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9 Answers

Instrument currency in IMC with CFI/CFII

Asked by: 5018 views , , ,
FAA Regulations, Flight Instructor, Instrument Rating

I'm currently in the 6-month period where I'm not instrument current, but don't yet need an IPC.  I was looking through 61.51 to determine if I could log approaches in actual IMC with an instrument-current CFI, or if I needed to be with a CFII.  In 61.51(e), it looks like I can log PIC time with a CFI:

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided -

(C) The supervising pilot in command holds -

(1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required;

And in 61.59(g):

(1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

Combining these, it looks like I can log PIC in IMC as long as I'm with a CFI, and I get to log instrument time because I'm operating the controls.  Is this right or am I missing another relevant reg?

Thanks,
Matt

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9 Answers



  1. KDS on Jan 22, 2020

    As long as the other pilot is instrument current and qualified and is acting as PIC during any portion of the flight where you are on an instrument clearance, yes.

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  2. Kris Kortokrax on Jan 23, 2020

    You need to be careful how you read regulations.

    61.51(e)(iv) is one way you can log PIC, but you must meet all the requirements including 61.51(e)(iv)(A) & (B) which state you must already hold a Commercial or ATP and you must be undergoing training in an approved pilot in command training program. Training programs are approved under Parts 121, 125 and 135. Part 61 has no training programs. Part 141 has training courses, not training programs.

    You would log PIC time under 61.51(e)(1).

    61.59 deals with falsification. 61.51(g) deals with logging instrument time.

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  3. Best Answer


    John D Collins on Jan 23, 2020

    As KDS says, if you are rated in the aircraft and are the sole manipulator of the controls, you can log the time as PIC and count the approach towards your currency. The other pilot must be fully current and act as PIC for the flight, since you may not. The other pilot does not need to be an instructor. If the other pilot is a CFII and providing instrument instruction, then both you and the CFII can log the instrument time and the approach towards meeting their IFR currency requirements.

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  4. Matt C on Jan 23, 2020

    Kris, I see, I was thinking A, B & C were ORs, but I suppose they’re ANDs.

    John, you’re saying that I would log PIC and the approaches, and the other pilot would ACT as PIC but not log it (unless he’s a CFII)? It seems crazy that the pilot who must explicitly act as PIC would not be able to log it, while the non-qualified pilot can.

    Thanks,
    Matt

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  5. John D Collins on Jan 24, 2020

    Matt,

    There are numerous FAA General Counsel opinions on this topic. The details matter. A pilot who is acting as PIC is not necessarily the one who is logging PIC.

    Pilot in command means the person who:
    (1) Has final authority and responsibility for the operation and safety of the flight;
    (2) Has been designated as pilot in command before or during the flight; and
    (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

    Both Acting as PIC and logging PIC, although they sound similar are different concepts that are easily confused. In some other countries, the pilot acting as PIC is termed as the Pilot Commander, which in my opinion is a clearer distinction. Who gets to log PIC is a complex topic covered by 61.51(e) which runs on for quite a bit of detail:

    (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
    (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
    (ii) When the pilot is the sole occupant in the aircraft;
    (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or
    (iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—
    (A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;
    (B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—
    (1) Preflight preparation;
    (2) Preflight procedures;
    (3) Takeoff and departure;
    (4) In-flight maneuvers;
    (5) Instrument procedures;
    (6) Landings and approaches to landings;
    (7) Normal and abnormal procedures;
    (8) Emergency procedures; and
    (9) Postflight procedures;
    (C) The supervising pilot in command holds—
    (1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or
    (2) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and
    (D) The supervising pilot in command logs the pilot in command training in the pilot\’s logbook, certifies the pilot in command training in the pilot\’s logbook and attests to that certification with his or her signature, and flight instructor certificate number.
    (2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.
    (3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.
    (4) A student pilot may log pilot-in-command time only when the student pilot—
    (i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;
    (ii) Has a solo flight endorsement as required under §61.87 of this part; and
    (iii) Is undergoing training for a pilot certificate or rating.

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  6. Craig on Jan 24, 2020

    I think the CFI would be similar to Pilot A in the Walker (2011) interpretation (also the Speranza 2009 interp)?

    faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Walker%20-%20(2011)%20Legal%20Interpretation.pdf

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  7. Matt C on Jan 26, 2020

    Thanks, John. Yes, I’d been sorting through 61.51(e) before asking. Just wanted to make sure I’d understood you correctly since it’s a bit counter-intuitive.

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  8. Mark Kolber on Jan 29, 2020

    >>I think the CFI would be similar to Pilot A in the Walker (2011) interpretation (also the Speranza 2009 interp)?

    Craig, no. Pilot A can’t log the time because there is no 61.51 “box” which allows him to log the time. The Walker Chief Counsel letter makes that very clear in its explanation – he is neither the sole manipulator nor in command of an operation which requires more than one pilot.

    But a CFI on an instructional flight does have a special 61.51 box — 61.51(e)(3) which allows a CFI to log PIC “for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.”

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  9. Craig on Feb 03, 2020

    Mark,

    So even though the instructor is not a CFII, she/he can still log it as instruction/PIC as part of “control and maneuvering of an airplane solely by reference to instruments”, correct? Sounds good to me.

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