Logging landings/approaches

[Atccfi]

Yet another question regarding logging times....sorry. But this one may be a little different. So as a cfi how are you supposed to log landings with your students? If your student lands, do you still log it? You are the PIC after all. How about with instrument approaches? your student is the one flying the approach, you are instructing him/her how to proceed, and still PIC, but not really flying it...do you still log it? just a thought to see how other instructors are doing it.... ATC

 

[phishn@daves]

That's what I used to ccall the "Landing Contest"..........with my students!!

I would make sure I got to land daily and it made the students try harder! Although I'm not really sure about the reg, it made for good practice! And for the new CFI's not a bad idea!

 

[igneousy2]

61.57 requires you to be sole manipulator during the 3 landings, day & night so it's pretty clear.

61.57 for instrument currency says you must "perform" the approaches, if you're IMC and doing the approach on your ticket I would say that you are performing the approach even though you aren't the sole manipulator.

 

[midlifeflyer]

61.57 requires you to be sole manipulator during the 3 landings, day & night so it's pretty clear.

61.57 for instrument currency says you must "perform" the approaches, if you're IMC and doing the approach on your ticket I would say that you are performing the approach even though you aren't the sole manipulator.

And, FWIW, the FAA Designee Standardization Section's Part 61 FAQ agrees with you on both counts (although the one about instrument approaches is one of the most controversial positions in the FAQ).

 

[Matterhorn]

A local FSDO inspector told us you can log the landings and approaches when you are acting as PIC. However, this does not go toward your personal currency. I agree with igneousy2 that you need to be the sole manipulator of the controls.

When I physically do a landing or approach (with a hood, in IMC, etc.) I make a remark in my comments column that I have done that toward currency. Occasionally I just have to rent a plane to get current on my own too.

 

[midlifeflyer]

A local FSDO inspector told us you can log the landings and approaches when you are acting as PIC. However, this does not go toward your personal currency.

The sole purpose of logging under 61.51 is to show the FAA that you meet the requirements for certificates, ratings or currency. Any FAA answer to "may I log" implies logging for that purpose.

Of course you can log things like don't count, like sitting is seat 16B on a 747, but if it doesn't count for anything, I can't imagine why would a FSDO inspector say you can log it (other than ignorance). Besides, I've been looking at that FAR agains and can't find a refernce to acting as PIC or "log but don't count" anywhere in the landing or instrument currency requirements.

Sounds like another of those FSDO folks who make up their own rules. The FAQ may be wrong from time to time, but every single FSDO inspector and DPE should follow it.

 

[A Squared]

>>>>>>A local FSDO inspector told us you can log the landings and approaches when you are acting as PIC. However, this does not go toward your personal currency.

Uhhh, be careful with the "log it but don't count it" concept. I can point to NTSB decisions in which pilots were having thier certificates revoked for falsifying thier logbooks. THe defense was used that the time was not actually used to qualify for a certificate or rating, thus it wasn't falsification. THe FAA's position is, it doesn't matter, if you put bogus time in your logbook, it's falsification, regardless of whether you put in on an 8710. The NTSB agrees.

>>>>>>The FAQ may be wrong from time to time, but every single FSDO inspector and DPE should follow it.

Even when it's demonstrably incorrect?

 

[midlifeflyer]

>>>>>>The FAQ may be wrong from time to time, but every single FSDO inspector and DPE should follow it.

Even when it's demonstrably incorrect?

Yes. There will always be an exception here and there, but having had some experience with people in authority who play by their own (interpretations of the) rules, I've come to the conclusion that, especially on a nationwide basis that affects many people across the country, consistency in application is more important than whether the application is technically right or not. It's one of the reasons that I'm a fan of Lynch and AFS640 even though I disagree with a bunch of stuff in the FAQ.

Let's use the approach issue as an example.

First the approach example. A CFI decides to count her student's approaches for currency. Maybe even called the local FSDO which looked to the FAQ and says it's okay. One day the pilot is flying along and has an incident in IMC. Unfortunately, the incident occurred in a different FAA region and =that= FSDO doesn't like the rule and is convinced it's wrong. So now the investigation comes and the FSDO decides to add violations of currency and logbook falsification into the mix. Whether that happens shouldn't depend on what part of the US the incident happens.

If the policy needs to be changes, it should be changed on a national basis, as it has with a number of FAQ that get revised after input from FAA Legal, not by each separate region deciding for itself whether something is "demonstrably incorrect" (whatever that means).

 

[transpac]

Yes. There will always be an exception here and there, but having had some experience with people in authority who play by their own (interpretations of the) rules, I've come to the conclusion that, especially on a nationwide basis that affects many people across the country, consistency in application is more important than whether the application is technically right or not. It's one of the reasons that I'm a fan of Lynch and AFS640 even though I disagree with a bunch of stuff in the FAQ.

Inter-FSDO standardization has been deficient for decades, and every Administrator comes into office promising to clean it up. The Handbook Standardization effort that started in the '80s was a good start. But, follow-up to the initial efforts never got the needed priority and the handbooks remain incomplete. While John Lynch's efforts are commendable, his opinions and interpretations have conflicted with published FAA guidance and legal precedents. Until such time as the FAQs are blessed by the Director of Flight Standards and the Chief Counsel, they have no legal standing and can't be used as a basis for local FSDO action or inaction.

 

[A Squared]

"demonstrably incorrect" That's a new legal term, I just made it up ... like it?

What I meant by that is the cases where John Lynch's "FAQ's" have been unambiguously in direct contradiction to a chief counsel interpretation. This has hapened, some have been fixed, I can't say for sure that any still exist, but it's ceratinly a possibility in the future. My point is this: If I were an FAA inspector faced with a potential enforcement situation and I have a Chief Counsel interpretation in one hand and John Lynch's FAQ in the other and they are contradictory, I would have a difficult time rationalizing chosing the guidance in the FAQ over the legal interepetation. That seems to be what you are suggesting.

I share your thoughts on having consistent enforcement, but I disagree that John Lynch is the answer. The problem is a result of FAA inspectors overstepping thier authority and "interpreting" based on what they think the regulations ought to mean, not what FAA counsel says they say. In that sense, John Lynch is just another part of the problem, an FAA empolyee wth no official authority taking it upon himself to issue his own interpretations.

The issue of enforcement standardization is important, but unless the soulution comes from, or is tightly coordinated with the Chief Counsel, It's just adding one more layer to the problem, not solving it.

 

[midlifeflyer]

We agree more than we disagree. Situations where there is a Legal Counsel opinion that contradicts Lynch is one of the exceptions.

Lynch is not the ultimate answer, but FAA Legal has more important things to do than running a FAQ. I don't have a huge problem with non-lawyer administrators doing interpretations (it's done all the time, not just in the FAA) but there should be a direct line to someone in Legal who is charged with the responsibility of at least responding quickly to challenges to the way the agency "unofficially" interprets a regulation.

 

[bobbysamd]

Logging landings and approaches - sole manipulator

Yet another question regarding logging times....sorry. But this one may be a little different. So as a cfi how are you supposed to log landings with your students? If your student lands, do you still log it?

As was written above, you can log anything you want; whether it would be prudent to do so is the question. For it to count legally for currency, you have to execute the landings yourself as sole manipulator of the controls. Same goes for instrument approaches; the 6-6-6 rule applies. 14 CFR 61.57(a),(c).

Hope that answers your question. The FAQs are entertaining to read, but the regs are what count, and the regs are clear on this issue. Relying on the FAQ as your legal authority will cause the ALJ to laugh you right out of your certificate enforcement hearing. I understand that FAA Legal Counsel opinions are given legal effect at hearings.

Finally, it's bad enough when ordinary pilots try to find a way around these rules which are really intended for their own good. It's worse when misinformed and/or malintentioned Chief Flight Instructors, who are supposed to set an example for his subordinates, try to further the practice. Once more, I am reminded of my FlightSafety Chief Pilot. Because he probably was too cheap to let instructors have proficiency time in the aircraft, he tried to shove down our throats that the approaches our instrument students executed as sole manipulator counted for our own personal currency. I don't remember the exact authority he cited, but it could have been somewhere in Part 121. He also said some FSDO puke said so. I agree with the points made above that FSDOs should be consistent, but I still wouldn't go to a FSDO for this kind of advice.

 

[nosehair]

How about this? Where in your logbook do you show that the landings marked in the landing column are yours for currency? Do any of you guys do that? I've not ever differentiated between 'my" landings and the student's landings. Anybody?

 

[bobbysamd]

Logbook landings column

I have the brown Jepp logbooks which have columns for landings. The landings I did I logged - which meant that landings were not listed for a great many of my flights.

 

[JAFI]

Bobbysamd said:


"He also said some FSDO puke said so."


Do you think that maybe, just maybe, your chief pilot made this up? Gee, I wonder how many times this happens?????

JAFI

------------------------
Thanks for the "FSDO Puke" comment. I am going to ad this to my list of names and comments. Though it will be hard to top Shakum's " I wouldn't piss on an FAA Inspector if he were on fire".

 

[bobbysamd]

FAA pukes - present company excepted

"He also said some FSDO puke said so."


Do you think that maybe, just maybe, your chief pilot made this up? Gee, I wonder how many times this happens?????

While the Chief Pilot had lied to me about the salary I was to receive and my promotion opportunities, he did not seem to be a liar in other ways.

Considering that he likely heard this from the MCO FSDO, which was responsible for our school, and which is known for giving pilots a hard time, it wouldn't be surprising, and, in this instance, the term "puke" fits. However, in all fairness,

Thanks for the "FSDO Puke" comment. I am going to ad this to my list of names and comments.

Please don't. Some of my best experiences in aviation were with FAA personnel. For example:

I was a member of Oklahoma Wing CAP in Oklahoma City. Several of our members were FAA employees at the Monroney Center. One was a FSS instructor, who was a great pilot and flight instructor, and with whom I reconnected when she was transferred to the PRC FSS.

Another was an ASI who trained DEs at the Center. He created a CAP Check Pilot course for our wing which was essentially a condensed version of his DE course. I took the course one year and, the next year, after being named an Assistant Wing Check Pilot, helped put on the course. The training this gentleman provided was some of the best I received in aviation. It served me well when I became a stage check pilot at ERAU because I already knew how to conduct a flight examination. This gentleman retired from the FAA and is now a DE in JAX.

The manager of the PWA FSDO was known to be a tough guy. He retired and became a DE. I went to him for a practical and he treated me extremely professionally and fairly. I liked him so well that I returned for two more practicals. I sent one of my first two signoffs to him for his practical and would have sent the second to him as well, but he wasn't available. Instead, I sent the second guy to a DE whom the FAA hired shortly thereafter. This lady treated this young man well.

Finally, I had three positive experiences at the SDL FSDO. The first was when I had my logbook reviewed for my ATP written signoff. The second and third were when I renewed my CFI based on activity. I walked in with my completed 8710s both times (the first being my application for Gold Seal). Each time I was treated courteously and professionally and not hassled in any way. The two times I renewed my CFI I renewed early and was never challenged about it.

Compare these experiences with my CFI renewal with the MCO FSDO. I had resigned from FlightSafety to take a new job in California. I wanted to renew, again early, because that office was familiar with my school and I did not want to walk into a FSDO that would be neither familiar with me nor with my school. I had my 8710 and records at the ready, just as with SDL. I arrived expecting the same kind of courteous treatment that I had been afforded at SDL and PWA. I was not ready for the third degree the inspectors gave me about why I was renewing early and their demands and doubts about my identity, my school's identity, and my pass/fail record. I asked why the third degree and I was threatened with a 609 (709). Although I finally got my renewal short of having electrodes strapped to me or being 609d, that is why I characterize the MCO FSDO as "pukes."

 

[JAFI]

Bobbysamd,



I will not ad the "Puke" comment to my list to honor your request.



I wish to apologize for the bad time you had at a certain FSDO or with a specific ASI. As always it is the bad apples that give us the most trouble. It pleases me that you have had positive experiences. There is not much I can do about the bad part.



I will however copy some parts of the New Customer Service Initiative for your consideration and review. You may find them useful in the future. In short what it means is that you can always elevate a “concern” to the next higher level. Your “concern” can be many things, you decide. The phone list will assist in finding the next higher level.



Basic - Flight Standards (AVR) web site for later reference: http://www.faa.gov/avr/afs/



-------On the AVR site click on:



AVR Customer Service Initiative page: http://www.faa.gov/avr/customerservice/



----------In the letter you will see under “Customer Service Principles”:





“As our customer, you can expect from us:”



ü Clear guidance on how you can elevate your concerns to the next higher level of authority





----------Now, to determine who to contact use the phone directory:





http://www.faa.gov/avr/afs/fsdo/index.cfm

The chain of command (not carved in stone and depending on which department your concern is in): Inspector, Supervisor, Office Manager, Regional Manager, AFS-1 (Head of) Flight Standards, AVR-1 Associate Administrator for Regulation & Certification, and as always - Administrator of the FAA.
​

​

I hope this will assist you in elevating any concerns.
​

​

JAFI
​

 

[bobbysamd]

Thanks, JAFI

I wish to apologize for the bad time you had at a certain FSDO or with a specific ASI. As always it is the bad apples that give us the most trouble. It pleases me that you have had positive experiences. There is not much I can do about the bad part.

I appreciate it. As it turns out, one of your brethren (sisters?) more than made up for it.

This gal and I were instructors at ERAU in Prescott. She was a great pilot and flight instructor - one of the few people I have met who could land a 182 without landing flat - and someone who had also battled the regional airline hiring wars. The PDX FSDO hired her to be an ASI. She had known about my bad treatment at the MCO FSDO and offered to renew my CFI based on acquaintance. It was good of her to do that. That was my last CFI renewal.

It is too bad that the actions of a few can slur the actions of so many.

 

[midlifeflyer]

How about this? Where in your logbook do you show that the landings marked in the landing column are yours for currency? Do any of you guys do that? I've not ever differentiated between 'my" landings and the student's landings. Anybody?

61.51 starts off with:

==============================
Each person must document and record the following time in a manner acceptable to the Administrator:
(1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.
(2) The aeronautical experience required for meeting the recent flight experience requirements of this part.
==============================

If you treat the logbook as your official record of demonstrating these two things to the FAA on request, it's a non-issue. You have no need to differentiate anything. If the number is in the logbook, it counts for one of these two purposes. If it doesn't count for one of these two purposes, it's not in the logbook (unless it's in a special column or is a point of interest that appears in "remarks")

I'm an "official record" logger. Every number in the standard logbook columns "counts". My student's landings simply don't get put in my logbook because they don't count for anything that has to do with my currency or any certificate or rating that I might aspire to.

 

[CLR2LAN]

ok, so for the past three months, i've been logging the total landings, both i or my students have been doing. I'm going to start changing over to only what i do. What would you do about all those entries with 4+ landings that you never performed, but were PIC, and how would you explain that in an interview?