Logging approaches in VMC

[MachFly]

AFAIK there is nothing stopping you from *logging* them as approaches. You just can't count them toward your instrument proficiency requirements (which is what everybody in this thread assumed that you meant by "logging").

So if you DO log them, you'd better have a way of differentiating which count toward 6HITS and which don't. To me, it's not worth that extra effort. Just remark them and be done with it.

That can work but when you have to show your logbook to someone won't you get a question as to why you logged approaches in VMC?


You can differentiate it by seeing whether you logged IMC or simulated instrument during that flight or not. If you did log it then chances are that that approach counts towards your currency, if you did not then chances are that it was VMC and it does not count.

 

[jason]

That can work but when you have to show your logbook to someone won't you get a question as to why you logged approaches in VMC?


You can differentiate it by seeing whether you logged IMC or simulated instrument during that flight or not. If you did log it then chances are that that approach counts towards your currency, if you did not then chances are that it was VMC and it does not count.

There is no requirement to log S(im)IC, IMC nor AIC (unless you want to use the time toward a rating). And just because you log AIC on a flight it doesn't mean that your approach counts toward your 6HITS. Maybe you just flew through one big puffy cloud at 9000ft between KMAF and KADS.

 

[MachFly]

And just because you log AIC on a flight it doesn't mean that your approach counts toward your 6HITS. Maybe you just flew through one big puffy cloud at 9000ft between KMAF and KADS.

True, I did say "chances are" .

 

[Velocity173]

That can work but when you have to show your logbook to someone won't you get a question as to why you logged approaches in VMC?


You can differentiate it by seeing whether you logged IMC or simulated instrument during that flight or not. If you did log it then chances are that that approach counts towards your currency, if you did not then chances are that it was VMC and it does not count.

I don't think you'd be wrong to log them VMC, I just think it would be a little confusioning trying to figure out which ones are for currency and which ones were just training. I also agree with you on wanting them to accumulate approaches. Lets not forget, there's good training involved here even if you don't file IFR. You still have to set up your avionics and instrumnets and hopefully even talk to approach and ask them for practice approaches in VFR conditions. Doing that is a lot better training then going out on a nice weekend sightseeing for an hour.

 

[midlifeflyer]

It used to be correct. There are even letters from FSDOs and DC to the folks who make the Frascas and Redbirds and such that said that flying a sim for proficiency wasn't "training" any more than going up with a safety pilot was.

Then our gloriously reigning Chief Counsel issued an interpretation that contradicted those, and that's how it stands. I believe that folks have asked for a reconsideration of that opinion but am not sure it's happened.

The problem was that the FAA intended to change the rule in the October 2009 Part 61 revision. Not only did you have FSDOs saying that you didn't need an instructor but the Final Rule commentary for the revision said so also.

Problem was, well, the rule writers sort of forgot to change the rule itself and the Chief Counsel merely said it's the rule that controls, not the commentary was never made into a rule. The problem isn't the Chief Counsel. It's the rule writers. It was never correct. There's nothing for the Chief Counsel to reconsider; it should have taken nothing more than a quick technical correction - an "oops! we forgot to add..."

 

[midlifeflyer]

AFAIK there is nothing stopping you from *logging* them as approaches. You just can't count them toward your instrument proficiency requirements (which is what everybody in this thread assumed that you meant by "logging").

Why bother logging something that doesn't count in a way that it looks like it does (unless of course, you want someone looking at the record to think it counts)?

 

[jason]

Why bother logging something that doesn't count in a way that it looks like it does (unless of course, you want someone looking at the record to think it counts)?

I wouldn't bother and I don't.

I was simply stating that there is nothing stopping him from logging them. I think that I made it pretty clear in my response that I feel that it just complicates matters with no added benefit.

 

[MachFly]

Why bother logging something that doesn't count in a way that it looks like it does (unless of course, you want someone looking at the record to think it counts)?

For personal satisfaction.

 

[Greg Bockelman]

Ok, but if you choose to go that route, you have to make 100% sure that you differentiate between what counts for FAR legal currency and what you log for personal reasons. There can be NO confusion as to what counts and what doesn't.

 

[MachFly]

Ok, but if you choose to go that route, you have to make 100% sure that you differentiate between what counts for FAR legal currency and what you log for personal reasons. There can be NO confusion as to what counts and what doesn't.

Is it still legal that I know the difference but no one else would?

I don't do that much IMC flying that by referencing my logbook I can exactly remember each IMC flight for the past 6 month, this way I can identify identify which approach was IMC and which was not. Therefore I know whether I'm current or not, but someone else who reads my logbook would only be able to assume that. So is it enough to me to know or do I have to specifically separate it in my logbook?

 

[Greg Bockelman]

Is it still legal that I know the difference but no one else would?

I don't do that much IMC flying that by referencing my logbook I can exactly remember each IMC flight for the past 6 month, this way I can identify identify which approach was IMC and which was not. Therefore I know whether I'm current or not, but someone else who reads my logbook would only be able to assume that. So is it enough to me to know or do I have to specifically separate it in my logbook?

The point isn't whether or not YOU can identify them, it is whether the FEDS can identify them. If there isn't a CLEAR delineation between the two, you are going to have to do a tapdance with the Feds, and you REALLY don't want to get involved with that.

 

[MachFly]

The point isn't whether or not YOU can identify them, it is whether the FEDS can identify them. If there isn't a CLEAR delineation between the two, you are going to have to do a tapdance with the Feds, and you REALLY don't want to get involved with that.

Understood

 

[poadeleted20]

There is no requirement to log S(im)IC, IMC nor AIC (unless you want to use the time toward a rating).

...or you want to use the events on that flight for recent instrument experience. If you don't log any instrument time on a flight, it's hard to argue that any events you logged on that flight were conducted under instrument conditions, especially since 61.51(b)(3) requires, and the Chief Counsel's letter recommends, that you log the conditions of the flight.

 

[Henning]

This sucks.
Well, thanks for clarifying.





What if it's perfectly VFR but you don't see it due to haze?

Its your log, if you want log it and in the comments 'had to switch to ILS due to reduced vis in haze.' They can accept it towards currency or not if you decide to claim it. If you don't claim it, it's just personal record keeping.

 

[MachFly]

Its your log, if you want log it and in the comments 'had to switch to ILS due to reduced vis in haze.' They can accept it towards currency or not if you decide to claim it. If you don't claim it, it's just personal record keeping.

If I was still flying in the north east this would work, but we don't get much haze in arizona. On a normal day we have at least 50nm of visibility.

 

[Henning]

If I was still flying in the north east this would work, but we don't get much haze in arizona. On a normal day we have at least 50nm of visibility.

The reality is you can practice flying approaches and flying VFR, you just have to choose to do so. Even if you can't log it, it still happened.

 

[Henning]

Many a time my call inbound would be "XX approach, unfamiliar, would like the ILS 30 in visual rules." and I get handled onto the ILS and handed off inbound. Just because you're VFR doesn't mean you can't take advantage of the system.

 

[jason]

...or you want to use the events on that flight for recent instrument experience. If you don't log any instrument time on a flight, it's hard to argue that any events you logged on that flight were conducted under instrument conditions, especially since 61.51(b)(3) requires, and the Chief Counsel's letter recommends, that you log the conditions of the flight.

Agreed...

 

[azure]

Many a time my call inbound would be "XX approach, unfamiliar, would like the ILS 30 in visual rules." and I get handled onto the ILS and handed off inbound. Just because you're VFR doesn't mean you can't take advantage of the system.

I've done that too -- especially when it's just getting dark and it's hazy and I don't want to have to search for the field. At an unfamiliar field with multiple runways, it also helps to avoid landing on a different runway than you announced (yeah, done that ).

 

[MachFly]

Many a time my call inbound would be "XX approach, unfamiliar, would like the ILS 30 in visual rules." and I get handled onto the ILS and handed off inbound. Just because you're VFR doesn't mean you can't take advantage of the system.

I've done that as well.

 

[Henning]

"Unfamiliar" is the magic word for 'give me the guided tour'. If they have the time and inclination they'll point out the local land marks and reporting points. Some controllers get board I guess.

 

[MachFly]

"Unfamiliar" is the magic word for 'give me the guided tour'. If they have the time and inclination they'll point out the local land marks and reporting points. Some controllers get board I guess.

You know where you fly into an airport that you never been too before and tower tells you to report some point on the ground which you have no idea where to find, if you say "unfamiliar" that wont happen.


Realistically the only time I used "unfamiliar" was when asking for progressive taxi.

 

[midlifeflyer]

You know where you fly into an airport that you never been too before and tower tells you to report some point on the ground which you have no idea where to find, if you say "unfamiliar" that wont happen.


Realistically the only time I used "unfamiliar" was when asking for progressive taxi.

I've used it as indicated in your first example. Flying into an airport for the first time and Tower asks me to report some local landmark I'm not familiar with. I haven't used it for progressive taxi - for that I just ask for a progressive taxi and haven't seen the need to add "unfamiliar."

 

[denverpilot]

The problem was that the FAA intended to change the rule in the October 2009 Part 61 revision. Not only did you have FSDOs saying that you didn't need an instructor but the Final Rule commentary for the revision said so also.

Problem was, well, the rule writers sort of forgot to change the rule itself and the Chief Counsel merely said it's the rule that controls, not the commentary was never made into a rule. The problem isn't the Chief Counsel. It's the rule writers. It was never correct. There's nothing for the Chief Counsel to reconsider; it should have taken nothing more than a quick technical correction - an "oops! we forgot to add..."

Somewhen the rule writers make commentary, the Chief Council says it isn't legal, but when the Chief Council makes commentary about rules that are unclear, everyone treats those as it they're were the law.

Haha. Makes sense to me.

 

[Ghery]

Flew IFR from PUW to OLM today. Got some actual decending into OLM, but by the time I was given final vectors to intercept the localizer I was VMC. No logging this one. Still shot the ILS 17, but it didn't count as I wasn't in the clouds at the FAF. Oh well...

 

[Palmpilot]

I used to hear instructors say that the requirement for logging an approach (without a hood) was flying in actual for any part of the approach, not just on the final segment. What brought about this change?

 

[jason]

I used to hear instructors say that the requirement for logging an approach (without a hood) was flying in actual for any part of the approach, not just on the final segment. What brought about this change?

There is no change.

See post #26 of this thread (and the post quoted by post 26 and the link in the post quoted in post 26).

 

[Palmpilot]

There is no change.

See post #26 of this thread (and the post quoted by post 26 and the link in the post quoted in post 26).

Are you saying that instructors are teaching the same thing they were teaching in the 1990s on this point? If so, that's not the way I remember it.

 

[jason]

Are you saying that instructors are teaching the same thing they were teaching in the 1990s on this point? If so, that's not the way I remember it.

I'm saying that there is no clear ruling on it. Instructors can teach whatever they want to teach because the Chief Counsel has not released an opinion and the regs are (thankfully) pretty vague.

So it's all a bunch of "somebody told/taught me". The most conservative way is to count it if you're in IMC/AIC until after the FAF. I don't think that level of conservatism is necessary and tend to make the decision on a case by case basis as I outlined in post #26. Neither is "wrong" because, as I said, no clear ruling has been released. It's all about what you feel comfortable and confident having to defend to the nice (wo)man from the FAA.

 

[Palmpilot]

I'm saying that there is no clear ruling on it. Instructors can teach whatever they want to teach because the Chief Counsel has not released an opinion and the regs are (thankfully) pretty vague.

So it's all a bunch of "somebody told/taught me". The most conservative way is to count it if you're in IMC/AIC until after the FAF. I don't think that level of conservatism is necessary and tend to make the decision on a case by case basis as I outlined in post #26. Neither is "wrong" because, as I said, no clear ruling has been released. It's all about what you feel comfortable and confident having to defend to the nice (wo)man from the FAA.

It's hard to see how defending one's practice on that could even come up with an FAA enforcement person. It's not like they have the budget to follow everyone around and compare weather conditions to what people log. What contribution it makes to proficiency is probably what matters. I certainly don't see a problem with approaching it as you described in post #26.

 

[weilke]

It's hard to see how defending one's practice on that could even come up with an FAA enforcement person. It's not like they have the budget to follow everyone around and compare weather conditions to what people log.

It only mattters if someone gets hurt.

I remember one ntsb report where someone crashed in a 'lost it in imc' accident. In his logs, the pilot had something like 90% of his past 100 hrs in 'actual'. They went back and compared the reported weather for those days and routes and stated that the weather on those days 'did not support the contention that those flights were conducted in actual instrument conditions'

 

[poadeleted20]

I'm saying that there is no clear ruling on it. Instructors can teach whatever they want to teach because the Chief Counsel has not released an opinion and the regs are (thankfully) pretty vague.

If you're speaking to the issue of how much of the approach must be flown in instrument conditions for it to count, that's correct. However, the Chief Counsel did give a legal interpretation in 1992 on how much of the approach must be flown and how low it must be taken. See the Slater interpretation, #92-5, quoted below:

Second, you questioned how low a pilot must descend (i.e., minimum descent altitude or decision height or full-stop landing) on the six instrument approaches he must log to meet the recent IFR experience requirements specified in FAR Section 61.57(e)(1)(i) (14 CFR Section 61.57(e)(1)(i)). You also asked if an instrument approach "counts" if only part of the approach is conducted in actual IFR conditions. Section 61.57(e)(1)(i) states that: No pilot may act as pilot in command under IFR, nor in weather conditions less than the minimums prescribed for VFR, unless he has, within the past 6 calendar months - (i) In the case of an aircraft other than a glider, logged at least 6 hours of instrument time under actual or simulated IFR conditions, at least 3 of which were in flight in the category of aircraft involved, including at least six instrument approaches, or passed an instrument competency check in the category of Ò aircraft involved. For currency purposes, an instrument approach under Section 61.57(e)(1)(i) may be flown in either actual or simulated IFR conditions. Further, unless the instrument approach procedure must be abandoned for safety reasons, we believe the pilot must follow the instrument approach procedure to minimum descent altitude or decision height.

I would note that it is probably a good thing that nobody has pressed the issue on how much of the approach must be flown in instrument conditions, as we probably could not stand the answer, which might be "all of it," in which case you'd not be able to count any approach you successfully completed, since if you were still in instrument conditions as DH/MDA, you wouldn't be able to land, so if you successfully landed, you wouldn't be able to count it. Best to let this sleeping dog continue to doze.

 

[Palmpilot]

It only mattters if someone gets hurt.

I remember one ntsb report where someone crashed in a 'lost it in imc' accident. In his logs, the pilot had something like 90% of his past 100 hrs in 'actual'. They went back and compared the reported weather for those days and routes and stated that the weather on those days 'did not support the contention that those flights were conducted in actual instrument conditions'

Clearly, the judgment of Mother Nature can be much more severe than that of the FAA!

 

[midlifeflyer]

Somewhen the rule writers make commentary, the Chief Council says it isn't legal, but when the Chief Council makes commentary about rules that are unclear, everyone treats those as it they're were the law.

Haha. Makes sense to me.

When the rule writers say they are changing a rule but don't actually change the rule, the rule doesn't change. That actually does make sense to me.

 

[poadeleted20]

I'm with Mark. While there are some cases where the Chief Counsel opinions make no sense based on the plain language of the regulations concerned (e.g., Mangiamele and 61.113), generally they do. Where we see problems arise is when Flight Standards doesn't do their homework properly when writing the reg so it actually says what they want it to say, or they try to short-cut the processes mandated by the Administrative Procedures Act (e.g., the issue about the AFS-800 letters of authorization for BATD's to be used for recent instrument experience without an instructor present in direct conflict with the plain language of 61.51(g)(4) which AFS-800 themselves wrote).

Mark can no doubt expound on the difference between a Letter of Authorization and a legal exemption from a regulation.

 

[midlifeflyer]

Mark can no doubt expound on the difference between a Letter of Authorization and a legal exemption from a regulation.

Yes, but I'd probably bore myself to death.

 

[poadeleted20]

Yes, but I'd probably bore myself to death.

Suffice it to say that an exemption is regulatory and an LoA is not?

 

[Velocity173]

Well it appears AOPA believes you can't log it even if you're not counting it towards currency-



Sadly no, to log an approach at all, it must be conducted under IMC or in VMC with a safety pilot and under the hood.
Regards,

Jose A. Tuya Jr.
Technical Specialist
Government Affairs – Pilot Information Center
AOPA
800-USA-AOPA

 

[poadeleted20]

Well it appears AOPA believes you can't log it even if you're not counting it towards currency-



Sadly no, to log an approach at all, it must be conducted under IMC or in VMC with a safety pilot and under the hood.
Regards,

Jose A. Tuya Jr.
Technical Specialist
Government Affairs – Pilot Information Center
AOPA
800-USA-AOPA

I don't know Mr. Tuya's source, but he is wrong. VMC vs IMC has nothing to do with whether you can log it or not or whether you need a hood/safety pilot or not. To log it, you need to be in either actual or simulated instrument conditions, regardless of IMC/VMC. You can be in actual instrument conditions in VMC and still log it without a hood/safety pilot (think dark night with no visible horizon and no usable ground references), and you may need to be in simulated instrument conditions with a safety pilot even in IMC (think 1900 feet laterally from the only cloud in the sky). See the following posts for more on that.
http://www.pilotsofamerica.com/foru...96&highlight=actual+simulated+carr#post362896
http://www.pilotsofamerica.com/foru...54&highlight=actual+simulated+carr#post599954

 

[Velocity173]

I think the biggest criteria in all that is the requirement to be controlling the aircraft by reference to instruments. In the Army the instrument or "W" time is more clear cut. Actual instrument meteorological conditions that does not permit visual contact with the natural horizon or the earth's surface and aircraft control must be made by reference to instruments. I flew with a couple instructors in the Army that logged weather (W) time during a hazy summer day where they couldn't see the horizon but could see the ground. I was sitting in the back and I seriously doubt they were controlling the aircraft by reference to instruments. To me it's an integrity thing.