Logging IMC when not current

[Dmahan]

I'm not sure if this is the correct place to post this question, but I think it will be the place most likely to find someone able to give a good answer.

I am a CFI, but not instrument current. I went flying today in IMC with an instrument rated and current private pilot friend of mine. We took turns flying, any other day we would either just split the time or call it an instruction flight and both take all the time and log his time as dual given. Today was different though being in IMC.

Can I log the IMC time and the approach (and count the approach towards currency)? My argument is that I cannot as I was not legal to act as PIC in that situation. The argument could also be made that I am a rated pilot acting within the limits of my certificate.

I don't want someone to see actual time being logged without me being able to prove currency. Probably won't ever be an issue, but I still want to keep the logbook as correct as possible.

[S-Works]

No...............................

[sapco2]

That's a question I've thought about too. I hold an ATPL/IR which is current, and I also hold an unrestricted FI rating. My CFI pointed out to me that until such time I renew my IMC rating I cannot fly in cloud in a single crew aircraft albeit I can teach IMC in VFR conditions. I'm not sure if he's correct but I've taken the safe option in renewing my IMC rating.

[Dmahan]

This is in the US, so that is something to keep in mind.

The best answer is to get instrument current and not worry about it. However, there is a dollar sign associated with doing that and as a full time CFI that just isn't in the budget.

[Another_CFI]

SAPCO2, Do you hold a CAA ATPL or a JAA ATPL? If it is a CAA ATPL then you have a non-expiring IMC. The rating is valid for life, or until EASA scr.ws it up!

[Genghis the Engineer]

Strikes me (in answer to the OP's post) that unless US regs are substantially different to the European regs, then unless your friend held a current CFI rating, then as soon as the aircraft went IMC/IFR you were a passenger handling the controls, and can't log that proportion of time at-all.

G

[Cobalt]

Dmahan, whatever you log makes no difference to instrument currency.

If you are already not instrument current (6 approaches / hold / tracking), logging an approach and time makes no difference - you need an IPC to get your instrument privileges back (FAR 61.57 (d))

I would talke your view that, since you lacked capacity to be PIC, you cannot log the time. The typical situations - IR training (where both CFII and student can log PIC) and safety/lookout pilot (where the safety pilot can log PIC in addition to the pilot flying the aircraft) do not really apply in this case.

[sapco2]

In reply to Another_CFI....
Mine started out as a CAA ATPL then changed to JAA ATPL on my last renewal date and I believe its due to change yet again to an EASA ATPL when I next renew.

[Whopity]

I think bose-x answered the original question very concisely!
My CFI pointed out to me that until such time I renew my IMC rating I cannot fly in cloud in a single crew aircraft albeit I can teach IMC in VFR conditions. You can teach basic instrument flying using your unrestricted FI rating without any further qualification however; to teach applied IF you need to hold an IRI qualification and a valid instrument qualification. You can't teach IMC, it is a state of the weather!

[sapco2]

Many thanks Whopity but its still as clear as mud to me... but maybe thats because I've had a 20 year break away from instructing and the ratings and terminology seems to have changed since my time.

I'm going to write to to the CAA to see if I can get a fuller explanation because "applied instrument flying" doesn't explain anything at all to me! All I need to know is, "am I allowed to teach the IMC syllabus or not?"

[mad_jock]

If you don't have a valid IMC or SPA IR no you can't.

If you hold an old CAA license CPL or ATPL it has an IMC for life.

If you hold a JAR license it has no SPA IMC rights and a seperate rating needs to be held.

And all the CAA will do is point you at lasors or the EASA CAP

[sapco2]

Thanks mad_jock, that's really appreciated.

Mine is a CAA ATPL issued in accordance with ICAO and JAR-FCL standards. It shows I have an IMC rating for which I was tested again recently, that's additional to my multi crew IR which is also current.

Questions still remaining are...

1. Is an IMC renewal a legal requirement, additional to a current multi-crew IR?

2. I still need to get my head around the term "applied instrument flying" I still don't know what that actually means?

If there's doubt there's no doubt... just ask!

[mad_jock]

Yes it is a seperate national rating. Intially they did give it and said that a MPA IR kept it current.

Then an ATPL MPA IR crashed on partial panel so they had a rethink and said you had to do the test. Can't really get worked up about that to be honest.

If you have a look through lasors at the IRI qualification

Basically its anything which leads to an instrument rating. The pre JAR FI rating made you get this restriction removed before you became unrestricted and JAR you didn't. EASA have a seperate rating the IRI which is going to cause problems with keeping people valid.

It has always been that any FI could teach the 180 to escape cloud instrument flying for PPL/NPPL.

There was a method under JAR that you could keep a SPA SEP IR valid through experence hooked on the back of your MPA IR. Only ever met one pilot that managed that and don't have a clue if you can do it under EASA.

Sounds like you have a JAR license which means no imbeded rights of the IMC.

[Whopity]

The JAR/EASA CPL has 10 hours of IF, this falls within the privileges of a JAA/EASA FI and does not require the IRI qualification, the training does not include any instrument approaches. Under EASA the same 10 hours can also be called the Basic Instrument Flight Module (BIFM) which actually requires an IRI to teach, although the same syllabus can still be taught on the EASA CPL by a FI. No wonder people are confused!

The parts of the UK IMC that do not involve approaches can also be taught by a FI without the " No applied Instrument" restriction being removed. This has always been the case, but as AFIs had to have the Restriction removed in order to upgrade to FI then it seldom occurred.

[blagger]

CAP804 and LASORS say all instruction on the IMC course must be given by an IRI or FI with the restriction removed

[Whopity]

As the authors don't know their arse from their elbow it could say anything!

From LASORS1. JAR-FCL CPL(A) holder without an IR(A)
To gain an IMC rating a JAR-CPL(A) holder will be
required to complete the following:-
i. 5 hours of applied dual instrument instruction in
accordance with the IMC Rating syllabus and;
ii. pass an initial IMC Rating Flight Test. The other 10 hours IF being completed on a CPL Course where the instructor is not IRI qualified!

CAP 804 States:Instruction on the course may only be given by an IRI or by an FI who
is qualified to teach applied instrument flying.All FIs are qualified to teach basic instrument flying but not necessarily Applied IF!

Then for the usual bit of inconsistency3.4 Rating Approach Types
The syllabus for the IMC Rating requires a minimum of training and testing in
proficiency in 2 approach types. IMC rating holders are strongly urged to undergo
further training with an appropriately qualified flight instructor before attempting to fly
additional approach types. Urgghh! does this imply parts of the course can be conducted by someone who is not qualified to teach approaches?

[mad_jock]

That did make me chuckle Whopity

[BEagle]

1. In Brave New Euroland, the only 'applied instrument' instructional criteria are those required in order to provide instruction for the IR. Such instruction may be provided either by an IRI or by an FI who meets the stated criteria.

2. Anyone who currently instructs / examines for the IMC Rating may continue to do so into the future, assuming that all relevant ratings / certificates remain valid. This will also apply to the 'IR(Restricted)' - which is identical to the IMC Rating in all but name.

3. However, the CAA has not yet formulated suitable requirements for future IMCr / IR(R) instructors / examiners - i.e. those who won't be qualified to do so before 17 Sep 2012 but would like to be at some future time. AOPA has submitted a paper which proposes a solution, but the CAA won't take this to EASA until it knows whether our NPA 2011-16 comments have been accepted.

[mad_jock]

Any time scale for when the authors are going to be shown the difference between thier arse and elbow?

[Aware]

NPA 2011-16 Any idea if accepted when the changes would likely take effect ?

[Whopity]

However, the CAA has not yet formulated suitable requirements for future IMCr / IR(R) instructors Hardly rocket science, the requirements have remained largely unchanged as far back as I can remember and if its good enough to train for an IR, its good enough for the IMCr. The last thing we want is another course for the FIC world.

[421C]

Dmahan, whatever you log makes no difference to instrument currency.


If you are already not instrument current (6 approaches / hold /
tracking), logging an approach and time makes no difference - you need an IPC to
get your instrument privileges back (FAR 61.57 (d))
No; you quote the right para of 14 CFR but have missed the bit in underline below

d) Instrument proficiency check. Except as provided in paragraph (e)
of this section, a person who has failed to meet the instrument experience
requirements of paragraph (c) for more than six calendar months may
reestablish instrument currency only by completing an instrument proficiency
check
What this means is that once your currency lapses, you have 6 months in which you can regain currency flying the required approaches etc under VFR with a view-limiting device and a suitably qualified safety pilot (or under IFR with a CFII). It's only after 6 months of lapsed currency that you must take an IPC. Of course, an IPC can be used at any time to regain currency.

[BEagle]

Hardly rocket science, the requirements have remained largely unchanged as far back as I can remember and if its good enough to train for an IR, its good enough for the IMCr. The last thing we want is another course for the FIC

Your usual bull in a china shop approach, Whopity.....

Whilst the course might be the same, the problem is that the reduced prerequisites for FIs wishing to instruct for the IMCr / IR(R) will no longer be available after 17 Sep 2012. Thus they would need to have achieved, amongst other things, at least 200 hours of flight time under IFR - no longer will the current alternative of 50 hours of IF time be acceptable. Whereas until that date, a reduced experience level of 10 hours flight time by sole reference to instruments is applicable for FIs wishing to have the 'no applied instrument' restriction removed in order to instruct for the IMCr.

This was pointed out to the CAA nearly 2 years ago, but nothing was done....

[Cobalt]

....correcting an error...

Thanks, 421C, I see it now. I now also dimly remember learning it properly when I did my FAA IR.

[Whopity]

Your usual bull in a china shop approach, Whopity..... Better that than leaving little piles of dog pooh everywhere that we all have to step around!

[B2N2]

I am a CFI, but not instrument current. I went flying today in IMC with an instrument rated and current private pilot friend of mine. We took turns flying, any other day we would either just split the time or call it an instruction flight and both take all the time and log his time as dual given.

Be carefull now, you can only log dual given/dual received if you have actually taught something.
Going funflying with a pilot friend does not constitute "dual given".
What are you teaching him anyway if he is already PPL/IR rated?

Back to your original question:
You cannot act as PIC under IFR if you do not meet the currency requirements.
You can however log PIC as the sole manipulator of the controls.

My interpretation is that you CAN log the IMC time and you CAN log the approach under the "sole manipulator" of the controls rule but your friend cannot log that time.
My source: http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/Walker.pdf

You may want to do some additional research yourself by searching on the applicable reg numbers such as 61.57;
Regulations Division - Legal Interpretations & Chief Counsel's Opinions (http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/Interpretations/)