SIC logging IMC question?

[KickSave]

I dunno why I thought of this, just bored I guess. We all know that the SIC can log as Instrument Flight Time only the time which the SIC operates the aircraft solely by reference to instruments. The PIC basically is under the same guidelines in terms of logging instrument time... but what about when you are using the Autopilot, which for your airline guys is most of the time, right?

Who is operating the aircraft when you are on autopilot? Do you just decide who is the PF and PNF and that is who is operating the aircraft then, or do both pilots log it as instrument time when you're in the clouds and also on autopilot? Or neither pilots logs that time? Or do you just not care?

 

[metrodriver]

The one who gets to do the takeoff can log the IFR (pf). As the pnf has to monitor the progress made by the pf (and as such has the same appr.plates hanging on the yoke, using the same charts interpreting if what the pf does is really printed on the charts) you do the same amount of IFR flying except for manipulating the controls. So why should the pnf not be able to log that time?

 

[Bluto]

KickSave,
Actually, we don't all agree that only the PF can log Instrument time. This has been debated numerous times on this board, however, under a 121 flight both crewmembers are considered to be "operating" the aircraft. Part 61 does not make any reference to "sole manipulator of the controls" with respect to logging instrument time as it does for takeoff/landing recency and instrument currency (approaches).

Metrodriver, I'm confused, first it sounds like you say only the PF can log it, then it sounds like you say both...which is it?

 

[rptrain]

there's been some good debate on this question over at propilot.com.

http://www.propilot.com/doc/bbs/msgs//8946.html

It boils down to this: the FAA FAQ for part 61 says an SIC can only log Instrument time while operating the airplane as sole manipulator. However, many have noted that this answer in the FAQ is not reasonably supported by the wording of the regulations (it's not legally binding, although it is policy). After all, you can log night time as an SIC, right? Night, like instrument, is merely a condition of flight. The 8710 distinguishes between night PIC and SIC. Instrument time should be no different.

My advice would be to keep a separate tally of SIC instrument time. If the Chief Counsel ever issues a formal interpretation you can go back and either add it in or remove it.

 

[metrodriver]

What I was saying the pnf can not log IMC time (not the manipulator of the controls), however I think that it should be possible to do that, just like rptrain says. You can log night, why not IMC time, considering the fact that you still have to monitor the flight. So maybe the rules need to change, or they need to be interpreted differently

 

[Bluto]

I agree. Good points.

 

[midlifeflyer]

Part 61 does not make any reference to "sole manipulator of the controls" with respect to logging instrument time as it does for takeoff/landing recency and instrument currency (approaches).

Actually Part 61 doesn't say anything about "sole manipulator of the controls" with respect to logging approaches for instrument currency. In fact, I'm pretty sure that except for logging PIC and some 142 training center requirements, all references to "sole manipulator" in the FAR refer to landings.

That's what leads to the debates about CFIIs logging approaches while giving training in IMC. The FAR use the word "perform" instead.

 

[Bluto]

Interesting point. I guess I just always took 'performed' to mean: physically manipulated the controls. However, I believe you are correct. The only place I recall reading "sole manipulator" is with reference to landing currency.

 

[canadflyau]

Personally, I do not log conditions of flight unless it is my leg.. I thought that was standard practice. You are not manipulating the controls whether it be an A/P, heading bug, or yoke. The PNF is just monitoring the flight and doing all the other stuff. Guess I just thought that was the norm.. I can't sight a reg or anything, just the way I was told it was and never questioned...

Good thread

 

[Hawker rider]

Very good thread.

Since in multi pilot airplanes the PF and PNF BOTH operate the aircraft, i think both can log it. IF not>> then at any given point during the flight is it approved by flightmanual to fly the plane single pilot?? as that's what they are sayng, with the PNF not operating the airplane, then he's basically not rerquired crewmember, so it'll have to be single pilot.

Further along the line, IF I'm seeing it wrong, then during periods of Autopilot no human is allowed to log ANY time, as monitoring the A/p is exactly the same as the PNF monitoring the PF, which is probably THE most important thing that happends in a cockpit, to see the flight through safely.

just my $0.02

M

 

[Timebuilder]

Until recently, I was using the standard of manipulation of the flight controls for my SIC logging of IFR, since I was using the term "operating" the aircraft to mean "hands on the yoke", or "sole manipulator". I was wrong.

On the propilot site mentioned above, Doc posted a letter of interpretation from the office of the chief pilot, which is the only authority who can legally interpret any 14 CFR regulation.

According to the letter, both pilots are continually operating the aircraft as a crew, and therefore the SIC is indeed operating the aircraft and may log all of the IFR time that he is doing so.

 

[ksu_aviator]

Here is how I look at it. It is a better representation of my skills as a pilot to log only that time which I am manipulating the controls in IMC as IFR.

In my opinion, it is splitting hairs to say that performing an approach can mean backing up another pilot's approach. You didn't really perform that approach, the other pilot did.

On the autopilot side of things, I consider the autopilot to be a flight control, so the pilot operating the autopilot logs the time.

But, its your log book and you can do with it what you want.

 

[Bluto]

Here's a question related to this discussion. What are your personal guidelines for logging an instrument approach flown in visual conditions. Do you log it at all towards currency? If not, how much time during the approach would you have to be IMC to feel comfortable logging it? IMC down to minimums? How about popping through a cloud just inside the IAF? Where do you personally draw the line?

 

[Timebuilder]

In my opinion, it is splitting hairs to say that performing an approach can mean backing up another pilot's approach. You didn't really perform that approach, the other pilot did.

Logging approaches is not addressed by the reg that allows the SIC to log IFR time. In order to log approaches for currency, you must be the PF.

 

[SquirrelDog]

I totally agree with KSU_Aviatior.

What good is logging time that one did not do anything to control the a/c. By controling the aircraft in IMC you as a pilot are gaining experience and getting better at your skills. If you are PNF and log the IMC time how does that help your skills? I see it as the one flying logs the time, interviewers probably agree.

As for logging the approach or not; I log the approach if its below VFR and needed to get into an airport. Otherwise its just a back up on a visual. Currency gets taken care of ever 6 to 12 months with checkrides.

Its your log book, time, and interview so whatever, just my little opinion.

Squirreldog

 

[Timebuilder]

I see it as the one flying logs the time, interviewers probably agree.

A good interviewer is probably aware of the FAA's stand on who is "operating" the aircraft, and therefore it wouldn't present a problem.

As for logging the approach or not; I log the approach if its below VFR and needed to get into an airport.

Then you need to check out what the FAA says about logging approaches. You'll love it. Head over to Doc's site.

 

[SquirrelDog]

I would assume that the interviewer would know the FAA's take of the logging of time, but like many pilots, people get on the interview boards without knowing the right information and comming from a bias opinion on different subjects.

Also, I am not sure who Doc is but I do not go logging approaches everytime I set a LOC FREQ in. I was referring to Bluto's reply about personal accounts of logging approaches.

Timebuilder: what is your opinion, or should I say the FAA's

squirreldog

 

[metrodriver]

Bluto, at a lot of 135 and 121 operations it is recommended / mandatory to use the ILS if it's available. I always dial the ILS in, especially at night just to give me a little bit more protection against visual illusions, landing at the wrong runway / airport and to keep me out of stuff that pokes high into the sky.

Regarding approaches: if I need part of an approach to get down, it gets in my logbook.
Same as the time spend as pnf in IFR conditions. Somewhere in the ops manual it says that the FO when acting as pnf has to make sure that the pf (in this case the PIC) doesn't do anything he is not supposed to do, and if the airplane does something it's not supposed to do that I bring it to the attention of the PIC. This means I'm reading the instrument like I'm flying the airplane except the controls are manipulated by the PIC or by George, or by my voice if the PIC is not reacting. I also have to call out courses /glideslopes alive, altitudes and a whole lot more to assist the pf.

 

[Twotter76]

Ill come in on this one. With regards to the first part I this thread I only log the time when it is my leg. When it is not my leg I am am operating the aircraft in a legal sense but I am not flying it. I also agree that the autopilot is just another flight control and it is there to assist me - I am still ultimately responsible for ensuring that the aircraft gets to where it needs to be.

Regarding Bluto's question about logging approaches for currency I again only log approaches on my leg and then only if I am still IMC upon starting the final segment. If I get that far I am going to log it. If I break out on the decent to the intercept then I am just as likely to call for a visual anyway to help out the controller and speed things along. I do this for my own sake not currency - since I fly part 121 being current isn't my responibity - thats up to the training department and why I fly sims every year. In my logbook all the approaches and actual time are what I FLEW - not what I assisted with. Just my take on it.

 

[Dieterly]

STRIIIIIKE 1!!!

since I fly part 121 being current isn't my responibity - thats up to the training department

 

[midlifeflyer]

Then you need to check out what the FAA says about logging approaches.

Which version of what the FAA says?

I'm with metrodriver and squirreldog on when to log it if I'm doing the flying.

 

[dondk]

Logging approaches...

My .02...

It is what you are cleared for and that is how I log it...

On those MVFR days if approach clears me for the ILS then in the company log and my logbook it is an ILS, regardless if we complete it visual.

If they clear me for the visual and I do the ILS it is logged as a visual.

Also, if it is clear and a million and they set me up on a 20 mile final for an ILS, then it is logged as one.

I know it is splitting hairs, but this is how my company told us to log it for the company purposes. How YOU log it is your own call.


SIC and IMC... I always understood it to be that in actual BOTH can log it.

I looked at this for one month in the winter.. I found that my IMC time was way out of proportion. Some days I would have 3 hours IMC for a 5 hour day.. Now I would think that would raise a flag or two and I chose to do it only if I was the PF.

 

[Timebuilder]

First, here is "legal opinon number 10" (numbered by Doc) regarding the definition of "operating" an aircraft:

http://www.propilot.com/doc/legal10.html

On the other topic, I did a search of this site under "logging approaches", and found a thread where Avbug had shared another one of those Chief Counsel opinions, which I must say again, are the ONLY binding interpretation of the regs:

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

 

[KickSave]

According to that response from Byrne, virtually no one would ever truly be current unless they put on the foggles, or got in a sim. Byrne (in)conveneiently leaves out the answer to the key question - how much of the approach needs to be in IMC? And he answers the question of how far down do you have to fly the approach, not what the debate is about.

If I break out of IMC at 100 feet above my DH darn strait I'm logging that as an approach for currency purposes. But that is not exactly what Byrne, or the Regs, say you may do.

Why is this so hard to get a final answer from the feds?

 

[Bluto]

I'm glad I'm not the only one without a clear understanding of what the feds mean...It seems like even they don't know what they really want.

 

[midlifeflyer]

FWIW, here's my personal FAQ on the issue. It's more a historical perspective than a definitive answer.

If you look at 61.57(c) (instrument currency) you'll see that the 6 instrument approaches that have to have been done in the prior 6 months must be "performed and logged under actual or simulated instrument conditions..." Some of the other requirements have changed through the years, but this one has been with us for a while.

Sounds pretty simple, doesn't it? Except some idiot thought to ask, "How much actual is actual?" What if you pass through a single scattered cloud on the way down for a total of 5 seconds of "actual"? Can you count the approach?

Sometime in 1989 or 1990, it seems FAAviation News ran an article that said that you had to fly the approach to minimums in IMC in order for it to count. Someone wrote in pointing out the illogic of a rule that meant that a very experienced pilot who flew hard IMC all the time would probably not be able to log the approaches, since most approaches don't involve breaking out at minimums.

In the July/August 1990 issue, FAAAviation News replied to the writer:

"Once you have been cleared for and have initiated an approach in IMC, you may log that approach for instrument currency, regardless of the altitude at which you break out of the clouds"

Problem is that this answer doesn't work either. Now, you're on a feeder route to the IAF above the cloud deck when you're cleared for the approach. You fly the full approach, enter the clouds just above glideslope intercept and break out at 200 AGL with 1/4 mile visibility. Oops! Sorry! You were not "cleared for and have initiated an approach in IMC".

(You're starting to see why I called the person who asked the "How much" question for the first time an idiot.)

In 1992, the FAA legal counsel chimed in:

"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."

Uh-oh! If you take the opinion at faces value, there's that reasoning again that essentially says that if you don't go missed, you can't log it.

There is a strong school of thought out there that says that what it "looks like" the FAA Counsel said is not what they meant. Note that despite the question, although the answer says that you have to follow the procedure all the way (unless it's not safe), it does not say that you have to follow the procedure all the way "in actual IFR conditions."

(You can see where his is much better fodder for arguments than anything else in the logging arena.)

The camp that says that the legal counsel didn't mean all the way in IMC (call them the "Rule of Reason" school) are essentially saying that "How much" is one of those undefined terms. Not everthing is susceptible to precise definition. Try to thing of all of the scenarios and come out with a rule that covers every probably (let alone possible) approach scenario. How many pages did you use?

When Part 61 was revised in 1997, there was a proposal to write the rule so that, in order to count, approaches had to be flown to MDA or DA to count. They got a lot of comments, including one that said,

"One commenter suggests revising the definition to permit the pilot to terminate the approach prior to DH or MDA for safety reasons. Another commenter proposes to define "instrument approach" as " * * * an approach procedure defined in part 97 and conducted in accordance with that procedure or as directed by ATC to a point beyond an initial approach fix defined for that procedure." The commenter explains that this definition would allow for logging instrument approaches that require some portion of the published approach procedure to be followed in order for the pilot to establish visual references to the runway"

The FAA decided against the new requirement.

Some point to the fact that the FAA posted this comment as support for the rule of reason approach.

Whew!