FAA IFR Currency - exact requirements for the 6/6 IR rolling currency (merged)

then not even airline pilots will be able to meet it.

Airline pilots are not flying under Part 61. They are flying under Part 121 or something like that and that has different rules. So for example they also don’t need to worry about having done the 3 night takeoffs and landings for passenger carriage at night.

In the US, we log either simulated instrument time or actual instrument time. There are no provisions for logging IMC. IMC and actual instrument time are not synonyms. IMC is simply anytime the conditions don’t meet the definition of VMC, which are defined in terms of cloud separation requirements and visibility. So 500 feet above a solid cloud deck in class E airspace with the visibility 100 NM is IMC. I spent a good part of an hour discussing the SAFO with the author, actually, he was more like the herder of cats responsible to produce a document that was acceptable to everyone in the FAA and the user community. The one piece of advice he gave was the document has to be read in its entirety and that a single sentence does not stand alone.

There is a formal definition for IMC, but there is none available for what constitutes actual instrument conditions. Simulated instrument conditions are defined as those where there is a view limiting device used by the pilot so that he must control the aircraft solely by instruments. My definition of “Actual Instrument Conditions” is:

Conditions such that manual control of the aircraft may not be accomplished by visual means and that manual control of the aircraft to maintain the desired attitude, altitude and track requires using the flight and navigation instruments.

In the US, if you are RNAV equipped, most RNAV approaches have a hold in lieu of a procedure turn, so it is easy to log holds.

This SAFO was written because of the large number of opinions on the topic that were being requested of the General Counsel and the desire to limit them in the future.

With regards to enforcement, there is nothing to prove what the conditions are for a given approach. I would presume that at least some actual instrument would be expected to be logged anytime that an instrument approach was logged, but no proof of conditions is needed to be logged. If the FAA has reason to examine the logbook of a pilot, there is usually more at issue. The guidance from the SAFO is trying to answer the common questions for what is able to be logged that meets the currency requirements.

Peter wrote:

On my reading, it doesn’t clarify anything as to what weather is required to be present. It does seem to say that you cannot log the approach in CAVOK conditions But nobody I know does that anyway.

So the visibility is 100 NM, it is a moonless night, the stars are hidden by a high thin cirrus layer, you are approaching over water and the destination airport that does not have approach lights, just dimly lit runway lights, the surrounding area is absolutely without lights on the ground. You are flying an approach which is oriented 90 degrees to the runway and requires a circle to land maneuver to align your aircraft with the runway. The runway has tall trees on either side of the runway to block your view of any runway lights until you are fairly close to the runway. Under all definitions, these are beautiful VMC conditions. I would say you are flying under actual instrument conditions or better be and probably won’t pick up the runway lights until you are close to the airport and well past the FAF and already at the MDA.

I would meet all 5 conditions, although 3 and 5 would not be applicable. I would log the time as actual instrument conditions.

Of course I agree with you

I have often said that night flight, on a genuine dark night, is 100% instrument flight. It’s a strange paradox that you can do it legally on a plain PPL…

Peter wrote:

It’s a strange paradox that you can do it legally on a plain PPL…

Well, you need a Night Qualification and that includes attitude flying. There are no IFR procedures you need to flye in night VFR.

Anyway, you can also find yourself in a 100% instrument flight situation in broad daylight VMC, e.g. over the sea in moderate visibility or on top of a slanting cloud layer.

Yes, there is more than one paradox is the way flight training is structured

IMHO the structure is based more on the requirements of flight training as a business for the general public. Let’s face it – airline pilot training is a bundled VFR+IFR package. Same AFAIK with the (active) military.

One exception to the above POV is aerobatics, which justifies a purely VFR flight training product.

Peter wrote:

I have often said that night flight, on a genuine dark night, is 100% instrument flight. It’s a strange paradox that you can do it legally on a plain PPL

When I was a student pilot (living in Texas) my instructor took me to Galveston Scholes for night flying instruction. Taking off to the south towards the Gulf of Mexico (which is just off the end of the runway), as soon as you rotate you’re pretty much like in IMC on a moonless night. Actually, it’s effectively IMC sometimes on a perfectly VMC day if there’s a bit of haze.

I know exactly what you mean but your terminology is not accurate.

alioth wrote:

Taking off to the south towards the Gulf of Mexico (which is just off the end of the runway), as soon as you rotate you’re pretty much like in IMC on a moonless night. Actually, it’s effectively IMC sometimes on a perfectly VMC day if there’s a bit of haze.

IMC is defined as:

INSTRUMENT METEOROLOGICAL CONDITIONS− Meteorological conditions expressed in terms of visibility, distance from cloud, and ceiling less than the minima specified for visual meteorological conditions.

I would agree if you had said:

Taking off to the south towards the Gulf of Mexico (which is just off the end of the runway), as soon as you rotate you’re pretty much like in actual instrument conditions on a moonless night. Actually, it’s effectively actual instrument conditions sometimes on a perfectly VMC day if there’s a bit of haze.

The conditions are VMC and not IMC as you have described them.