Logging IMC time

[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.