CFII currency

[cjh]

Thanks, but I'm not certain we do agree.

So, let me make it perfectly clear that I do NOT believe an instructor can log a student's approach just because it's done under instrument flight conditions. I don't care that the current FAQ, which "yes" I posted above, says otherwise. I don't find the supporting documentation in the FAR to back it up. So what if you have to be on your toes, so what if you're doing most of the work. You're a flight instructor and those two statements cover the initial training aspect of any maneuver. Granted the lack of VMC conditions adds to the sweat factor, but are you only slightly less dead if you screw up in VMC?

Below is the reg that covers logging of instrument flight time. Forget about 61.57, which covers currency. We're talking about logging and that's covered only under 61.51. Show me where, in 61.51(g) it says you, as a flight instructor, can log anything more than instrument flight time, given instrument flight conditions.

61.51(g) Logging instrument flight time.
(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

(2) An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions.

(3) For the purposes of logging instrument time to meet the recent instrument experience requirements of § 61.57(c) of this part, the following information must be recorded in the person's logbook --

(i) The location and type of each instrument approach accomplished; and

(ii) The name of the safety pilot, if required.

 

[midlifeflyer]

We all know that John Lynch's FAQ has been wrong before and it will be wrong again.

But, strictly as a matter of interpretation (not necessarily wisdom), he is arguably correct. I don't know what his thinking is, but notice that =only= landing currency under 61.57(a)&(b) require the logger to be sole manipulator.

If the FAA intended that the CFII be the sole manipulator, the section would have used that language.

Note that "perform" is also used in the landing currency regs. In order to count, the landings must be "performed" with the pilot at sole manipulator. This also suggests that "perform" means something less than "manipulate the controls.

Without the sole manipulator language, we're left with the general 61.51(g) rule that an "instructor may log instrument time when conducting instrument flight instruction in actual instrument flight conditions."

Might simple be another case of what's legal isn't necessarily safe.

 

[cjh]

I disagree.

61.51(g) makes no provision for an instructor logging a student's approaches. Instrument time is allowed for "actual" conditions, but there is nothing there that allows the instructor to glom onto the student's performance of an approach for the purposes of logging.

Looking at 61.57(c), the key is the reference to the person who wishes to maintain currency. The language indicates that *that* person must be the one to *perform* and log the approach. Either the instructor is performing the approach and the student is watching or the student is executing the approach and the instructor is instructing. They can't *both* be executing the same approach. Assuming the student is logging approaches, the instructor cannot also log the same for his/her own currency. Neither 61.51 nor 61.57 support doing that.

61.57(c) is listed below, with emphasis added by me.

So, I still contend there is no supporting language for CFIIs taking their students' approaches for their own currency.

As for the argument that an instructor is soooo involved in keeping it all together, if your family were on a flight where an approach was being shot to mins, who would you rather have flying it. The guy who's actually executed them time and again, or the guy who's *watched* them exectued repeatedly. As an instructor you may be really involved, and working hard, but there's still no substitute for hands on practice.

-------------------
61.57(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:

(1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or flight training device that is representative of the aircraft category for the instrument privileges sought --

 

[CitationLover]

can't we all just get along?

172driver....using your logic can an airbus captain log an approach for 121 currency if using a cat-iii autoland?

 

[avbug]

The FAA did not make a mistake on the language. One must have performed the approach.

As observed previously, one must consider the circumstances of the approach.

One cannot simply claim the approach as an instructor, or as PIC. We are all aware that commonly circumstances exist in which one may be PIC, but may not be able to log the time, so that's no justification. However, this is an issue of performing, rather than manipulating.

One may fly a coupled approach via the autopilot, doing little more than monitoring, and may count the approach. In fact, for currency under certain parts for certain operations, it's required. Quite obviously, when not actually physically manipulating the controls, one may still utilize the approach for meeting the recency of experience requirements as outlined in 61.57.

In the case of a student, if the student is able to fly the approach and does so, then the student has executed and performed the approach, and you may not log it. Consider the spirit of the regulation here, which speaks to proficiency. No legal interpretation has been assigned on this subject, but the intent of the regulation is clear.

If the student is essentially an extention of the instructor, with the instructor working the student to fly the approach, then the instructor may be said to have performed the approach, even though the student may have manipulated the controls (with help).

A good rule of thumb, however, is to refrain from logging approaches flown by another individual, regardless of your function in the airplane (instructor, PIC, PNF, captain, hairy knuckled drooler, whatever).

My personal policy is that I don't log an approach or a landing that I don't fly.

 

[JediNein]

The 2000 hour IMC logged pilot may not catch everything either. How long has it been since that last IMC flight? Are those hours monitoring an autopilot and never needing to put down the cup of coffee? Or is there a freight dog in the other seat, putting on some more polish before the next interview?

Spatial disorientation can hit anyone. There's an airline pilot that crashed a 172 in Arkansas, got into the clouds and lost it. Then there is the flight instruments, vaccuum pump, and other things that will go wrong. It's sooo much easier to back up a student's judgement of instrument failure, than have to go from magazine to scanning...

Fly SAFE!
Jedi Nein

 

[cjh]

One cannot simply claim the approach as an instructor, or as PIC. [/I]

However, unfortunately the FAQ site says in instrument conditions the instructor can do just that, "co-claim" the approach. I posted the Q&A earlier so will not repost it here. While any number of us disagree with the opinion, as long as it sits out there any number of CFIIs will point to it to justify logging approaches they have not performed. No skin off my back, I don't and won't, but it is the point we're discussing.

One may fly a coupled approach via the autopilot, doing little more than monitoring, and may count the approach.

Yeah, I forgot the "autopilot defense". I get so tired of the autopilot being referenced in these discussions like it's a second (or third) PF. "I don't understand how we could have crashed, the autopilot was flying the plane!"

In the case of a student, if the student is able to fly the approach and does so, then the student has executed and performed the approach, and you may not log it. Consider the spirit of the regulation here, which speaks to proficiency. No legal interpretation has been assigned on this subject, but the intent of the regulation is clear.

Apparently not clear to everyone, including John Lynch!

If the student is essentially an extention of the instructor, with the instructor working the student to fly the approach, then the instructor may be said to have performed the approach, even though the student may have manipulated the controls (with help).

No different from landings. Only one person gets to do the logging.

A good rule of thumb, however, is to refrain from logging approaches flown by another individual, regardless of your function in the airplane (instructor, PIC, PNF, captain, hairy knuckled drooler, whatever).

My personal policy is that I don't log an approach or a landing that I don't fly.

Amen!

 

[cjh]

jEDI,

All the more reason to maintain currency using only approaches you actually fly, not those you observe.

 

[avbug]

Even Mr. Lynch is crystal clear on the spirit of the law, which speaks to safety. The intent of the regulation is that a pilot remain proficient.

The FAQ site, as discussed before, does contain known errors, and in some cases, does not agree with legal interpretations. Legal interpretations represent the stand of the administrator, are regulatory, and are defensible in court. The FAQ site is not.

A flight instructor who stakes his or her actions on the FAQ site, may do just as well asking someone at the FSDO, or taking a clipping from Flying magazine. All good entertainment, but none defensible, or authoratative.

Personally, I prefer the little plastic 8 ball that you turn over to get a message in the blue goo underneath. I live by what the 8 ball says. So far it's stymied my career, cost me a bank account and a marriage, but one of these days I'm going to pick it up, and it will be right...and then it's my turn to laugh.

 

[JediNein]

I work harder and scan far faster when I'm observing a student than when I'm the one flying. I've never had to rely on going out to keep current as I always am quite sharp and legally current just by flying in southern CA. If it ain't the ***** Tule Fog, it's the **** coastal fog.

Fly SAFE!
Jedi Nein