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5 Answers

Can I log the flight as the authorized instructor on board? Commercial long cross country

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Commercial Pilot, FAA Regulations, Flight Instructor, Student Pilot

I was an authorized instructor on board for my students long commercial cross country. Do I log any of that flight time?

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5 Answers



  1. Mark Kolber on Jan 31, 2019

    Yes. You log it as PIC because you were acting as an authorized instructor.

    The CFI logging reg says so and it is covered in the 2014 Kuhn Chief Counsel interpretation.

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2014/kuhn%20-%20(2014)%20legal%20interpretation.pdf

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  2. Kris Kortokrax on Jan 31, 2019

    Mark,

    He may be looking for more than PIC. Lots of low time pilots now want to log X-C as well to show X-C PIC time when applying for an airline job.

    This raises a question. We are all familiar with the Gebhart interpretation concerning X-C that states only one pilot may log X-C based on the idea that logging X-C time requires that a pilot perform a takeoff and landing. What would Legal say if confronted with a question concerning whether an instructor could log X-C for a flight during which he made not takeoff or landing? (I personally think the instructor should be able to log this time because 1. He is the actual PIC and 2. the instruction is required by the regulations.)

    This goes even further. I have seen situations where two instructors make a flight with instructor A flying the outbound leg (with no hood) and instructor B flying the return leg (with no hood). Both log X-C PIC time for both legs based on a logbook entry that each was providing the other with “X-C dual”. (i.e. for each leg, one was manipulating and the other was “providing instruction”.)

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  3. Mark Kolber on Feb 01, 2019

    Kris, yep, he may be looking for more.

    FWIW, my take of the the Gebhardt issue, I wouldn’t want to ask.

    As I read them, that series of opinions ultimately said that only the pilot who flies the entire flight, including the takeoff and landing is entitled to log cross country time. It’s not about who is PIC or who is in charge or who is required or whose ticket is on the line.

    OTOH, there are also interpretations on various topics which make exceptions for instructors.

    One has to “perform” an instrument approach in order to log it for currency. But while the nonflying pilot in a two-pilot crew in an aircraft or operating requiring one is not considered to be “performing” an approach in actual instrument conditions, a wet-behind the ears CFII doing recurrent training with a current ATP holder is. (Maintaining landing currency with student landings is different since it’s hard to get around the “sole manipulator” language)

    In the opinion responding to one of your questions, despite prior statements that a student pilot is “always a passenger” with respect to a CFI, the Chief Counsel said a student pilot is **not** a passenger for the purpose of passenger currency requirements.

    In neither is there any substantive basis for the differentiation other than that it’s a CFI acting as an authorized instructor. IMO, it’s about a policy of supporting CFIs, their time building and currency.

    Since the Gebhardt series is IMO more about regulatory policy than regulatory construction to begin with (this is the time we **want** people to count toward their instrument and commercial), it’s at least as likely the Chief Counsel would create yet another CFI exception here as apply Gebhardt.

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  4. wheels_up on Feb 01, 2019

    Was actual flight instruction given on the entire flight? If not, then you cant log PIC since you were not the sole manipulator of the controls.

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  5. Mark Kolber on Feb 01, 2019

    wheels_up, it is by definition, not an instructional flight. But the CFI is acting as an authorized instructor and can log PIC time.

    You are welcome to your opinion but I’d rather rely on the FAA Chief Counsel’s.

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