Logging Instrument Approaches as a Flight Instructor

Aspen 1000I recently acted as a flight instructor for a customer who is learning new avionics (especially an Aspen Evolution PFD and a Garmin GTN750) recently installed in his 1970s vintage Cessna Turbo Centurion (T210).

For more information about logging flight time, see this item here at BruceAir.

Typical autumn weather prevailed in Seattle, so we conducted the entire flight under IFR, and we were in the clouds for most of the 1.5 hour flight. The owner flew two ILS approaches and one RNAV (GPS) procedure with LPV minimums. We also flew a hold-in-lieu of a procedure turn (see AIM 5-4-9).

Now, IFR pilots generally must meet the requirements of 14 CFR 61.57(c) to maintain their IFR currency. That regulation states:

…(c) Instrument experience. Except as provided in paragraph (e) of this section, a person may act as pilot in command under IFR or weather conditions less than the minimums prescribed for VFR only if:

…Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations in an airplane, powered-lift, helicopter, or airship, as appropriate,…

(i) Six instrument approaches.

(ii) Holding procedures and tasks.

(iii) Intercepting and tracking courses through the use of navigational electronic systems.

The question, often asked, is whether I, as the flight instructor, can log the approaches flown by the owner. FAA issued a legal interpretation on this specific issue in 2008 (Levy 2008). (You can search the FAA website for legal interpretations here.)

The Levy 2008 letter states in part:

Am I correct in understanding that a CFII may log approaches that a student flies when the approaches are conducted in actual instrument conditions? Is there a reference to this anywhere in the rules?

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 instructions” and this would count for instrument currency requirements under § 61.67(c).

The letter elaborates by noting that:

The FAA views the instructor’s oversight responsibility when instructing in actual instrument flight conditions to meet the obligation of 61.57(c) to have performed the approaches.

Although the letter does not specifically address the other requirements for IFR currency–holding procedures and tasks and intercepting and tracking courses through the use of navigational electronic systems–the reasoning of the interpretation seems to support allowing an instrument instructor also to log those tasks when the aircraft is operating in actual IMC.