It drives me a little crazy that the Code of Federal Aviation Regulations is so vague on so many crucially important points.
For example, the regs say private pilots can share certain flight costs with passengers. The rule seems pretty straightforward. It’s not until you come across up various “legal interpretations” by FAA lawyers that you read terms like “common purpose” and “holding out” that add specific nuances that don’t exist in the actual regulations.
The same legalese applies to logging approaches for instrument currency. The regulations say you must perform six instrument approaches in the preceding six calendar months, under actual or simulated conditions, to maintain your instrument currency.
But the regs never spell out what that really means. Do the approaches that are flown in actual conditions have to be to minimums? What about simulated approaches under the hood?
Many pilots make up their own interpretations of what the regs mean, but the only one that matters is the FAA’s definition. The agency issued a legal opinion over 20 years ago on this point, and followed up recently with a more specific legal interpretation. Here’s the deal, spelled out in this FAA InFO letter issued last month.
When flying in simulated conditions under the hood, you must continue under the hood all the way to DA or MDH for the approach to count for currency. When flying in actual conditions, you must be in IMC when you start the approach and remain in IMC until passing the Final Approach Fix for the approach to count. If you break out into the clear at any point after the FAF but before DH or MDH, the approach counts.
It’s important to note, however, that you must fly all segments of the IAP except the missed approach for the procedure to count. While the FAA “recommends” pilots fly the missed approach procedure, it’s not a requirement for currency.
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