logging instrument approach question

[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.

 

[teach2fly]

wow..this turned out to be an interesting discussion.

 

[Timebuilder]

Really, all I was initially doing was pointing out that the FARs consider "instrument" to be a condition of flight the same as "night".

Yes.

I thought that this particular reg was an "exception" to the theory that both night and IMC are "conditions of flight".

Maybe I'm just too used to these regs seeming arbitrary and contradictory, such as the whole question of the difference betwen the "acting" and "logging" of PIC time. To my way of thinking, the ONLY time a reasonable person would "log" something, PIC time for instance, would be when the had "acted" as PIC for the flight in question. As we have seen, this isn't the way the regs approach this, which makes them seem very arbitrary.

 

[midlifeflyer]

I was referring to Lynch (whoever he may be)

Just an FYI for the few who don't know at this stage of the game. John Lynch is with the FAA certification branch. To the extent that there really is one, he's the author of the 1997 revisions to Part 61. In an effort to standardize the way Examiners use the rules, the FAA's Regulatory Support Division (http://afs600.faa.gov/AFS640.htm) publishes a Part 61 and Part 141 FAQ. Lynch is the "guru" who answers the questions.

Unfortunately, Lynch's interpretations are not always correct. Fortunately, some these have been corrected from time to time, usually the result of comments from the FAA Legal Counsel's office, which is the final authority on what the FAA says the FAR mean. Unfortunately, in some cases, the correction came after Lynch, with one flick of his pen (keyboard?) contradicted 20 years of consistent FAA policy. Fortunately, the FAQ itself disclaims it's own authority. Unfortunately, until corrected, the FAQ is =the= guidance relied upon by DPEs and FSDOs. Fortunately, a bad interpretation, uniformly used, can sometimes be better that every region going off half-cocked with it's own version. Unfortunately, the regions sometimes go off half-cocked anyway.

 

[Timebuilder]

I think I was able to follow that whole paragraph about FAA thoughts.

Unfortunately.

 

[JungleJetFO]

I'm still shaking my head about that idiot JungleJetFO shooting his mouth off about logging approaches in VMC.

First of all, screw you.

There it is, in IMC or simulated IMC right down to the minimums, or it doesn't count. Now, if you break out 100 feet above minimums ..... well, I think that is probably close enough, but logging an entire approach flown by yourself in VMC? Where do people dream up this crap?

So why the hell are you dreaming up you're own crap? It's talking about shooting the approach down to minimums, not the weather "idiot". If the weather is IMC, that doesn't mean it has to be "at" minimums. If it did, no one would be able to maintain their currency. Last time I checked, IMC was below 1000/3.

Section 1.57(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.

When's the last time you updated your FAR/AIM, 1991? You might want to read the latest, it's changed a bit.

If you put something in your logbook that ain't right, the FAA considers it falsification

Logging an approach in VMC and recording it as actual is falsification. Logging an approach in VMC is not falsification. Idiot.

 

[A Squared]

JungleJetFO,

>>>>>If the weather is IMC, that doesn't mean it has to be "at" minimums. If it did, no one would be able to maintain their currency. Last time I checked, IMC was below 1000/3.

We can argue about exactly what the legal interpreteion means regarding how low the IMC conditions actually has to be, but that would be beside the point.

The point is that you claimed that you can log approaches performed in VMC which is completely wrong. Remember, that's what you were saying in your earlier posts. Here's what you wrote:

>>>An instrument approach is an approach no matter what the weather.

and;

>>>If you are on an IFR flight plan and you shoot a non-precision or precision approach in VMC or IMC, log it.

and;

>>>>Who cares what the weather is

The idea that you can log approaches flown entirely in VMC is an absurd fantasy. It makes about as much sense as logging instrument time when you are in VMC on an IFR flight plan. Even ignoring the legal implications of logging it, presenting such time as a measure of your experience is dishonest.

>>>>>>When's the last time you updated your FAR/AIM, 1991? You might want to read the latest, it's changed a bit.

Read a little more carefully there ace, that's a legal interpretation which was written in 1992. They obviously quoted the regulation as it was written then. I assumed that we were all intelligent enough that the obvious didn't need to be stated. Apparently that was a bad assumption.
Anyway, I am fully aware that the regulation is worded a bit differently now and that some of the requirements have been changed. The approaches are still required to be in simulated or actual instrument conditions.


>>>>Logging an approach in VMC is not falsification.

Oh, really? Do you have anything to back this up, or do you just beleive it because you really really want to log approaches in VMC? You want to bet your certificates on this?

 

[Timebuilder]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

 

[cjh]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

And talks to himself, thereby becoming his own safety pilot.

 

[A Squared]

Perhaps JungleJetFO means to say that he puts on a pair of foggles to meet the requirement of simulated instrument conditions when he makes an approach without actual conditions?

Well, I suppose that is possible. However there doesn't seem to be anything in his posts which suggest that, and he appears to be contradicting a poster who is telling him that he needs to simulate IMC and have a saftey pilot, and he's certainly made no attempt to clarify that he was speaking of logging approaches in VMC with a view limiting device and a safety pilot.

 

[Checks]

Ok, I will be honest when I say I have just skimmed the responses on here.

Let us look at the pertinent part of the reg:

(1) For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions,

Ok, so what does this say? It says you must fly the approach under actual or simulated instrument conditions.
What are actual instrument conditions??? Here is what the FAA legal counsel wrote regarding the definition of “actual instrument conditions”(because you won’t find a definition anywhere else)
--------------------------------------------------------------------------------
-"Actual" instrument flight conditions occur when some outside conditions make it necessary for the pilot to use the aircraft instruments in order to maintain adequate control over the aircraft. Typically, these conditions involve adverse weather conditions.
-----------------------------------------------------------------------------

So can I log the approach if the visibility is 2 miles and I am operating the aircraft solely by aircraft instruments while shooting the ILS down to DH? YES! Additionally, there is a difference between IMC and actual instrument conditions. If the ceiling at the airport is 900ft OVC and 10sm vis I would be in IMC conditions but not in actual instrument conditions(anything less than VMC is IMC).

Does it matter if I break out of the overcast layer just past the FAF? NO, unless you believe that actual instrument conditions are defined as 0/0. The key point is to stay on the aircraft instruments to DH and to be in “adverse weather conditions”

Can you claim to be in "adverse weather" when it is CAVU out? NO. Which means you can not log it legally.

Just my 2 cents