Logging IMC time

[dana172]

Can I log actual if flying in IMC conditions while working on my instrument rating?

Who's name should be on the flight plan if we are doing instrument training on an IFR flight plan?

Totaly different senario. In a 2 pilot aircraft does the SIC log actual (when flying in IMC conditions) when the PIC is flying?

I have had a few discussions with my instructor about thes questions. I have been unable to find any refrence in the AIM or FAR's to document these questions.

Thank you for your help.

Dana

 

[maverick_fp00]

You can log actual if you are with a CFII.

When I go on an IFR flight plane with my instructor I put his name down.

As far as the SIC goes, I haven't got a clue.

 

[avbug]

Dana,

You may log conditions of flight, regardless of what they may be. If you are in given conditions, then log them that way. While working toward your instrument rating, if you are in instrument conditions, then log instrument conditions. 14 CFR 61.51(b)(3) specifies that the conditions of flight should be logged for every entry, and these include day or night, actual instrument, or simulated instrument.

It makes no difference if you are receiving instruction, acting as SIC, acting as PIC, etc. Conditions of flight have nothing to do with the type of pilot time. A PIC in instrument conditions is still in instrument conditions. A SIC in instrument conditions is still in instrument conditions. A Student pilot in instrument conditions is still in instrument conditions, as is a private pilot without an instrument rating.

If you are not able to legally act as pilot-in-command in instrument conditions or under IFR, then you should provide the name of the pilot in command, or the person who acted as pilot in command, in the remarks section of your logged entry. If this person is a flight instructor, then you should have the instructor endorse the logbook. If the pilot in command is not a flight instructor, then you should still identify that person.

The name entered on the flight plan should be that of the pilot in command, or the person responsible for the outcome of the flight. If you will be flying under IFR, this should be the name of your instructor, or the PIC, as you are not yet instrument rated, and cannot act as PIC under IFR. (You can log PIC under IFR, but cannot act as PIC, under IFR).

 

[dana172]

avbug,

I knew you would have the references that I wanted. You da' the man.

Thank you very much.


Dana

 

[bayoubandit]

.

Totaly different senario. In a 2 pilot aircraft does the SIC log actual (when flying in IMC conditions) when the PIC is flying?

I have to disagree with Avbug about SIC for aircraft requiring 2 pilots. The only time a SIC can log actual instrument time is when he/she is at the controls. The PIC can log all actual IMC flight time. So, to sum it up, if the PIC is at the controls and in IMC, the SIC cannot log that as IMC time. If the SIC is at the controls in IMC, they both may log the actual IMC flight time.
61.51(g) is the source.

 

[avbug]

Bayoubandit,

That is a common misunderstanding of the regulation, and is easily forgiven. The regulation to which you refer, 14 CFR 61(g)(1), states that "A person may log instrument time only for that flight time when the person operates the aircraft soley by reference to instruments under actual or simulated instrument conditions."

Some mistakenly believe that this indicates only the pilot-in-command may log instrument time, but this is clearly not the case due to the wording of that paragraph. Others mistakenly believe that this indicates only the pilot manipulating the controls may log the time as instrument time; this is also clearly not the case. Note that 61.51(g) does not make mention of pilot authority (PIC vs. SIC), nor is it worded to reflect anything regarding sole manipulator.

In an aircraft requiring two crew members, the aircraft may not be operated without both crew members. The conditions under which one crewmember might be in actual instrument conditions and not the other, are rare, indeed. The only time when one crewmember in a two-or-more crew cockpit would log instrument time when the other would not, would be simulated instrument flight in visual conditions.

The SIC may log instrument time, regardless of weather he or she manipulates the controls.

Another common question arises about logging landings and approaches. Some mistakenly believe that the PIC should log all the approaches and landings, regardless of who makes the approach, or the landing. Logging of landings is assigned according to sole manipulator, and the individual logging the approaches must have performed them, in accordance with 61.57(c)(1).

A pilot should only log the landings which he or she has done, regardless of position in the aircraft or assignment by the certificate holder. The same is true for instructors, who often mistakenly believe they should log a student's landings or approaches.

A pilot should always log the conditions of flight. One might just as well state that the non-flying SIC cannot log night time when the flight is conducted at night; this is obviously wrong. The SIC may log night time when acting as a required crewmember. He or she may show it as total night time in the logbook, or divide it into PIC/SIC night if so inclined. The FAR does not differentiate.

The same applies to instrument conditions, as specified in 61.51(b)(3)(ii)&(iii). Weather acting as PIC or SIC, and regardless of who is flying, if the flight is conducted in instrument conditions, all parties entitled to log time should log the conditions under which the flight is conducted.

 

[bayoubandit]

Is there a defintion of what a person is? A person could mean the person flying (sole manipulator) or a person on the flight deck.
Is there a reason it doesn't say "person(s)". I'm asking in all seriousness. Everyone you ask has a different interpretation of the rule. How did you come to yours? It's like talking to a FSDO, call 3 different FSDO's, get 3 different answers. Most guys in the airlines only log the time they fly.

As far as 61.57. That just states what is needed for currency to act as PIC. You must make the landings as sole manipulator to remain current. It doesn't say who may/may not log landings otherwise. Now I agree with you though, whoever lands the plane logs the landing. I haven't instructed in years and most of this goes out the window. Thanks for the challenge!

 

[avbug]

If you are referring to 61.51(g)(1), which states in part, "A person may log instrument ime only for that flight time when the person operatoes the aircraft...", then the answer to your question is clear. Unless two people share a logbook, the wording must be in the singular.

The regulation is referring to the logging of flight time, not to the operation of aircraft. Clearly an aircraft requiring two crewmembers to operate, is operated by two crewmembers. However, each crewmember logs that time separately. Therefore, as the regulation speaks to the individual airman, it is written in the singular.

The regulation referring to the requirement for more than one crewmember is legion, and begins with the type certification for the aircraft, includes the operations specifications and airworthiness limitations, and may include other parts of 14 CFR. Unless otherwise approved by the administrator, an aircraft requiring more than one crewmember is operated by each required crewmember.

A SIC in instrument conditions is in them every bit as much as the PIC. The regulation does NOT differentiate between SIC and PIC instrument time. An employer may ask for a breakdown, but legal logging of time in accordance with 14 CFR 61.51 only requires the logging of instrument time. This time may be further broken down, by definition, into actual or simulated instrument time.

A SIC may log the conditions of flight. To do so would be to ignore the fact that the SIC performed the duties of SIC and operated the aircraft as SIC, in instrument conditions, or at night.

One might postulate that because the SIC didn't perform a landing, he or she is not entitled to show arriving at LAX. Instead, only the PIC would be allowed to log the destination. This is obviously ridiculous. Both parties are there, both parties made the flight; both parties identify the location to which they flew, in their logbooks. Likewise, if both parties entered instrument conditions or flew at night, then both parties log the conditions of flight, as dictated in 61.51(b)(3).

Only the pilot performing a landing or an approach logs that landing or approach. Otherwise, both pilots log the conditions of flight.

 

[avbug]

I should add in all fairness that John Lynch, who writes much of FAR 61 and maintains the FAA AFS-640 FAQ web site, takes the opposite stance of the information I have given. In his FAQ on the subject, he states that the PNF should not log instrument time.

The FAQ site is not endorsed by the FAA and is not regulatory, and for the most part, it provides an element of clarity for the regulations. There are areas of general disagreement, and I have disagreed on several points in the past with what is printed there.

Mr. Lynch states that instrument time logged as SIC/PNF is not useable for the purposes of currency (the response was written when 6 hours were still required for currency), and is not valid for the purposes of meeting the instrument time requirements for the ATP certificate. I agree in substance to both these claims, as the purpose of each is to provide actual instrument experience, and speaks to a different purpose in logging.

However, for logging instrument time, the fact remains that one is not logging experience with respect to manipulation of the controls in reference to instruments, but conditions of flight.

Mr. Lynch also states that he personally believes that instrument conditions in legal VFR (dark moonless night over the ocean, with legal separation from clouds, for example) should be listed as simulated instrument flight. I disagree, though by most counts, my view on that subject would be a losing cause. (As far as I am concerned, flight requiring reference to instruments represents instrument conditions, and absent a view limiting device, represents actual instrument conditions, while not necessarily instrument meteorological conditions).

Interestingly, Mr. Lynch also takes a potentially controversial stance that one does not require a safety pilot in conditions mentioned above, as a view limiting device is not used, although he states that such conditions represent simulated, and not actual instrument conditions. To each his own. I don't see his version being particularly defensible, except that it most likely represents the viewpoint at-large for the majority of inspectors.

 

[AWACoff]

I see both sides of the debate. I only log IMC time for when I am flying the aircraft. I do it simply because I believe it shows a certain skill level and experience. Watching somebody fly in IMC is a lot different than actually doing it. Let's agree to disagree so that at least we agree about something, eh?

 

[328Pilot]

Avbug,

Actually, I believe you are incorrect. Have you taken your ATP written yet? There is a question in the ATP written that asks about logging IMC time while SIC. The correct answer is that the SIC may only log IMC while at the flight controls. I'm afraid that I don't know the reference, but that would be the interpretation from the FAA.

I have never heard that the PIC may log IMC while the SIC is at the controls. Makes me wonder if maybe I'm owed some IMC time.

 

[avbug]

I obtained my ATP a long time ago, but thanks for checking.

 

[PastMmo]

Proof?

Hey Avbug,

Any documented statements OR FAA clarification on the reg's that will support what you are saying.

I remember a website devoted to FAR clarification that is/was sanctioned by the FAA, but don't remember where it was.

Also, what is the FAQ website you were referring to?

 

[avbug]

The web site to which you're referring is the AFS-640 FAQ. Both John Lynch and Allen Pinkerton who put the responses on the site are FAA employees, and in fact have written much of FAR 61 (etc.).

The web site is not sanctioned by the FAA, however. There is a disclaimer on the site that provides that the information there is not regulatory. It is in fairness to Mr. Lynch that I provided a response above, stating his opinion.

No legal interpretation has been provided on this topic. As the FAA no longer requires hours for currency, it's most likely of minimal interest from a regulatory point of view. The only regulatory interest touched on by Mr. Lynch in his response, is that of using instrument time to apply for the ATP certificate.

No further guidance is provided in the various FAA orders and handbooks, applicable to this question. However, rendering of other portions of the FAR, as touched on in previous posts here, show that a pilot who is a required crewmember is in fact operating the aircraft (and may be subject to enforcement action in the event of a violation), weather manipulating the controls, or not. Both pilots are required to operate the aircraft, and both pilots may log the conditions of flight.

The FAA does not differentiate between PIC-instrument, and SIC-instrument. Many companies ask about this in the application process, but that's a private issue, and not a logging or regulatory issue.

 

[328Pilot]

AVbug,

I didn't mean any offense, but it is a question on the ATP written, with the answer being that SIC can only log while in actual. Doesn't make any difference to me how anyone else logs it, but good luck for them explaining to an interviewer in the future if they're wrong.

 

[A Squared]

328pilot,

This is an interesting question, and I don't claim to know the answer for certain. Given the way the regulation is worded, and given the meaning that the FAA gives "operates", I would tend to side with Avbug. I would make a couple of observations about your comment that it's in the ATP knowledge exam. It is indeed, the question and answers read:

What instrument flight time may be logged by a second in command of an aircraft requiring two pilots?
A. All of the time the second in command is controlling the airplane solely by reference to flight instruments.
B. One-half the time the airplane is in actual IFR conditions.
C. One-half the time the flight is on an IFR flight plan.

Now that might seem to imply that an SIC may only log that time which he is sole manipulator of the controls, however look at it a differnt way;

Regardless of whether an SIC may log all time in imc, or only the time he is sole manipulator, answer A is correct. If you look closely, answer A does not restrict the time to OLNY the time the SIC is sole manipulator.


If it is true that the SIC may ONLY log the time he is manipulator of the controls, than answer A is obviously correct.

If it is true that the SIC may log all the time the aircraft is in IMC, then answer A is still true, as it doesn't say ONLY the time he is flying. He may log all of the time he is "controlling the airplane solely by reference to flight instruments" (answer A) PLUS he may log the rest of the time the airplane is operated solely by reference to the instruments

See what I'm saying? My point is that the test question doesn't answer the question. Remember the correct answer is the MOST correct answer, not the complete correct answer. The complete correct answer may not be listed.

From a sheer logical standpoint, if answer A is correct if "X" is true, and answer A is true if "Y" is true, then the fact that answer A is correct cannot be used to determine which is true, "X" or "Y"

Note that answer A uses the term "controlling" while the regulation uses the term "operating" these are not the same.


This is one of the pitfalls of learning by studying the test, the test questions may tend to lead one to incorrect conclustions.

Regards

 

[328Pilot]

A Squared, (and AvBug)

I can't say that you're wrong. I do see your point. However, I would also add that the most conservative thing to do would be to only log the time that you are the person physically in control of the aircraft. The fact that we have this disagreement is evidence enough that there is not a clear-cut answer. I would rather not have to deal with the question in the interview than have someone catch on that I didn't do the landing or the approach on a number of legs, yet I was able to log instrument time. Would they? Maybe not, some of these places seem to go over your logbook carefully and others do not.

Although if the interviewer was of the mind that the FAA intended only for the person physically in control of the aircraft to log the time, then it leads to questions that didn't need to be asked. Is it a deal-breaker? I don't know, but I sure don't want to find out that not knowing the regs (in that interviewers mind) or arguing about it was what killed my chances at the job. Especially when there were ten other guys who didn't log it that way and the question never came up for them.

I'm probably exagerating, but I think the point is still valid. You should still get enough instrument time that it wouldn't make a difference in the interview if your skills were up to par. I've started it the other way, I still think it's the most conservative, but I also can't tell either of you that you are wrong.

Fly safe.

 

[A Squared]

>>>>>>However, I would also add that the most conservative thing to do would be to only log the time that you are the person physically in control of the aircraft.

328Pilot, I agree. As a matter of fact, I fly in a 2 pilot cockpit and I only log instrument time when I am PF. I beleve that I should be logging all time in clouds, but because the question is so controversial, I chose the most conservative approach. I don't need the time for any certificates, and I log more than 10 % of my flight time in IMC anyway (there's a lot of bad Wx where I fly)

So, I disagree with you on the legality, but agree with you on what practial approach should be taken.

Regards,

 

[BTapsco]

Logging IMC Time

You don't have be with a CFII to log instrument time while training; you can go with an instrument rated pilot as your safety pilot (if you can find one you trust and who is willing to put his name on the flight plan) and fly in IMC and log it as such

 

[flydog]

I have an easy answer. If someone looks in your logbook and asks tell them you were PF and you logged that IMC time only. IMC time is not required for any certificates or ratings after the ATP or for any type of currency except maybe that required in an airline SOP. It should be a non issue except for airline interviews.

If the FAA ever asks to see your logbook tell them you dont own one or your dog ate it

 

[skydiverdriver]

I've read all the arguements, and I personally believe that it's legal and proper to log IMC time when you are the SIC, whether it's your leg or not. However, this seems to be a controversial subject, so you would probably be better served to not log it. It only matters for your next interview, and once you start flying regularly, how much time you log will seem pretty silly. You will get enough either way.

Hope this helps, and good luck to you.

 

[skydiverdriver]

Also, as a small point, I would never go by airman knowledge tests to see if an FAR is interpreted a certain way. They are often worded incorrectly, and nobody knows what the real "correct" answer is. Also, who is operating the airplane when the autopilot is flying? Nobody? what if the PIC presses a button, then the SIC presses the next one? Operates has to mean that you are a required flight crewmember. Nothing else makes sense. But, as you probably know, we won't decide this here. Do what you feel you should, as you are the only one who will ever have to justify your logbook to someone. Good luck to all.

 

[BTapsco]

Logging Approaches

Lets take anaother scenario: For instrument currency the reguslations state: "must have 'performed' 6 approaches, etc. Ther's no mention of sole manipulator so if an instrument instructor is teaching approaches in actual down to, or near minimums, can he count those approaches toward his currency even though he may have done no more than watch the trainee. ?????? Any opinions

 

[A Squared]

BTapsco,

I believe that the answer is no, you may not count these approaches. It is true that there is no mention of "sole manipulatior" but the regulation uses the word "performed", which I believe has a different meaning than "operates"


regards

 

[Acestick]

An interesting aside regarding the required approaches for currency...

Does a pilot need to fly the entire approach down do MDA or DH to log it as a "complete approach, or can you go missed 5 seconds after the FAF and still log it as an approach?


I've heard both yes and no on this one...

 

[172driver]

logging approaches

As a CFII, I log all approaches in IMC. For that matter, so do all the CFI's I know. In my opinion, I am performing that approach right along with the student. If the FAA wanted me to be the sole manipulator, they would've said so as they do in many other cases. The student is unrated and quite possibly physically and mentally unable to fly in IMC, so how can he/she be 'performing' the approach without my help? If I am giving instruction, I am at least helping to perform the approach, although not manipulating the controls. Seems to me the FAA should be more specific about many logbook issues but, since they're not, they ought to accept a rational and logical explanation of why somebody logged what they did. Any thoughts?

 

[avbug]

Acestick,

In order to count an approach for meeting the requirements of 61.57(c), the approach must be conducted in instrument conditions, or under simulated instrument conditions, and must be flown under those conditions to approach minimums. See the following response by Donald Byrne, FAA Assistant Chief Counsel in a legal interpretation dated January 28, 1992. I have excluded the non-relevant parts for brevity. Note that this interpretation refers to hours of instrument time, which have been eliminated from the regulation. This does not change the legal requirement, as stated in this binding interpretation, to fly the full proceedure to minimums, under actual or simulated instrument conditions.

January 28, 1992
(no name given)

This is in response to your October 24, 1991, letter in which you asked several questions about certain Federal Aviation Regulations (FAR).

Second, you questioned how low a pilot must descend (i.e., minimum descent altitude or decision height or full stop landing) on the six instrument approaches he must log to meet the recent IFR experience requirements specified in FAR Section 61.57(e)(1)(i) (14 CFR Sec. 61.57 (e)(1)(i)). You also asked if an instrument approach "counts" if only part of the approach is conducted in actual IFR conditions. Section 61.57(e)(1)(i) states that:

No pilot may act as pilot in command under IFR, nor in weather conditions less than the minimums prescribed for VFR, unless he has, within the past 6 calendar months - (i) In the case of an aircraft other than a glider, logged at least 6 hours of instrument time under actual or simulated IFR conditions, at least 3 of which were in flight in the category of aircraft involved, including at least six instrument approaches, or passed an instrument competency check in the category of aircraft involved.

For currency purposes, an instrument approach under Section 61.57(e)(1)(i) may be flown in either actual or simulated IFR conditions. Further, unless the instrument approach procedure must be abandoned for safety reasons, we believe the pilot must follow the instrument approach procedure to minimum descent altitude or decision height.

Please do not hesitate to contact us if you require any further information in this regard.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel

 

[avbug]

172driver,

You may not log the approaches you have described. My time is limited to post a full reply, but I will include part of a related reply given in a legal interpretation by Mr. Donald Byrne to Mr. Renato Simone, dated December 9, 1992. I have deleted the non-relevant parts. This specific reply in interpretation relates to the ability of a flight instructor to log landings performed by the student.

Note that legal interpretations are binding, and defensible in court, as these represent the offical stance of the FAA on the particular topic.

December 9, 1992
Mr. Renato Simone

Dear Mr. Simone:

This is in response to your November 7, 1991, letter to the Federal Aviation Administration (FAA), Office of the Chief Counsel, in which you pose questions relating to certain requirements in Parts 61, 71, 91, and 135 of the Federal Aviation Regulations (FAR)...

...Finally, you asked whether a CFI can log landings day or night if the manipulations of the flight controls are shared by both student and instructor. FAR section 61.51(c)(2)(iii) states that a CFI may log as PIC time all flight time during which he acts as a flight instructor. For recent flight experience, however, under Section 61.57(c) and (d), to log PIC time one must be the "sole manipulator of the flight controls." In the scenario you presented, where the "flight controls are shared by both student and instructor," the CFI can log that as PIC flight time under Section 61.51(c)(2)(iii) but the CFI cannot log this as PIC flight time towards recent flight experience under Section 61.57(c) and (d).

 

[172driver]

For recent flight experience, however, under Section 61.57(c) and (d), to log PIC time one must be the "sole manipulator of the flight controls." In the scenario you presented, where the "flight controls are shared by both student and instructor," the CFI can log that as PIC flight time under Section 61.51(c)(2)(iii) but the CFI cannot log this as PIC flight time towards recent flight experience under Section 61.57(c) and (d). [/B][/QUOTE]



Avbug, I defer to your authority as I have read many of your posts and you certainly have mastered the regs. However, I have some problems with the quote you sent.

1. Mr. Byrne is talking about landings and he quotes 61.57(c) and (d) which have nothing to do with landings. What he should've used was 61.57(a)(1)(i) which specifically states that for recency, the pilot must be the sole manipulator during landing.

2. 61.57(c) which does deal with logging approaches for currency absolutely does not say anything about manipulating the controls. It says you must "perform the approach" under actual or simulated IMC."

3. The fact that the FAA specifically states "sole manipulator" in 61.57(a) and not in 61.57(c), in the same reg for God's sake, makes me believe that "sole manipulator" was not intended or implied in 61.57(c).

4. For recent flight experience, however, under Section 61.57(c) and (d), to log PIC time one must be the "sole manipulator of the flight controls." What on earth is he talking about??? I see not one mention in 61.57 (c) or (d) about being the sole manipulator of the flight controls.

5. It will make you happy to know that I don't log any landings unless I am the sol;e manipulator.

Please respond. I am very curious to know if I have some logbook editing to do...but you'll have to prove it to me more eloquently than Mr. Byrne.

 

[avbug]

You're relatively new to flying, or you'd know that a major re-write of 14 CFR 61 took place three years ago. At that time, some of the designations for various subparagraphs was slightly altered. For this reason, I clearly identified the date of the legal interpretation twice, before presenting it.

The specific subparagraph enumerations have changed, but the clarification and legal stand of the interpretation have NOT. Do not fault Mr Byrne for quoting the regulations correctly at the time the interpretation was issued. The fact is that this is a legally defensible interpretation of the meaning of the regulation, despite subtleties in the specific numerical designation.

The FAA intends that only the person performing the approach may log it. If your student performs the approach, it matters not a whit that you supervised, cajoled, coerced, influenced, oversaw, instructed, kibbitzed, queried, or otherwise was involved with the approach. To be sure, 61.57(c) does not specifically state sole manipulator. However, the intent of the regulation is quite clear; one should NOT log approaches flown by others, students or not. One should NOT log landings made by others, students or not.

The FAA stipulated the regulations set forth in 14 CFR 61 for your sake, not for God's. I'm sure he has a firm grasp on the applicable regulation.

Instrument proficiency is maintained by doing, not by watching.