How low must you go?

9 Answers

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   Mark Kolber on Dec 05, 2013

   If you look at my FAQ on “How Much Actual Is Required to Log an Instrument Approach?” At http://www.midlifeflight.com/faq/faq.php?s=3#12 you’ll see a reference to a 1992 FAA Chief Counsel opinion. In the course of the opinion, the FAA says;

   “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 airport being busy and you needing to cut the approach off early is, IMO, a “safety” reason.

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   Kris Kortokrax on Dec 05, 2013

   Mark,

   I followed the link to your website and read the whole section. What I found most interesting is the comment near the end where someone suggested a definition for an instrument approach.

   This already exists in Part 1 and looks like this:

   “Instrument approach procedure (IAP) is a series of predetermined maneuvers by reference to flight instruments with specified protection from obstacles and assurance of navigation signal reception capability.

   It begins from the initial approach fix, or where applicable, from the beginning of a defined arrival route to a point:

   (1) From which a landing can be completed; or

   (2) If a landing is not completed, to a position at which holding or en route obstacle clearance criteria apply.”

   The proficiency requirements are to complete 6 approaches.

   I would say that if one is in IMC and breaks out prior to the MAP (a better description the DH/MDA because arrival at MDA is not arrival at the MAP), the approach counts.

   If one is sumulating IMC, then one could fly the approach to the MAP and either miss or land. Or one could “simulate” breaking out at a point prior to the MAP.

   I think that in some cases, it is inadvisable to allow attorneys to issue interpretations when they have no practical experience.

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   Mark Kolber on Dec 05, 2013

   “IWhat I found most interesting is the comment near the end where someone suggested a definition for an instrument approach.”

   Who? There shouldn’t be anything there that attempts to define what an instrument approach is. Just a discussion of how much of it needs to be in actual or simulated conditions to count for currency purposes.

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   Wes Beard on Dec 05, 2013

   If you read John Lynch’s Part 61 FAQ’s (not regulatory by any measure) he answers the question that if you are flying solely by reference to instruments inside the FAF then you can count the approach for proficiency.

   If this is simulated I would expect you to break out at minimums. John Lynch is the author of most of the FARs we read today.

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   Kris Kortokrax on Dec 05, 2013

   This is the text from your website I was referring to.

   “Another commenter proposes to define “instrument approach” as ” * * * an approach procedure defined in part 97 and conducted in accordance with that procedure or as directed by ATC to a point beyond an initial approach fix defined for that procedure.” The commenter explains that this definition would allow for logging instrument approaches that require some portion of the published approach procedure to be followed in order for the pilot to establish visual references to the runway”

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   Mark Kolber on Dec 06, 2013

   Ah. That’s a quote from the Federal Register from a commenter to the Proposed Rule, suggesting an amendment To the FAR definition to include a defined point to which one must fly in order for then approach to “count” for currency. As I noted, it was rejected by the FAA.

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   Kris Kortokrax on Dec 06, 2013

   Probably because it wasn’t needed. There is only a requirement to complete 6 approaches for currency. There is a definition in Part 1 as to what constitutes an approach (where it begins and where it ends).

   Why would it need to begin and/or end somewhere else in the context of practice?

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   Mark Kolber on Dec 06, 2013

   I agree. But for different reasons.

   As I put it to start, someone was, as I put it, stupid enough to ask the “how much of the approach has to be in IMC” question to begin. The FAA itself has given various unhelpful answers. So someone suggested a formal answer, which was just as unhelpful as the others.

   I can’t tell if you are arguing with me or not. If you are, i don’t know why since we agree.

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   Kris Kortokrax on Dec 06, 2013

   Not arguing at all. That’s the problem with this form of communication. There can be a certain tone intended or not intended on the part of the sender and the opportunity for the reader to infer something not intended or to not infer something that was intended.

   The original poster seemed to be asking how low he had to go for the approach to count. Since he mentioned being with another instructor, I assumed that he was simulating instrument conditions. The definition of when the approach procedure ends would seem to allow one to simulate breaking out prior to the MAP. While undergoing proficiency checks, I have been told (while wearing a view limiting device) that at some point prior to the MAP, I had the airport in sight. Usually because the tower wants us to break off early and begin a circle.

   The question of how much needs to be in IMC seems to be an issue that would come up while conducting approaches in actual IMC during normal operations. These still count for currency even though the purpose of the flight is not practice. I suppose that it is ultimately up to the individual pilot as to which approaches he chooses to count for currency because no one is looking over his shoulder to see how much was flown during actual conditions.

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