CFII's logging approaches

[ShortFinal]

Just a quick question (hopefully it hasn't been talked about recently).

I remember hearing from another CFI that as a CFII I can long an approach that my student flys as long as it is IMC past the FAF. Is this true? And if so, what FAR can I find it under?

Thanks for your help.

 

[midlifeflyer]

The question may be short, but the answer is often and hotly debated.

John Lynch in the Part 61 FAQ says you can do it.

QUESTION: 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: 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).

He doesn't really explain why. And keep in mind that the FAQ doesn't have any real legal weight (Lynch has been corrected on more than one occasion by the FAA Legal Counsel office), but the best argument that I could find that supports it goes something like this:

1. The landing currency part 61.51 of specifically says "sole manipulator"
2. The instrument currency part says "performed" approaches.
3. The different wording means that you =don't= have the be the sole manipulator in order to log the approach.
4. We're left with the FAR that says that a CFI can log instrument time when teaching in IMC.

The supporting common sense arguments tend to be:

1. That the CFI who is monitoring the student's approach is not only responsible for it (the justification for CFIs logging anything while giving instruction) but is working harder by needing to stay not only ahead of the airplane but ahead of the student.
2. That the CFI who is monitoring the student's approach is definitely doing a lot more in terms of performance than the pilot who is monitoring her autopilot flying the approach and who clearly can log it.
3. The general policy of the FAR is to let CFIs log all sorts of stuff.


The con arguments come down to:

1. The requirement in the logging regulation to "perform" the approach means something more than monitoring another pilot.

2. It's stupid.

 

[bobbysamd]

Gotta love those John Lynch FAQs . . . .

The question may be short, but the answer is often and hotly debated.

The con arguments come down to . . . .

2. It's stupid.

Sure, it's stupid.

Apparently, John Lynch and my former Chief Pilot at FlightSafety in Vero in 1991-'92 are cut from the same bolt of cloth. The Chief Pilot tried to convince us instructors that we could, and should, log our students' approaches for currency. First time that I ever heard that theory in four years of instructing, including the hallowed halls of ERAU, where debates over the FARs were routine and often.

Neither individual apparently was aware of 14 CFR 61.57(c)(1), which sets forth the requirement that the approaches must be performed for them to count for currency:

(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 --

(i) At least six instrument approaches . . . .

(emphasis added)

What's not to understand?? What else can "perform" mean other than having your hands on the controls and shooting the approach yourself? I don't see where there is anything to debate.

Now, you can certainly write the approaches your student executed your logbook. I did, to make a record of the details of the flight. But I was extremely careful to keep them separate and apart from the approaches that I flew.

Think about it. If you follow John Lynch's theory, a busy CFI-I could remain perpetually current without ever having his/her hands on the controls and flying an approach!

I believe my FSI Chief Pilot dug out something from Part 121 to support his theory and/or heard something from the school's (Orlando) POI. He also tried to use a similar theory to blow sunshine up our rears about counting our students' night landings for currency. The long and short of it was he was too cheap to give instructors proficiency time to stay current.

Don't buy this malarkey. Fly your approaches either in actual or hooded with a safety pilot or take a comp check.

Epilogue: This gentleman was ousted as Chief Pilot about six months after espousing his theories - not for that reason, but for others, I'm sure. I was gone two months before his outster.

 

[DrewBlows]

Both of these arguements sound reasonable. Keep in mind that your local FSDO will undoubtedly have its own opinion which it will undoubtedly feel very strongly about. I think a call to your local FSDO would render an answer fairly quickly. I spoke to a DPE about this subject, and he said that I should log only my own approaches for currency. He didn't elaborate, and I didn't ask him to. I figure it's better to err on the conservative side than to rely on an Inspector's opinion on the subject. I'm not trying to say that logging student's approaches is right or wrong, just expressing my experience. Hope it helped.

 

[midlifeflyer]

Re: Gotta love those John Lynch FAQs . . . .

Think about it. If you follow John Lynch's theory, a busy CFI-I could remain perpetually current without ever having his/her hands on the controls and flying an approach!

...as can the pilot of an airplane with an IFR-Certified GPS and coupled autopilot. I watched this being done in a Bonanza and was very impressed.

Drew has the right answer. Both views make sense depending on the viewpoint. Obviously true proficiency demands hands-on flight. But just as obviously, none of the currency regulations guarantee proficiency and there's an strong FAA policy of permitting CFIs to log all sorts of things (with the only absolutely clear exception being landings) merely by virtue of the fact that they're a CFI. My favorite example is the blind CFI who gets to log PIC time.

That's why I just lay it out and keep my opinion on which is right to myself.