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FAA Clarifies Logging of Instrument Approach Procedures

“What constitutes a ‘loggable’ instrument approach?” is the question that the FAA addressed in a recent InFo statement.   The statement was issued after recent requests for clarification and legal interpretations concerning the six instrument approach procedures (IAPs) that an instrument-rated pilot must log every six months in order to maintain his or her IFR currency, as required by FAR 61.57(c): “Instrument Experience.”

Generally stated, FAR 61.57(c) provides that a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if, within the six calendar months preceding the month of the flight, that person performed and logged at least six instrument approaches, holding procedures and tasks, and intercepting and tracking courses through the use of navigational electronic systems. Meeting the requirements of the FAR through the use of an aircraft, as opposed to a simulator or other trainer, requires that the flight be performed “in actual weather conditions, or under simulated conditions using a view-limiting device.”

According to the FAA, a pilot may log an IAP for currency or training when the pilot accomplishes the IAP in accordance with several conditions. The pilot must operate the aircraft solely by reference to instruments, in actual or simulated instrument meteorological conditions (IMC). To log the IAP, the pilot must be established on each required segment of the IAP to the minimum descent altitude (MDA) or decision altitude/decision height (DA/DH).   

Typically, to log the IAP pilots must execute the entire IAP commencing at an initial approach fix or associated feeder route and fly the initial segment, the intermediate segment, and the final segment of an IAP. However, the pilot may receive actual or simulated radar vectors to the final approach course or be otherwise directed through an appropriate air traffic control clearance to a specific IAP and still log the approach. The missed-approach segment does not have to be flown for the IAP to be logged, although the FAA encourages doing so for proficiency purposes.   

The FAA does not require the ceiling to be at MDA or DA/DH during a flight in IMC. The approach may still be logged if an aircraft maneuvering in IMC transitions from IMC to visual meteorological conditions (VMC) on the final approach segment of the IAP prior to or upon reaching MDA or DA/DH.   

If the operations are conducted in simulated IMC, the simulated IMC must continue to MDA or DA/DH. The FAA noted that if a flight in simulated IMC deviates from the final approach segment for safety reasons such as traffic avoidance, the pilot may still log the IAP as long as the aircraft has passed the final approach fix. The FAA further noted that simulated instrument conditions require that the other control seat be occupied by a safety pilot with a current medical certificate who is appropriately rated in the aircraft, and the pilot operating under the simulated instrument conditions must also log the name of the safety pilot.     

Jared Allen

Mr. Allen is AOPA’s Legal Services Plan (LSP) senior staff attorney and is an instrument-rated private pilot. He provides initial consultations to pilots through the LSP when the FAA has contacted them about potential FAR violations. Jared has helped numerous pilots successfully navigate through compliance actions.

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