Logging Approaches

[ilkwamh2]

As a CFII, is it legal to log an instrument approach when in Actual conditions teaching an instrument student/CFII student even though I'm not actually flying the airplane???

 

[Flying Illini]

Do you log PIC when in IMC when teaching a CFII even though you aren't flying?

 

[avbug]

You may log PIC, but you may not log the approach for currency.

 

[Flying Illini]

Avbug's got a good point there. Are these being logged for currency or just for the sake of logging them?

 

[avbug]

I should have clarified. You may log PIC, but you may not log the approach for currency, unless you actually perform the approach. Watching the student perform the approach, or instructing the student as the student performs the approach, is not the same as having performed it.

The FAA doesn't require that one be the "sole manipulator of the controls," and and used the wording "performed" as the guiding terminology. Some might try to justify it by stating that the student flies they approach, but the instructor is performing it. The FAA disagrees.

Sometimes the issue of logging approaches is equated with 14 CFR 61.51, logging of flight time. However, the FAA Chief Legal Counsel specifically stated that currency requirements cannot be equated with logging requirements of 61.51, in the following legal interpretation (last paragraph...I've eliminated a large part of the text as it's not germaine).

OCT. 28, 1980

WINSTON SCOTT JONES

Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.

We trust that this discussion answers your questions.

Sincerely,

EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division

 

[Visceral]

It is possible that with a date of 1980, this interpretation may have been replaced by another. Still, a good indicator of the way things have been interpreted in the past. I don't log them for currency just to be conservative btw.

 

[Ralgha]

You can log the approach and it does count for currency.

Here is the source, it is a Word document, and was last updated on July 14, 2003.

Quote from that source:

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).

 

[avbug]

The Part 61 FAQ is not binding, nor regulatory, but opinion. It does not represent the Administrator, nor is it defensible.

The legal interpretation has not been superceded, and is legally accepted, and is the official stance of the Administrator. It is an interpretation of the regulation.

Approaches flown by a student cannot be counted for currency.

 

[Ralgha]

Excuse me for being doubtful of a letter from 1980. I think I will call the FAA Regulations Division on Monday with this question.

 

[LJDRVR]

Your call to the FAA is a pointless exercise. When the regulations (Read that LAW) require interpretation, the ONLY source of guidance is a legal interpretation from the FAA Chief Counsel. Anything else is meaningless opinion. What Avbug means by indefensible is that in the event of certificate action, your FAQ's or "Inspector so and so told me..." would not be of any value to you at all. You would still be violated. Chief Legal Counsel interpretations are valid until superceded, so the 1980 date is irrelevant. You mention the regulations division. Still worthless opinion. those folks have no ability, right or mechanism under the law to interpret the law.

 

[bobbysamd]

Logging approaches

We had a similar discussion on this issue about four months ago. Here is a link to that discussion.

The long and short of it is you can certainly write up the approaches your student executed in your logbook, if you want (I used to), but you cannot use said approaches for your own instrument currency.

Finally, the FAA FAQ, while entertaining and semi-informative, is not black-letter law. It seems to be agreed that FAA General Counsel opinions are regarded as legal authority on regulations interpretations.

 

[midlifeflyer]

Re: Logging approaches

The long and short of it is you can certainly write up the approaches your student executed in your logbook, if you want (I used to), but you cannot use said approaches for your own instrument currency.

Actually, the long and ths short of it is that whether you can log the approaches for currency (there really isn't any other legitimate purpose for logging them) it's an open question with two opposing but equally valid viewpoints.

 

[bobbysamd]

Logging approaches v. counting approaches for instrument currency

As far as counting approaches for instrument currency purposes, 14 CFR 61.57(c)(1)(i) is dispositive:

(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 . . . 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)

You can log, or not log, anything you want. You must execute the approaches yourself for them to count toward your personal instrument currency.

 

[labbats]

Law is law, and I abide by that. However, it must be said that teaching someone to fly an approach in actual IMC requires twice the proficiency as simply doing it yourself.

 

[Flying Illini]

Agreed. No one has ever accused a govt. operation of always making sense.

 

[avbug]

You're right. How nonsensical of the government to expect you to actually fly the approaches you take credit for...especially when it's just for currency. I think you should lobby the point...make 'em take out all the requirements to stay current. After all, who needs it, and isn't it expensive? Sure it is! And to think, they actually want you to stay current, and to fly the approaches yourself. How ridiculous is that? I swear. Great onionballs, what will they think of next? If somebody doesn't put a stop to it, they'll want you to be proficient at landings, next, and you already know right where that's going to lead.

Soon they'll be expecting current medical certificates, and some kind of flight review every couple of years or so. And who knows whee it's gonna end?

 

[midlifeflyer]

Re: Logging approaches v. counting approaches for instrument currency

(1) For the purpose of obtaining instrument experience in an aircraft . . . performed and logged under actual or simulated instrument conditions either in flight in the appropriate category of aircraft

That doesn't challenge the reasonability of the opposing viewpoint. The same regulation uses the phrase "sole manipulator of the controls" four times and then simply says "performed" for the approaches. 61.55, dealing with SIC privileges. uses the phrasing "performed...as sole manipulator". So "perform" and "sole manipulator" are not synonymous. My only problem is that I'm not sure what "performed" =does= mean.

The proficiency arguments don't impress me. The currency regulations have almost nothing to do with proficiency. I really don't think that a pilot is =proficient= to take his family on a long night cross country when the only night flight experience he's had in the past 7 years is the 0.5 he put on the Hobbs the evening before when doing 3 stop and goes at the home field.

Besides, who's more proficient? The pilot who maintains instrument currency by watching his autopilot fly the exact same coupled approach again and again or the CFII who regularly teaches in IMC?

 

[midlifeflyer]

Law is law, and I abide by that. However, it must be said that teaching someone to fly an approach in actual IMC requires twice the proficiency as simply doing it yourself.

Just don't make the error of assuming that the "law" about logging approaches is as clear as some folks say it is.

Lynch has been wrong more than once. He'll be wrong again. He may well be wrong about this one. But he may not.

(This topic is =way= more fun than the usual "can I log PIC if my dog flied the airplane ones. Brings out even more zealots who will try to convince your that their personal interpretation is the only one. )

 

[chuychanga]

My general rule is that if it's questionable, then I won't log it. When an interviewer asks me how accurate my log book is, I know I can look them in the eye and say it's about 95% accurate. There are probably some approaches and landings I've performed that did not get logged. There is certainly a little bit of actual IMC time that didn't get logged as I usually make my estimates on the conservative side for that.

Nothing will get you thrown out of an interview quicker than a having them question the validity of your logbook.

 

[bobbysamd]

Instrument proficiency v. performance

Besides, who's more proficient? The pilot who maintains instrument currency by watching his autopilot fly the exact same coupled approach again and again or the CFII who regularly teaches in IMC?

Neither. That's why 14 CFR 61.57(c)(1)(i), above, requires one to actually perform the approaches. The definition of "perform," standing alone and in the context and scope of this reg, should be clear to any reasonable person or semanticist. Just the same, here is a dictionary definition:

per·form [ pər fáwrm ] (past per·formed, past participle per·formed, present participle per·form·ing, 3rd person present singular per·forms)

verb

1. transitive verb accomplish: to carry out an action or accomplish a task
*the surgeon who performed the operation

If someone applied the rationale that the regs permit a flight instructor to count all the instrument approaches performed by his/her students as his/her own along with the agreed-upon and clear regulation that the instructor can count his/her students' actual instrument time, than, conceivably, an instrument instructor who is busy would be perpetually current without ever having his/her hands on the controls or not having taken a recent IPC, proficency notwithstanding!

Applying this to a practical situation, your student is in IMC performing an approach. It is somewhat turbulent on the way down and your student starts to suffer from spatial disorientation. The airplane is getting away from the student and an unsafe situation is developing. You, who have not actually performed an approach since G-d knows when, must put things right. Most people generally lose their cross-check if they don't keep it up. Now, the instructor must reorient the airplane, but he/she is not proficient because of inactivity. Did the rationale above contemplate this situation? No. But 14 CFR 61.57 did.

Originally posted by Avbug
How nonsensical of the government to expect you to actually fly the approaches you take credit for...especially when it's just for currency.

Really.