Flying_Corporal
New Member
Can you log approaches as a CFII flown by your students in
a) VFR
b) IMC
Can (b) be used toward your own currency? thanx.
a) VFR
b) IMC
Can (b) be used toward your own currency? thanx.
logging approaches??
- Thread starter Flying_Corporal
- Start date
EatSleepFly
Well-Known Member
a.) No
b.) Yes, if you're still in IMC inside the final (some say yes even if you're on a published segment of the approach, but I think thats a bit liberal). Yes you can use it for currency.
Now, prepare to read 47 answers different from mine. I researched this last summer when I was giving a lot of instrument instruction. After looking at the FAR's, the FAA FAQ's (yes, I know, they're not regulatory), and Chief Counsel opinions, I came by the answers that I give you. Its how I log it. Its not wrong or illegal, but there are some differences of interpretation on the matter (just like most regs).
b.) Yes, if you're still in IMC inside the final (some say yes even if you're on a published segment of the approach, but I think thats a bit liberal). Yes you can use it for currency.
Now, prepare to read 47 answers different from mine. I researched this last summer when I was giving a lot of instrument instruction. After looking at the FAR's, the FAA FAQ's (yes, I know, they're not regulatory), and Chief Counsel opinions, I came by the answers that I give you. Its how I log it. Its not wrong or illegal, but there are some differences of interpretation on the matter (just like most regs).
Minnesota_Flyer
New Member
ESF, so your take is that you can log an approach as IFR/IMC if (and only if) you are in IMC crossing the FAF? Or do I misunderstand? I've gotten about 3 different answers to this question from my instructors over the years.
MF
MF
MidlifeFlyer
Well-Known Member
[ QUOTE ]
ESF, so your take is that you can log an approach as IFR/IMC if (and only if) you are in IMC crossing the FAF? Or do I misunderstand? I've gotten about 3 different answers to this question from my instructors over the years.
[/ QUOTE ]Personal FAQ:
==============================
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 below 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 this 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 think of all of the scenarios and come out with a rule that covers every probable (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 to specifically say that 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!
==============================
ESF, so your take is that you can log an approach as IFR/IMC if (and only if) you are in IMC crossing the FAF? Or do I misunderstand? I've gotten about 3 different answers to this question from my instructors over the years.
[/ QUOTE ]Personal FAQ:
==============================
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 below 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 this 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 think of all of the scenarios and come out with a rule that covers every probable (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 to specifically say that 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!
==============================
that's all fine and dandy, but the FAQ's are not regulatory, the CFR's are. And the CFR's use the word "perform", not "preside over", or "ACT as PIC during". My interpretation is probably too literal, but's what my local DPE says also.
I dont log any approaches that my students do, VMC or IMC. I log the approaches that I do.
Oh, one more thing... happy Easter
I dont log any approaches that my students do, VMC or IMC. I log the approaches that I do.
Oh, one more thing... happy Easter
[ QUOTE ]
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]
Agree with bluelake on the approach logging. For me personally, I only log approaches I fly (when in a multi-seat aircraft and with someone else, obviously). Same with landings. If I'd ever fly with a student in a 172, for example, they log the landings they do, I log the ones I do/demonstrate.
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]
Agree with bluelake on the approach logging. For me personally, I only log approaches I fly (when in a multi-seat aircraft and with someone else, obviously). Same with landings. If I'd ever fly with a student in a 172, for example, they log the landings they do, I log the ones I do/demonstrate.
mtsu_av8er
Well-Known Member
[ QUOTE ]
Obviously its time for me to go get a beer and watch Simpsons and make dinner !!!!!
[/ QUOTE ]
We're about to sit down and watch the South Park Movie like a good American family should...
(Right after I finish burning these backup copies of CD's for archival purposes.....)
Obviously its time for me to go get a beer and watch Simpsons and make dinner !!!!!
[/ QUOTE ]
We're about to sit down and watch the South Park Movie like a good American family should...
(Right after I finish burning these backup copies of CD's for archival purposes.....)
MidlifeFlyer
Well-Known Member
[ QUOTE ]
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]You are doing the right thing. The rule for logging landings for currency requires that the pilot logging them be the "sole manipulator of the controls"
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]You are doing the right thing. The rule for logging landings for currency requires that the pilot logging them be the "sole manipulator of the controls"
MidlifeFlyer
Well-Known Member
[ QUOTE ]
that's all fine and dandy, but the FAQ's are not regulatory, the CFR's are. And the CFR's use the word "perform", not "preside over", or "ACT as PIC during". My interpretation is probably too literal, but's what my local DPE says also.
[/ QUOTE ]It's funny the way this boartd works. We sometimes "reply" to things that weren't said by the person wo we are "replying" to. I coulda sworn that I posted the FAQ on how much actual. I did (whew, I'm not completely crazy).
Here's the one on CFIs logging students' approaches. Like the other one, it just sets out what has been said on the subject and leaves you to make your own conclusions.
==============================
May a CFI Log Student Approaches 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 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.
==============================
that's all fine and dandy, but the FAQ's are not regulatory, the CFR's are. And the CFR's use the word "perform", not "preside over", or "ACT as PIC during". My interpretation is probably too literal, but's what my local DPE says also.
[/ QUOTE ]It's funny the way this boartd works. We sometimes "reply" to things that weren't said by the person wo we are "replying" to. I coulda sworn that I posted the FAQ on how much actual. I did (whew, I'm not completely crazy).
Here's the one on CFIs logging students' approaches. Like the other one, it just sets out what has been said on the subject and leaves you to make your own conclusions.
==============================
May a CFI Log Student Approaches 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 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.
==============================
[ QUOTE ]
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.
==============================
[/ QUOTE ]
LOL. On that same note, the FAA thinks it's fine to do that same long night XC, for sake of argument over middle of nowhere Colorado, without an instrument rating.
Legal? Yeah. Qualified? Yeah. Smart? Grey area.....
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.
==============================
[/ QUOTE ]
LOL. On that same note, the FAA thinks it's fine to do that same long night XC, for sake of argument over middle of nowhere Colorado, without an instrument rating.
Legal? Yeah. Qualified? Yeah. Smart? Grey area.....
MidlifeFlyer
Well-Known Member
[ QUOTE ]
On that same note, the FAA thinks it's fine to do that same long night XC, for sake of argument over middle of nowhere Colorado, without an instrument rating.
Legal? Yeah. Qualified? Yeah. Smart? Grey area.....
[/ QUOTE ]LOL! Yes, it's doable. If you know the area, when I do my dual nigh cross country with my students, it's a round robin from APA -GXY-FTG-APA. The first leg is easy: highways, city lights, etc. But that second leg has nothing in the way of ground references or night-visible features, and with the weather just right...
Good thing that as soon as my student realizes she really doesn't want to go that way at night we manage to have a "problem" that makes Denver International Airport (which has wonderfully accommodating controllers) a logical "diversion"
On that same note, the FAA thinks it's fine to do that same long night XC, for sake of argument over middle of nowhere Colorado, without an instrument rating.
Legal? Yeah. Qualified? Yeah. Smart? Grey area.....
[/ QUOTE ]LOL! Yes, it's doable. If you know the area, when I do my dual nigh cross country with my students, it's a round robin from APA -GXY-FTG-APA. The first leg is easy: highways, city lights, etc. But that second leg has nothing in the way of ground references or night-visible features, and with the weather just right...
Good thing that as soon as my student realizes she really doesn't want to go that way at night we manage to have a "problem" that makes Denver International Airport (which has wonderfully accommodating controllers) a logical "diversion"
Mavmb
Well-Known Member
[ QUOTE ]
[ QUOTE ]
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]
Agree with bluelake on the approach logging. For me personally, I only log approaches I fly (when in a multi-seat aircraft and with someone else, obviously). Same with landings. If I'd ever fly with a student in a 172, for example, they log the landings they do, I log the ones I do/demonstrate.
[/ QUOTE ]
I log the landings whenever my life was put in jeopardy.
[ QUOTE ]
What about landings? I haven't been logging landings with students unless I was demonstrating one for them (physically controlling the airplane).
[/ QUOTE ]
Agree with bluelake on the approach logging. For me personally, I only log approaches I fly (when in a multi-seat aircraft and with someone else, obviously). Same with landings. If I'd ever fly with a student in a 172, for example, they log the landings they do, I log the ones I do/demonstrate.
[/ QUOTE ]
I log the landings whenever my life was put in jeopardy.
Icelandair
New Member
During one of the meetings for new CFIs at my school someone asked if we should log the students landings. Afterall, when we are in training and the instructor demonstrated the first landing to us, we still logged it as ours. The answer was: "how many airlines advertise saying you need 10000 landings?" So i only log the ones i do for currency purposes or if i physically demonstrated the landing to a student.