Practice IAPs

[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/showthr...light=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/...es/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