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Logging IMC time
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172driver
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Avbug,
Your point is well taken about not knowing the rewrite. However, numbers aside, Mr. Byrne's interpretation seems to pertain to logging of landings, not approaches. I disagree that the intent of the reg (61.57(c)) is to only log what you've flown. If so, why doesn't it say that? The landings portion of the reg does specifically state that you must be the sole manipulator of the controls (61.57(a)(1)(i)). The approach currency portion of the reg does not.
Also, where are the legal interpretations of instructors logging approaches? Surely this must have come up before as a legal issue, just as landings have. It seems like a stretch for you to transpose Mr. Byrne's interpretation of logging landings to the logging of approaches. We don't know the intent of the reg unless it is specifically stated that way or it has been legally interpreted as such.
Finally, I disagree with your statement that you can't stay instrument proficient by watching. Flying 4-8 hrs a day, watching students perform 10 approaches and 3 holds daily, is certainly valuable experience. Of course, it's not as valuable as flying them yourself, but given the number of approaches that CFII's "watch," it's pretty close. I will assert that I have learned more and gained more proficiency in instrument flying by "watching" than I ever did as a student. I would put my instrument skills after "watching" for six months up against anybody with six approaches and a hold in that same time frame. In six months, I would've "watched" over 1000 approaches and 100 holds, while the other guy "performed" six and one. That's an approach a month. Who's going to be more proficient?
Your point is well taken about not knowing the rewrite. However, numbers aside, Mr. Byrne's interpretation seems to pertain to logging of landings, not approaches. I disagree that the intent of the reg (61.57(c)) is to only log what you've flown. If so, why doesn't it say that? The landings portion of the reg does specifically state that you must be the sole manipulator of the controls (61.57(a)(1)(i)). The approach currency portion of the reg does not.
Also, where are the legal interpretations of instructors logging approaches? Surely this must have come up before as a legal issue, just as landings have. It seems like a stretch for you to transpose Mr. Byrne's interpretation of logging landings to the logging of approaches. We don't know the intent of the reg unless it is specifically stated that way or it has been legally interpreted as such.
Finally, I disagree with your statement that you can't stay instrument proficient by watching. Flying 4-8 hrs a day, watching students perform 10 approaches and 3 holds daily, is certainly valuable experience. Of course, it's not as valuable as flying them yourself, but given the number of approaches that CFII's "watch," it's pretty close. I will assert that I have learned more and gained more proficiency in instrument flying by "watching" than I ever did as a student. I would put my instrument skills after "watching" for six months up against anybody with six approaches and a hold in that same time frame. In six months, I would've "watched" over 1000 approaches and 100 holds, while the other guy "performed" six and one. That's an approach a month. Who's going to be more proficient?
Last edited:
172driver,
To my knowledge, there are no legal interpretations regarding the logging of instrument approaches by flight instructors. If you're at all familiar with the proceedures for obtaining a legal interpretation, and the time required to obtain one, you'll understand why.
In fairness, as I indicated earlier in the thread, I'll include Allen Pinkstons' (AFS-640) take on the subject. He and John Lynch (AFS-840) write 14 CFR 61 (perform the re-writes on it) for the FAA, and Mr. Lynch publishes a web site with FAQ on the subject. His viewpoint doesn't represent the FAA's viewpoint, and it is not binding, or official. However, he states that an instructor may log the approaches made by a student.
This viewpoint also comes with a caveat, however. Mr. Lynch states that the instructor may log the approach when it is flown in instrument conditions . See the copy of the FAQ reference (and additional appropriate reference on instrument conditions) at the end of this reply. Logging of approaches under simulated conditions, with the student wearing a view limiting device and the instructor having a clear view of the world, does not count. This is reasonable, considering that to count, an approach must be flown under simulated or actual instrument conditions. These conditions apply to the person logging the approach. If the student is under simulated conditions and the instructor is not, the instructor cannot log the approach.
While many instructors seem to feel that their skills are top of the heap, and that they far and exceed the average bear, I've yet to find this to consistently be the case when those instructors move on. I've worked for a variety of companies that hired lower time or experience pilots, often those who had come from an instructing position. Almost universally, these individuals were welcomed as inexperienced, much to the chagrin of those individuals. They were welcomed in that manner, rightfully so.
Watching someone do something doesn't make you proficient. It may help keep your mind open and the mental juices circulating, but it doesn't make you proficient. Ask yourself this: should a SIC in a crewed environment log the approaches made by the PIC? The answer is no. Of course not. What makes the relationship of the instructor to the student any different? Should the PIC log the approach when the SIC flies it? Legally, he or she can. Should he or she do so? No, not really.
Don't use the standards set forth in the FAR for deciding proficiency. Legal proficiency as applied under 61.57(c) is pathetically lacking. What is legal is not necessarily safe, and what is safe is not always legal. Professionalism demands adherence to the letter of the law, as well as the law of safety. In short, it must be legal, AND safe. To meet the 6 month minimums only, is far lacking in what is required to maintain instrument proficiency. One certainly wouldn't hope to see a student progress far by conducting one lesson a month; neither any more should we expect to see highly perishable instrument skills maintained at the same frequency. Making a comparison between watching approaches, and someone meeting the bare minimum requirements of the law then, is inappropriate.
The FAQ references follow:
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).
QUESTION: I have not been able to find a definition of "actual" conditions in the FARs or the AIM, but I believe that the definition of actual is somewhat more restrictive than IMC. Please confirm that the following is correct:
Is IMC is simply visibility’s, clearances from clouds, and ceilings less than the minima for VMC (AIM - pilot controller/glossary) "Actual" requires that the pilot be flying the airplane solely by reference to instruments, which means he must be either completely in the soup (i.e. zero-zero) or in conditions which provide no horizon reference of any kind. Therefore, being in IMC conditions is not always adequate for logging actual.
ANSWER: Ref. §61.51(g); As previously answered above, there is no official FAA definition on “actual instrument time” or “simulated instrument time” in the FARs, FAA Orders, advisory circulars, FAA bulletins, etc. Part 61 merely refers to the instrument time in reference to aeronautical experience to be “. . . instrument flight time, in actual or simulated instrument conditions . . .” Otherwise the reference is merely instrument flight time, in actual or simulated instrument conditions.
Now the term “actual” in reference to instrument conditions that require operations to be performed solely by reference to the aircraft instruments are sometimes subjective. No question that “actual” instrument conditions exist with flight in clouds or other phenomena that restrict visibility to the extent that maintaining level flight or other desired flight attitude, can only be accomplished with reference to the aircraft instruments. This goes back to earlier statement in Answer 1 where I said the weather conditions establish whether the flight is in “actual instrument conditions.” And that is dependent on the weather conditions where the aircraft is physically located and the pilot makes that determination as to whether the flight is in “actual instrument conditions” or he is performing instrument flight under “simulated instrument conditions.”
Your realization that "IMC" and "VMC" and also, in fact, "IFR" and "VFR" are not necessarily related to "actual" conditions is accurate. These terms are used with respect to airspace operating requirements. Per §91.155, a flight may be in IMC (requiring IFR operations) with four (4) miles visibility in Class E airspace above 10,000'MSL (more than 1,200'AGL), but still be in VMC (allowing VFR operations) with only one (1) mile visibility in Class G below 10,000'MSL during day time. That is why none of these terms were used in §61.51(g) to describe when we may or may not log instrument flight time. IMC and VMC are used in association when describing airspace weather conditions. VFR or IFR are used to describe operating requirements [i.e., §91.173 requiring IFR flight plan for operating in controlled airspace under IFR, §691.169 information required for operating on an IFR flight plan; §91.155 basic VFR weather minimums, etc].
QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?
ANSWER: §61.51(g)(1) and §61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach which would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is NO.
To my knowledge, there are no legal interpretations regarding the logging of instrument approaches by flight instructors. If you're at all familiar with the proceedures for obtaining a legal interpretation, and the time required to obtain one, you'll understand why.
In fairness, as I indicated earlier in the thread, I'll include Allen Pinkstons' (AFS-640) take on the subject. He and John Lynch (AFS-840) write 14 CFR 61 (perform the re-writes on it) for the FAA, and Mr. Lynch publishes a web site with FAQ on the subject. His viewpoint doesn't represent the FAA's viewpoint, and it is not binding, or official. However, he states that an instructor may log the approaches made by a student.
This viewpoint also comes with a caveat, however. Mr. Lynch states that the instructor may log the approach when it is flown in instrument conditions . See the copy of the FAQ reference (and additional appropriate reference on instrument conditions) at the end of this reply. Logging of approaches under simulated conditions, with the student wearing a view limiting device and the instructor having a clear view of the world, does not count. This is reasonable, considering that to count, an approach must be flown under simulated or actual instrument conditions. These conditions apply to the person logging the approach. If the student is under simulated conditions and the instructor is not, the instructor cannot log the approach.
While many instructors seem to feel that their skills are top of the heap, and that they far and exceed the average bear, I've yet to find this to consistently be the case when those instructors move on. I've worked for a variety of companies that hired lower time or experience pilots, often those who had come from an instructing position. Almost universally, these individuals were welcomed as inexperienced, much to the chagrin of those individuals. They were welcomed in that manner, rightfully so.
Watching someone do something doesn't make you proficient. It may help keep your mind open and the mental juices circulating, but it doesn't make you proficient. Ask yourself this: should a SIC in a crewed environment log the approaches made by the PIC? The answer is no. Of course not. What makes the relationship of the instructor to the student any different? Should the PIC log the approach when the SIC flies it? Legally, he or she can. Should he or she do so? No, not really.
Don't use the standards set forth in the FAR for deciding proficiency. Legal proficiency as applied under 61.57(c) is pathetically lacking. What is legal is not necessarily safe, and what is safe is not always legal. Professionalism demands adherence to the letter of the law, as well as the law of safety. In short, it must be legal, AND safe. To meet the 6 month minimums only, is far lacking in what is required to maintain instrument proficiency. One certainly wouldn't hope to see a student progress far by conducting one lesson a month; neither any more should we expect to see highly perishable instrument skills maintained at the same frequency. Making a comparison between watching approaches, and someone meeting the bare minimum requirements of the law then, is inappropriate.
The FAQ references follow:
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).
QUESTION: I have not been able to find a definition of "actual" conditions in the FARs or the AIM, but I believe that the definition of actual is somewhat more restrictive than IMC. Please confirm that the following is correct:
Is IMC is simply visibility’s, clearances from clouds, and ceilings less than the minima for VMC (AIM - pilot controller/glossary) "Actual" requires that the pilot be flying the airplane solely by reference to instruments, which means he must be either completely in the soup (i.e. zero-zero) or in conditions which provide no horizon reference of any kind. Therefore, being in IMC conditions is not always adequate for logging actual.
ANSWER: Ref. §61.51(g); As previously answered above, there is no official FAA definition on “actual instrument time” or “simulated instrument time” in the FARs, FAA Orders, advisory circulars, FAA bulletins, etc. Part 61 merely refers to the instrument time in reference to aeronautical experience to be “. . . instrument flight time, in actual or simulated instrument conditions . . .” Otherwise the reference is merely instrument flight time, in actual or simulated instrument conditions.
Now the term “actual” in reference to instrument conditions that require operations to be performed solely by reference to the aircraft instruments are sometimes subjective. No question that “actual” instrument conditions exist with flight in clouds or other phenomena that restrict visibility to the extent that maintaining level flight or other desired flight attitude, can only be accomplished with reference to the aircraft instruments. This goes back to earlier statement in Answer 1 where I said the weather conditions establish whether the flight is in “actual instrument conditions.” And that is dependent on the weather conditions where the aircraft is physically located and the pilot makes that determination as to whether the flight is in “actual instrument conditions” or he is performing instrument flight under “simulated instrument conditions.”
Your realization that "IMC" and "VMC" and also, in fact, "IFR" and "VFR" are not necessarily related to "actual" conditions is accurate. These terms are used with respect to airspace operating requirements. Per §91.155, a flight may be in IMC (requiring IFR operations) with four (4) miles visibility in Class E airspace above 10,000'MSL (more than 1,200'AGL), but still be in VMC (allowing VFR operations) with only one (1) mile visibility in Class G below 10,000'MSL during day time. That is why none of these terms were used in §61.51(g) to describe when we may or may not log instrument flight time. IMC and VMC are used in association when describing airspace weather conditions. VFR or IFR are used to describe operating requirements [i.e., §91.173 requiring IFR flight plan for operating in controlled airspace under IFR, §691.169 information required for operating on an IFR flight plan; §91.155 basic VFR weather minimums, etc].
QUESTION: As far as logging an approach in actual, is there any requirement (i.e. must it be in actual conditions beyond the final approach fix)? Assume that the pilot was flying single-pilot IFR so he couldn't simply put on the hood if he broke out?
ANSWER: §61.51(g)(1) and §61.57(c)(1)(i); Again the only place where it defines logging “instrument flight time” means “. . . a person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments . . . .” As for logging an "actual" approach, it would presume the approach to be to the conclusion of the approach which would mean the pilot go down to the decision height or to the minimum decent altitude, as appropriate. If what you’re asking is whether it is okay to fly to the FAF and break it off and then log it as accomplishing an approach, the answer is NO.
172driver
Well-known member
- Joined
- Apr 4, 2002
- Posts
- 744
Thank you for being fair avbug. I completely agree with you that watching approaches from the right seat is not as valuable as flying them. Also, that legal currency is nowhere near safe currency. I do shoot my own approaches, both in the sim and the a/c, to stay proficient and current.
Please don't generalize about CFI's being nonproficient. I bet there are a lot of them out there who can fly the pants off of 121 captains as there are plenty who can't fly a lick. When was the last time you took a 2500 lb aircraft, or any aircraft, into turbulent IMC, without an autopilot? 121 guys are excellent pilots or they wouldn't be where they are but can they keep the blue side up without that AP? I've flown with 121 and 135 guys who scared the h*** out of me, just as I would them if I were trying to fly their make and model. I don't go around saying that 121/135 pilots are generally nonproficient pilots based on the few I've flown with. Don't mean to bag on anyone but I take offense to someone assuming my skills are poor because I belong to a group.
That being said, the argument was whether or not it is LEGAL to log the students' approaches. I think the reference you sent answers that one, although not officially. And, of course, the CFII would not log VFR approaches. That's a no-brainer.
Please don't generalize about CFI's being nonproficient. I bet there are a lot of them out there who can fly the pants off of 121 captains as there are plenty who can't fly a lick. When was the last time you took a 2500 lb aircraft, or any aircraft, into turbulent IMC, without an autopilot? 121 guys are excellent pilots or they wouldn't be where they are but can they keep the blue side up without that AP? I've flown with 121 and 135 guys who scared the h*** out of me, just as I would them if I were trying to fly their make and model. I don't go around saying that 121/135 pilots are generally nonproficient pilots based on the few I've flown with. Don't mean to bag on anyone but I take offense to someone assuming my skills are poor because I belong to a group.
That being said, the argument was whether or not it is LEGAL to log the students' approaches. I think the reference you sent answers that one, although not officially. And, of course, the CFII would not log VFR approaches. That's a no-brainer.
Last edited:
"When was the last time you took a 2500 lb aircraft, or any aircraft, into turbulent IMC, without an autopilot?"
I'm afraid I'm not a good comparison. My background includes formation flight under telephone wires and power lines, and working large four engine airplanes at 200' AGL in box cayons in high winds and extreme turublence, in low or zero visibility, often inside flames exceeding 300'. I do pretty darn well without the autopilot, though I'll be the first to state that most I meet are far better than me.
In the final analysis, we're all student pilots.
The point being that yes, we are all different. However, most experienced professional pilots are flight instructors, have been instructors, and maintain their instructor certificates. Most full time flight instructors are not experienced; it's often their first job. Regardless of our level or assignment, flying skills are still perishable, and one can get killed as quickly in a J-3 cub as in a 747. Personal proficiency and skill is the only thing that counts, far and above certification, place in the aircraft, or total time.
Fly safe.
I'm afraid I'm not a good comparison. My background includes formation flight under telephone wires and power lines, and working large four engine airplanes at 200' AGL in box cayons in high winds and extreme turublence, in low or zero visibility, often inside flames exceeding 300'. I do pretty darn well without the autopilot, though I'll be the first to state that most I meet are far better than me.
In the final analysis, we're all student pilots.
The point being that yes, we are all different. However, most experienced professional pilots are flight instructors, have been instructors, and maintain their instructor certificates. Most full time flight instructors are not experienced; it's often their first job. Regardless of our level or assignment, flying skills are still perishable, and one can get killed as quickly in a J-3 cub as in a 747. Personal proficiency and skill is the only thing that counts, far and above certification, place in the aircraft, or total time.
Fly safe.
utahpilot
Seeing the light
- Joined
- Nov 27, 2001
- Posts
- 337
Mr. P says....
My. Pinkston replied to my query on currency. He said:
"On this second question I can only give an opinion. I am not aware of a
"legal interpretation" not any court-room outcome regarding this specific
question about instrument currency as required by section 61.57(c).
I would not log approaches flown by a student for currency purposes. In
61.57(c)(1) is stated: "that person has: (1) For the purpose ... performed
and logged ..." If something happened, are you confident that you could
convince a Law Judge or a jury that giving instruction to a student is the
same as performing as a pilot? I would be most uncomfortable going to
court to avoid paying for an airplane (or worse) if I could only establish
(for currency) that I had "monitored, observed, or was teaching" the
instrument approaches rather than being the sole manipulator of the
controls.
I can not predict how a particular Flight Standards District Office may
view such currency. I must admit that my "collaborator" in these
Frequently Asked Questions, John Lynch of AFS-840 in Washington DC has a
different view. He says the instructor may log the approaches since he/she
is authorized to log PIC while instructing per 61.51(e)(3). And that is
true, but I suggest you consider the practical outcome with respect to
liability that I previously mentioned.
For a philosophical aspect: Almost all of the aviation regulations have
evolved in response to accidents and incidents. Currency requirements have
been established to promote safety -- actually, survival. Watching someone
else perform is just not as good as doing it yourself, in my opinion. You
may log the approaches -- it is your logbook. Will those entries really be
that much help if you are faced with needing to make an approach in actual
low ceiling &/or visibility conditions? You are the judge.
Allan Pinkston"
so there you go
My. Pinkston replied to my query on currency. He said:
"On this second question I can only give an opinion. I am not aware of a
"legal interpretation" not any court-room outcome regarding this specific
question about instrument currency as required by section 61.57(c).
I would not log approaches flown by a student for currency purposes. In
61.57(c)(1) is stated: "that person has: (1) For the purpose ... performed
and logged ..." If something happened, are you confident that you could
convince a Law Judge or a jury that giving instruction to a student is the
same as performing as a pilot? I would be most uncomfortable going to
court to avoid paying for an airplane (or worse) if I could only establish
(for currency) that I had "monitored, observed, or was teaching" the
instrument approaches rather than being the sole manipulator of the
controls.
I can not predict how a particular Flight Standards District Office may
view such currency. I must admit that my "collaborator" in these
Frequently Asked Questions, John Lynch of AFS-840 in Washington DC has a
different view. He says the instructor may log the approaches since he/she
is authorized to log PIC while instructing per 61.51(e)(3). And that is
true, but I suggest you consider the practical outcome with respect to
liability that I previously mentioned.
For a philosophical aspect: Almost all of the aviation regulations have
evolved in response to accidents and incidents. Currency requirements have
been established to promote safety -- actually, survival. Watching someone
else perform is just not as good as doing it yourself, in my opinion. You
may log the approaches -- it is your logbook. Will those entries really be
that much help if you are faced with needing to make an approach in actual
low ceiling &/or visibility conditions? You are the judge.
Allan Pinkston"
so there you go
EOpilot
Dormant
- Joined
- Mar 20, 2002
- Posts
- 123
172driver
Hey, you don't happen to fly in NJ, do you? I've been furloughed for a while and would be willing to take one around a couple times just to vindicate the 121 pilots of the world. Plus, I could use the practice.
By the way have you ever seen the autopilot in the 727? It's worth is best felt in cruise, when it works. There have been plenty of hand flown 3+ hour legs at 330. Not fun.
And I'm sure there's still some Jetstream 31s out there flying 121, those pilots would give any instructor a run for his/her money.
All this excitement has made me sleepy. Time for a nap. The exciting life of a furloughee never ends.
Hey, you don't happen to fly in NJ, do you? I've been furloughed for a while and would be willing to take one around a couple times just to vindicate the 121 pilots of the world. Plus, I could use the practice.
By the way have you ever seen the autopilot in the 727? It's worth is best felt in cruise, when it works. There have been plenty of hand flown 3+ hour legs at 330. Not fun.
And I'm sure there's still some Jetstream 31s out there flying 121, those pilots would give any instructor a run for his/her money.
All this excitement has made me sleepy. Time for a nap. The exciting life of a furloughee never ends.
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