Interestingly, this is an area of the regulations which has seen much revision and debate in the past twenty years. In 1990, the FAAviation News ran an article stating an approach must be flown to its minimums in order for it to count towards currency. A reader, however, pointed out that it would be difficult to log any approaches considering most IMC approaches break out before MDA. The FAAviation News replied to the commenter in a later issue, “Once you have been cleared for and have initiated an approach in IMC, you may log that approach for instrument currency, regardless of the altitude at which you break out of the clouds”. This definition brought upon a whole new problem because if a pilot was “cleared for and initiated” an approach in VFR conditions, but flew the majority of the approach in IMC the approach was considered unloggable. Realizing their mistake, in 1992 the FAA legal counsel noted “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.” Okay, so now it sounds like if you don’t go missed, you can’t log the approach. On the other hand, this revision does not say that the entire approach must be flown in actual IFR meteorological conditions.
Now we have a group of instrument pilots who are wondering if the FAA will ever bring more clarity than confusion to this discussion. These pilots call themselves the Rule of Reason group, and as suggested by their name, they decide to use their own basic reasoning when logging approaches. Rule of Reason members will log an approach if the IMC involved was enough to demand one to use their instrument piloting skills, or as aviation author Bob Gardner has put it, “You are the best judge of whether an approach has made you a more proficient instrument pilot or has just allowed you to fill a gap in your log.”
When Part 61 of the Federal Aviation Regulations was revised in 1997 it was proposed that the rule be rewritten to require approaches to be flown to MDA or DA to be eligible for currency. The FAA received many suggestions such as, “The definition should be revised to allow the pilot to cease the approach prior to MDA or DH for safety concerns.” Another pilot suggested that “instrument approach” be defined as “An approach outlined in Part 97 and carried out in compliance with that procedure, or as directed by air traffic control to a point beyond the initial approach fix for that procedure.”
The FAA decided against the rule revision, and left it simply as:
§ 61.57 Recent flight experience: Pilot in command. (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: (i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of navigation systems.
Despite the final vagueness of this regulation, many suggest the FAA decided against further revision because they support the “Rule of Reason” definition. Today the majority of instrument pilots log approaches for currency if they feel the procedure maintained or developed their instrument flying skills. Personally I think it is safe to play by a rule of “log what you want, fly what you need” when it comes to approaches. Additionally if you are ever in question of your own instrument piloting skills don’t hesitate to hire an instructor for a currency check. This is one way to get an instrument currency without concerning yourself over the regulations definition. A final alternative would be to bring a second pilot along so you can use foggles or an instrument hood to fly six simulated approaches to minimums. No matter your method, instrument currency should be handled with personal skill level, and operating safety as precedent concerns.
I was told during my training, and it has served me well since, that for an approach to be used for currency, it had to be conducted to somewhere past the final fix (FAF). So, whether vectored or folowing a transition path, if you established on the final course, met the FAF and descended along the published course, it was a useful approach – whether you broke out at minimums or just 100 feet below the FAF. Those are the ones I log, and they are also the ones that keep me sharp.
I like the motto of “log what you want, fly what you need”. i also like the attitude of ‘ if you are wondering whether you are current enough, you likely are not’
Of course, so long as nothing goes wrong, none of this matters, right?