I don't think that's correct. I'm too lazy to check right now, but I think the wording of the reg is "actual or simulated instrument conditions", not IFR conditions.
Ah. One of the things I learned from this forum was that there is no IFR conditions. There's VMC and IMC, and you can be IFR in VMC and VFR in IMC (SVFR, I suppose). I know you know this. And, I freely admit I'm into hair splitting territory.
The intent of the reg comes down to what "actual instrument conditions" means, and I guess this is where the Reasonableness interpretation would have me assume "IMC, as defined by cloud clearance requirements".
I think the phrase the FAA has used in other situations, and should have in this one if they meant it was "solely by reference to instruments". The problem with that is that as pointed out earlier, almost no one would be able to stay current unless you have to go missed, since successfully completing the approach means picking up the runway environment at some point before MDA or DH.
Instrument conditions means you need to be on the gauges to control the airplane. IOW I don't think it's legitimate to log an approach when you were 200 feet below the bases the whole way down. Yes, you were IMC, because IMC means "not VMC", i.e. in violation of the VFR vis or cloud clearance requirements, but you were perfectly capable of flying the approach visually.
If it's IMC -for the entire approach- you're looking at less than 1000 ft ceiling and less than 3 miles visibility. Most approaches I've looked at have substantional portions above that. Not zero/zero, but not exactly CAVU either.
Again, I think the "rule of reason" is the best guide here. The point of the reg is to promote proficiency in flying by instruments alone. If you're in visual conditions without a hood, how does that help you maintain the skills needed for instrument flying? You get to practice using your avionics and procedural details, but not the exquisite challenge of keeping the plane right side up without visual reference at the same time. Having the buttonology down and second nature is an important subset of the needed skills, but it's not enough.
I see your point, but assuming IMC and, say, a 500fpm descent rate, the -maximum- time you're able to "cheat" and see the runway environment would be 2 minutes. The rest of the approach would be flown in reduced visibility.
Your line of reasoning leads to the situation where even airline captains would have trouble staying current since even approaches done in IMC done to (almost) minimums wouldn't count toward currency.
Thanks y'all. I knew it would have been asked and answered to death, but I couldn't find a simple summary of the current best recommendation.
Clearly, the current definition is a less than perfect (well, no, it's a horrible) way to specify currency requirements. If zero/zero approaches are that important, then the "actual IFR conditions" part should be eliminated and you should be required to fly with a safety pilot or instructor. If that's not the intent, there darn well oughta be an explanation of what "actual instrument conditions" really means. And the reference to it being "intentionally vague" should result in, at the very least, someone getting fired.
Nothing that affects safety like this should be intentionally vague. wtf.
