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Logbook labyrinth

Parsing the regs for logging instrument time

To log or not to log. If only that were the question.
Advanced Pilot

Knowing how to properly log most flight time isn’t particularly difficult, but the rules around logging instrument flight time are confusing and have been the subject of various FAA guidance and legal interpretations.

There are perhaps three situations where logging accurate instrument flight time is important: for your résumé as a professional pilot; insurance paperwork as an owner or renter; and currency. Given that the regs spell out currency requirements, let’s start there.

In general terms, plan to log the time you’re under the hood and in instrument conditions as instrument time, and the location and type of each instrument approach for the sake of currency. The name of your safety pilot, if your flight requires one, must also be logged. FAR 61.51 has more specific language, but this is the gist of it in layman’s terms.

This should be all you need to know, but with the regulations nothing is easy. Let’s say you’re trying to remain instrument current (six approaches within six months, holding, and intercepting and tracking a radial), and it’s an IFR kind of day. The ceiling is around 800 feet and visibility is two miles. These are perfect conditions for training. It gives you some space to climb before entering the clouds, and the approaches won’t be to minimums. But can you count them for currency?

In a word, yes. But there’s an important distinction here. Because the approaches are being conducted in actual instrument conditions, the FAA has taken the position that breaking out somewhere along the final approach segment and then following that approach to the decision height or minimum descent altitude constitutes an approach and can be logged (and thus be used for currency). Break out before the final approach fix and it doesn’t count.

In a 2015 Information for Operators, the FAA said that each segment of the approach must be flown for an approach to be logged, except for the missed approach. Thankfully, there is a specified exception for a pilot who receives vectors to the final approach course, so you do not need to start at the initial approach fix in these cases.

When flying under the hood, the document makes it clear that the approach must continue to the decision height or minimum descent altitude for it to be considered valid for training or currency, so no cheating and taking the hood off early.

For some reason the FAA also thought it important to note in the document that to log an approach, a pilot must also log instrument time. I guess the thinking is that you can’t conduct a valid approach without flying on instruments or under the hood, which feels redundant. The rules around logging instrument flight time are confusing and have been the subject of various FAA guidance and legal interpretations.

This discussion brings up a whole slew of additional questions concerning safety pilots and their responsibilities. In short, if you are flying in simulated instrument conditions, a safety pilot is required. She must be qualified for the category and class of aircraft, but need not be current or instrument rated. If the pilot flying decides to act as pilot in command, the safety pilot can log second in command time as a required crewmember. When the safety pilot acts as PIC, both can log PIC time—the pilot as sole manipulator of the controls and the safety pilot as acting PIC.

Much of the guidance of the Information for Operators comes from previously issued FAA letters of interpretation. The scenarios and questions are virtually endless, but two examples show how closely the FAA parses these interpretations. In one letter, a pilot asked whether acting as second in command on an airline flight allowed him to log instrument time and the approach when the captain was the one flying the airplane. According to the FAA’s answer, the second in command is a required crewmember, and may log the instrument time as SIC, but didn’t perform the approach and therefore can’t log it for currency.

In a separate letter a CFI asks about the same scenario, but between student and instructor. Here the FAA considers the CFI’s supervision so important that it said the CFI can log both instrument time and the approach, even if she never touches the controls.

Confused yet? Don’t worry. Even the FAA produces contradictory guidance sometimes. Common sense goes a long way toward answering some of these questions, but if you’re uncertain, seek clarification before you make your logbook entry.

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Ian J. Twombly

Ian J. Twombly

Ian J. Twombly is senior content producer for AOPA Media.

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