Logging Instrument Approaches

[VSUPilot]

In 61.51(c), it states "An authorized instructor may log instrument time when conducting instrument flight instruction in actual instrument conditions." The argued topic here is that if you (CFII) are providing instruction is ACTUAL instrument conditions may you for the purpose of instrument currency log the approaches that your student performs.

I have always interpreted 61.57(c) as requiring one to "perform and log" approaches, holding procedures, etc. PERFORM being the operative word. Just because an instructor can log actual instrument time due to the meteorological conditions does not mean that they can or should log those approaches that their student performs toward meeting theri own currency requirements.

any thoughts?

 

[midlifeflyer]

Not quite as beaten to death as some others, but sure to stir up a bit of controversy. Here's a cut-and-paste of my personal FAQ that covers the arguments, but leaves it up to you to make the decision:

May a CFII Log Student Approaches Flown in Actual IMC?

In the (now-defunct) Part 61 FAQ, John Lynch says "Yes". This is probably the most controversial position took in the FAQ. A lot of folks disagree with him. FWIW, here's my personal FAQ on the issue, which sets out the FAQ and some of the pro and con arguments. You'll have to make up your own mind which way to go

The FAQ

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).


The arguments

John Lynch doesn't go into great detail about the reasons for his view, 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" (a CFI can't log student landings) .
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. The phrase "sole manipulator of the controls" appears 4 different times in 61.57. It's absence from approach currency sticks out like a sore thumb.
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. The CFI who is monitoring the student's approach is not only responsible for it (probably one of the FAA's rationales for permitting CFIs to anything while giving instruction) but is working harder by needing to stay not only ahead of the airplane but ahead of the student.
2. 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.
3. The general policy of the FAR is to let CFIs log all sorts of stuff.

The opposing view comes down to:

1. The regulation requires that the approach be "performed". While maybe not a tight as "sole manipulator" it obviously contemplates more than just sitting there.
2. It's just plain stupid for anyone to get credit for an instrument approach for currency by just sitting there and doing nothing. That can certainly be the case, say during an IPC or other recurrent training with an experienced instrument pilot.

BTW, I don't personally see it as a proficiency issue. I'm not particularly impressed by the arguments on either side about whether watching someone else fly an approach makes you proficient. Legal currency rarely has much to do with proficiency. Watching your autopilot coupled airplane do 6 identical ILS approaches into your home airport (which you've memorized anyway) hardly makes one proficient to fly even mild IMC. (Anyway, I'd stack up the CFII who teaches in actual conditions against that guy any day). Even if we don't look at approaches, does anyone really think that doing three night stop and goes night home airport makes you proficient to take the family on a long night cross-county to a strange airport if you haven't flown at night for 7 years. But the FAA says, sure, that's enough for the legalities.

Me, I'll continue to log for currency, fly for proficiency, and pray I'll never confuse the two.

 

[VSUPilot]

Great post Midlife, I agree completely

 

[NYCPilot]

It's amazingthere isnt a concrete answer about this published by the FAA.

IMO, log the approach in actual as a CFII. They wouldn't be able to do it without you, nor would they be able to act as PIC in IMC/IFR conditions.

 

[Dr Pokenhiemer]

How about this--your Instrument STUDENT cannot file an instrument flight plan and cannot legally fly an instrument approach in IMC as PIC. He/she may log PIC under the hood in VMC, but not PIC in IMC. In IMC, student cannot log that time as PIC, so who logs the approach? The only other person in the plane is the CFII. I always logged it as PIC and DUAL GIVEN, and my student as ACTUAL IMC/DUAL RECEIVED.

 

[midlifeflyer]

He/she may log PIC under the hood in VMC, but not PIC in IMC. In IMC, student cannot log that time as PIC,

Nice scenario. But this part is not accurate. A non IFR rated pilot may indeed log PIC in actual. Logging PIC under 61.51 is based on =aircraft= ratings, not flight condition (weather) ratings. Old stuff. Interpreted by FAA Legal more than 25 years ago.

 

[Dr Pokenhiemer]

.....

 

[Dr Pokenhiemer]

I stand corrected. I haven't instructed since 2002. Guess I need to brush up in the regs again.