logging instrument approach question

[A Squared]

I'm still shaking my head about that idiot JungleJetFO shooting his mouth off about logging approaches in VMC. Ok, ignoring the obvious, that logging approaches is supposed to demonstrate experience in flying approach procedures in IMC, what if you do follow junglejetfo's advice? Say for whatever reason the FAA has aksed to review your logbook, and they're interested in your IFR currency. They notice that you're logging approaches, but no IMC time, and no saftey pilot listed. Hmmm, so they look up the weather for that airport on that day in the archives....turns out they were reporting 100 sct 10 miles vis...hmmm doesn't sound like IMC to me.....busted. Keep in mind that they *are* going to go for revocation of your certificates.

regards

 

[midlifeflyer]

Re: Whatever floats your boat . . . .

I don't recall at the moment what he saw in the FARs to give him that hare-brained notion; it doesn't matter because it obviously flies in the face of common sense.

Actually this particular harebrained notion is supported by John Lynch's sometimes harebrained FAQ. He doesn't explain why, but the best argument that I could find that supports it goes something like this:

1. The FAR for landing currency specifically says "sole manipulator"
2. The FAR for instrument currency 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.

Personally, I'm not terribly impressed. Of course in Colorado the issue is academic anyway

 

[Timebuilder]

I'm not familiar with Lynch, but if looking at the totality of regulations, I'd include the fact that an SIC in a two-crew airplane can only log instrument time at all when he is flying the airplane, not as a "condition of flight", such as "night", which can always be logged.

If you think of the CFI as a "required crew member", or a "second in command", then he would have to be flying the airplane to log the approaches. Luckily, he can still log the IMC time, unlike the SIC!

 

[flx757]

I'd include the fact that an SIC in a two-crew airplane can only log instrument time at all when he is flying the airplane, not as a "condition of flight", such as "night", which can always be logged.

I disagree. FAR 61.51(b)(3) lists "conditions of flight" as (i) Day or night (ii) Actual instrument (iii) Simulated instrument conditions in flight, a flight simulator, or a flight training device.

If you believe you can always log "night" time "as a condition of flight", then by that same logic, you can log "instument" time.

Further, FAR 61.51(g) "Logging instrument flight time" states that a person may log instrument time when the person operates the aircraft solely be reference to instruments...(note it doesn't say is the sole manipulator of the controls.)
If an SIC is required for a two-pilot aircraft, then both pilots are operating the aircraft, and both may log the instrument time.

 

[midlifeflyer]

If you think of the CFI as a "required crew member", or a "second in command"

But a CFI is neither. The CFI logging regulations don't really have anything to do with the CFI as a crewmember of any kind. I think they are pretty much a policy decision by the FAA to let CFIs log certain things simply because they are acting as an instructor. In addition to allowing career track pilots to use instruction to build time, there's probably also a general recognition that there's no better way to learn something than to teach it.

For an example, take it out of the "hot" approach issue. Think of a CFI who is giving a flight review to a pilot a week before the pilot's previous review "expires." The pilot is in all respects current and qualified to act as PIC in the airplane being used for the review. On the other hand, the CFI lost her medical 3 years earlier due to an unfortunate heart condition.

Clearly, the CFI isn't (and can't be) a required crewmember. But just as clearly, the CFI gets to log PIC. If it were an IPC in actual under similar circumstances (pilot who is qualifies to act as PIC under IFR) , the CFI could even log actual!

 

[Timebuilder]

If you believe you can always log "night" time "as a condition of flight", then by that same logic, you can log "instument" time.

Doc seems to agree with you, and his "legal definition number ten" supports the idea that a Second in Command is "operating" the airplane, by definition.

I think we are getting into an area of interpretation based on our own ideas and those of others we have asked, which is always a murky area. I was referring to Lynch (whoever he may be) making reference to some regulations when I mentioned thinking about a CFI as a required crewmember, which Mark correctly pointed out is not the case. The operative word in my supposition was "if", used for example of looking at several regulations for guidance.

I recall seeing a regulation, which I have been unable to find today, that references a SIC being able to log all of the time spent controlling the aircraft by reference to the flight instruments. If that is correct, when the PIC or the autopilot is flying the airplane, the SIC can't be controlling by reference to the flight instuments. While logical, this may not be the "letter of the law".

If this approach to logging instrument time is incorrect, then I will chalk it up to being perhaps the best example of inconsistent regulatory oversight that I have come across.

 

[Timebuilder]

Ah, here we go.

In the ATP study guide, there is a reference to FAR 61.51:

"A second in command of a two pilot flight - may log as instrument flight time all of the time the second in command is controlling the airplane solely by reference to flight instruments" (my emphasis).

To me controlling sounds a lot more specific than operating, and sounds to me like a reference to having one's hands on the flight yoke, making control inputs.

Now, I'll confess, I can't find this wording in last year's seachable CD rom of the regs, but it's there in the ATP question bank, (number 9342) and may not be correct and up to date.

From my CD:
(g) Logging instrument flight time.
(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

What a nice feeling: to know that the material I am studying for the ATP may no longer be correct. Ah, the government.

 

[flx757]

The references to 61.51 which I quoted in my post above are from the current online version of the FARs, as well as my 2003 FAR/AIM.

The gist of my original post was to point out that, according to 61.51, instrument flight is a "condition of flight", the same as "night". Therefore, I didn't understand why you have no problem logging night time "all the time", but instrument time only when you were actually flying the airplane.

I'm not sure any of this made it any clearer, but to me, it seems clear that a both pilots of a required two-pilot crew may legally log actual instrument time anytime the aircraft is in IMC regardless who is the "flying pilot".

BTW, good luck with the ATP written.

 

[Timebuilder]

Therefore, I didn't understand why you have no problem logging night time "all the time", but instrument time only when you were actually flying the airplane.

It's because I had been studying information that apparently is so old as to be incorrect. That's very frustrating, as you might imagine. The word "controlling" sure sounds like the SIC is "flying the airplane":

"A second in command of a two pilot flight - may log as instrument flight time all of the time the second in command is controlling the airplane solely by reference to flight instruments".

Nice to have up to date information to study, eh?

 

[flx757]

Don't get me wrong. I understand totally about your ATP guide using the word "controlling", which the FARs do not, and how misleading, and therefore frustrating, that can be.

Really, all I was initially doing was pointing out that the FARs consider "instrument" to be a condition of flight the same as "night". It sort of went from there into the SIC thing.

Again, I wish you good luck with the ATP written. I'm sure you'll do well in spite of your study materials.