? for Active CFII's

EatSleepFly

Well-Known Member
? for Active CFII\'s

I was reading a post over on flightinfo where someone asked if you can log approaches toward currency if you are a CFII on an approach in IMC with a student. My answer to this has always been yes, based on the FAA's FAQ thingy, and my own interpretation of a few select FAR's. Well, those guys are all getting their panties in a wad saying that the FAQ's aren't regulatory and they're quoting a vintage 1980 Letter of Interpretation. Anyone have an opinion on this, or a more recent Letter of Interpretation? Cause if you can't use approaches with students in IMC towards currency, I haven't been legally instrument current in a verrrrry long time!
 

Cosmo1999

Well-Known Member
Re: ? for Active CFII\'s

I also log the approaches in IMC and I think it makes you just as current. I mean we all know what its like to go in the clouds for the first time knowing that if you look up nothing is there. It can be a little disconcerting. The first approach or two in IMC with a student usually isnt pretty. The instructor has to keep just as active of a scan going to make sure the student doesnt get disoriented. Plus the student isnt legal to be in the clouds without you yet since he isnt IFR rated. This means that since you are ultimately responsible you should definately get to log the approaches. It also states in the regs that you can log all the time in actual.. When someone I know went on his MEI checkride they had to blast through the clouds to get up to manuevering altitude. The Examiner asked him to show he was current so he showed the approaches he did with students in actual. He accepted this with no problem. There really isnt a specific reg for this but if the student isnt allowed to be there without you and since you have to babysit the entire approach you should be able to log it.
 

MidlifeFlyer

Well-Known Member
Re: ? for Active CFII\'s

I read the thread and I really don't see where the 1980 opinion says that a CFI =can't= log them for currency. The argument that it can be logged but not for currency makes no sense - all legitimate logging is for meeting certificate rating or currency requirements. But this is a very controversial issue. Here's my personal FAQ on the issue:

==============================
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 FAQ 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.
==============================
 

EatSleepFly

Well-Known Member
Re: ? for Active CFII\'s

Thanks guys! Personally, I don't use them for currency anyways, unless we're still IMC at/inside the FAF.

Also, in my logbook I distinguish between approaches that I can count, and those that I can't. For example: I go out with an instrument student and we fly 4 approaches. On two of them, we are in IMC past the FAF. On the other two, the weather improved, and we are in and out of IMC, but in VMC after the Final. In my logbook, under approaches, I would log this: "2/4" Two of the four total that we did count toward my currency. I do the same with landings. Might be overkill, but at least I can distinguish between what we did, and what I can use to keep current.
 

sixpack

New Member
Re: ? for Active CFII\'s

I log the dual-given IMC approaches -- so I'm legal.
I occasionally fly the approaches myself -- so I'm safe.

Oh, by the way. I'm sure the FAA realizes that CFII's are logging these approaches for currency. If they thought this was the wrong practice, they could easily add about 20 words to the FAR/AIM 2005 and fix the problem.
 

MidlifeFlyer

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
I would log this: "2/4" Two of the four total that we did count toward my currency. I do the same with landings. Might be overkill, but at least I can distinguish between what we did, and what I can use to keep current.

[/ QUOTE ]I'm curious about this. Why?

I understand why you are distinguishing them. If you are going to log things that don't count, It's definitely =not= overkill to identify them in some way. I think to do otherwise would be fraudulent.

What I don't understand is why you put the ones that =don't= count in the IAP or landing column at all. What are they for?


BTW, my version of sixpack's comment is:

I log for currency, (hopefully) fly based on proficiency, and pray that I never confuse the two.
 

EatSleepFly

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
What I don't understand is why you put the ones that =don't= count in the IAP or landing column at all. What are they for?

[/ QUOTE ]

Just so I know the type, number, and location that I've done with each individual student. Sure, its in their record folder as well, but this way I have it for future reference should it ever be called into question what kind of approaches we did during the course of their training. Like I said, maybe its overkill.
 

MidlifeFlyer

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
Just so I know the type, number, and location that I've done with each individual student.

[/ QUOTE ]Gotcha. If you generally put what you covered with a student in your logbook, then it makes sense to put these in also, although if I were doing it in this context, I'd probably put the no-count ones in "remarks" and not put the number in the IAP column.
 

DE727UPS

Well-Known Member
Re: ? for Active CFII\'s

Flightinfo guys get thier panties in a wad all the time. Especially that Avbug guy. I don't spend a lot of time at Flightinfo anymore cause of the attitudes....

Anyhow...while the FAQ's might not be regulatory, I think they are darn helpful in figuring out or confirming what the FAR's are supposed to mean. When it comes right down to it, FSDO guys aren't regulatory, either, but you wouldn't tell them that or ignore their advice....I wouldn't ignore what the FAQ's have to say.
 

EatSleepFly

Well-Known Member
Re: ? for Active CFII\'s

Thats pretty much why I just lurk over there. Besides, Jetcareers is far superior!

Anyways, thanks for the input, guys!
 

MidlifeFlyer

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
Flightinfo guys get their panties in a wad all the time.

[/ QUOTE ]That's one of the reasons I enjoy it. It's fun to say something and then watch.
 

SUSPilot

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
Flightinfo guys get thier panties in a wad all the time. Especially that Avbug guy. I don't spend a lot of time at Flightinfo anymore cause of the attitudes....


[/ QUOTE ]

I've never been to Flightinfo, but the aviation board that I used to post on three or four years ago was ipilot (I found it because of the cheap sectional charts they sell), and he was in there screaming and yelling at people all the time saying how much he knew about any type of aviation job be it cropdusting, helicoptors, flight instructing, airline flying, corproate, or A&P work. It almost gets to the point with him where you want to say what is it you really do besides post on the internet.
 

EDUC8-or

Well-Known Member
Re: ? for Active CFII\'s

Yes, I log them. Until I read something from the FAA that says I can't, I will continue to do so.
 

PeanuckleCRJ

Poodle Wrangler
Re: ? for Active CFII\'s

Since I am acting PIC as CFII when teaching, it seems to me that it is a no-brainer that the approaches and hodling that you are teaching certainly goes in the logbook.


Now i logged the landings that my students did, but that's another subject.
My currency was never in question, and keeping a logbook seems to be like accounting...sometimes several answers and grey areas for things.
 

MidlifeFlyer

Well-Known Member
Re: ? for Active CFII\'s

[ QUOTE ]
Since I am acting PIC as CFII when teaching, it seems to me that it is a no-brainer that the approaches and hodling that you are teaching certainly goes in the logbook.

[/ QUOTE ] What does acting as PIC have to do with logging =anything=? The logging a CFI is permitted to do is based on the act of giving training, not on being PIC.
 

JEP

Malko In Charge
Staff member
Re: ? for Active CFII\'s

As a current IFR student, I am logging my simulated IMC time as PIC. My instructor is not the PIC, unless we are in Actual conditions. Does he actually get to log his non-IMC time as PIC, eventhough he is not flying the plane?
Otherwise he is in a role similiar to a safety pilot. Because I am not instrument rated, I cannot log PIC in Actual conditions. Or I am I missing the boat on that one? Can I log PIC in Actual conditions without the rating?
 

Ralgha

Well-Known Member
Re: ? for Active CFII\'s

Your instructor IS the PIC, you are only PIC because you are sole manipulator of the controls. Your instructor is responsible for everything that happens in, to, or because of that airplane.
 

EatSleepFly

Well-Known Member
Re: ? for Active CFII\'s

To clarify what Ralgha said- you're logging PIC because of the "sole manipulator of the controls" thing. No student of mine will ever act as PIC when I'm there.

To answer your question, you can log IMC time as PIC because you're sole manipulator of the controls receiving instruction from a CFII.
 

JEP

Malko In Charge
Staff member
Re: ? for Active CFII\'s

....and to clarify my statement, I did not mean for others to think that I am PIC. I should have just referred to Logging PIC.
I understand that the CFII could take the plane at anytime should I slip up somewhere.
 

Ralgha

Well-Known Member
Re: ? for Active CFII\'s

It's actually you, the student, who the exception is made for. You get to log PIC even though you are not PIC, they make the allowance since you are the sole manipulator of the controls. The instructor gets to log PIC because he/she IS PIC.
 
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