definitely made me feel happier!)

Chilli: don't forget that plain-vanilla JAR PPLs can fly IFR in this country in VMC. I can't see anything legally preventing them requesting an instrument approach in VMC, therefore, though I don't think any would in fact. NPPLs are of course day VFR only.

Tim

[Chilli Monster]

Tim - don't worry, I've not forgotten that at all, hence my previous comment about not doing IAP's.

The reasons still stand - picture the scenario:

Vanilla PPL says he's IFR, asks for a RAS and a radar vectored ILS. I vector him towards a cloud and he says "I can't take that - not qualified". My response is going to be an equally rapid "Roger - Radar Information Service, position is xyz, resume own navigation for the field and report visual, expect a left/right base join".

Would have probably saved you time not asking for it in the first place ;)

[slim_slag]

Bookworm,

As ever your posts are informative and relevant. However I only speak for myself when saying I will consider myself 100% VFR when shooting practice approaches, and that doesn't depend on the country I fly in.

The controller is free to consider me IFR or VFR when providing services, but he cannot tell me what rules I should fly under. If I was shooting an approach with weather below VFR minimums it would not be a practice, it would be for real, I would consider myself IFR, and I would expect the missed approach procedure to be clear if I went missed for whatever reason.

So my agreement to differ with chilli is based upon what I consider myself to be doing, not what he considers himself to be doing.

Placing yourself under the control of an Approach Control Unit by requesting practice approaches is taken as an implicit request for participation in (at least) procedural separation from other flights

I don't like implicit requests, but even so, the same applies in US airspace. Even when I am VFR, they will separate you as if you are IFR, with the get out clause that if you hit something it's the pilot's fault. :)

If a spitoon has problems, not surprising I do too!

[bookworm]

You make fair points slim_slag.

Though I would normally say that misunderstandings between the pilot and ATC are the makings of disaster, in this case I can't see a major issue. Provided you tell ATC if you deviate from instructions, it doesn't really matter if you treat yourself as VFR or IFR. ATC will separate you from (participating) IFR flights.

[IO540]

If an FAA IR holder needs to fly the six approaches down to minima, with a safety pilot, how do passenger-carrying FAA ATPLs keep their currency?

The requirement cannot be that strict - it would be unworkable.

[englishal]

The FARs don't specify "down to minima"....

1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or flight training device that is representative of the aircraft category for the instrument privileges sought—

(i) At least six instrument approaches;

(ii) Holding procedures; and

(iii) Intercepting and tracking courses through the use of navigation systems


Also some other info from AOPA and John Lynch, author of the FARS:


"When paragraph 61.57(c)(1)(ii) [i.e., "Holding procedures"] was written it was not intended to mean multiple holdings. The emphasis is on the word procedures. There is more to holding than just flying circles in the sky. There is the planning for holding, slowing the aircraft down prior to entry, entering the holding pattern correctly, correcting for winds, establishing the one-minute inbound leg, etc. That is why I wrote it as 'Holding procedures.' So no, I never intended it to be multiple holdings."

He goes on to say that you need not document in the logbook where the maneuver took place. But what about tracking? Here, again, the answer is simple.

"Yes," Lynch told AOPA, "when a person does an approach or holding, he/she is also intercepting and tracking a course. See how simple we made paragraph 61.57(c)?" Imagine that; something from the FAA that is intentionally simple and easy to understand. No gotchas. No hidden traps.

As one might expect, Lynch has been asked a constant stream of questions about all aspects of the new Part 61, including IFR currency requirements. All of the answers are available on the Web (http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afs/afs600/).

[slim_slag]

EnglishAl,

I don't have the bandwidth here to download it and quote the paragraph, but if you go find Lynch's current Part 61 FAQ (Feb 2005 I think) you will find his take on approaches for currency. I think he says the presumption is that the approach completes at DH or MAP/MDA. I think he says you cannot just break off at the FAF and expect it to count. i.e if you are actual, you need to fly to minimum to log it. In practice this means going missed for most people who would have a higher personal minimum (I hope!)

IO540, no idea. In the States, they fly under part 121. I guess their 6 monthly check keeps them current.

[englishal]

I assume he means that the approach must either be flown in actual or simulated conditions. If actual it is unrealistic to expect every one to be down to minimums, because this rarely happens. I would assume the sensible take would be that the approach is flown as if a proper IFR approach, i.e. in / through IMC then breaking out of IMC somewhere above DH or MDA . Once broken out, the approach is continued as per a proper IAP to landing or IFR missed. Otherwise, you could argue that why do an ILS with DH of 220' when the cloudbase is 881', which won't count, but a circle to land at 880' would count.....?

If simulated then minimums could realistically be down to the deck.

I haven't got the bandwidth either here, the last copy I downloaded was a few megabytes I seem to remember....

cheers

I think he says the presumption is that the approach completes at DH or MAP/MDA
Just another thought as well....When doing "practice" approaches simulated, with VFR missed, they will often tell you to "circle south of the field at the Sears....." or something along those lines. Again these would not be at the true IFR minimums, yet these count for currency?

[slim_slag]

Englishal,

Haven't got his FAQ to hand, but seem to remember he mentioned that the IAP has to be flown with sole reference to instruments for it to count for currency.

So, taking this literally, breaking out at 220ft on an ILS will not count. Neither, I guess, will seeing the rabbit at 250ft even if the clouds go down to 100ft, as the rabbit will give you course information visually - and you can still fly the approach legally to below straight ILS minimums, but not log it. Quite strange.

I suppose one way to log the approach in actual is find an airport reporting cloud deck at 100ft, and shoot the ILS for the hell of it, just to take a look.... making sure you don't look for the approach lights, and going missed at 200ft.

Shooting the ILS for a circling approaches will count as they are published with a higher MDA than the ILS DH, I suppose. I suppose you could also fly the ILS, but log the LOC, bit naughty...

Easier to keep current flying practice approaches in VMC under VFR under a hood with a safety pilot. Sort of explains why a lot of people I know are probably not legal, but still perfectly safe, for what they want to do.

[englishal]

I'm sure that is not the intent. Mr Lynch seems a sensible chap and I think what Mr Lynch is saying is that "ok, you can shoot an approach, and so long as it is in Actual IMC and the approach is completed properly, under IFR, using instruments to at least the MAP then that is ok".

Otherwise it would be silly, un-realistic, and unworkable - the sort of thing they would employ in JAR Land....;)

[bookworm]

Here's the bit from the Part 61 FAQ:

QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?

ANSWER: § 61.51(g)(1), § 61.57(c)(1)(i), and § 61.1(b)(9); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an “actual” approach, it would presume the approach to be to the conclusion of the approach which would mean the pilot goes down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is no.
{Q&A-291}

[tmmorris]

minimum decent altitude

I rather like this idea. I've seen one or two ac recently below this altitude, mind you...

Tim

[Keef]

Not sure I follow some of this. I fly an ILS down to minima, and land. I happen to break cloud 100 feet above minima. Surely it still counts? Does anything in the FARs say they have to be to minima in IMC? I don't remember that when I did mine.

If I flew it to 1500 feet above minima, then went round, I could understand that not counting.

I cheat: I do most of mine in VMC with an IR in the RHS and me under the hood. I yell "decide!" when I get to the MAP.

[DFC]

Two points.

If one does not have a valid IMC or an IR then why would one want to practice an IFR approach procedure unless acompanied by an instructor who would be teaching you how to do it? Is this a case of practicing something that can't be done for real and if so then why?

If the instructor is in the aircraft then going IMC/IFR for a period during a practice approach eg Chilli vectors you into a cloud is no problem. Thus in this respect, I agree with the CAA and Chilli's view - don't practice IAPs unless your flight can accept being IFR, IMC at some stage.

US ATS philosophy, built around class E where IFR is assumed to be able to see and avoid random VFR traffic

That is worldwide ICAO and UK philosophy in Class D E F and G airspace i.e. IFR flights in such airspace should be able to see and avoid VFR flights and vise versa hence the VMC criteria, speed limitations and lack of a requirement for separation.

Even in UK Class G there is no separation provided regardless of service received - Even RAS is Advisory and separation is not guaranteed for a number of reasons.

US IR holders flying N reg aircraft in Europe must comply with the US rules for the number of approaches, VOR check etc etc to fly IFR, unlike their UK cousins flying G reg who can fly IFR in a piper cub with a map and compass!

This leaves the US IR holder who does not fly IFR reguluarly in a bit of a pickle by having to bag lots of instrument approaches and having to pay the practice approach fees at various fields. Of course claiming to be VFR could avoid such charges and also enroute charges if the aircraft is heavy enough. Not unusual for French Authorities to complain to the CAA about aircraft claiming to be VFR departing into IMC enroute to the UK!

Regards,

DFC

[englishal]

This leaves the US IR holder who does not fly IFR reguluarly in a bit of a pickle by having to bag lots of instrument approaches and having to pay the practice approach fees at various fields.
Not really, luckily the CAA gave me an IMC rating for free, which is valid for two years. Even if my FAA IR were outside the 6 months, I could still shoot the approaches, in IMC if I wished, using my IMC rating. Not only that, I can use the various FAA approved sims around the country should I wish. Then every two years I do an IPC while in the USA, and get my FAA IR zero timed, my IMC renewed....

Anyway, its not an issue for me, I go to the USA normally twice a year or more....

[slim_slag]

DFC,

You don't need an instructor on board when doing your 3 landings in 90 days, and you don't need one one when doing your 6 approaches in 6 months.

Unless the pilot considers it necessary.

One can tell from these threads the people who are the product of a nanny state, and those who aren't.

Keef, read the FAQ kindly posted by bookworm, what do you think?

[Keef]

Keef, read the FAQ kindly posted by bookworm, what do you think?

I think my approaches to minima under the hood are fine, and I think approaches in IMC are OK where I land off the approach, even if I break cloud above the DH/MAP.

Do you think different?

[englishal]

I belive the "intent" in part 61 is for the approach to be carried out as a *normal* approach, and not some mickey mouse way of keeping current.

I still think that if you shoot the IAP in or through IMC but break out at or above DH or MDA, but continue the full approach (either to land, missed or something else), then this is acceptable for logging as a proper approach. Mr Lynch seems to indicate this, he doen not mention that it must be IMC down to DH or MDA, and nor do the FARs, but what he does say is that the approach must be continued until MAP, which seems fair enough to me.

[slim_slag]

Very dangerous to interpret the "intent" of the FARs, unless you wrote them :)

Lynch says “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .”

i.e not when flying visually, which is what you do when you break out above DH/MDA. That last 30 seconds does not count, so the approach cannot be logged, in exactly the same way as you cannot log the approach if you take your hood off 30 seconds before you get to the DH. IMO of course :)

[IO540]

This one "what constitutes instrument time" has been done to death here a while ago.

Lots of things in aviation aren't written down precisely. A lot of the time one could speculate that the reason is that it is completely unenforceable. Example: regs specify equipment to be CARRIED but don't specify equipment to be USED.

This is the same. Except in really obvious cases (a clear blue sky, and a DH of 200ft) nobody can tell exactly when the pilot became visual.

The way I look at it is that one does what one is happy with, being honest with oneself. After all, a dishonest pilot could write up all sorts of fictitious logbook entries, couldn't he?

Most IFR pilots don't have a problem with this stuff if they own a plane and actually go places. If they are renting, basic currency will be the problem that dwarfs all the others. Most pilots flying an N aircraft will be whole or part owners. And this is all about IFR currency; if you fly often then you will be current and hopefully safe.

[OVC002]

The wave of disgruntled contempt unleashed in the US when the Lynch opinion regarding what was loggable re IAP's was brought to everyone's attention could be described as overwhelming.

I don't have the reference but I am informed by my CFI that the unworkable position described has been "clarified". If you are IMC anywhere between the FAF and MDA/DA you can log the approach. If simulated, then it's all the way from the IAF, or vectors for the approach, to the MDA/DA.

Simple and sensible. Very FAA.

[slim_slag]

Well, if we are going to cite interpretations that we cannot back up then I will say that a lawyer called Byrne in the FAA general counsel office said that the approach had to be flown to minimums for it to count, agreeing with what we know Lynch said in writing.

The FAA is sensible because it lets you do it under the hood with a safety pilot.

[englishal]

Slim,

I normally agree with Mr Lynch, but on this occasion I don't. What he suggested would be unworkable as it'd mean that no one could possibly log an IAP in actual except once in a blue moon. Myself, I have only shot one ILS down to minimums in 4 years in "actual", and if you took what lynch says literally, then if DH is 200' and cloudbase is 201', then the approach is not loggable.

Just my opinion of course, it would be nice to find the reference OVC002's is refering to ....;)