CFII currency

[bobbysamd]

Sole manipulator v. perform

what's the difference between "sole manipulator of the controls" and "perform"?

14 CFR 61.57(a), (b) and (e) reference "sole manipulator." All of these sections discuss takeoffs and landings. 14 CFR 61.57(c), which we're discussing, references instrument procedures. That's where I see the difference.

I learned in my legal writing class in paralegal school that one should use the same terms throughout a piece because changing them within the piece could confuse meaning. 14 CFR 61.57 has undoubtedly been redrafted several times, but maybe several drafters were involved in writing it.

 

[midlifeflyer]

bobbysamd wrote:
14 CFR 61.57(a), (b) and (e) reference "sole manipulator." All of these sections discuss takeoffs and landings. 14 CFR 61.57(c), which we're discussing, references instrument procedures. That's where I see the difference.

Ah, so "sole manipulator" means "sole manipulator" only when we're talking only abut takeoff and landing currency, logging PIC time, glider towing currency and instructor requirements under Part 142. And "perform" means "sole manipulator" but only for approaches.

Hmmmm....

Can you tell me what "is" is?

 

[midlifeflyer]

Just came across a post in another group discussing this.

Are there approaches that =require= more than one pilot to perfrom them?

 

[WMUSIGPI]

Sounds like everyone has thier own opinion. It also sounds like it is time that the FAA put together a website like the Lynch site and make the answers official, legal, and binding rather than leaving everyone to make up thier own opinions and decide which is right after the fact.

As for logging issue, I agree that logging students' approaches in actual is legal for currency (at least today it is... who knows tomorrow) and yes I also log all of my students landings...BUT NOT FOR CURRENCY... I try to keep my log entries as close as possible to my students. Rather than just write in instrument training I actually list which approaches were flown or commercial training I list which maneuvers, and as part of that I list every landing done on the flight. I specifically do a night flight with 3 full stop landings within every 90 days to show currency. I don't think it's right to "steal a landing" on a dual flight to keep myself current or to count a last moment grab of the yoke to save a bad landing as a landing for currency. Besides that is only half the requirement anyway, you still haven't done 3 takeoffs that way.

As far as instrument currency I think that everyone should do a 6 month IPC and put an end to the 6 approaches and holding stuff.
A person that hasn't flown IFR in 10 months that then grabs a friend and does 6 approaches and a hold and tracking (hooded)isn't safe to be flying IFR most likely. But they are legal. And the same thing might hold true for a CFII but as the rules are today both can and do take off into the clouds legally.

 

[cjh]

Can you tell me what "is" is?

Hey, he never said he was playing the part of a president!

And on that subject, could someone please tell Martin Sheen that he is.

 

[cjh]

Just came across this in another Q&A. To further muddy the waters, you'll note this response makes clear the intent of 61.57 is to be hands-on! The answer makes no exception for any subset of 61.57 or certificate held, and the questioner specifically references the inability to log approaches.

"QUESTION: I recently upgraded to captain and have a question regarding the logging of flight time. My question is: As the PIC, when I’m not the flying pilot, should I be logging night and/or instrument flight time? Obviously the approaches can't be logged, but I'm wondering if the actual instrument time can be logged. Same goes for the night time.

ANSWER: Ref. § 61.51(e)(2) and § 61.57; If you’re a holder of an ATP certificate, and provided you’re “. . . acting as pilot-in-command of an operation requiring an airline transport pilot certificate” then yes you may log actual instrument time and night time while acting as pilot-in-command. But don’t read into that answer, that you can count the time toward meeting the recent flight experience of § 61.57. Because you can’t. Those requirements are “hands-on-the-controls” requirements."

 

[midlifeflyer]

Logging student activities generally

and yes I also log all of my students landings...BUT NOT FOR CURRENCY...

in a separate column? If not, how can someone tell the difference between the ones that count and the ones that don't just by looking at your logbook?

(BTW, I have a different approach on student flights. The only thing that appears in my logbook is the time that counts for me. So long as my student's logbook shows a record of maneuvers that Part 61 says must be logged as a prerequisite for a certificate we're working on, I don't much care what else is put in the student's "remarks" column. My "remarks" column only contains the student's name. I use a separate document, signed by both me and the student as the record of everything covered in the flight.)

 

[WMUSIGPI]

by putting in the remarks section "3 night full stop patterns solo for currency"

 

[WMUSIGPI]

Just came across this in another Q&A. To further muddy the waters, you'll note this response makes clear the intent of 61.57 is to be hands-on! The answer makes no exception for any subset of 61.57 or certificate held, and the questioner specifically references the inability to log approaches.

"QUESTION: I recently upgraded to captain and have a question regarding the logging of flight time. My question is: As the PIC, when I’m not the flying pilot, should I be logging night and/or instrument flight time? Obviously the approaches can't be logged, but I'm wondering if the actual instrument time can be logged. Same goes for the night time.

ANSWER: Ref. § 61.51(e)(2) and § 61.57; If you’re a holder of an ATP certificate, and provided you’re “. . . acting as pilot-in-command of an operation requiring an airline transport pilot certificate” then yes you may log actual instrument time and night time while acting as pilot-in-command. But don’t read into that answer, that you can count the time toward meeting the recent
flight experience of § 61.57. Because you can’t. Those requirements are “hands-on-the-controls” requirements."

That is being asked by an ATP not a CFII so we are not comparing the same thing. The ATP pilot is not acting as and authorized instructor in this example he is acting as a pilot.

But all the more reason to have the FAA come up with an OFFICIAL " Q/A " site

 

[cjh]

Yeah, I realized he was asking as a pilot, not an instructor. My point, although I should have clarified it, was that we have two differing opinions from the same source as to what 61.57 means.

If that particular reg is meant to be applied differently to instructors then it should state that. It doesn't, however, which would lead me to believe that it is meant to be applied equally to everyone looking to maintain currency. I believe that "that person...has performed and logged" doesn't somehow take on a different meaning with respect to instructors than to all other pilots.

Note in comparison 61.51 with regard to logging. Instructors are granted specific, separate logging privileges.

 

[cjh]

No pondering needed.

I can assure you that all of the posters here who feel you cannot log an approach you have not personally performed are not talking about the autopilot. It is a flight instrument just like anything else in the cockpit for which you are responsible. It may be engaged but YOU are responsible for monitoring its function and assuring it's operating correctly. An approach involving the autopilot is no different from an approach using a GPS, HSI or any other piece of equipment that improves the margin of getting down safely. It doesn't count against you for currency and it doesn't effect logging.

Hope that helps!

 

[cjh]

It may be engaged but YOU are responsible for monitoring its function and assuring it's operating correctly.
__________________________________________________

OK...that's the opinion I was hoping for. Now, ponder this:
If an instructor is providing IAP instruction in IFR conditions, isn't the CFII responsible for monitoring "the students" function and assuring correct operation?

Yes

If the approach is unsuccessful and the a/c makes a smoking hole in the ground, wouldn't the CFII be responsible?

Yes

If the CFII says "ok, localizer alive, start your intercept; glide slope alive...more flaps; one dot...lower the gear; etc etc etc, then isn't s/he performing the INTENT of maintaining currency? If you do not have to have your hands on the control wheel during an autopilot approach?????

No

Where is the difference?

One's a pilot who must use his skills in hands-on practice to maintain currency, and the other is a dumb machine. I'll let you figure out which is which.

 

[bobbysamd]

Ofishull FAA Website

It . . . .sounds like it is time that the FAA put together a website like the Lynch site and make the answers official, legal, and binding rather than leaving everyone to make up thier own opinions and decide which is right after the fact.

But the problem with that is the Administrative Law judges evaluate every situation strictly on a case-by-case basis. Unfortunately, and stupidly, precedent isn't binding.

I . . . try to keep my log entries as close as possible to my students. Rather than just write in instrument training I actually list which approaches were flown or commercial training I list which maneuvers, and as part of that I list every landing done on the flight. I specifically do a night flight with 3 full stop landings within every 90 days to show currency. I don't think it's right to "steal a landing" on a dual flight to keep myself current or to count a last moment grab of the yoke to save a bad landing as a landing for currency.

I did the same thing. Another benefit from that practice is your logbook becomes a record of student training. You cover yourself and you can replicate your role in a student's logbook if his/hers is ever lost.

 

[midlifeflyer]

OK...that's the opinion I was hoping for. Now, ponder this:
If an instructor is providing IAP instruction in IFR conditions, isn't the CFII responsible for monitoring "the students" function and assuring correct operation?[/i]

A bit different, but that is a very good point. If Lynch is correct in his interpretation, this could be part of the FAA policy reasoning.

Earlier, 172Driver asked

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

We know that legality doesn't necessarily equal proficiency. So saying "This interpretation is safer" doesn't mean it's the correct one. But sticking with the proficiency issue for a moment, let's turn the question around:

Do you really think you are as proficient flying the exact same approach 6 times in 6 months under the hood in severe clear, doing the full missed once during that period as you would be if you continually monitored and corrected students deviations in actual IMC with your own ticket on the line every time they made mistakes?

 

[TheAmazingRando]

I think that this goes back to the old saying "whats safe is not always legal, and whats legal is not always safe" Personally, I think that you can watch a person fly approaches, chandelles, whatever all day and not gain anything in the way of proficiency. Why do we have logbooks, then? If all we had to do was watch, what would the purpose be then to actually do any flying at all? Anyway just my $.20

That's right 20 cents!