CFII currency

[WMUSIGPI]

Can a CFII log FOR IFR CURRENCY the approaches, tracking, and holding that the student does while in IMC?

 

[172driver]

NO. To be IFR current, you must have performed and logged 6 approaches within the preceding 6 months. Many CFI's seem to interpret their instruction as performing the approach. Dangerous ground if you ask me.

1. Do you really think you are as proficient teaching approaches as you would be if you flew them?

2. Can you prove that to the FAA if the chit hits the fan?

 

[cjh]

Although I agree totally with 172driver's comments, unfortunately the current FAQ indicates otherwise. I've posted the current opinion below. Because I agree that the interpretation is not supported by 61.51 language, I've also included Doc's (of Doc's FAR Pages) opinion on this issue. (If you're not familiar with Doc's web site, it is THE place to get accurate information on reg interpretation. http://www.propilot.com/doc/logging2.html.)

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From the FAA FAQ web site:
QUESTION 2: Am I correct in understanding that a CFII may log approaches that a student flies when those approaches are conducted in actual instrument conditions? Is there a reference to this anywhere in the rules?

ANSWER 2: Ref. §61.51(g)(2); Yes, a CFII may log approaches that a student flies when those approaches are conducted in actual instrument flight conditions. And this would also permit that instructor who is performing as an authorized instructor to “. . . log instrument time when conducting instrument flight instruction in actual instrument flight conditions” and this would count for instrument currency requirements under §61.57(c).

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From Doc's FAR Pages, in response to someone asking the same question:

I strongly disagree with the FAA's policy on allowing a CFI to log approaches flown by someone else. There is simply no legal basis for it in the FAR (See the link below). Yes, I know that the FAA has issued a policy through the AFS-640 site, and you can follow that until it is changed, if you wish.

But let me ask you a couple of questions. Why would you want to log the trainee's approaches as if you had flown them? Do you want to base your instrument proficiency on someone else's ability to fly?

I certainly cannot support and will never support basing instrument currency on someone else's instrument approaches. But, the FAA certification folks will (presently) allow it as stated on the FAA AFS-640 site and as quoted by Scott. However, that policy could change at any time. And we still do not know if the FAA Chief Counsel agrees with that position or whether you would be protected if there ever was a violation alleged based on the fact that you were maintaining currency on the back of someone else. Again, the current policy is not legally supported in the FAR. The FAR allows you to log instrument TIME, but is silent as to approaches (FAR 61.51(g)).

As for logging landings, the FAR (and the FAA AFS-640 BBS) are clear. In order to log landings for recency of experience, you must be the "sole manipulator of the flight controls" -- e.g. you cannot log student-flown landings (see FAR 61.57).

 

[172driver]

Logs the time as PIC...yes. 61.51(e)(3)
Logs the instrument time...yes. 61.51(g)(2)
Logs the approach...no. 61.57(c)(1)

These areas are covered by different regulations and should not be lumped together as such. How can a CFII say they performed the approach if they never touched the flight controls? You can make an argument for 'teaching' meeting the requirement for 'performing' but I sure wouldn't want to stand up in front of the FAA Chief Counsel and do so.

 

[172driver]

Keep in mind that a question and answer IS NOT a legal interpretation.

Falcon, where'd you go?

 

[cjh]

172driver,

The other poster apparently decided to delete his comments.

I totally agree with being unable to log a student's approaches no matter how "involved" you as a CFII are with the safe landing (or miss) of the aircraft. 61.51 does not say anything that would support logging approaches. It only speaks to the ability to log the time in actual as instrument time. I have never understood the logic behind the FAQ position.

 

[cjh]

True a Q&A is not legal interpretation, but it does provide insight as to the thinking of the FAA folks, at least until changed! Obviously when one is looking for guidance and direction, short of waiting months for a response to personal correspondence, one looks to the FAQ site for the current trend in thinking.

 

[tarp]

"1. Do you really think you are as proficient teaching approaches as you would be if you flew them?"

I think this is why the FAA used "performed" instead of the usual "as sole manipulator", etc. It may be up to the person doing the performing.

As to your question, when I have a 2,000hr instrument pilot and am doing an IPC or other review, I'm not performing anything. When I have a 6hr instrument student, seeing the inside of a cloud for the first or second time, I'd say I'm performing quite a bit.

My hands may not be on the controls but if I'm watching every move to make sure that the holding pattern entry is correct, that the holding pattern is flown within specs, that we intercept radials, make calls, time, brief, descend, etc, etc - then I'd say I'm very proficient. That little bump on the right hand side of my yoke wasn't turbulence, it was me getting the airplane nudged back in the cross-hairs.

So my answer is that when you are flying in real IMC on my ticket and I'm sweating the details, you bet it's my approach and my IFR time. If it's not IMC or I'm just sitting back watching a very adept person fly the plane correctly, then I can't justify logging that one. My log book shows at least 6 approaches where I've done the work.

There are people out there that never uncouple the autopilot until they can see the ground. So I guess they didn't "perform" the approach and shouldn't count it. I guess all our 135 FOs better get out there and start "performing" some approaches because they are mostly illegal. (At least at carrier's that only have 12 month recurrent for FO's.)

I'm thinking the FAA won't have a problem with my logbook.

 

[banned username 2]

I agree with Tarp & cjh....

If it is in IMC and the student does not have an Instrument rating, then they are operating on my ticket, I am the PIC and I have the ultimate authority over the vehicle and the procedure flown...

Again, the FAA chose NOT to use the phrase "Sole manipulator of the controls" in this instance.. I don't think that was an oversight on their part, I think it was intentional for this very reason...

(my previous posts were deleted through my own stupidity, tried to combine them into one, didn't work and ended up deleting both on accident)

 

[172driver]

I'm thinking the FAA won't have a problem with my logbook.

You're probably right, at least until you do something wrong. If you screw up while IFR -- violate separation, miss a clearance, stray into a TFR, violate an altitude, bend something, etc. -- they will hang you with it if all you have to show for currency is your students' approaches. Just my opinion.

I have taught many primary IFR students and I was definitely working as hard as them to teach the approach and keep the airplane where it needed to be. So, I see your point. However, I still believe the most conservative method for logging time is the safest.

I choose to follow the regs as I see them written rather than interpreting them for my convenience. A CFII without an MEI can give instruction in a twin according to the FAQ's but I would never do it. Reason...if I have an engine failure and things go badly, they will point to the reg that says in black and white that I should not have been giving instruction in that airplane.