The great thing about the FAA IR 6/6 rolling currency is that it is easy to stay legal in the normal course of flying. It gives the pilot the opportunity to do his own risk management, via risk compensation.
I log about 3x the required number of approaches, so even a low-time pilot should have no trouble logging the 6. What is hard is to maintain this rolling currency if you are flying hardly at all, especially if you are renting, especially if your home airfield is VFR-only.
I much prefer it to the JAA/EASA annual IR test which is just a hassle. I have to do that as well and have to get the DfT/CAA permission for it (GBP 70 or so, reportedly) because the IRE is being paid in an N-reg in UK airspace. Admittedly he also signs off my PPL class rating (every 2 years) which saves a flight with an instructor. Actually I skipped the last IR reval flight (Dec 2014) because of the April 2016 derogation in EASA’s attack on N-regs, and the UK CAA is now (again) allowing the IR to remain valid for up to 7 years if you are current on another ICAO IR. I will probably do the IR reval in December.
So, back to the topic, the FAA is saying they want to see some IMC around the place, around the start of the IAP. I wonder how they could prove/disprove that retrospectively? A METAR of CAVOK is not useful because almost every IAP has a portion more than 5nm from the airport…
Peter wrote:
I log about 3x the required number of approaches, so even a low-time pilot should have no trouble logging the 6. What is hard is to maintain this rolling currency if you are flying hardly at all, especially if you are renting, especially if your home airfield is VFR-only.
I strongly disagree. If you’re at a VFR airport and a lot of your preferred destinations are VFR airports and your main reason for flying IFR is the ease of planning and enroute flying, then it can be very difficult to maintain the rolling currency.
I have asked quite a few FAA pilots in Europe about this and several have admitted to me that they have probably gone out of the rolling currency at some point and in general don’t check for this.
If one is of the opinion that a currency requirement is necessary at all, then I very much prefer the EASA way of doing it. I personally do not block the approach segment of a big and busy airport on a CAVOK day with my pointless IAP just to stay current. I always try to get to the ground as fast as possible and not be a nuisance to anybody and given that most of my flying is in nice weather, this means that I very often do not fly the IAP.
I also found the 6 approaches hard to get to when I had my plane and flew it regularly, but I’m in Californa where the weather normally is CAVOK, which doesn’t help. But what really is impossible to just “get”, is the single hold. I had to ask ATC to randomly give me a hold of his choice in the middle of nowhere just to comply. Unless you go missed (which is also rare), or do a hold-in-lieu-of-a-procedure turn, one just doesn’t get holds very often.
Well, just do a hold (wherever) on any VFR flight. Yes, you need to have a safety pilot on board for that, at least in theory.
Once again, re the “validity” of approaches for currency purposes: I am rather sure that in the context of IFR approaches, the final approach starts at the final approach fix. What’s before that is the initial or intermediate approach. So again: IMC at the FAF is what’s required.
I wonder how they could prove/disprove that retrospectively?
Not really possible. But do they want to? It’s just that this question was asked to the FAA and that circular tries to give an answer. Nothing more.
If you really have to be in IMC on the FAF, then the FAA give a very unfair advantage to the Brits! 
I would estimate that I have done 3 approaches this year where I was in IMC at the FAF. Out of maybe 30 IAPs.
Yes, but it’s a purely theoretical disussion (one more time…).
On a given flight, one would log say “1ILS at xxxx” and then also log say “0.2 hours of IFR conditions”. This record doesn’t even say where the IMC occured. Could have been 3 hours before shooting the approach.
For “European” pilots, it is even more absurd: Most of us don’t even log “flight time under instrument conditions”, only “flight time under IFR”, because that is how Europe works. I agree that pilots with dual licenses should probably log both, but most don’t. So when I fly an IAP under VFR, with a safety pilot on board, then I will not log any IFR time (it was VFR) and no IMC time (since I don’t do that), even though the above circular says that approaches don’t count if you don’t log at least some IFR time on those flights where you flew an approach that you’d like to log.
The FAA could always catch most of us on these details, if they wanted to.
achimha wrote:
If one is of the opinion that a currency requirement is necessary at all, then I very much prefer the EASA way of doing it. I personally do not block the approach segment of a big and busy airport on a CAVOK day with my pointless IAP just to stay current. I
Note the FAA rolling requirement isn’t the only way to do it in FAA-land: you can also fly with an instructor or examiner if you’ve not been able to do the rolling currency. So you have essentially the best of both worlds.
If that’s the FAA’s true interpretation, then not even airline pilots will be able to meet it. I suppose it’s a little better than IMC at minima, which was a previous interpretation. Just log what you need.
alioth wrote:
Note the FAA rolling requirement isn’t the only way to do it in FAA-land: you can also fly with an instructor or examiner if you’ve not been able to do the rolling currency.
If FAA IFR currency expires, an IFR rated pilot can fly approaches with any pilot rated for the flight, under the hood if its VMC. I act as safety pilot with a friend a couple of times a year because he doesn’t have a need to file his flights very often. Depending on conditions and time available we may do all the approaches required in one flight, generally into 3 or 4 local airports. The airports like it because they keep track of movements to support their funding, at least those with ATC.
It gets me out and about, and (more importantly) his wife puts on a nice hangar dinner after the flight 
Some people in reality don’t bother with the hood in VMC, as per Adam’s post.
boscomantico wrote:
So when I fly an IAP under VFR, with a safety pilot on board, then I will not log any IFR time (it was VFR) and no IMC time (since I don’t do that), even though the above circular says that approaches don’t count if you don’t log at least some IFR time on those flights where you flew an approach that you’d like to log.
In this case you don’t need to log IMC time, you just note the name of the safety pilot in your logbook.
AdamFrisch wrote:
If that’s the FAA’s true interpretation, then not even airline pilots will be able to meet it.
I haven’t gone into detail as to how it works and how useful it is, but as I am currently studying for the FAA IR theory, I came across this paragraph in 14 CFR §61.57 which talks of exceptions for airline pilots:
(2) This section does not apply to a pilot in command who is employed by an air carrier certificated under part 121 or 135 and is engaged in a flight operation under part 91, 121, or 135 for that air carrier if the pilot is in compliance with §§121.437 and 121.439, or §§135.243 and 135.247 of this chapter, as appropriate.
