Would these VFR practice approaches be loggable for currency?

[mjburian]

I fly a C172/A and always think "If the electrical system dies in IMC, my iPad/Stratus (with SV) will serve as an emergency backup." And I've tested that out while in straight/level flight under the hood. But, I'd also like to see whether that combination (or even my 496) would allow me to shoot an emergency approach to get back on the ground. Realizing that this equipment isn't legal for actual IFR flying in a non-emergency situation, I'm wondering whether I can log the practice approaches flown under the hood with a safety pilot for currency's sake.

I'd like to fly them either way and I generally stay well ahead of the "6 in 6 plus holding and tracking" but I don't know what happens if somewhere down the road an approach or two of this variety ends up being needed for IFR currency.

Is a VFR practice approach flown under the hood with non-legal IFR equipment loggable for currency? (Citation of FARs and/or legal interpretations appreciated.)

 

[kevmor99]

Is a VFR practice approach flown under the hood with non-legal IFR equipment loggable for currency? (Citation of FARs and/or legal interpretations appreciated.)

61.51 says:

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of §61.57(c) of this part, the following information must be recorded in the person's logbook—

(i) The location and type of each instrument approach accomplished; and

Are you going to be flying with a legal primary means of navigation (ie, on the ILS, past glideslope intercept) when the primary fails and you use the iPad? I think that may count, but if you're just trying to "get it on the ground" using an iPad, I don't think you can put "iPad" as "type of approach"...

 

[frfly172]

First I can tell you the 496 works great for an approach . They specify you have to log the type of approach,and holds. They don't say you have to specify the equipment you used on the approach. I'm partial to the I pad stratus set up for spatial recognition.

 

[MAKG1]

First I can tell you the 496 works great for an approach . They specify you have to log the type of approach,and holds. They don't say you have to specify the equipment you used on the approach. I'm partial to the I pad stratus set up for spatial recognition.

Is it an ILS approach if you don't use the ILS?

Similarly, is it an LPV approach if you don't use a WAAS IFR certified GPS?

 

[mjburian]

Are you going to be flying with a legal primary means of navigation (ie, on the ILS, past glideslope intercept) when the primary fails and you use the iPad? I think that may count, but if you're just trying to "get it on the ground" using an iPad, I don't think you can put "iPad" as "type of approach"...

I'm not sure if you mean in an actual emergency or in the practice approaches I mentioned. In an actual emergency, I'll do whatever I deem necessary to get the plane on the ground and stopped in as few pieces as possible. For the practice approaches, I assume an ILS would be a challenge (given that I don't have vertical guidance on the iPad)... but, what about flying the LOC portion of that ILS and using GPS altitudes (plus, obviously, a safety pilot keeping me from danger)?

I'm certain that the approaches CAN be flown this way in VMC... the only question is whether they can be legally logged for currency. (Assuming under the hood and with a safety pilot.)

 

[mjburian]

First I can tell you the 496 works great for an approach . They specify you have to log the type of approach,and holds. They don't say you have to specify the equipment you used on the approach. I'm partial to the I pad stratus set up for spatial recognition.

It sounds like you're saying that your opinion is that using either the 496 or the iPad would be legal for currency. I tend to agree. But, I'd like some reasonable way to be able to back that up if it ever came down to it.

Edited to add:
Glad to hear the 496 works great. That helps back up my "in an emergency" thoughts. But, I'd still like to practice with it so that I know the proper usage/buttonology of setting up and flying the approach on a device I've never used for that purpose before.

 

[midlifeflyer]

But, I'd still like to practice with it so that I know the proper usage/buttonology of setting up and flying the approach on a device I've never used for that purpose before.

So go ahead and practice it. Why does it have to count for currency?

This question came up long before the iPad existed. I used to fly emergency approaches using a GPSMap handheld.

I don't have an official answer and my personal opinion is as worthless as anyone else's. But I do have a few thoughts.

1. I agree with kevmor's observation that the reg requires an actual instrument approach, not something we make up on the fly (so to speak). So if we're not talking about a "real" IAP, I doubt it is loggable for currency at all.

2. There's nothing in 61.57 that requires you to say anything about what real approach you flew other than to identify it. There's no requirement to state in your logbook, for example, whether it was flown full panel, partial panel, autopilot coupled, uncoupled, losing glideslope (actual or simulated), no-gyro vectors (a reason for the additional requirement to log navaid interception and tracking), etc...

3. 61.57 represents the bare minimum of currency and arguably has very little to do with real proficiency. So, assuming the iPad emergency approach is not loggable, why limit yourself to the bare minimum. Do what you need for bare currency and add the iPad guided approach as a practice emergency procedure that doesn't count for currency.

 

[mjburian]

So go ahead and practice it. Why does it have to count for currency?

This question came up long before the iPad existed. I used to fly emergency approaches using a GPSMap handheld.

I don't have an official answer and my personal opinion is as worthless as anyone else's. But I do have a few thoughts.

1. I agree with kevmor's observation that the reg requires an actual instrument approach, not something we make up on the fly (so to speak). So if we're not talking about a "real" IAP, I doubt it is loggable for currency at all.

2. There's nothing in 61.57 that requires you to say anything about what real approach you flew other than to identify it. There's no requirement to state in your logbook, for example, whether it was flown full panel, partial panel, autopilot coupled, uncoupled, losing glideslope (actual or simulated), no-gyro vectors (a reason for the additional requirement to log navaid interception and tracking), etc...

3. 61.57 represents the bare minimum of currency and arguably has very little to do with real proficiency. So, assuming the iPad emergency approach is not loggable, why limit yourself to the bare minimum. Do what you need for bare currency and add the iPad guided approach as a practice emergency procedure that doesn't count for currency.

That was the plan. And likely how it'll work out. But:

I'd like to fly them either way and I generally stay well ahead of the "6 in 6 plus holding and tracking" but I don't know what happens if somewhere down the road an approach or two of this variety ends up being needed for IFR currency.

It sounds like you're saying don't log them for currency. Which is a completely valid opinion. I'm just wondering if there's any legal reason that a person could/couldn't log them for currency.

 

[AustinPilot]

The definition of "instrument approach" doesn't change based on whether you are in actual or simulated conditions. Ergo, it stands to reason that if you could not legally execute an instrument approach in actual conditions with your iPad, then neither can you claim to have executed it under simulated conditions with your iPad.

Seems easy enough to kill two birds with one stone, however, and fly your approach with the primary/certified instruments while checking to see if the iPad agrees with them.

 

[Jim_R]

Seems easy enough to kill two birds with one stone, however, and fly your approach with the primary/certified instruments while checking to see if the iPad agrees with them.

Part of the purpose of requiring pilots to fly approaches for currency is to ensure they retain the knowledge and skills required to safely follow the instrument-defined path in the sky. That means "flying the needles", including such basic things as "when the needle drifts left, you turn the airplane left to chase the needle", and for approaches with glidepaths, being able to set the engine power and trim to follow the glideslope.

It also ensures that you remember how to find the required frequency data from the plates and dial that into your radios, dial up directions on CDIs as appropriate, and operate your IFR-certified panel-mounted GPS for RNAV approaches.

Are you practicing those things if you are "flying the approach by iPad"? Certainly not all of those things, and maybe not any of 'em.

So why would it make sense that "flying the approach with the iPad" would count anything for currency?

I echo AustinPilot: If you are really curious about how your iPad might help you fly an approach in an emergency, then why not fly a practice approach the way you're supposed to do it, and just take your iPad along for the ride? Why try to make it any bigger deal than that?

 

[mjburian]

Seems easy enough to kill two birds with one stone, however, and fly your approach with the primary/certified instruments while checking to see if the iPad agrees with them.

I do this on most every approach, since the Foreflight approach plates are georeferenced. But I already know I can fly an approach using the primary/certified instruments. What I don't know for certain is whether I'm capable of using ONLY the iPad, in the case where I lose the electrical and need to get down. To realistically practice this, I'd have to ignore the certified instruments altogether.

Part of the purpose of requiring pilots to fly approaches for currency is to ensure they retain the knowledge and skills required to safely follow the instrument-defined path in the sky. That means "flying the needles", including such basic things as "when the needle drifts left, you turn the airplane left to chase the needle", and for approaches with glidepaths, being able to set the engine power and trim to follow the glideslope.

It also ensures that you remember how to find the required frequency data from the plates and dial that into your radios, dial up directions on CDIs as appropriate, and operate your IFR-certified panel-mounted GPS for RNAV approaches.

Are you practicing those things if you are "flying the approach by iPad"? Certainly not all of those things, and maybe not any of 'em.

So why would it make sense that "flying the approach with the iPad" would count anything for currency?

I echo AustinPilot: If you are really curious about how your iPad might help you fly an approach in an emergency, then why not fly a practice approach the way you're supposed to do it, and just take your iPad along for the ride? Why try to make it any bigger deal than that?

I understand what you're saying, but we also spend a fair amount of time/effort practicing for emergency situations and how to react to them. Which is why I assumed (maybe incorrectly?) that the FAA would want us to practice these sorts of things and would allow it to be logged for currency. Of course, then you'll end up with people flying ONLY the iPad for practice approaches vs. maybe 1 or 2 every few months, to keep the emergency scenario fresh enough.

 

[AustinPilot]

I do this on most every approach, since the Foreflight approach plates are georeferenced. But I already know I can fly an approach using the primary/certified instruments. What I don't know for certain is whether I'm capable of using ONLY the iPad, in the case where I lose the electrical and need to get down. To realistically practice this, I'd have to ignore the certified instruments altogether.

Good scenario to figure out, I just don't think you can log that for currency.

 

[Henning]

61.51 says:



Are you going to be flying with a legal primary means of navigation (ie, on the ILS, past glideslope intercept) when the primary fails and you use the iPad? I think that may count, but if you're just trying to "get it on the ground" using an iPad, I don't think you can put "iPad" as "type of approach"...

RNAV like it says on the plate.

 

[mjburian]

Good scenario to figure out, I just don't think you can log that for currency.

Got it.

Thanks all for your thoughts on this. I'll still go through the exercise for my own peace of mind, but won't log these approaches for currency based on the conversation here.

 

[Palmpilot]

Is it an ILS approach if you don't use the ILS?

Similarly, is it an LPV approach if you don't use a WAAS IFR certified GPS?

I don't see anyplace where certification of the equipment enters into the logging regulations. I think the issue is whether you're using equipment that receives and displays the signals that are specified on the approach plate. For an ILS, if you had a portable device that received and displayed the localizer and glide slope, I don't see why that wouldn't count for currency. Same for an LPV approach if you had a portable GPS device that was WAAS-capable and displayed the glide path and lateral deviation.

That having been said, for proficiency purposes, most of the time I would want to use the type of equipment that I would normally use in actual instrument conditions.

 

[Jim_R]

I don't see anyplace where certification of the equipment enters into the logging regulations. I think the issue is whether you're using equipment that receives and displays the signals that are specified on the approach plate. For an ILS, if you had a portable device that received and displayed the localizer and glide slope, I don't see why that wouldn't count for currency.

Can you use that setup to legally fly an actual IFR approach?

If the purpose of "currency" is to maintain the skills required to fly an approach, how is not flying the approach with the tools that are legally required accomplishing that?

"Golly gee, Mr. NTSB guy, don't get all mad at me for bending my airplane trying to fly that approach on my GTN750. I always fly my practice approaches with my iPad, so I just kinda forgot what buttons to punch on the panel, and got confused, is all..."

 

[midlifeflyer]

Can you use that setup to legally fly an actual IFR approach?

If the purpose of "currency" is to maintain the skills required to fly an approach, how is not flying the approach with the tools that are legally required accomplishing that?

"Golly gee, Mr. NTSB guy, don't get all mad at me for bending my airplane trying to fly that approach on my GTN750. I always fly my practice approaches with my iPad, so I just kinda forgot what buttons to punch on the panel, and got confused, is all..."

As I said earlier, I don't know the "legal" answer. But you are making a pretty big jump here from doing the odd approach on an uncertified device (could be an iPad, Android, Garmin x96, whatever) to find out how it might help out in an emergency (which seems to be what folks here are talking about) to never ever using anything else (your criticism's assumption).

Let's try this alternate dialog on for size (we'll leave in your NTSB, although they aren't the ones one would be worried about talking to in either case)

"Golly gee, Mr. NTSB guy, I'm sure happy to be here to be able to talk to you today. I had an electrical system failure and my GTN750 crapped out while I was flying the approach. Guess it's a good thing I practice flying an approach once in a while with my iPad so I was able to get down safely, although I did manage to prang the prop on landing."

 

[petrolero]

Yes it counts for currency. It's a VFR approach. Your primary instrument for legality is the safety pilot's eyeballs. During my training we practiced emergency approaches with all sorts of instruments out. There is no rule that says you must practice them using ideal instrumentation, you just have to fly the procedure. It's a simulated emergency and in an emergency you use what you have available.

I think we should all practice those to see how it works.

 

[petrolero]

Can you use that setup to legally fly an actual IFR approach?

If the purpose of "currency" is to maintain the skills required to fly an approach, how is not flying the approach with the tools that are legally required accomplishing that?

"Golly gee, Mr. NTSB guy, don't get all mad at me for bending my airplane trying to fly that approach on my GTN750. I always fly my practice approaches with my iPad, so I just kinda forgot what buttons to punch on the panel, and got confused, is all..."

It is flying the approach "with the tools that are legally required" - even though that is not the legal standard. Using your logic... he is simulating an emergency. In an emergency, it is legal to use whatever you have. So flying the procedure with an ipad and stratus in VFR conditions with a safety pilot is just as legal as flying one in any other partial-panel situation. He is still receiving the GPS signal that is required for the approach.

By that logic, it would be illegal to fly VFR practice approaches in an airplane that is out of pitot/static/xpdr check currency, or with an expired database/plate, or when the pilot is not legal for IFR (as would be the case if he hasn't logged his 66HIT requirements but hasn't reached the 12 calendar month limit). None of that is in the regs or counsel opinions as far as I have ever heard.

Log it.

 

[Palmpilot]

Can you use that setup to legally fly an actual IFR approach?

If by actual IFR approach, you mean under instrument flight rules, my answer would be no, unless it's an emergency. However, I don't see any reason why you couldn't legally fly a practice IFR approach under visual flight rules with it, and I'm aware of no regulation that says you can't legally log it.

If the purpose of "currency" is to maintain the skills required to fly an approach, how is not flying the approach with the tools that are legally required accomplishing that?

By practicing skills that may be required in an emergency.

I don't know about you, but I've experienced alternator failure two or three times, so far.

"Golly gee, Mr. NTSB guy, don't get all mad at me for bending my airplane trying to fly that approach on my GTN750. I always fly my practice approaches with my iPad, so I just kinda forgot what buttons to punch on the panel, and got confused, is all..."

Which is why I said "for proficiency purposes, most of the time I would want to use the type of equipment that I would normally use in actual instrument conditions."

 

[EdFred]

Why does everyone try to inject more into what the regulations say vs what they actually say?

If you haven't done a VOR check in your plane in the past 30 days, but the GPS database is up to date, does that mean any GPS approaches you fly aren't counted towards currency because your plane isn't technically IFR legal, even though you flew them with a safety pilot under VFR?

Don't read into what isn't there.

 

[midlifeflyer]

Why does everyone try to inject more into what the regulations say vs what they actually say?

If you haven't done a VOR check in your plane in the past 30 days, but the GPS database is up to date, does that mean any GPS approaches you fly aren't counted towards currency because your plane isn't technically IFR legal, even though you flew them with a safety pilot under VFR?

Don't read into what isn't there.

You got me confused with that one. What reg did you read into to require a current VOR check when flying a GPS approach?

 

[EdFred]

You got me confused with that one. What reg did you read into to require a current VOR check when flying a GPS approach?

*I'm* not reading into any regs. I was addressing the posters who were saying if you can't fly the approach under IFR/with the correct equipment you can't log it for currency.

I was offering another absurd scenario to see if makes anyone use their head. Because I bet practice approaches have been logged and flown without the 30 day check.

 

[AustinPilot]

You guys are thinking about it a little backwards. The safety pilot rule is an exception to normal operation and is clearly spelled out to allow you to regain/maintain currency. Otherwise you have to follow all the rules and regs when executing SIDs, STARs, and IAPs. That is all defined in Part 97 and extends to scores of technical Advisory Circulars expounding on things like RNP, equipment TSOs, etc. Hence the existence of "IFR-certified" planes.

The question isn't "where does it prohibit it?" but rather "where does it provide an exception for it?" In other words, why should you call it an "instrument approach" under VFR if it would not be a legally-executed approach under IFR?

And FWIW you actually don't need a VOR check if you will not be using it for navigation...

 

[JimNtexas]

I sometimes do practice 'ipad approaches' in VMC under the hood with a safety pilot, which I log for currency. I do this because I've had electrical failures, one in particular that happened night IMC before I had a gps.

I'm practice flying a published approach against the day that I might have to depend on my iPad to get me down. Which would of course be 100% legal since I would certainly do in the future as I did that night in question, which is immediately use the E-word.

 

[Palmpilot]

You guys are thinking about it a little backwards. The safety pilot rule is an exception to normal operation and is clearly spelled out to allow you to regain/maintain currency. Otherwise you have to follow all the rules and regs when executing SIDs, STARs, and IAPs. That is all defined in Part 97 and extends to scores of technical Advisory Circulars expounding on things like RNP, equipment TSOs, etc. Hence the existence of "IFR-certified" planes.

The question isn't "where does it prohibit it?" but rather "where does it provide an exception for it?"

The equipment required is specified in the approach procedures, which are incorporated into Part 97 by reference. As the regulations are written, it appears that the approach procedures are only legally binding because 91.175(a) states that they must be used. But notice that 91.175 is in the section entitled "INSTRUMENT FLIGHT RULES." That means that nothing in 91.175, and therefore nothing in the approach procedures, is legally binding when you are operating under visual flight rules. So, for example, you could not be sanctioned for busting minimums when an approach is conducted under visual flight rules, nor could you be sanctioned for using non-certified equipment.

Note also that 61.51 and 61.57 are silent on the subject of whether equipment used to meet instrument currency requirements in an aircraft must be certified.

 

[midlifeflyer]

*I'm* not reading into any regs. I was addressing the posters who were saying if you can't fly the approach under IFR/with the correct equipment you can't log it for currency.

I was offering another absurd scenario to see if makes anyone use their head. Because I bet practice approaches have been logged and flown without the 30 day check.

I think I got the intent. But I'm not sure how flying an approach with uncertified equipment is analogous to flying one with certified and current equipment. Unless I misread it entirely (possible), it dealt with flying a GPS approach with a certified GPS with a current database.

you haven't done a VOR check in your plane in the past 30 days, but the GPS database is up to date, does that mean any GPS approaches you fly aren't counted towards currency because your plane isn't technically IFR legal, even though you flew them with a safety pilot under VFR?

There's nothing that even remotely requires a VOR check when using only GPS for navigation, even when flying for real under IFR. You are "technically legal" for IFR without the VOR check.

Not so sure not logging an approach that is flown with an ipad falls into the absurd" category, but I think your scenario works fear better if it discusses flying a VOR approach without the 30 day check.

What I've mostly noticed in this thread, though, is that most of the arguments (not yours) have seemed to center on the value of doing ipad approaches. That really has nothing to do with whether it is loggable under the rules for currency.

What I would point to is ASR type assistance for a published approach, which I'm pretty comfortable is loggable for currency (which is why the currency reg also requires navaid interception and tracking). If one may log a published approach with no navigation equipment at all, why not with uncertified equipment? But that's just a thought, not necessarily THE answer.

 

[Palmpilot]

I think I got the intent. But I'm not sure how flying an approach with uncertified equipment is analogous to flying one with certified and current equipment. Unless I misread it entirely (possible), it dealt with flying a GPS approach with a certified GPS with a current database. There's nothing that even remotely requires a VOR check when using only GPS for navigation, even when flying for real under IFR.

Not so sure not logging an approach that is flown with an ipad falls into the absurd" category, but I think your scenario works fear better if it discusses flying a VOR approach without the 30 day check.

What I've mostly noticed in this thread, though, is that most of the arguments (not yours) have seemed to center on the value of doing ipad approaches. That really has nothing to do with whether it is loggable under the rules for currency.

What I would point to is ASR type assistance for a published approach, which I'm pretty comfortable is loggable for currency (which is why the currency reg also requires navaid interception and tracking). If one may log a published approach with no navigation equipment at all, why not with uncertified equipment? But that's just a thought, not necessarily THE answer.

I suspect that the arguments on both sides fall into the category of plausibility arguments (except mine, of course ).

 

[midlifeflyer]

I suspect that the arguments on both sides fall into the category of plausibility arguments (except mine, of course ).

Of course. To be sure some address the required equipment issue directly but others seem to be in the "it's a good idea to fly an emergency procedure so I should be able to log it as a countable approach" category, which could arguably be used to justify logging "roll your own" approaches too. (Uh oh.....)

 

[EdFred]

I think I got the intent. But I'm not sure how flying an approach with uncertified equipment is analogous to flying one with certified and current equipment. Unless I misread it entirely (possible), it dealt with flying a GPS approach with a certified GPS with a current database.

There's nothing that even remotely requires a VOR check when using only GPS for navigation, even when flying for real under IFR. You are "technically legal" for IFR without the VOR check.

Not so sure not logging an approach that is flown with an ipad falls into the absurd" category, but I think your scenario works fear better if it discusses flying a VOR approach without the 30 day check.

What I've mostly noticed in this thread, though, is that most of the arguments (not yours) have seemed to center on the value of doing ipad approaches. That really has nothing to do with whether it is loggable under the rules for currency.

What I would point to is ASR type assistance for a published approach, which I'm pretty comfortable is loggable for currency (which is why the currency reg also requires navaid interception and tracking). If one may log a published approach with no navigation equipment at all, why not with uncertified equipment? But that's just a thought, not necessarily THE answer.

Did something change in policy, because I thought for sure that non-WASS GPS units had to have a back up means of navigation - generally the VOR system. Which would require the VOR check before flying under IFR.

 

[midlifeflyer]

Did something change in policy, because I thought for sure that non-WASS GPS units had to have a back up means of navigation - generally the VOR system. Which would require the VOR check before flying under IFR.

I guess it has been so long that I forget there are still non-WAAS units out there . Point taken.

 

[EdFred]

I guess it has been so long that I forget there are still non-WAAS units out there . Point taken.

Yep, I'm still flying with a straight 430.

 

[AustinPilot]

The equipment required is specified in the approach procedures, which are incorporated into Part 97 by reference. As the regulations are written, it appears that the approach procedures are only legally binding because 91.175(a) states that they must be used. But notice that 91.175 is in the section entitled "INSTRUMENT FLIGHT RULES." That means that nothing in 91.175, and therefore nothing in the approach procedures, is legally binding when you are operating under visual flight rules. So, for example, you could not be sanctioned for busting minimums when an approach is conducted under visual flight rules, nor could you be sanctioned for using non-certified equipment.

Sure but there's a difference between what's legal and what is an actual instrument approach per the regs. By this reasoning you can make up your own approach, shoot it, and log it.

Note also that 61.51 and 61.57 are silent on the subject of whether equipment used to meet instrument currency requirements in an aircraft must be certified.

Part 61 defines an instrument approach as that which conforms with Part 97.

In the end I guess it's one of those academic things where you're not likely to get caught. I would rather just avoid such gray areas in my logbook.

 

[midlifeflyer]

Part 61 defines an instrument approach as that which conforms with Part 97.

...and Part 97 discusses procedures and how they are created, with reference to terms and other criteria. How many times is there is a reference to any kind of equipment in that Part?

So, are you also saying a practice (or, for that matter, real) ASR-assisted approach after an electrical failure is also not loggable for currency because you aren't using a certified nav radio?

Really an enjoyable thread

 

[Gucci Pilot]

Here is the question I would ask myself: "If I can't legally use the ipad/stratus combo out in the system, why would I be able to use it to stay current?" Now lets say you get in an accident on an IFR flight plan and they want to check your logbook for currency, is anyone really going to be able to tell if you were using the ILS CDI or your ipad, probably not. But if you are literally down to having to use those approaches to count for currency you might as well not even do them at all and just log em. I have heard this float around the FBO numerous times: "Fly what you can, log what you need"

In a nutshell: I wouldn't log them. I am not demonstrating my true instrument flying abilities using it. If the FAA is making me stay current for my own safety and the safety of other, I am going to do it the hard way. Don't cheat yourself.

 

[Palmpilot]

Sure but there's a difference between what's legal and what is an actual instrument approach per the regs. By this reasoning you can make up your own approach, shoot it, and log it.

That's prevented by your next sentence:

Part 61 defines an instrument approach as that which conforms with Part 97.

61.1 says that an instrument approach is a procedure that is defined in Part 97. In answer to Mark's rhetorical question, Part 97 does not say that equipment used has to be certified. The closest I can find to a regulatory requirement for that is in section 91.205(d), which says that navigational equipment must be suitable for the route to be flown. But here again, notice the title of that section: "Instrument flight rules." And notice that the very first sentence of that section starts out with the words, "For IFR flight," thus rendering the entirety of 91.205(d) inapplicable for flights conducted under visual flight rules.

In the end I guess it's one of those academic things where you're not likely to get caught.

As explained above, there's nothing to get "caught" for.

I would rather just avoid such gray areas in my logbook.

I certainly don't have any quarrel with your choosing not to log something.

 

[AustinPilot]

It's difficult to wade through the dozens of ACs and other docs out there to get to a clear-cut legal answer, but the AIM does offer this:

Visual flight rules (VFR) and hand−held GPS systems are not authorized for IFR navigation, instrument approaches, or as a principal instrument flight reference. During IFR operations they may be considered only as an aid to situational awareness.

Read that how you will but it does say instrument approaches are not authorized with non-certified GPS devices. The AIM also goes into all the equipment certification requirements to fly such approaches under IFR, if you're interested.

 

[Palmpilot]

It's difficult to wade through the dozens of ACs and other docs out there to get to a clear-cut legal answer, but the AIM does offer this:

Visual flight rules (VFR) and hand−held GPS systems are not authorized for IFR navigation, instrument approaches, or as a principal instrument flight reference. During IFR operations they may be considered only as an aid to situational awareness.

Read that how you will but it does say instrument approaches are not authorized with non-certified GPS devices. The AIM also goes into all the equipment certification requirements to fly such approaches under IFR, if you're interested.

Notice the heading of the section that quote is taken from (1-1-18b2): "IFR Use of GPS."

Again, nothing in that section is applicable to operations conducted under visual flight rules.

We can't ignore context.

 

[AustinPilot]

So let's take the thought experiment a step further. Attitude indicators are not required for VFR flight. Would you fly/log an instrument approach under the hood without any attitude reference? What if you had a non-certified replacement (Stratus)? Why or why not?

 

[Henning]

Here is the question I would ask myself: "If I can't legally use the ipad/stratus combo out in the system, why would I be able to use it to stay current?" Now lets say you get in an accident on an IFR flight plan and they want to check your logbook for currency, is anyone really going to be able to tell if you were using the ILS CDI or your ipad, probably not. But if you are literally down to having to use those approaches to count for currency you might as well not even do them at all and just log em. I have heard this float around the FBO numerous times: "Fly what you can, log what you need"

In a nutshell: I wouldn't log them. I am not demonstrating my true instrument flying abilities using it. If the FAA is making me stay current for my own safety and the safety of other, I am going to do it the hard way. Don't cheat yourself.

That my friends is the long and the short of it. It's your life, as long as you're not flying commercially, it's all up to you. You will gain the rewards of your efforts, or lack thereof.