Logging approaches [Archive]

Ron Garrison

January 30th 04, 01:34 AM

Good advice, thanks! Hand flying that ILS while having to look out for the
multiple VFR targets did more to keep me sharp than flying a coupled
autopilot approach to minimums in solid IMC from before the IAF.

The purpose of the question was to get a better understanding of what the
rules are, knowing that what is legal and what is safe are two different
things. Flying one ILS approach through a calm, thick overcast layer each
month, with one hold thrown in every six months, would keep me perfectly
legal, but the only thing that it would give me real confidence in is my
ability to fly an ILS on a calm day. I am still sorting out in my own mind
the difference between "flight in IFR conditions", which is clearly defined
as conditions below VMC minimums, and "flight by reference to instruments",
which is what gets logged and is vaguely defined at best.

"Roy Smith" > wrote in message
...
> In article >,
> "Ron Garrison" > wrote:
>
> > I had a 'first' last week, and I am looking for other peoples thoughts
on
> > this one. It was my first (I believe) loggable instrument approach in
what
> > was legally VMC. I was flying from the San Francisco bay area down to
> > Burbank. The reported conditions were sky clear, visibility 4 miles in
haze,
> > with the ILS 8 in use, no mention of visual approaches. The visibility
part
> > was right, from about 4,000 feet down to the surface there was about 4
miles
> > visibility based on when the runway appeared. I could see the ground
below
> > just fine the whole time, but looking forward there was no visible
horizon.
> >
> > I considered the approach loggable because:
> > 1) navigation aids were required to find the airport
> > 2) There was no visible horizon so the attitude indicator was
required
> > to identify and maintain the desired aircraft attitude.
> >
> > Any differing opinions on this one?
> >
> >
>
> I can only repeat something I've said before. You can lie to your
> instructor, you can lie to the FAA, and you can lie to your logbook.
> But you can't lie to yourself.
>
> Do you honestly feel the experience of flying the approach was such that
> it helped keep your instrument skills sharp? If the answer is "yes",
> then go ahead and log it with a clear conscience.

Jay Somerset

January 30th 04, 02:57 AM

On Fri, 30 Jan 2004 00:49:38 GMT, "Steven P. McNicoll"
> wrote:

>
> "Ron Garrison" > wrote in message
> ...
> >
> > I had a 'first' last week, and I am looking for other peoples thoughts on
> > this one. It was my first (I believe) loggable instrument approach in what
> > was legally VMC. I was flying from the San Francisco bay area down to
> > Burbank. The reported conditions were sky clear, visibility 4 miles in
> haze,
> > with the ILS 8 in use, no mention of visual approaches. The visibility
> part
> > was right, from about 4,000 feet down to the surface there was about 4
> miles
> > visibility based on when the runway appeared. I could see the ground below
> > just fine the whole time, but looking forward there was no visible
> horizon.
> >
> > I considered the approach loggable because:
> > 1) navigation aids were required to find the airport
> > 2) There was no visible horizon so the attitude indicator was required
> > to identify and maintain the desired aircraft attitude.
> >
> > Any differing opinions on this one?
> >
>
> Could you have landed at that field without flying the approach? That's the
> test I use.

An excellent, common-sense answer!!!

>

Ross Oliver

January 30th 04, 08:24 AM

Ron Garrison > wrote:
>I could see the ground below
>just fine the whole time, but looking forward there was no visible horizon.
>
>I considered the approach loggable because:
> 1) navigation aids were required to find the airport
> 2) There was no visible horizon so the attitude indicator was required
>to identify and maintain the desired aircraft attitude.
>
>Any differing opinions on this one?

Well, I believe the FARs differ:

FAR 61.51(g) Logging instrument flight time
(1) A person may log instrument time only for that flight time when
the person operates the aircraft solely by reference to instruments
under actual or simulated instrument conditions.

IMHO, the key word is "solely." Since you say: "I could see the ground
below just fine the whole time," you were not operating solely by reference
to instruments, and therefore the flight time and approach cannot legally
be counted toward instrument currency.

Setting aside the legalities, from a practical standpoint:

Roy Smith > wrote:
>Do you honestly feel the experience of flying the approach was such that
>it helped keep your instrument skills sharp? If the answer is "yes",
>then go ahead and log it with a clear conscience.

I would apply a more stringent test: if you flew six approaches ONLY
in these conditions, would you feel your instrument skills would be
sufficiently current to fly in your personal IMC minimums?

Ross Oliver

Gary Drescher

January 30th 04, 12:23 PM

"Ross Oliver" > wrote in message
...
> Ron Garrison > wrote:
> >I could see the ground below
> >just fine the whole time, but looking forward there was no visible
horizon.
> >
> >I considered the approach loggable because:
> > 1) navigation aids were required to find the airport
> > 2) There was no visible horizon so the attitude indicator was
required
> >to identify and maintain the desired aircraft attitude.
> >
> >Any differing opinions on this one?
>
> Well, I believe the FARs differ:
>
> FAR 61.51(g) Logging instrument flight time
> (1) A person may log instrument time only for that flight time when
> the person operates the aircraft solely by reference to instruments
> under actual or simulated instrument conditions.
>
> IMHO, the key word is "solely." Since you say: "I could see the ground
> below just fine the whole time," you were not operating solely by
reference
> to instruments, and therefore the flight time and approach cannot legally
> be counted toward instrument currency.

Seeing the ground doesn't necessarily mean you're operating the aircraft by
reference to the ground at all. You could fly an approach with visibility
of, say, 0.5 sm (and therefore be solidly in IMC), and still see be able to
the ground the whole time. But you wouldn't necessarily be using that view
to aviate or navigate.

--Gary

> Setting aside the legalities, from a practical standpoint:
>
> Roy Smith > wrote:
> >Do you honestly feel the experience of flying the approach was such that
> >it helped keep your instrument skills sharp? If the answer is "yes",
> >then go ahead and log it with a clear conscience.
>
> I would apply a more stringent test: if you flew six approaches ONLY
> in these conditions, would you feel your instrument skills would be
> sufficiently current to fly in your personal IMC minimums?
>
>
> Ross Oliver

John T

January 30th 04, 03:09 PM

"Gary Drescher" > wrote in message
news:K0sSb.143265$5V2.761500@attbi_s53
>
> Seeing the ground doesn't necessarily mean you're operating the
> aircraft by reference to the ground at all. You could fly an
> approach with visibility of, say, 0.5 sm (and therefore be solidly in
> IMC), and still see be able to the ground the whole time. But you
> wouldn't necessarily be using that view to aviate or navigate.

Not to mention that this thread is about logging approaches - not IMC time.
There is a difference.

--
John T
http://tknowlogy.com/TknoFlyer
http://www.pocketgear.com/products_search.asp?developerid=4415
____________________

Peter R.

January 30th 04, 04:17 PM

Gary Drescher ) wrote:

> Seeing the ground doesn't necessarily mean you're operating the aircraft by
> reference to the ground at all. You could fly an approach with visibility
> of, say, 0.5 sm (and therefore be solidly in IMC), and still see be able to
> the ground the whole time. But you wouldn't necessarily be using that view
> to aviate or navigate.

I agree. Last week I was practicing approaches in moderate lake effect
snow where the RVR fluctuated between 1800 and 5000, yet I could see the
ground directly below the aircraft.

Not sure how seeing the ground below is relevant to logging an approach,
unless, of course, I am flying in that direction. :)

--
Peter

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David Brooks

January 30th 04, 05:30 PM

"Ron Garrison" > wrote in message
...
> Good advice, thanks! Hand flying that ILS while having to look out for the
> multiple VFR targets did more to keep me sharp than flying a coupled
> autopilot approach to minimums in solid IMC from before the IAF.
>
> The purpose of the question was to get a better understanding of what the
> rules are, knowing that what is legal and what is safe are two different
> things.

At least on this forum, I don't think it has been settled what the rules
are. The question at its extreme is whether you have to be in IMC all the
way to minimums. The most commonly quoted response is Lynch's FAQ, but even
though he seems to be trying to say you do have to go to minimums (making it
a practical impossibility to find a loggable IMC approach), he seems
determined to be vague by answering a question that wasn't asked.

I don't have enough experience to opine, but "do you honestly feel it was
valuable" makes sense. Another common answer seems to be that you should log
it if you are still solid at FAF.

-- David Brooks

January 31st 04, 07:11 PM

I believe the requirement for logging the time is conditional upon the
following phrase. "...maneuvering the aircraft solely by reference to
instruments..." If you have ever had an experience flying over water or in
the mountains with a high overcast, moonless night, there might be a
reported visibility from stations of 50 miles. Trust me, your maneuvering
soley by reference to your instruments, and every bit of it is loggable as
actual.
"Peter R." > wrote in message
...
> Gary Drescher ) wrote:
>
> > Seeing the ground doesn't necessarily mean you're operating the aircraft
by
> > reference to the ground at all. You could fly an approach with
visibility
> > of, say, 0.5 sm (and therefore be solidly in IMC), and still see be able
to
> > the ground the whole time. But you wouldn't necessarily be using that
view
> > to aviate or navigate.
>
> I agree. Last week I was practicing approaches in moderate lake effect
> snow where the RVR fluctuated between 1800 and 5000, yet I could see the
> ground directly below the aircraft.
>
> Not sure how seeing the ground below is relevant to logging an approach,
> unless, of course, I am flying in that direction. :)
>
> --
> Peter
>
>
>
>
>
>
>
>
>
>
>
>
> ----== Posted via Newsfeed.Com - Unlimited-Uncensored-Secure Usenet
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Newsgroups
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Steven P. McNicoll

January 31st 04, 07:28 PM

"sn" > wrote in message ...
>
> I believe the requirement for logging the time is conditional upon the
> following phrase. "...maneuvering the aircraft solely by reference to
> instruments..." If you have ever had an experience flying over water or in
> the mountains with a high overcast, moonless night, there might be a
> reported visibility from stations of 50 miles. Trust me, your maneuvering
> soley by reference to your instruments, and every bit of it is loggable as
> actual.
>

Fine, but the complete phrase is "A person may log instrument time only for
that flight time when the person operates the aircraft solely by reference
to instruments under actual or simulated instrument flight conditions." If
you're not in actual instrument flight conditions or using a vision
restricting device, how can you log any instrument time?

Teacherjh

January 31st 04, 08:40 PM

>>
If you have ever had an experience flying over water or in
the mountains with a high overcast, moonless night, there might be a
reported visibility from stations of 50 miles. Trust me, your maneuvering
soley by reference to your instruments, and every bit of it is loggable as
actual.
<<

Even if you are on a VFR flight plan and are not instrument rated?

Jose

--
(for Email, make the obvious changes in my address)

Hilton

February 1st 04, 06:29 AM

Teacherjh wrote:
>
> If you have ever had an experience flying over water or in
> the mountains with a high overcast, moonless night, there might be a
> reported visibility from stations of 50 miles. Trust me, your maneuvering
> soley by reference to your instruments, and every bit of it is loggable as
> actual.
> <<
>
> Even if you are on a VFR flight plan and are not instrument rated?

The FARs do not specify 'must be on an IFR flight plan', nor do they specify
that you need to be instrument rated to log actual.

Hilton

Andrew Sarangan

February 1st 04, 03:23 PM

I am quite familiar with the situation you are describing. I used to
encounter it all the time in New Mexico. But I do not believe that
such flights were loggable instrument flights. If you are flying
solely by reference to instruments who is keeping you separated from
other aircraft? I agree that those flights require greater use of
instruments than a normal VFR flight, but I don't see how it qualifies
as sole reference to instruments. Sole implies 100% use of instruments
without any outside visuals.

"sn" > wrote in message >...
> I believe the requirement for logging the time is conditional upon the
> following phrase. "...maneuvering the aircraft solely by reference to
> instruments..." If you have ever had an experience flying over water or in
> the mountains with a high overcast, moonless night, there might be a
> reported visibility from stations of 50 miles. Trust me, your maneuvering
> soley by reference to your instruments, and every bit of it is loggable as
> actual.
> "Peter R." > wrote in message
> ...
> > Gary Drescher ) wrote:
> >
> > > Seeing the ground doesn't necessarily mean you're operating the aircraft
> by
> > > reference to the ground at all. You could fly an approach with
> visibility
> > > of, say, 0.5 sm (and therefore be solidly in IMC), and still see be able
> to
> > > the ground the whole time. But you wouldn't necessarily be using that
> view
> > > to aviate or navigate.
> >
> > I agree. Last week I was practicing approaches in moderate lake effect
> > snow where the RVR fluctuated between 1800 and 5000, yet I could see the
> > ground directly below the aircraft.
> >
> > Not sure how seeing the ground below is relevant to logging an approach,
> > unless, of course, I am flying in that direction. :)
> >
> > --
> > Peter
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> >
> > ----== Posted via Newsfeed.Com - Unlimited-Uncensored-Secure Usenet
> News==----
> > http://www.newsfeed.com The #1 Newsgroup Service in the World! >100,000
> Newsgroups
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> =---

Steven P. McNicoll

February 1st 04, 03:34 PM

"Andrew Sarangan" > wrote in message
om...
>
> I am quite familiar with the situation you are describing. I used to
> encounter it all the time in New Mexico. But I do not believe that
> such flights were loggable instrument flights. If you are flying
> solely by reference to instruments who is keeping you separated from
> other aircraft?
>

You are. See and avoid.

Roy Smith

February 1st 04, 04:53 PM

In article >,
(Andrew Sarangan) wrote:
> I am quite familiar with the situation you are describing. I used to
> encounter it all the time in New Mexico. But I do not believe that
> such flights were loggable instrument flights. If you are flying
> solely by reference to instruments who is keeping you separated from
> other aircraft?

Inability to see any horizon or other outside visual attitude reference
does not in any way affect your ability to separate yourself from other
aircraft visually.

I suppose the most extreme example would be military pilots who fly
formation in IMC. Although, one could make the argument that even if
you're in IMC, if you're formed up on your lead's position lights,
you're flying by visual reference and therefore cannot log the time as
instrument time. Oh what silly webs we weave when we try to
language-laywer the rules to death :-)

John R Weiss

February 1st 04, 06:26 PM

"Hilton" > wrote...
>> Even if you are on a VFR flight plan and are not instrument rated?
>
> The FARs do not specify 'must be on an IFR flight plan', nor do they specify
> that you need to be instrument rated to log actual.

Indeed, you can legally fly under VFR (even without any flight plan at all) as
long as the weather is as prescribed in 91.155. There is no mention of a
visible horizon...

OTOH, you may find yourself at odds with 91.13(a) or 91.113(b) if you have not
sufficiently prepared for the flight or don't have enough experience to safely
fly in the conditions...

John R. Copeland

February 1st 04, 07:47 PM

Similarly if you are in uncontrolled airspace.
There's less of that than there used to be, though.
---JRC---

"John R Weiss" > wrote in message =
news:OxbTb.72923$U%5.402002@attbi_s03...
>=20
>=20
> Indeed, you can legally fly under VFR (even without any flight plan at =
all) as
> long as the weather is as prescribed in 91.155. =20
>=20
>

Barry

February 1st 04, 09:35 PM

>> Indeed, you can legally fly under VFR (even without any flight plan at all)
>> as long as the weather is as prescribed in 91.155.

> Similarly if you are in uncontrolled airspace.
> There's less of that than there used to be, though.

Even in uncontrolled (Class G) airspace, VFR is permitted only if the weather
meets the requirements of 91.155. If the weather is below VFR minimums, you
can fly IFR without a clearance, but this is still IFR and must be in
accordance with the appropriate rules of Part 91, including fuel reserve,
cruising altitude, etc.

Barry

Hilton

February 1st 04, 11:27 PM

John,

The important point to note is that we should not try 'mix' FARs. If you
want to know about logging, go look in the logging FAR. All others such as
91.155, 91.13, etc are completely irrelavent.

The FAR says: "A person may log instrument time only for that flight time
when the person operates the aircraft solely by reference to instruments
under actual or simulated instrument flight conditions."

For example, let's say that a Private non-IR pilot is flying over an
undercast. His/her engine fails completely and he/she glides through the
clouds to a safe landing. The pilot should log that actual time because the
'logging' FAR says the pilot can. IFR, VFR, reckless, cloud distances etc
etc etc has absolutely no bearing on the issue.

Hilton

John R Weiss wrote:
> "Hilton" > wrote...
> >> Even if you are on a VFR flight plan and are not instrument rated?
> >
> > The FARs do not specify 'must be on an IFR flight plan', nor do they
specify
> > that you need to be instrument rated to log actual.
>
> Indeed, you can legally fly under VFR (even without any flight plan at
all) as
> long as the weather is as prescribed in 91.155. There is no mention of a
> visible horizon...
>
> OTOH, you may find yourself at odds with 91.13(a) or 91.113(b) if you have
not
> sufficiently prepared for the flight or don't have enough experience to
safely
> fly in the conditions...
>

Eclipsme

February 2nd 04, 12:01 PM

my understanding is that all the flight time above an undercast is logable
as IFR, because there is no natural horizon. You must use the Gyros to stay
level. An undercast isn't always level!

Harvey

"Hilton" > wrote in message
ink.net...
> John,
>
> The important point to note is that we should not try 'mix' FARs. If you
> want to know about logging, go look in the logging FAR. All others such
as
> 91.155, 91.13, etc are completely irrelavent.
>
> The FAR says: "A person may log instrument time only for that flight time
> when the person operates the aircraft solely by reference to instruments
> under actual or simulated instrument flight conditions."
>
> For example, let's say that a Private non-IR pilot is flying over an
> undercast. His/her engine fails completely and he/she glides through the
> clouds to a safe landing. The pilot should log that actual time because
the
> 'logging' FAR says the pilot can. IFR, VFR, reckless, cloud distances etc
> etc etc has absolutely no bearing on the issue.
>
> Hilton
>
>
> John R Weiss wrote:
> > "Hilton" > wrote...
> > >> Even if you are on a VFR flight plan and are not instrument rated?
> > >
> > > The FARs do not specify 'must be on an IFR flight plan', nor do they
> specify
> > > that you need to be instrument rated to log actual.
> >
> > Indeed, you can legally fly under VFR (even without any flight plan at
> all) as
> > long as the weather is as prescribed in 91.155. There is no mention of
a
> > visible horizon...
> >
> > OTOH, you may find yourself at odds with 91.13(a) or 91.113(b) if you
have
> not
> > sufficiently prepared for the flight or don't have enough experience to
> safely
> > fly in the conditions...
> >
>
>

Steven P. McNicoll

February 2nd 04, 12:28 PM

"Eclipsme" > wrote in message
.. .
>
> my understanding is that all the flight time above an undercast is logable
> as IFR, because there is no natural horizon. You must use the Gyros to
stay
> level. An undercast isn't always level!
>

Are you in actual or simulated instrument flight conditions when you're
above an undercast?

Steven P. McNicoll

February 2nd 04, 05:21 PM

"Hilton" > wrote in message
ink.net...
>
> The FARs do not specify 'must be on an IFR flight plan', nor do they
> specify that you need to be instrument rated to log actual.
>

But they do specify that it must be actual or simulated instrument flight
conditions.

Steven P. McNicoll

February 2nd 04, 05:23 PM

"John R. Copeland" > wrote in message
.. .
>
> Similarly if you are in uncontrolled airspace.
>

In uncontrolled airspace you can even fly under IFR without any flight plan
or clearance at all in weather less than that prescribed in FAR 91.155.

Ron Natalie

February 2nd 04, 05:38 PM

"Teacherjh" > wrote in message ...
> >>
> If you have ever had an experience flying over water or in
> the mountains with a high overcast, moonless night, there might be a
> reported visibility from stations of 50 miles. Trust me, your maneuvering
> soley by reference to your instruments, and every bit of it is loggable as
> actual.
> <<
>
> Even if you are on a VFR flight plan and are not instrument rated?
>
Absolutely! How else would you get the instrument time needed to obtain
the rating?

What sort of flight plan or even flight rules the operation is conducted under
has never made a difference in logging.

The one bizarre twist is that the FAA even allows you to log instruments while
operating VFR. It can be legal VFR and be bad enough to have to fly by
instruments. The FAA allows this to count.

Ron Natalie

February 2nd 04, 05:40 PM

"Barry" > wrote in message ...

> Even in uncontrolled (Class G) airspace, VFR is permitted only if the weather
> meets the requirements of 91.155. If the weather is below VFR minimums, you
> can fly IFR without a clearance, but this is still IFR and must be in
> accordance with the appropriate rules of Part 91, including fuel reserve,
> cruising altitude, etc.

Yes, but immaterial. The weather can still be legal VFR, but bad enough to cause
yout to fly solely by instruments. The FAA has affirmed this is legally logable as
instrument time.

Teacherjh

February 2nd 04, 07:24 PM

>>
It can be legal VFR and be bad enough to have to fly by
instruments. The FAA allows this to count.
<<

Where does the FAA say that this counts?

Jose

--
(for Email, make the obvious changes in my address)

John R Weiss

February 2nd 04, 07:52 PM

"Steven P. McNicoll" > wrote...
>
> Are you in actual or simulated instrument flight conditions when you're
> above an undercast?

If you can't maintain level flight without reference to instruments, because
there is no discernible horizon for outside reference, you are in actual
instrument flight conditions.

Ron Natalie

February 2nd 04, 10:44 PM

Ron Natalie

February 2nd 04, 10:47 PM

"Teacherjh" > wrote in message ...
> >>
> It can be legal VFR and be bad enough to have to fly by
> instruments. The FAA allows this to count.
> <<
>
> Where does the FAA say that this counts?
>

It is what the regs literally say. All they say is you have to be in instrument conditions. Doesn't
say anything about flight rules. This was affirmed in the following opinion by FAA counsel.

To answer your first question, actual instrument conditions may occur in the case you described a moonless night over the ocean
with no discernible horizon, if use of the instruments is necessary to maintain adequate control over the aircraft. The
determination as to whether flight by reference to instruments is necessary is somewhat subjective and based in part on the sound
judgment of the pilot. Note that, under Section 61.51(b)(3), the pilot must log the conditions of the flight. The log should include
the reasons for determining that the flight was under actual instrument conditions in case the pilot later would be called on to
prove that the actual instrument flight time logged was legitimate

Judah

February 3rd 04, 01:59 AM

"Ron Natalie" > wrote in
:

> Yes, but immaterial. The weather can still be legal VFR, but bad
> enough to cause yout to fly solely by instruments. The FAA has
> affirmed this is legally logable as instrument time.

Where'd they do that?

Hilton

February 3rd 04, 05:05 AM

Steven P. McNicoll wrote:
>
> Hilton wrote:
> >
> > The FARs do not specify 'must be on an IFR flight plan', nor do they
> > specify that you need to be instrument rated to log actual.
> >
>
> But they do specify that it must be actual or simulated instrument flight
> conditions.

That was exactly my point.

Hilton

Casey Wilson

February 3rd 04, 05:38 PM

> > But they do specify that it must be actual or simulated instrument
flight
> > conditions.

So what qualifies the approach as being in actual? Santa Monica (KSMO),
California, has more often than not a deck of clouds over it right on the
Pacific Coast. the circling minimum for the VOR or GPS-A approach is 1120
and the MAP is 6.7 NM from the FAF. Minimum altitude at the FAF is 2600.
(1) If on the descent course you enter the cloud deck at 3,500 feet and
drop out of it at 2700 one mile before the FAF, does the approach count?
(2) ....drop out of it at 2500 feet one mile past the FAF......?

Discussing this in another forum, one camp says yes to both, another no
to (1) and yes to (2), and still another says you have to go down to
minimums. It seems to me the third group will never have an "actual"
approach in their logbook.

Steven P. McNicoll

February 3rd 04, 05:49 PM

"John R Weiss" > wrote in message
news:NTxTb.164149$5V2.843814@attbi_s53...
>
> If you can't maintain level flight without reference to instruments,
> because there is no discernible horizon for outside reference, you
> are in actual instrument flight conditions.
>

How can that be? IFR conditions are weather conditions below the minimum
for flight under visual flight rules. You can easily have weather
conditions well above the minimum for flight under visual flight rules above
an undercast.

Steven P. McNicoll

February 3rd 04, 06:21 PM

"Ron Natalie" > wrote in message
. ..
>
> It's what the rules literally say. Affirmed by FAA legal counsel:
>

The rule does not say that. The rule says, ""A person may log instrument
time only for that flight time when the person operates the aircraft solely
by reference
to instruments under actual or simulated instrument flight conditions." So,
literally, it must be below VFR minimums or you must wear a hood.

PaulaJay1

February 3rd 04, 06:23 PM

In article >, "Casey Wilson"
> writes:

> So what qualifies the approach as being in actual?

This whole thread is missing the real point. i think that the 90% reason to
log approaches is for your own information. You can look back a few months and
"evaluate" your readyness to fly IFR. Yea, I know that there laws that are to
be met but.... If you do 12 approaches(real or other) in the 6 months you will
be better prepared and if one didn't quite count, so what. You are not
satisfying a law, you are remaining capable of a skill once learned.

Chuck

Ron Natalie

February 3rd 04, 06:28 PM

"Steven P. McNicoll" > wrote in message ink.net...
>
> "Ron Natalie" > wrote in message
> . ..
> >
> > It's what the rules literally say. Affirmed by FAA legal counsel:
> >
>
> The rule does not say that. The rule says, ""A person may log instrument
> time only for that flight time when the person operates the aircraft solely
> by reference
> to instruments under actual or simulated instrument flight conditions." So,
> literally, it must be below VFR minimums or you must wear a hood.
>
It doesn't say anything about VFR minimums. The FAA affirms that there
are times when you can be technically above VFR minimums (not in the clouds
and sufficient visibility), but the horizon and the ground is obscured and those
qualify for actual instrument conditions, even though it's not bad enough to
require IFR.

Steven P. McNicoll

February 3rd 04, 06:29 PM

"Casey Wilson" > wrote in message
...
>
> So what qualifies the approach as being in actual? Santa Monica
> (KSMO), California, has more often than not a deck of clouds over it
> right on the Pacific Coast. the circling minimum for the VOR or GPS-A
> approach is 1120 and the MAP is 6.7 NM from the FAF. Minimum
> altitude at the FAF is 2600.
> (1) If on the descent course you enter the cloud deck at 3,500 feet
> and drop out of it at 2700 one mile before the FAF, does the approach
> count?
> (2) ....drop out of it at 2500 feet one mile past the FAF......?
>
> Discussing this in another forum, one camp says yes to both, another
> no to (1) and yes to (2), and still another says you have to go down to
> minimums. It seems to me the third group will never have an "actual"
> approach in their logbook.
>

What's the local MIA/MVA? If a descent to the minimum enroute altitude
leaves you in the clouds, then an IAP is required, even if the field is
reporting VFR conditions. If an approach is required how can it not be
logable?

Steven P. McNicoll

February 3rd 04, 06:31 PM

"Ron Natalie" > wrote in message
. ..
>
> "Teacherjh" > wrote in message
...
> > >>
> > It can be legal VFR and be bad enough to have to fly by
> > instruments. The FAA allows this to count.
> > <<
> >
> > Where does the FAA say that this counts?
> >
>
> It is what the regs literally say. All they say is you have to be in
> instrument conditions. Doesn't say anything about flight rules.
>

If you're in instrument conditions it's not legal VFR.

Ron Natalie

February 3rd 04, 06:34 PM

"Steven P. McNicoll" > wrote in message news:VNRTb.7809> > It is what the regs literally say. All
they say is you have to be in
> > instrument conditions. Doesn't say anything about flight rules.
> >
>
> If you're in instrument conditions it's not legal VFR.
>
Show me where it says that in the rules?

My interpretation of the FAA's interpretation is that instrument conditions just means
those that are necessitate operation by the instruments rather than requiring it to be less
than the VFR minimums.

Steven P. McNicoll

February 3rd 04, 06:40 PM

"Ron Natalie" > wrote in message
. ..
>
> Show me where it says that in the rules?
>

Title 14--Aeronautics and Space

CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

PART 1--DEFINITIONS AND ABBREVIATIONS

§ 1.1 General definitions.

IFR conditions means weather conditions below the minimum for flight under
visual flight rules.

>
> My interpretation of the FAA's interpretation is that instrument
conditions
> just means those that are necessitate operation by the instruments rather
> than requiring it to be less than the VFR minimums.
>

That interpretation is not consistent with the applicable regulations.

gpsposter

February 3rd 04, 07:02 PM

"Steven P. McNicoll" > wrote in
ink.net:

>
> "Ron Natalie" > wrote in message
> . ..
>>
>> Show me where it says that in the rules?
>>
>
> Title 14--Aeronautics and Space
>
> CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF
> TRANSPORTATION
>
> PART 1--DEFINITIONS AND ABBREVIATIONS
>
> § 1.1 General definitions.
>
> IFR conditions means weather conditions below the minimum for flight
> under visual flight rules.
>

'IFR conditions' and 'instrument conditions' are not necessarily the same
thing.

>
>>
>> My interpretation of the FAA's interpretation is that instrument
> conditions
>> just means those that are necessitate operation by the instruments
>> rather than requiring it to be less than the VFR minimums.
>>
>
> That interpretation is not consistent with the applicable regulations.
>
>

Steven P. McNicoll

February 3rd 04, 07:08 PM

"gpsposter" > wrote in message
...
>
> 'IFR conditions' and 'instrument conditions' are not necessarily the same
> thing.
>

How do they differ?

Tarver Engineering

February 3rd 04, 07:26 PM

"Ron Natalie" > wrote in message
. ..
>
> "Steven P. McNicoll" > wrote in message
news:VNRTb.7809> > It is what the regs literally say. All
> they say is you have to be in
> > > instrument conditions. Doesn't say anything about flight rules.
> > >
> >
> > If you're in instrument conditions it's not legal VFR.
> >
> Show me where it says that in the rules?
>
> My interpretation of the FAA's interpretation is that instrument
conditions just means
> those that are necessitate operation by the instruments rather than
requiring it to be less
> than the VFR minimums.

Sort of like Ron's interpreation of CFR 14 Part 21 that claimed "a homebuilt
is not an Experimental. :)
>

Ron Natalie

February 3rd 04, 09:10 PM

"Steven P. McNicoll" > wrote in message nk.net...
>
> "gpsposter" > wrote in message
> ...
> >
> > 'IFR conditions' and 'instrument conditions' are not necessarily the same
> > thing.
> >
>
> How do they differ?
>
>
As I said, there is no definition of instrument conditions in the rules. Hence the best
we can come up with is the legal counsel.

Your excessively pedantic nature can clearly see that they are different words.

Ron Natalie

February 3rd 04, 09:10 PM

"Tarver Engineering" > wrote in message ...
> Sort of like Ron's interpreation of CFR 14 Part 21 that claimed "a homebuilt
> is not an Experimental. :)
> >
>
I never said any such thing. Prove your allegations.

Tarver Engineering

February 3rd 04, 09:19 PM

"Ron Natalie" > wrote in message
. ..
>
> "Tarver Engineering" > wrote in message
...
> > Sort of like Ron's interpreation of CFR 14 Part 21 that claimed "a
homebuilt
> > is not an Experimental. :)
> > >
> >
> I never said any such thing. Prove your allegations.

You posted your ignorance to the "FAA form 337" thread at
rec.aviation.homebuilt.

Did you cancel you post, so you could lie now, Ron?

Your track record for understanding CFR 14 is zero for three, over the past
couple of weeks, Ron.

Rich

February 4th 04, 12:47 AM

Tarver Engineering wrote:
> "Ron Natalie" > wrote in message
> . ..
>
>>"Tarver Engineering" > wrote in message
>
> ...
>
>>>Sort of like Ron's interpreation of CFR 14 Part 21 that claimed "a
>
> homebuilt
>
>>>is not an Experimental. :)
>>>
>>I never said any such thing. Prove your allegations.
>
>
> You posted your ignorance to the "FAA form 337" thread at
> rec.aviation.homebuilt.
>
> Did you cancel you post, so you could lie now, Ron?
>
> Your track record for understanding CFR 14 is zero for three, over the past
> couple of weeks, Ron.
>
>

Don't wrestle with a pig, Ron.
The pig loves it, and all you will get is muddy.

Tarver Engineering

February 4th 04, 12:54 AM

"Rich" > wrote in message
...

>
> Don't wrestle with a pig, Ron.

I think Ron cancelling his errant posts tells volumes.

Saddam.net, eh?

Bwahahahahahaha

Ron Natalie

February 4th 04, 02:10 AM

"
> > I never said any such thing. Prove your allegations.
>
> You posted your ignorance to the "FAA form 337" thread at
> rec.aviation.homebuilt.
>
> Did you cancel you post, so you could lie now, Ron?

I didn't cancel any post. What I said, and it is still true, that 337's do not apply
to homebuilts (or any other experimental). It is you who have a mistaken view
of the rules. Part 43 does NOT apply to experimentals. It says this explicitly
in 43.1 (b), but you seem to not be able to understand that.

Travis Marlatte

February 4th 04, 03:11 AM

How many of you log specific minutes of a flight as instrument time when you
are flying in and out of clouds? (I count it all as instrument time)

If you settle into severe clear on top, do you stop timing instrument time?
(I sort of do. I guess as to how much of the flight was really instrument
time)

For those of you who log the whole flight as instrument time in the last
question, what if you cancel IFR when on top and re-file when you get to
your destination and need to descend through the clouds to get down?

For approaches, I think the rules force us into a corner. If there was a
minimum number of approach minutes that had to be logged in the previous 6
months. Then it would be easier to interpret that those 15 seconds
descending through the cloud deck was loggable but not the rest of the
approach.

However, since it is simply a yes or no for each approach, then I tend to
err in my favor. If I pass through a thin, thin, really thin layer and then
get cleared for a visual, I find it hard to log that as an instrument
approach. But, if I have to intercept, track, or maneuver while in the
clouds during any part of the approach, I consider that loggable.

Ron and Steven, this answers the question of what kind of approach is
loggable, how? If you're going to have a cat fight, at least change the
subject line.

--------------------------------
Travis

"Ron Natalie" > wrote in message
. ..
>
> "
> > > I never said any such thing. Prove your allegations.
> >
> > You posted your ignorance to the "FAA form 337" thread at
> > rec.aviation.homebuilt.
> >
> > Did you cancel you post, so you could lie now, Ron?
>
> I didn't cancel any post. What I said, and it is still true, that 337's
do not apply
> to homebuilts (or any other experimental). It is you who have a
mistaken view
> of the rules. Part 43 does NOT apply to experimentals. It says this
explicitly
> in 43.1 (b), but you seem to not be able to understand that.
>

Steven P. McNicoll

February 4th 04, 03:24 AM

"Ron Natalie" > wrote in message
. ..
>
> As I said, there is no definition of instrument conditions in the rules.
Hence
> the best we can come up with is the legal counsel.
>
> Your excessively pedantic nature can clearly see that they are different
words.
>

So you think 'instrument conditions' is something other than 'IFR
conditions'? What?

Steven P. McNicoll

February 4th 04, 03:38 AM

"Ron Natalie" > wrote in message
. ..
>
> It doesn't say anything about VFR minimums.
>

It says "instrument flight conditions", which are below VFR minimums.

>
> The FAA affirms that there are times when you can be technically
> above VFR minimums (not in the clouds and sufficient visibility), but
> the horizon and the ground is obscured and those qualify for actual
> instrument conditions, even though it's not bad enough to require IFR.
>

Which is literally contrary to the FARs.

Tarver Engineering

February 4th 04, 04:00 AM

"Ron Natalie" > wrote in message
. ..
>
> "
> > > I never said any such thing. Prove your allegations.
> >
> > You posted your ignorance to the "FAA form 337" thread at
> > rec.aviation.homebuilt.
> >
> > Did you cancel you post, so you could lie now, Ron?
>
> I didn't cancel any post. What I said, and it is still true, that 337's
do not apply
> to homebuilts (or any other experimental).

No, Ron, that is what I posted.

What you posted is that a homebuilt is not an experimental.

Zero for three, Ron. You might want to stick to posting about something you
know something about. CFR 14 is obviously not your area of expertice.

Teacherjh

February 4th 04, 04:25 AM

>>
How many of you log specific minutes of a flight as instrument time when you
are flying in and out of clouds? (I count it all as instrument time)

If you settle into severe clear on top, do you stop timing instrument time?
<<

If any part of my flight takes me into a cloud, I log at least .1 for that
flight. If I'm in and out, I log only the part that's in, estimating as well
as I can to the tenth of an hour. Above an undercast but in the clear, I do
not log as instrument time. Between layers I'll sometimes log as instrument
time, depending on conditions, but I tend not to. If I can stay right side up
by looking out the window, I don't log it as instrument time. There really is
a big difference between being solid, and being sort of in the clouds.

Jose

--
(for Email, make the obvious changes in my address)

Eclipsme

February 4th 04, 12:20 PM

"Steven P. McNicoll" > wrote in message
ink.net...
>
> "Ron Natalie" > wrote in message
> . ..
> >
> > It doesn't say anything about VFR minimums.
> >
>
> It says "instrument flight conditions", which are below VFR minimums.
>
>
> >
> > The FAA affirms that there are times when you can be technically
> > above VFR minimums (not in the clouds and sufficient visibility), but
> > the horizon and the ground is obscured and those qualify for actual
> > instrument conditions, even though it's not bad enough to require IFR.
> >
>
> Which is literally contrary to the FARs.
>
>
I don't think so. Think about being in multiple solid, sloping layers. No
horizon at all. More than VFR viz, but definitely IFR.

Harvey

Gary Drescher

February 4th 04, 01:16 PM

"Eclipsme" > wrote in message
...
> Think about being in multiple solid, sloping layers. No
> horizon at all. More than VFR viz, but definitely IFR.

That's self-contradictory, because the FAA explicitly defines "IFR
conditions" as conditions that do NOT meet the VFR visibility requirements
(AIM Pilot/Controller Glossary).

--Gary

>
> Harvey
>
>

John R Weiss

February 4th 04, 06:11 PM

"Steven P. McNicoll" > wrote...
>
>> If you can't maintain level flight without reference to instruments,
>> because there is no discernible horizon for outside reference, you
> > are in actual instrument flight conditions.
>
> How can that be? IFR conditions are weather conditions below the minimum
> for flight under visual flight rules. You can easily have weather
> conditions well above the minimum for flight under visual flight rules above
> an undercast.

....OR you could just as easily have better than 3 miles visibility, 1,000'
clearance from the clouds, and NO way to determine the horizon from outside
reference: cumulus in the distance, towering cumulus in the area, sloped tops
of stratus in a front...

Ron Natalie

February 4th 04, 06:29 PM

"Steven P. McNicoll" > wrote in message news:1CZTb.9561>
> So you think 'instrument conditions' is something other than 'IFR
> conditions'? What?
>
According to the FAA counsel, it just means conditions that require you
to fly on instruments.

John R Weiss

February 4th 04, 06:42 PM

"Steven P. McNicoll" > wrote...
>
> The rule does not say that. The rule says, ""A person may log instrument
> time only for that flight time when the person operates the aircraft solely
> by reference
> to instruments under actual or simulated instrument flight conditions." So,
> literally, it must be below VFR minimums or you must wear a hood.

Not quite... The FAA maintains a "Part 61 FAQ" at
http://www.faa.gov/AVR/AFS/AFS800/DOCS/pt61FAQ.doc, which addresses "Frequently
Asked Questions on 14 CFR Part 61 and represents FAA Flight Standards Service
policy as it relates to this regulation." In the Mar 30, 2000 version I found
the following, starting on p. 50 (page 98 in the latest, which I just
downloaded):

QUESTION 1: The question came up about logging "actual" instrument time when
over the desert at night with no visual references. When you are flying with
sole reference to instruments, is that actual time? If not, is it "simulated"
instrument time? Our take on the question is actual instrument time can only be
logged when the aircraft is in IMC. The weather determines actual instrument
time, not flying by sole reference to instruments. That settles the actual
instrument question, but what about "simulated" instrument time? Our feeling is
it can be logged as "simulated instrument time." It would be the same as having
a hood on while flying by sole reference to instruments. What about the
requirement for a safety pilot under these conditions? Our answer is "no"
because the pilot is still able to "see and avoid" conflicting traffic.

.. . .

I agree with your statement that just because a person is flying ". . . by sole
reference to instruments . . ." has nothing to do with whether the flight can be
logged as "actual instrument time" or "simulated instrument time." Only the
weather conditions establish whether the flight is in "actual instrument
conditions." And that is dependent on the weather conditions where the aircraft
is physically located and the pilot makes that determination as to whether the
flight is in "actual instrument conditions" or he is performing instrument
flight under "simulated instrument conditions." But for a "quick and easy"
answer to your question, it was always my understanding if I were flying in
weather conditions that were less than the VFR weather minimums defined in
§91.155 and I was flying "solely by reference to instruments" then that was the
determining factor for being able log instrument flight under "actual instrument
conditions."

Otherwise, if I were flying solely by reference to instruments in VMC conditions
then I would log it as instrument flight in "simulated instrument conditions."
In your example, the flight is clear of clouds and in good visibility conditions
at night over the desert with an overcast above and no visible horizon. But
other examples could include flight between sloping cloud layers or flight
between layers of clouds at night. These could equally meet the requirement for
operations that can only be accomplished solely by reference to instruments.
But, the lack of sufficient visual reference to maintain aircraft control
without using instruments does not eliminate the possibility of collision hazard
with other aircraft or terrain.

.. . .

Normally, in order to log instrument flight time under "simulated instrument
conditions," the pilot needs to be utilizing a view limiting device. But, the
only place in the rules requiring a view limiting device will be found under
§61.45(d)(2) as part of the equipment for a practical test. Otherwise, no where
else in the rules, orders, bulletins, or advisory circulars does it specifically
state that pilots need to be utilizing a view limiting device. But, except for
meteorological conditions as in our examples above, how else, could a pilot
comply with §61.51(g) for logging instrument flight time [i.e., ". . . when the
person operates the aircraft solely by reference to instruments . . ."] unless
the pilot was utilizing a view limiting device when logging instrument flight
time in simulated instrument conditions?

QUESTION 3: I have not been able to find a definition of "actual" conditions in
the FARs or the AIM, but I believe that the definition of actual is somewhat
more restrictive than IMC. Please confirm that the following is correct:

Is IMC is simply visibility’s, clearances from clouds, and ceilings less than
the minima for VMC (AIM -pilot controller/glossary) "Actual" requires that the
pilot be flying the airplane solely by reference to instruments, which means he
must be either completely in the soup (i.e. zero-zero) or in conditions which
provide no horizon reference of any kind. Therefore, being in IMC conditions is
not always adequate for logging actual.

ANSWER 3: Ref. §61.51(g); As previously answered above in Answer 1 above, there
is no official FAA definition on "actual instrument time" or "simulated
instrument time" in the FARs, FAA Orders, advisory circulars, FAA bulletins,
etc. Part 61 merely refers to the instrument time in reference to aeronautical
experience to be ". . . instrument flight time, in actual or simulated
instrument conditions . . ." Otherwise the reference is merely instrument flight
time, in actual or simulated instrument conditions.

Now the term "actual" in reference to instrument conditions that require
operations to be performed solely by reference to the aircraft instruments are
sometimes subjective. No question that "actual" instrument conditions exist with
flight in clouds or other phenomena that restrict visibility to the extent that
maintaining level flight or other desired flight attitude, can only be
accomplished with reference to the aircraft instruments. This goes back to
earlier statement in Answer 1 where I said the weather conditions establish
whether the flight is in "actual instrument conditions." And that is dependent
on the weather conditions where the aircraft is physically located and the pilot
makes that determination as to whether the flight is in "actual instrument
conditions" or he is performing instrument flight under "simulated instrument
conditions."

Your realization that "IMC" and "VMC" and also, in fact, "IFR" and "VFR" are not
necessarily related to "actual" conditions is accurate. These terms are used
with respect to airspace operating requirements. Per §91.155, a flight may be in
IMC (requiring IFR operations) with four (4) miles visibility in Class E
airspace above 10,000'MSL (more than 1,200'AGL), but still be in VMC (allowing
VFR operations) with only one (1) mile visibility in Class G below 10,000'MSL
during day time, . That is why none of these terms were used in §61.51(g) to
describe when we may or may not log instrument flight time. IMC and VMC are used
in association when describing airspace weather conditions. VFR or IFR are used
to describe operating requirements [i.e., §91.173 requiring IFR flight plan for
operating in controlled airspace under IFR, §691.169 information required for
operating on an IFR flight plan; §91.155 basic VFR weather minimums, etc].

QUESTION 4: 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 4: §61.51(g)(1) and §61.57(c)(1)(i); 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 go 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.

John R Weiss

February 4th 04, 06:53 PM

"Steven P. McNicoll" > wrote...
>
>> The FAA affirms that there are times when you can be technically
>> above VFR minimums (not in the clouds and sufficient visibility), but
>> the horizon and the ground is obscured and those qualify for actual
>> instrument conditions, even though it's not bad enough to require IFR.
>
> Which is literally contrary to the FARs.

How is it contrary to the FARs (and which ones)? The weather is not subject to
FARs, and neither is an individual pilot's real-time ability to maintain level
flight -- he either CAN do so by means of outside references, or he CANNOT; and
that may change dynamically.

John R Weiss

February 4th 04, 06:53 PM

"Gary Drescher" > wrote...
>
> That's self-contradictory, because the FAA explicitly defines "IFR
> conditions" as conditions that do NOT meet the VFR visibility requirements
> (AIM Pilot/Controller Glossary).

.. . .which isn't regulatory in nature (i.e., not a part of the FARs).

Ron Natalie

February 4th 04, 07:02 PM

"John R Weiss" > wrote in message news:rcbUb.91085$U%5.470879@attbi_s03...
> "Gary Drescher" > wrote...
> >
> > That's self-contradictory, because the FAA explicitly defines "IFR
> > conditions" as conditions that do NOT meet the VFR visibility requirements
> > (AIM Pilot/Controller Glossary).
>
> . . .which isn't regulatory in nature (i.e., not a part of the FARs).
>
And it makes no difference because the rule says "instrument conditions"
not IFR conditions.

John R Weiss

February 4th 04, 07:03 PM

"Steven P. McNicoll" > wrote...
>
>> 'IFR conditions' and 'instrument conditions' are not necessarily the same
>> thing.
>
> How do they differ?

According to "the FAA" (John D. Lynch, GENERAL AVIATION CERTIFICATION BRANCH,
AFS-840):

'This goes back to earlier statement in Answer 1 where I said the weather
conditions establish whether the flight is in "actual instrument conditions."
And that is dependent on the weather conditions where the aircraft is physically
located and the pilot makes that determination as to whether the flight is in
"actual instrument conditions" or he is performing instrument flight under
"simulated instrument conditions."' (Part 61 FAQ, 7/14/03, p. 99)

Note: "the pilot makes that determination"

Steven P. McNicoll

February 4th 04, 08:30 PM

"Eclipsme" > wrote in message
...
>
> I don't think so. Think about being in multiple solid, sloping layers. No
> horizon at all. More than VFR viz, but definitely IFR.
>

Not according to the regulation.

Steven P. McNicoll

February 4th 04, 08:31 PM

"John R Weiss" > wrote in message
news:rcbUb.91085$U%5.470879@attbi_s03...
>
> . . .which isn't regulatory in nature (i.e., not a part of the FARs).
>

This is:

Title 14--Aeronautics and Space

CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

PART 1--DEFINITIONS AND ABBREVIATIONS

§ 1.1 General definitions.

IFR conditions means weather conditions below the minimum for flight under
visual flight rules.

Steven P. McNicoll

February 4th 04, 08:31 PM

"Ron Natalie" > wrote in message
. ..
>
> And it makes no difference because the rule says "instrument conditions"
> not IFR conditions.
>

Same thing.

Steven P. McNicoll

February 4th 04, 08:32 PM

"John R Weiss" > wrote in message
news:wBaUb.220881$xy6.1133716@attbi_s02...
>
> ...OR you could just as easily have better than 3 miles visibility, 1,000'
> clearance from the clouds, and NO way to determine the horizon from
outside
> reference: cumulus in the distance, towering cumulus in the area, sloped
tops
> of stratus in a front...
>

Yes, you can easily have that, but that is not IFR conditions.

Steven P. McNicoll

February 4th 04, 08:33 PM

"Ron Natalie" > wrote in message
. ..
>
> According to the FAA counsel, it just means conditions that require you
> to fly on instruments.
>

The FAA counsel is at odds with the regulations.

Steven P. McNicoll

February 4th 04, 08:35 PM

"John R Weiss" > wrote in message
news:G2bUb.216614$I06.2379975@attbi_s01...
>
> Not quite... The FAA maintains a "Part 61 FAQ" at
> http://www.faa.gov/AVR/AFS/AFS800/DOCS/pt61FAQ.doc, which addresses
"Frequently
> Asked Questions on 14 CFR Part 61 and represents FAA Flight Standards
Service
> policy as it relates to this regulation." In the Mar 30, 2000 version I
found
> the following, starting on p. 50 (page 98 in the latest, which I just
> downloaded):
>
> QUESTION 1: The question came up about logging "actual" instrument time
when
> over the desert at night with no visual references. When you are flying
with
> sole reference to instruments, is that actual time? If not, is it
"simulated"
> instrument time? Our take on the question is actual instrument time can
only be
> logged when the aircraft is in IMC. The weather determines actual
instrument
> time, not flying by sole reference to instruments. That settles the actual
> instrument question, but what about "simulated" instrument time? Our
feeling is
> it can be logged as "simulated instrument time." It would be the same as
having
> a hood on while flying by sole reference to instruments. What about the
> requirement for a safety pilot under these conditions? Our answer is "no"
> because the pilot is still able to "see and avoid" conflicting traffic.
>
> . . .
>
> I agree with your statement that just because a person is flying ". . . by
sole
> reference to instruments . . ." has nothing to do with whether the flight
can be
> logged as "actual instrument time" or "simulated instrument time." Only
the
> weather conditions establish whether the flight is in "actual instrument
> conditions." And that is dependent on the weather conditions where the
aircraft
> is physically located and the pilot makes that determination as to whether
the
> flight is in "actual instrument conditions" or he is performing instrument
> flight under "simulated instrument conditions." But for a "quick and easy"
> answer to your question, it was always my understanding if I were flying
in
> weather conditions that were less than the VFR weather minimums defined in
> §91.155 and I was flying "solely by reference to instruments" then that
was the
> determining factor for being able log instrument flight under "actual
instrument
> conditions."
>
> Otherwise, if I were flying solely by reference to instruments in VMC
conditions
> then I would log it as instrument flight in "simulated instrument
conditions."
> In your example, the flight is clear of clouds and in good visibility
conditions
> at night over the desert with an overcast above and no visible horizon.
But
> other examples could include flight between sloping cloud layers or flight
> between layers of clouds at night. These could equally meet the
requirement for
> operations that can only be accomplished solely by reference to
instruments.
> But, the lack of sufficient visual reference to maintain aircraft control
> without using instruments does not eliminate the possibility of collision
hazard
> with other aircraft or terrain.
>
> . . .
>
> Normally, in order to log instrument flight time under "simulated
instrument
> conditions," the pilot needs to be utilizing a view limiting device. But,
the
> only place in the rules requiring a view limiting device will be found
under
> §61.45(d)(2) as part of the equipment for a practical test. Otherwise, no
where
> else in the rules, orders, bulletins, or advisory circulars does it
specifically
> state that pilots need to be utilizing a view limiting device. But, except
for
> meteorological conditions as in our examples above, how else, could a
pilot
> comply with §61.51(g) for logging instrument flight time [i.e., ". . .
when the
> person operates the aircraft solely by reference to instruments . . ."]
unless
> the pilot was utilizing a view limiting device when logging instrument
flight
> time in simulated instrument conditions?
>
>
>
> QUESTION 3: I have not been able to find a definition of "actual"
conditions in
> the FARs or the AIM, but I believe that the definition of actual is
somewhat
> more restrictive than IMC. Please confirm that the following is correct:
>
> Is IMC is simply visibility’s, clearances from clouds, and ceilings less
than
> the minima for VMC (AIM -pilot controller/glossary) "Actual" requires that
the
> pilot be flying the airplane solely by reference to instruments, which
means he
> must be either completely in the soup (i.e. zero-zero) or in conditions
which
> provide no horizon reference of any kind. Therefore, being in IMC
conditions is
> not always adequate for logging actual.
>
> ANSWER 3: Ref. §61.51(g); As previously answered above in Answer 1 above,
there
> is no official FAA definition on "actual instrument time" or "simulated
> instrument time" in the FARs, FAA Orders, advisory circulars, FAA
bulletins,
> etc. Part 61 merely refers to the instrument time in reference to
aeronautical
> experience to be ". . . instrument flight time, in actual or simulated
> instrument conditions . . ." Otherwise the reference is merely instrument
flight
> time, in actual or simulated instrument conditions.
>
> Now the term "actual" in reference to instrument conditions that require
> operations to be performed solely by reference to the aircraft instruments
are
> sometimes subjective. No question that "actual" instrument conditions
exist with
> flight in clouds or other phenomena that restrict visibility to the extent
that
> maintaining level flight or other desired flight attitude, can only be
> accomplished with reference to the aircraft instruments. This goes back to
> earlier statement in Answer 1 where I said the weather conditions
establish
> whether the flight is in "actual instrument conditions." And that is
dependent
> on the weather conditions where the aircraft is physically located and the
pilot
> makes that determination as to whether the flight is in "actual instrument
> conditions" or he is performing instrument flight under "simulated
instrument
> conditions."
>
> Your realization that "IMC" and "VMC" and also, in fact, "IFR" and "VFR"
are not
> necessarily related to "actual" conditions is accurate. These terms are
used
> with respect to airspace operating requirements. Per §91.155, a flight may
be in
> IMC (requiring IFR operations) with four (4) miles visibility in Class E
> airspace above 10,000'MSL (more than 1,200'AGL), but still be in VMC
(allowing
> VFR operations) with only one (1) mile visibility in Class G below
10,000'MSL
> during day time, . That is why none of these terms were used in §61.51(g)
to
> describe when we may or may not log instrument flight time. IMC and VMC
are used
> in association when describing airspace weather conditions. VFR or IFR are
used
> to describe operating requirements [i.e., §91.173 requiring IFR flight
plan for
> operating in controlled airspace under IFR, §691.169 information required
for
> operating on an IFR flight plan; §91.155 basic VFR weather minimums, etc].
>
>
> QUESTION 4: 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 4: §61.51(g)(1) and §61.57(c)(1)(i); 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 go 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.
>

That's fine, but we're discussing what the regulation actually says.

Steven P. McNicoll

February 4th 04, 08:35 PM

"John R Weiss" > wrote in message
news:qcbUb.91084$U%5.469867@attbi_s03...
>
> How is it contrary to the FARs (and which ones)? The weather is not
subject to
> FARs, and neither is an individual pilot's real-time ability to maintain
level
> flight -- he either CAN do so by means of outside references, or he
CANNOT; and
> that may change dynamically.
>

Title 14--Aeronautics and Space

CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF TRANSPORTATION

PART 1--DEFINITIONS AND ABBREVIATIONS

§ 1.1 General definitions.

IFR conditions means weather conditions below the minimum for flight under
visual flight rules.

Steven P. McNicoll

February 4th 04, 08:36 PM

"John R Weiss" > wrote in message
news:6mbUb.221265$xy6.1135343@attbi_s02...
>
> According to "the FAA" (John D. Lynch, GENERAL AVIATION CERTIFICATION
BRANCH,
> AFS-840):
>
> 'This goes back to earlier statement in Answer 1 where I said the
weather
> conditions establish whether the flight is in "actual instrument
conditions."
> And that is dependent on the weather conditions where the aircraft is
physically
> located and the pilot makes that determination as to whether the flight is
in
> "actual instrument conditions" or he is performing instrument flight under
> "simulated instrument conditions."' (Part 61 FAQ, 7/14/03, p. 99)
>
>
> Note: "the pilot makes that determination"
>

Read the regulation.

John R Weiss

February 4th 04, 09:40 PM

"Steven P. McNicoll" > wrote...
>
> That's fine, but we're discussing what the regulation actually says.

IIRC, the original question was regarding the propriety or "legality" of logging
approaches and/or instrument time. FAA Flight Standards has weighed in as
saying it is up to the pilot to determine what to log in "questionable"
circumstances. Since the bare regulations are unclear, it would be wise to
follow the Flight Standards guidance.

You can nitpick individual regs -- which have already been cussed, discussed,
and re-interpreted ad nauseum -- all you want. However, that will not likely
give any more useful information to the average pilot. Ultimately, it will be
someone who represents Flight Standards who will accept or challenge the pilot's
logbooks, not an Air Traffic Controller.

Steven P. McNicoll

February 4th 04, 09:44 PM

"John R Weiss" > wrote in message
news:AFdUb.217912$I06.2383445@attbi_s01...
>
> IIRC, the original question was regarding the propriety or "legality" of
logging
> approaches and/or instrument time.
>

Ron Natalie wrote:

"It is what the regs literally say. All they say is you have to be in
instrument conditions. Doesn't say anything about flight rules. This was
affirmed in the following opinion by FAA counsel."

John R Weiss

February 5th 04, 12:27 AM

"Steven P. McNicoll" > wrote...
>
>>> That's fine, but we're discussing what the regulation actually says.
>
>> IIRC, the original question was regarding the propriety or "legality" of
logging
>> approaches and/or instrument time.
>
> Ron Natalie wrote:
>
> "It is what the regs literally say. All they say is you have to be in
> instrument conditions. Doesn't say anything about flight rules. This was
> affirmed in the following opinion by FAA counsel."

Ummm... The original referred directly to the lack of visible horizon during an
instrument approach. The post was:

----- Original Message -----
From: "Ron Garrison" >
Newsgroups: rec.aviation.ifr
Sent: Thursday, January 29, 2004 4:11 PM
Subject: Logging approaches

> I had a 'first' last week, and I am looking for other peoples thoughts on
> this one. It was my first (I believe) loggable instrument approach in what
> was legally VMC. I was flying from the San Francisco bay area down to
> Burbank. The reported conditions were sky clear, visibility 4 miles in haze,
> with the ILS 8 in use, no mention of visual approaches. The visibility part
> was right, from about 4,000 feet down to the surface there was about 4 miles
> visibility based on when the runway appeared. I could see the ground below
> just fine the whole time, but looking forward there was no visible horizon.
>
> I considered the approach loggable because:
> 1) navigation aids were required to find the airport
> 2) There was no visible horizon so the attitude indicator was required
> to identify and maintain the desired aircraft attitude.
>
> Any differing opinions on this one?

Steven P. McNicoll

February 5th 04, 01:25 AM

"John R Weiss" > wrote in message
news:36gUb.176434$sv6.932027@attbi_s52...
>
> Ummm... The original referred directly to the lack of visible horizon
during an
> instrument approach. The post was:
>
> ----- Original Message -----
> From: "Ron Garrison" >
> Newsgroups: rec.aviation.ifr
> Sent: Thursday, January 29, 2004 4:11 PM
> Subject: Logging approaches
>
>
> > I had a 'first' last week, and I am looking for other peoples thoughts
on
> > this one. It was my first (I believe) loggable instrument approach in
what
> > was legally VMC. I was flying from the San Francisco bay area down to
> > Burbank. The reported conditions were sky clear, visibility 4 miles in
haze,
> > with the ILS 8 in use, no mention of visual approaches. The visibility
part
> > was right, from about 4,000 feet down to the surface there was about 4
miles
> > visibility based on when the runway appeared. I could see the ground
below
> > just fine the whole time, but looking forward there was no visible
horizon.
> >
> > I considered the approach loggable because:
> > 1) navigation aids were required to find the airport
> > 2) There was no visible horizon so the attitude indicator was
required
> > to identify and maintain the desired aircraft attitude.
> >
> > Any differing opinions on this one?
>

Yeah, I read it. Threads evolve.

Tarver Engineering

February 5th 04, 02:38 AM

"Steven P. McNicoll" > wrote in message
hlink.net...
>
> "Ron Natalie" > wrote in message
> . ..
> >
> > According to the FAA counsel, it just means conditions that require you
> > to fly on instruments.
> >
>
> The FAA counsel is at odds with the regulations.

The FAA counsel is also at odds with the regulation WRT 100 hour inspections
acording to Natalie. I wonder if the FAA counsel understands the
implications of the terms "gross negligence" and "restraint of trade". Much
like the MIDO making a lubrication chnage for DC-9s for Kelly on "no basis".

Ron Natalie

February 5th 04, 01:55 PM

"Tarver Engineering" > wrote in message ...
..
>
> The FAA counsel is also at odds with the regulation WRT 100 hour inspections
> acording to Natalie.

I don't know where Tarver keep pulling this nonsense up. I never said that FAA
counsel was at odds. What I said is that certain A&P schools and other non
FAA types were at odds with the regulation. The regs and the FAA counnsel are clear
that rental without flight instruction do not require 100 hour inspections.

What I disagree with the FAA interpretations on is whether experimentals should be
banned from flight instruction for hire. The 100 hour rules have very specific
wording on flight instruction, the similar prohibition on carrying passengers for
hire is missing from the experimental rules. It merely says you can't use experimentals
for carrying passengers for hire.

It's clear if you search back in google, that Tarver seems to be off in a world of his
own when it comes to responding to anybody else's post. Why he's decided to
pick on me today is unclear.

Doug

February 5th 04, 04:10 PM

It's in the FAR's. You can log actual IMC if you have to use the
instruments to fly the airplane. This can occur and you still meet VFR
visibility requirements. For instance, between layers at night.

You are in IFR conditions if you are flying and do not have the VFR
minimums, ie
500 below, 1000 above and 2000 horizontal and 3 miles visibility in
Class E below 10k etc. If you were less than 1000' above a cloud deck
in Class E airspace you would be in IFR conditions and be navigating
by looking outside, that is, NOT navigating by looking at the
instruments. Thus you could not log actual IMC for this time.

And yes, you can be legal IFR and not be on an IFR flight plan or have
an IFR clearance. Class G airspace allows you to fly in IFR conditions
without a clearance. You only need a clearance in CONTROLLED airspace
(A,B,C,D and E).

This is all USA of course other countries differ.

Judah > wrote in message >...
> "Ron Natalie" > wrote in
> :
>
> > Yes, but immaterial. The weather can still be legal VFR, but bad
> > enough to cause yout to fly solely by instruments. The FAA has
> > affirmed this is legally logable as instrument time.
>
>
> Where'd they do that?

Eclipsme

February 5th 04, 04:48 PM

"Doug" > wrote in message
om...
> It's in the FAR's. You can log actual IMC if you have to use the
> instruments to fly the airplane. This can occur and you still meet VFR
> visibility requirements. For instance, between layers at night.
>
> You are in IFR conditions if you are flying and do not have the VFR
> minimums, ie
> 500 below, 1000 above and 2000 horizontal and 3 miles visibility in
> Class E below 10k etc. If you were less than 1000' above a cloud deck
> in Class E airspace you would be in IFR conditions and be navigating
> by looking outside, that is, NOT navigating by looking at the
> instruments. Thus you could not log actual IMC for this time.

I was taught that you can not (should not?) use a cloud deck for atitude
reference, as it could be sloping and is not a reliable horizon. In this
example, it seems to me the time could be logged.

>
> And yes, you can be legal IFR and not be on an IFR flight plan or have
> an IFR clearance. Class G airspace allows you to fly in IFR conditions
> without a clearance. You only need a clearance in CONTROLLED airspace
> (A,B,C,D and E).
>
> This is all USA of course other countries differ.

Is this true? It has been a bit since I have flown IFR, but it used to be
under 700ft agl - some places 1200ft, and outside of other controlled
airspace such as ATAs, the airspace was uncontrolled. There was quite a bit
of uncontrolled airspace out in Nevada, as I recall. This was before the
airspace revisions. Has this changed?

Harvey

>
> Judah > wrote in message
>...
> > "Ron Natalie" > wrote in
> > :
> >
> > > Yes, but immaterial. The weather can still be legal VFR, but bad
> > > enough to cause yout to fly solely by instruments. The FAA has
> > > affirmed this is legally logable as instrument time.
> >
> >
> > Where'd they do that?

Tarver Engineering

February 5th 04, 05:03 PM

"Ron Natalie" > wrote in message
. ..
>
> "Tarver Engineering" > wrote in message
...
> .
> >
> > The FAA counsel is also at odds with the regulation WRT 100 hour
inspections
> > acording to Natalie.
>
> I don't know where Tarver keep pulling this nonsense up.

I just reposted the 337 thread statement that you lied about making, Ron.
What more proof that it is you that has a problem do you believe is needed?

Ron Natalie

February 5th 04, 05:05 PM

"Eclipsme" > wrote in message ...
>
> Is this true? It has been a bit since I have flown IFR, but it used to be
> under 700ft agl - some places 1200ft, and outside of other controlled
> airspace such as ATAs, the airspace was uncontrolled.

ATA's were never controlled airspace by themselves. The controlled
airspace was the control zone.

>There was quite a bit
> of uncontrolled airspace out in Nevada, as I recall. This was before the
> airspace revisions.

Dunno. Don't forget even in uncontrolled airspace you have the rest of the
IFR rules to deal with. The minimum altitude rules pretty much keep you
from going very far under a 1200' floor.

Ron Natalie

February 5th 04, 05:18 PM

"Tarver Engineering" > wrote in message ...
>
> "Ron Natalie" > wrote in message
> . ..
> >
> > "Tarver Engineering" > wrote in message
> ...
> > .
> > >
> > > The FAA counsel is also at odds with the regulation WRT 100 hour
> inspections
> > > acording to Natalie.
> >
> > I don't know where Tarver keep pulling this nonsense up.
>
> I just reposted the 337 thread statement that you lied about making, Ron.
> What more proof that it is you that has a problem do you believe is needed?
>
I didn't lie about anything. It is you who misinterpreted a statement that I never
denied making. You said "Homebuilts are type certificated as expermintals"
and I said "They don't have type certificates at all." It was your incorrect assumption
to think that I was saying they were not experimentals.

You're the one who appears to not understand what the difference between a
type certificate and an airworthiness certificate is.

FiPe

February 5th 04, 06:10 PM

>From: "Ron Natalie"

> don't know where Tarver keep pulling this nonsense up. I never said that
>FAA.....

>Why he's decided to
>pick on me today is unclear

Because you keep answering him. Ignore him and he will go away. Seems like
everyone knows about him, but you.

Fidel

Tarver Engineering

February 5th 04, 07:34 PM

"Ron Natalie" > wrote in message
. ..
>
> "Tarver Engineering" > wrote in message
...
> >
> > "Ron Natalie" > wrote in message
> > . ..
> > >
> > > "Tarver Engineering" > wrote in message
> > ...
> > > .
> > > >
> > > > The FAA counsel is also at odds with the regulation WRT 100 hour
> > inspections
> > > > acording to Natalie.
> > >
> > > I don't know where Tarver keep pulling this nonsense up.
> >
> > I just reposted the 337 thread statement that you lied about making,
Ron.
> > What more proof that it is you that has a problem do you believe is
needed?
> >
> I didn't lie about anything.

Dude, grow up.

Tarver Engineering

February 5th 04, 07:35 PM

"FiPe" > wrote in message
...
> >From: "Ron Natalie"
>
> > don't know where Tarver keep pulling this nonsense up. I never said
that
> >FAA.....
>
> >Why he's decided to
> >pick on me today is unclear
>
> Because you keep answering him. Ignore him and he will go away. Seems like
> everyone knows about him, but you.

Everyone replies to me.

Ron is just having a little problem with the truth and a larger problem
interpreting CFR 14 in a sane mannner.

Doug

February 6th 04, 12:16 AM

There are some fairly large Class G areas that go up to 14500' MSL in the west.

"Ron Natalie" > wrote in message >...
> "Eclipsme" > wrote in message ...
> >
> > Is this true? It has been a bit since I have flown IFR, but it used to be
> > under 700ft agl - some places 1200ft, and outside of other controlled
> > airspace such as ATAs, the airspace was uncontrolled.
>
> ATA's were never controlled airspace by themselves. The controlled
> airspace was the control zone.
>
> >There was quite a bit
> > of uncontrolled airspace out in Nevada, as I recall. This was before the
> > airspace revisions.
>
> Dunno. Don't forget even in uncontrolled airspace you have the rest of the
> IFR rules to deal with. The minimum altitude rules pretty much keep you
> from going very far under a 1200' floor.

Judah

February 6th 04, 08:22 PM

(Doug) wrote in
om:

> It's in the FAR's. You can log actual IMC if you have to use the
> instruments to fly the airplane. This can occur and you still meet VFR
> visibility requirements. For instance, between layers at night.
>

Let's look at the FARs...

FAR 61.51.(g) Logging instrument flight time. "(1) A person may log
instrument time only for that flight time when the person operates the
aircraft solely by reference to instruments under actual or simulated
instrument flight conditions." [Quoted from the AOPA site...
http://www.aopa.org/members/files/fars/far-61.html ]

It says you must be operating solely by reference to the instruments under
Actual or Simulated IFR.

ie: Operating solely by reference to the instruments in VFR conditions
wihtout IFR simulation (ie: foggles, hood, etc.) would seem NOT to be
loggable as Instrument Flight Time. Even if it's only marginal.

Now, in FAR 61.57
(c) Instrument experience. "Except as provided in paragraph (e) of this
section, no person may act as pilot in command under IFR or in weather
conditions less than the minimums prescribed for VFR, unless within the
preceding 6 calendar months, that person has:

(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 -- " [Quoted from the AOPA site...
http://www.aopa.org/members/files/fars/far-61.html ]

Performing and logging the specific things described (6 approaches, holding
procedures and intercepting and tracking courses) in actual or simulated
conditions also seems to be required.

I see nothing that affirms that you can legally log flying by reference to
the instruments in VFR conditions under any circumstances, unless
simulating IFR. So I was wondering what Ron's source for an affirmation
from the FAA otherwise might have been. Admittedly, I would love to be able
to log approaches by reference to the instruments in VFR. But I just don't
see that as being what's in the FARs. And as much as I like Ron, I just
don't want to bet my ticket on his hearsay...

> You are in IFR conditions if you are flying and do not have the VFR
> minimums, ie
> 500 below, 1000 above and 2000 horizontal and 3 miles visibility in
> Class E below 10k etc. If you were less than 1000' above a cloud deck
> in Class E airspace you would be in IFR conditions and be navigating
> by looking outside, that is, NOT navigating by looking at the
> instruments. Thus you could not log actual IMC for this time.

This statement I agree with. And in many respects, I think that is a pretty
clear definition of what IMC is.

> And yes, you can be legal IFR and not be on an IFR flight plan or have
> an IFR clearance. Class G airspace allows you to fly in IFR conditions
> without a clearance. You only need a clearance in CONTROLLED airspace
> (A,B,C,D and E).
>
> This is all USA of course other countries differ.
>
> Judah > wrote in message
> >...
>> "Ron Natalie" > wrote in
>> :
>>
>> > Yes, but immaterial. The weather can still be legal VFR, but bad
>> > enough to cause yout to fly solely by instruments. The FAA has
>> > affirmed this is legally logable as instrument time.
>>
>>
>> Where'd they do that?

Ron Natalie

February 6th 04, 09:23 PM

"Judah" > wrote in message ...

>
> It says you must be operating solely by reference to the instruments under
> Actual or Simulated IFR.

No, it does not say that. The letters IFR nor the term flight rules do
not appear in the regulation. It says "actual or simulated instrument
conditions."

> ie: Operating solely by reference to the instruments in VFR conditions
> wihtout IFR simulation (ie: foggles, hood, etc.) would seem NOT to be
> loggable as Instrument Flight Time. Even if it's only marginal.

That's not what the reg says. That's not what the FAA says. The interpretation
is that "instrument conditions" are those that cause you to have to fly solely by
instruments. Hence, flying without foggles on a clear day isn't instrument time,
flying without foggles across Lake Michigan with 3 miles in haze, might be, even
though it is legal VFR.

> So I was wondering what Ron's source for an affirmation
> from the FAA otherwise might have been

It comes from an FAA Chief Legal Counsel interpretation (John Cassady,
Nov. 7 1984). Others have pointed out the Lynch's Part 61 FAQ echoes
this interpretation.

Ron Rosenfeld

February 6th 04, 09:30 PM

On Fri, 06 Feb 2004 20:22:43 GMT, Judah > wrote:

>FAR 61.51.(g) Logging instrument flight time. "(1) A person may log
>instrument time only for that flight time when the person operates the
>aircraft solely by reference to instruments under actual or simulated
>instrument flight conditions." [Quoted from the AOPA site...
>http://www.aopa.org/members/files/fars/far-61.html ]
>
>It says you must be operating solely by reference to the instruments under
>Actual or Simulated IFR.

Not really. It uses the term "instrument flight conditions". It does not
use the term or abbreviation "IFR" or Instrument Flight Rules". These are
two entirely different concepts.

According to published FAA legal counsel opinion, "'Actual' instrument
flight conditions occur when some outside conditions make it necessary for
the pilot to use the aircraft instruments in order to maintain adequate
control over the aircraft. Typically, these conditions involve adverse
weather conditions.

" ... actual instrument conditions may occur in the case (of a) moonless
night over the ocean with no discernible horizon, if use of the instruments
is necessary to maintain adequate control over the aircraft.

"The determination as to whether flight by reference to instruments is
necessary is somewhat subjective and based in part on the sound judgment of
the pilot.

"Note that, under Section 61.51(b)(3), the pilot must log the conditions of
the flight. The log should include the reasons for determining that the
flight was under actual instrument conditions in case the pilot later would
be called on to prove that the actual instrument flight time logged was
legitimate."

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

John R Weiss

February 7th 04, 03:15 AM

"Ron Natalie" > wrote...
>
> It comes from an FAA Chief Legal Counsel interpretation (John Cassady,
> Nov. 7 1984).

Is that readily available somewhere?

Judah

February 7th 04, 08:08 PM

Please advise the source of this published FAA legal counsel opinion that
you are quoting from.

Thanks.

Ron Rosenfeld > wrote in
:

> On Fri, 06 Feb 2004 20:22:43 GMT, Judah > wrote:
>
>>FAR 61.51.(g) Logging instrument flight time. "(1) A person may log
>>instrument time only for that flight time when the person operates the
>>aircraft solely by reference to instruments under actual or simulated
>>instrument flight conditions." [Quoted from the AOPA site...
>>http://www.aopa.org/members/files/fars/far-61.html ]
>>
>>It says you must be operating solely by reference to the instruments
>>under Actual or Simulated IFR.
>
> Not really. It uses the term "instrument flight conditions". It does
> not use the term or abbreviation "IFR" or Instrument Flight Rules".
> These are two entirely different concepts.
>
> According to published FAA legal counsel opinion, "'Actual' instrument
> flight conditions occur when some outside conditions make it necessary
> for the pilot to use the aircraft instruments in order to maintain
> adequate control over the aircraft. Typically, these conditions involve
> adverse weather conditions.
>
> " ... actual instrument conditions may occur in the case (of a)
> moonless night over the ocean with no discernible horizon, if use of
> the instruments is necessary to maintain adequate control over the
> aircraft.
>
> "The determination as to whether flight by reference to instruments is
> necessary is somewhat subjective and based in part on the sound
> judgment of the pilot.
>
> "Note that, under Section 61.51(b)(3), the pilot must log the
> conditions of the flight. The log should include the reasons for
> determining that the flight was under actual instrument conditions in
> case the pilot later would be called on to prove that the actual
> instrument flight time logged was legitimate."
>
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Judah

February 7th 04, 09:56 PM

You are correct in that I erred by referring to IFR and not IMC.

Thank you for identifying the source of your interpretation. I could not
find the 1984 document, but I was able to locate the current Part 61 FAQ,
here...

http://www2.faa.gov/avr/afs/afs800/docs/pt61faq.doc

Some excerpts from section [Q&A 291],

'ANSWER: § 61.51(g)(1) and § 61.57(c)(1)(i); 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 . . . ." '

Implying that meteorological conditions are irrelevant...

But earlier in that section, he answers a question as follows...

'But for a "quick and easy" answer to your question, it was always my
understanding if I were flying in weather conditions that were less than
the VFR weather minimums defined in §91.155 and I was flying "solely by
reference to instruments" then that was the determining factor for being
able log instrument flight under "actual instrument conditions."
Otherwise, if I were flying solely by reference to instruments in VMC
conditions then I would log it as instrument flight in "simulated
instrument conditions."'

Mr. Lynch interprets a situation where one is flying solely by reference to
the instruments in VFR conditions as Instrument Flight in Simulated
Instrument Conditions.

However, he later adds to the exact same question the following points:

'So, now to answer your other question "What about the requirement for a
safety pilot under these conditions? Your question is answered by §91.109
(b)(1) and it states:

"(b) No person may operate a civil aircraft in simulated instrument flight
unless-
(1) The other control seat is occupied by a safety pilot who possesses at
least a private pilot certificate with category and class ratings
appropriate to the aircraft being flown."'

Basically outlining that in order to log it as Simulated Instrument
Conditions you must have a safety pilot, although you need not be wearing a
hood.

So it seems if you fly an approach with a Safety Pilot in the right seat,
only by reference to the instruments, even in VFR, you can log this as
Simulated Instrument Conditions.

But if you don't have a Safety Pilot in the right seat, you're SOL...

Add to all that the following quote which appears in Q&A-288...

'Before discussing this issue, please note that the Frequently Asked
Questions - Part 61 & 141 (FAQ's) are provided by the Flight Standards
Service (AFS) for standardization purposes. The Office of the Chief
Counsel does not review the FAQ's and accordingly, information provided on
his website is not legally binding.'

Which basically means the faq is irrelevant anyway...

At the end of the day, it all just makes me more cynical about lawyers! Mr.
Lynch's "quick & easy" answer does not seem so quick and easy, and
completely dodges the basic question: What are the official FAA definitions
for the terms "Actual Instrument Conditions" and "Simulated Instrument
Conditions" as used in FAR 61.51(g)?

I would be interested to see the original interpretation from 1984, but
have been unable to find it... Can you provide a link?

Thanks!

"Ron Natalie" > wrote in
:

>
> "Judah" > wrote in message
> ...
>
>>
>> It says you must be operating solely by reference to the instruments
>> under Actual or Simulated IFR.
>
> No, it does not say that. The letters IFR nor the term flight rules
> do not appear in the regulation. It says "actual or simulated
> instrument conditions."
>
>> ie: Operating solely by reference to the instruments in VFR conditions
>> wihtout IFR simulation (ie: foggles, hood, etc.) would seem NOT to be
>> loggable as Instrument Flight Time. Even if it's only marginal.
>
> That's not what the reg says. That's not what the FAA says. The
> interpretation is that "instrument conditions" are those that cause you
> to have to fly solely by instruments. Hence, flying without foggles
> on a clear day isn't instrument time, flying without foggles across
> Lake Michigan with 3 miles in haze, might be, even though it is legal
> VFR.
>
>> So I was wondering what Ron's source for an affirmation from the FAA
>> otherwise might have been
>
> It comes from an FAA Chief Legal Counsel interpretation (John Cassady,
> Nov. 7 1984). Others have pointed out the Lynch's Part 61 FAQ echoes
> this interpretation.
>

Ron Rosenfeld

February 8th 04, 03:34 AM

On Sat, 07 Feb 2004 20:08:00 GMT, Judah > wrote:

>Please advise the source of this published FAA legal counsel opinion that
>you are quoting from.

The source is The FAA Office of the Chief Counsel.

The current holder of that position is Andrew B. Steinberg.

He can be reached at:

Federal Aviation Administration
800 Independence Avenue, S.W.
Washington, DC 20591

The ruling came from the Regulations Division (AGC-200) which has been
headed up for quite some time by Donald P. Byrne. I do not know if he was
in charge of that division in 1984 when the ruling was published. He is at
the same address. Telephone: (202) 267-3073

------

In another post you quoted Mr. John Lynch's opinion regarding logging
matters. Mr. Lynch is not part of the Office of the Chief Counsel, and his
opinions in various areas, as originally published in his FAQ's, have been
'corrected' in the past.

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

John R Weiss

February 8th 04, 03:55 AM

"Ron Rosenfeld" > wrote...
>
> In another post you quoted Mr. John Lynch's opinion regarding logging
> matters. Mr. Lynch is not part of the Office of the Chief Counsel, and his
> opinions in various areas, as originally published in his FAQ's, have been
> 'corrected' in the past.

However, his quoted post concerning logging instrument time has persisted
unchanged for over 3 years...

Besides, Mr. Lynch represents Flight Standards, which is the office that has
cognizance over logging matters for most pilots (i.e., screening of logbooks for
new ratings). Following their policy is not likely to get anyone into trouble
with their logbooks...

Judah

February 8th 04, 06:48 AM

Hi Ron,
Is there some manner of identifying the ruling? Perhaps a case number or
article number?

In the other branch of this thread, I quoted Mr. Lynch's FAQ because the
poster to whom I was responding referred to that document directly, as
supporting his argument. I think I also made mention of the fact that the
document itself claims to not be binding, and as such is irrelevant.

The bottom line is that I am still looking for any specific, official
document that supports the case for being able to log instrument flight
time (either in Actual or Simulated instrument conditions) while solo in
VFR conditions under any circumstances. While you have provided me with
some great contact information, you still have not identified the actual
source of your quoted statements, and I just don't get that.

Ron Rosenfeld > wrote in
:

> On Sat, 07 Feb 2004 20:08:00 GMT, Judah > wrote:
>
>>Please advise the source of this published FAA legal counsel opinion
>>that you are quoting from.
>
> The source is The FAA Office of the Chief Counsel.
>
> The current holder of that position is Andrew B. Steinberg.
>
> He can be reached at:
>
> Federal Aviation Administration
> 800 Independence Avenue, S.W.
> Washington, DC 20591
>
> The ruling came from the Regulations Division (AGC-200) which has been
> headed up for quite some time by Donald P. Byrne. I do not know if he
> was in charge of that division in 1984 when the ruling was published.
> He is at the same address. Telephone: (202) 267-3073
>
>
> ------
>
> In another post you quoted Mr. John Lynch's opinion regarding logging
> matters. Mr. Lynch is not part of the Office of the Chief Counsel, and
> his opinions in various areas, as originally published in his FAQ's,
> have been 'corrected' in the past.
>
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Gary Drescher

February 8th 04, 12:32 PM

"Judah" > wrote in message
...
> The bottom line is that I am still looking for any specific, official
> document that supports the case for being able to log instrument flight
> time (either in Actual or Simulated instrument conditions) while solo in
> VFR conditions under any circumstances. While you have provided me with
> some great contact information, you still have not identified the actual
> source of your quoted statements, and I just don't get that.

It's a continuing travesty that the FAA manufactures "interpretations" of
the FARs that supersede the FARs and cannot rationally be derived from the
FARs, yet are not readily accessible to pilots.

On the other hand, although the FAA's FAR FAQs are not officially binding, I
imagine it would be difficult for the FAA to penalize a pilot for conduct
consistent with the FAQs' interpretation (doing so would arguably constitute
entrapment: inducing someone to commit a violation and then prosecuting them
for it). Does anyone know if the imposition of such a penalty has ever been
documented?

The real solution here would be not to publicize the official
interpretation, but rather to rewrite the FARs to make them more sensible.
The problem is that here (as elsewhere), the FAA confusingly uses a key term
to designate two different things: the phrase "instrument conditions",
although it refers to meteorological conditions, means something different
from the phrase "instrument meteorological conditions"!

The two conflated concepts should be called Instrument Separation Conditions
and Instrument Aviation Conditions. Instrument Separation Conditions (which
the FAA calls "IFR conditions" or "IMC") are meteorological conditions that
don't meet the VFR requirements for visual separation. Instrument Aviation
Conditions (which the FARs refer to as "instrument conditions" or
"instrument flight conditions", but without ever defining those terms) are
meteorological conditions that require flight by reference to instruments.
You can be in ISC without being in IAC (for instance, flying in unlimited
visibility 400' below a layer) or vice versa (for instance, flying on a
clear, dark night over water).

--Gary

Ron Rosenfeld

February 8th 04, 01:05 PM

On Sun, 08 Feb 2004 06:48:17 GMT, Judah > wrote:

>The bottom line is that I am still looking for any specific, official
>document that supports the case for being able to log instrument flight
>time (either in Actual or Simulated instrument conditions) while solo in
>VFR conditions under any circumstances.

It seemed as if you wanted a copy of the original document. I gave you the
government source for that information. Under FOIA, you should be able to
contact them to obtain the document, knowing also that it was written in
1984.

If you wish to pay for the document, Summit Aviation publishes a fully
searchable database of vital aviation publications, updated bi-weekly,
which should include this legal interpretation. I believe you can purchase
a single CD, but you'd have to check their web site for more information.

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld

February 8th 04, 01:13 PM

On Sun, 08 Feb 2004 03:55:56 GMT, "John R Weiss"
> wrote:

>However, his quoted post concerning logging instrument time has persisted
>unchanged for over 3 years...

That only means that no one in the legal department as reviewed his
interpretations for accuracy.

>
>Besides, Mr. Lynch represents Flight Standards, which is the office that has
>cognizance over logging matters for most pilots (i.e., screening of logbooks for
>new ratings). Following their policy is not likely to get anyone into trouble
>with their logbooks...

Especially since Lynch's interpretation, as stated here by others, is
*more* restrictive than what is allowed by AGC-200, which is the
Regulations Section of the Chief Counsel office of the FAA.

Following the policy of the legal division which interprets the FAA
aviation regulations is even less likely to get anyone in trouble.

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

John R Weiss

February 8th 04, 09:05 PM

"Gary Drescher" > wrote...
>
> The real solution here would be not to publicize the official
> interpretation, but rather to rewrite the FARs to make them more sensible.
> The problem is that here (as elsewhere), the FAA confusingly uses a key term
> to designate two different things: the phrase "instrument conditions",
> although it refers to meteorological conditions, means something different
> from the phrase "instrument meteorological conditions"!

Unfortunately, the NPRM process is so political when it comes to major changes
in the FARs that it takes WAY too long to effect any change -- of course, unless
the TSA decides it needs the authority to force the FAA to revoke Pilot
Certificates, with little or no reason or recourse available to the affected
Pilot...

Judah

February 9th 04, 03:01 AM

In this case, it seems to me that there are already two clearly separate
terms used, and all they need to add to the FARs is a definition of
"Instrument Conditions".

"Gary Drescher" > wrote in
news:h%pVb.205324$nt4.976461@attbi_s51:

> "Judah" > wrote in message
> ...
>> The bottom line is that I am still looking for any specific, official
>> document that supports the case for being able to log instrument
>> flight time (either in Actual or Simulated instrument conditions)
>> while solo in VFR conditions under any circumstances. While you have
>> provided me with some great contact information, you still have not
>> identified the actual source of your quoted statements, and I just
>> don't get that.
>
> It's a continuing travesty that the FAA manufactures "interpretations"
> of the FARs that supersede the FARs and cannot rationally be derived
> from the FARs, yet are not readily accessible to pilots.
>
> On the other hand, although the FAA's FAR FAQs are not officially
> binding, I imagine it would be difficult for the FAA to penalize a
> pilot for conduct consistent with the FAQs' interpretation (doing so
> would arguably constitute entrapment: inducing someone to commit a
> violation and then prosecuting them for it). Does anyone know if the
> imposition of such a penalty has ever been documented?
>
> The real solution here would be not to publicize the official
> interpretation, but rather to rewrite the FARs to make them more
> sensible. The problem is that here (as elsewhere), the FAA confusingly
> uses a key term to designate two different things: the phrase
> "instrument conditions", although it refers to meteorological
> conditions, means something different from the phrase "instrument
> meteorological conditions"!
>
> The two conflated concepts should be called Instrument Separation
> Conditions and Instrument Aviation Conditions. Instrument Separation
> Conditions (which the FAA calls "IFR conditions" or "IMC") are
> meteorological conditions that don't meet the VFR requirements for
> visual separation. Instrument Aviation Conditions (which the FARs
> refer to as "instrument conditions" or "instrument flight conditions",
> but without ever defining those terms) are meteorological conditions
> that require flight by reference to instruments. You can be in ISC
> without being in IAC (for instance, flying in unlimited visibility 400'
> below a layer) or vice versa (for instance, flying on a clear, dark
> night over water).
>
> --Gary
>
>

Judah

February 9th 04, 06:13 AM

I do appreciate that. And yes, you are right. Before I go logging time
for IFR currency that seems to conflict with the Regs and the FAQ, I want
a copy of the document that supports me when the FAA comes-a-knockin' at
my door... I suspect a copy of your post on Google.Com will not hold
up... ;)

But I am still trying to figure out how to identify the document in my
request to the FAA, though. Is there a docket number or some other
identifying code? I suspect there were many legal opinions written by the
Chief Counsel in 1984. I am not a lawyer, so perhaps I am asking an
obvious or stupid question. But I would love to have a copy of this
document for my files... An on-line reference would be most convenient if
available...

I have done a search on faa.gov, but that has turned up empty because it
seems they only go back to 1995...

Thanks!

Ron Rosenfeld > wrote in
:

> On Sun, 08 Feb 2004 06:48:17 GMT, Judah > wrote:
>
>>The bottom line is that I am still looking for any specific, official
>>document that supports the case for being able to log instrument flight
>>time (either in Actual or Simulated instrument conditions) while solo
>>in VFR conditions under any circumstances.
>
> It seemed as if you wanted a copy of the original document. I gave you
> the government source for that information. Under FOIA, you should be
> able to contact them to obtain the document, knowing also that it was
> written in 1984.
>
> If you wish to pay for the document, Summit Aviation publishes a fully
> searchable database of vital aviation publications, updated bi-weekly,
> which should include this legal interpretation. I believe you can
> purchase a single CD, but you'd have to check their web site for more
> information.
>
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Gary Drescher

February 9th 04, 12:07 PM

"Judah" > wrote in message
...
> In this case, it seems to me that there are already two clearly separate
> terms used, and all they need to add to the FARs is a definition of
> "Instrument Conditions".

Defining two separate terms would be a good start. But for the choice of
terminology to be competent, the words need to be chosen to reflect their
meaning. It is nonsensical for the FAA to use the phrase "instrument
conditions", in reference to meteorological conditions, to mean something
different from the phrase "instrument meteorological conditions". There's
nothing in that wording to suggest that there's even a difference, let alone
suggesting what the difference *is*. In contrast, defining the terms
"Instrument Separation Conditions" and "Instrument Aviation Conditions"
would make the intended distinction immediately obvious.

--Gary

> "Gary Drescher" > wrote in
> news:h%pVb.205324$nt4.976461@attbi_s51:
>
> > "Judah" > wrote in message
> > ...
> >> The bottom line is that I am still looking for any specific, official
> >> document that supports the case for being able to log instrument
> >> flight time (either in Actual or Simulated instrument conditions)
> >> while solo in VFR conditions under any circumstances. While you have
> >> provided me with some great contact information, you still have not
> >> identified the actual source of your quoted statements, and I just
> >> don't get that.
> >
> > It's a continuing travesty that the FAA manufactures "interpretations"
> > of the FARs that supersede the FARs and cannot rationally be derived
> > from the FARs, yet are not readily accessible to pilots.
> >
> > On the other hand, although the FAA's FAR FAQs are not officially
> > binding, I imagine it would be difficult for the FAA to penalize a
> > pilot for conduct consistent with the FAQs' interpretation (doing so
> > would arguably constitute entrapment: inducing someone to commit a
> > violation and then prosecuting them for it). Does anyone know if the
> > imposition of such a penalty has ever been documented?
> >
> > The real solution here would be not to publicize the official
> > interpretation, but rather to rewrite the FARs to make them more
> > sensible. The problem is that here (as elsewhere), the FAA confusingly
> > uses a key term to designate two different things: the phrase
> > "instrument conditions", although it refers to meteorological
> > conditions, means something different from the phrase "instrument
> > meteorological conditions"!
> >
> > The two conflated concepts should be called Instrument Separation
> > Conditions and Instrument Aviation Conditions. Instrument Separation
> > Conditions (which the FAA calls "IFR conditions" or "IMC") are
> > meteorological conditions that don't meet the VFR requirements for
> > visual separation. Instrument Aviation Conditions (which the FARs
> > refer to as "instrument conditions" or "instrument flight conditions",
> > but without ever defining those terms) are meteorological conditions
> > that require flight by reference to instruments. You can be in ISC
> > without being in IAC (for instance, flying in unlimited visibility 400'
> > below a layer) or vice versa (for instance, flying on a clear, dark
> > night over water).
> >
> > --Gary
> >
> >
>

Judah

February 9th 04, 12:20 PM

OK. I found what I was looking for...

http://groups.google.com/groups?hl=en&lr=&ie=UTF-8&oe=UTF-8&threadm=
32E55577.5B0B%40waid.com&rnum=3&prev=/groups%3Fhl%3Den%26lr%3D%26ie%
3DUTF-8%26oe%3DUTF-8%26q%3D1984%2B61.51%2Bifr%26sa%3DN%26tab%3Dwg

Said post references "Legal Interpretation #84-29" written Nov 7, 1984,
and quotes it in its entirety. Interestingly enough, it does indeed
contradict the FAQ almost directly...

"Simulated" instrument conditions occur when
the pilot's vision outside of the aircraft is intentionally
restricted, such as by a hood or goggles. "Actual" instrument
flight conditions occur when some outside conditions make it
necessary for the pilot to use the aircraft instruments in order
to maintain adequate control over the aircraft. Typically, these
conditions involve adverse weather conditions.

In my hunting, I also found the following thread:

http://groups.google.com/groups?hl=en&lr=&ie=UTF-8&oe=UTF-8
&threadm=a6mhrr%249pg%241%40slb3.atl.mindspring.net&rnum=28&prev=/groups%
3Fq%3D61.57%26hl%3Den%26lr%3D%26ie%3DUTF-8%26oe%3DUTF-8%26start%3D20%
26sa%3DN

Which references a more recent opinion from January 28, 1992 (and is not
quoted in its entirety, nor does it reference a document number - so I
will be hunting for that later...). While it does not contradict the
above opinion, it reads as follows:

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.

The poster in that thread interprets that to mean that the entire
approach down to minimums must be in IFR conditions. I'm not 100% sure I
agree that it must be interpreted this way. But what is interesting is
that the Assistant Chief Counsel who authored this document referred
specifically to "actual or simulated IFR conditions" not "actual or
simulated IMC conditions"...

At the end of the day, I think I'm just gonna make sure to have some
foggle time with a buddy or an instructor every 6 months and be done with
it.

I hate lawyers!

Ron Rosenfeld > wrote in
:

> On Sun, 08 Feb 2004 06:48:17 GMT, Judah > wrote:
>
>>The bottom line is that I am still looking for any specific, official
>>document that supports the case for being able to log instrument flight
>>time (either in Actual or Simulated instrument conditions) while solo
>>in VFR conditions under any circumstances.
>
> It seemed as if you wanted a copy of the original document. I gave you
> the government source for that information. Under FOIA, you should be
> able to contact them to obtain the document, knowing also that it was
> written in 1984.
>
> If you wish to pay for the document, Summit Aviation publishes a fully
> searchable database of vital aviation publications, updated bi-weekly,
> which should include this legal interpretation. I believe you can
> purchase a single CD, but you'd have to check their web site for more
> information.
>
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
>

Ron Natalie

February 9th 04, 12:26 PM

"John R Weiss" > wrote in message news:YKYUb.187404$Rc4.1460112@attbi_s54...
> "Ron Natalie" > wrote...
> >
> > It comes from an FAA Chief Legal Counsel interpretation (John Cassady,
> > Nov. 7 1984).
>
> Is that readily available somewhere?
>

I get it off the Summit Aviation disks. I've already posted it once in this
thread.

Ron Rosenfeld

February 9th 04, 12:59 PM

On Mon, 09 Feb 2004 12:20:44 GMT, Judah > wrote:

> 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.
>
>The poster in that thread interprets that to mean that the entire
>approach down to minimums must be in IFR conditions. I'm not 100% sure I
>agree that it must be interpreted this way. But what is interesting is
>that the Assistant Chief Counsel who authored this document referred
>specifically to "actual or simulated IFR conditions" not "actual or
>simulated IMC conditions"...

There is frequently inconsistency in FAA documents. When these are
important or questioned, they get ironed out in subsequent revisions.
However, with regard to this particular opinion, there was quite a bit of
discussion at the time it was issued. I don't have the documentation to
prove the point, but I'm pretty certain that it is not considered binding
by anyone. Most consider this to be a gray area.

I generally log the approach if enough of it was conducted in instrument
conditions that I felt I really got some benefit to my currency by
conducting it. So a thin overcast at the FAF would not count for me. But
a ceiling 100-200' above DA would count.

Don't forget that the purpose of logging is for currency, and/or
qualification for a rating. If you cheat on currency, you are cheating
yourself and your passengers. And if you are going to be tested for a
rating, the examiner WILL have you conduct the approach (perhaps in
simulated conditions) down to the MDA or DA(H).

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)