Re: Another \"logging\" question . . .
Personal FAQ
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May a CFII Log Student Approaches Flown in Actual IMC?
In the Part 61 FAQ, John Lynch says yes. This is probably the most controversial position he's taken. A lot of folks disagree with him. FWIW, here's my personal take on the issue, which sets out the FAQ and some of the arguments that support it. 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 arguments 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. In fact, 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 (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. 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, for me this isn't a proficiency issue. Arguments about whether watching someone else fly an approach makes you proficient don't impress me. 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.
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