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10 Answers

practice IFR appoaches single pilot without a safety pilot?

Asked by: 8277 views Commercial Pilot, FAA Regulations, Helicopter

ok, here's the situation.  I'm a commercial helicopter pilot, flying single pilot air medical helicopters under VFR rules (we do not have an IFR rated helicopter) operating under a part 135 certificate.

so my company wants us to do practice instrument approaches on our own during the course of the operations.  In other words, on the return flight back to the base try to do an approach to the airport. 

However, I contend that this is not legal. In order for me to fly a practice instrument approach I would need a safety pilot.  Some say to use the medical crew members, then I say you can't because they are not pilots, then I get well you can still do the approach you just can't log it.  I tend to disagree, no I can't log it but I say that if I'm trying to fly looking inside at instruments then I'm not seeing and avoiding traffic and it's my responsibility as the single pilot PIC to do so.  

So what do you more experienced smart guys out there think?  Am I legal to fly, as a single pilot, a practice instrument approach under VFR conditions, on a VFR flight plan, without a safety pilot?

 

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10 Answers



  1. Jeff on Feb 22, 2016

    You are correct. Legally you cannot log approaches flown without a safety pilot (and the safety pilot must be rated in the same category of aircraft and have a valid medical). Also, for it to count towards IFR currency requirements, you would need to use a view-limiting device. Obviously you will not be able to see and avoid other traffic, and would be in violation.

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  2. Koehn on Feb 22, 2016

    As pointed out above, you cannot fly instrument approaches in VMC without a safety pilot. While this person doesn’t have to have a current medical or BFR, the regs say they have to be a pilot.

    Good luck with the company; they’re not within their rights to demand you do something illegal to maintain currency. I understand that helicopter time is expensive; maybe they can make it up with a deal at a local flight school and use their birds?

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  3. Mike O on Feb 22, 2016

    as you stated you can’t log it and you can’t use a view limiting device. and that’s where the difference of opinion comes in….some say you can do the approach you just can’t use a view limiting device or log it.

    I’m saying you can’t even do it at all. 91.109 (c) says “no person may operate a civil aircraft in simulated instrument flight unless-”

    operate is the key, even if your not using a view limiting device, if you ask approach for a practice ILS and you fly it (looking inside and outside during the approach) your attempting (in my opinion) to operate simulated instruments without a safety pilot.

    Thoughts?

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  4. John D Collins on Feb 23, 2016

    Koehn,

    The safety pilot is a required crew member and therefore must have a current medical, see 61.3(c ).

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  5. Mark Kolber on Feb 23, 2016

    Mike O,

    You can fly approaches in VMC all you want but without a view limiting device and a safety pilot you cannot log it for currency.

    I have no idea what you are getting at when you say that one is “attempting (in my opinion) to operate simulated instruments without a safety pilot.” Either you are using a view-limiting device that prevents you from looking outside (which the FAA pretty much defines as simulated instrument conditions) and meeting your see-and-avoid responsibilities or you are not.

    Yes, if you are staring at the instruments and not looking outside at all, you are not meeting your 91.113(b) obligations. But that has nothing to do with whether one is flying an instrument approach or not. Pilots flying IFR for real have to and do divide their attention between the instruments and meeting their see-and-avoid responsibilities every day. VFR pilots can violate their see-and-avoid responsibilities without going anywhere near an instrument approach.

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  6. Mark Kolber on Feb 23, 2016

    Ah, I think I see.

    so my company wants us to do practice instrument approaches on our own during the course of the operations. In other words, on the return flight back to the base try to do an approach to the airport.

    IFR is less than 20% flying by reference to instruments and more than 80% about understanding and complying with rules and procedures.

    Your company’s policy sounds to me like simply variation of filing IFR everywhere even on a CAVU day – it keeps your head “in the system” and your procedural knowledge and skill current. Flying an IAP is more than not seeing out the window. It involves understanding the elements of an approach, how to brief an approach, how to request the appropriate approach based on airport and runway, how to get from the enroute environment to the approach, when a procedure turn is and is not required, compliance with ATC instructions, and a whole bunch of other stuff.

    Yes, those tasks take on an additional element of difficulty when you can’t see out the window. That’s why the FAA requires them to be done in actual or simulated IMC for currency purposes. But that doesn’t not negate the value of doing them “for practice” even on a clear, cloudless day.

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  7. Mike O on Feb 24, 2016

    I know I can’t log it for currency, just wasn’t sure if it was legal at all even without foggles to be practicing the instrument approaches without a safety pilot on board.

    We are a vfr only program but they want us to practice approaches because if you go iimc you’ll need to be proficient. We all know that there’s a huge difference between currency and proficiency.

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  8. Mark Kolber on Feb 25, 2016

    It’s not illegal, Mike. Any more that flying a SID or STAR on a CAVU day is illegal.

    But what I’m curious about though, is why you would think flying a series of published headings, courses and altitudes using navigational aids for guidance would be illegal.

    That is not a flame. I ask this question often to help my own understanding.

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  9. Mike O on Feb 25, 2016

    I guess maybe I was hoping it was so that I could attempt to get my employer to give us real ifr training. While we are a vfr program, going inadvertent imc is a killer to ems helicopter pilots mostly because we fly low level into areas with little to zero weather reporting with little notice.

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  10. Mike O on Feb 25, 2016

    Some legs by me can have over 60 miles with no weather reporting. We launch within 5 minutes of a call there is no time to plan it’s all on the fly.

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