Maintaining Instrument Currency

Instrument Procedures

Larry sez:

As I am writing this in the early summer of 2020, many flight departments are doing minimal flying as their companies are "locked down" due to a worldwide pandemic. Pilots are scrambling to maintain currency and every little trick helps with the battle. We got this question from a corporate captain:

I have a question regarding logging an instrument approach.

61.57 is very specific about landings stating “sole manipulator of the controls”. With regards to Instrument experience, 61.57 states “that person performed and logged”.

My question is, in an aircraft that is certificated for more than one crew member is there a situation where both crew members could log the same approach. Since both crew members are “performing” their duties on the approach, if flown in actual conditions could both pilots log that approach. The pilot flying was “performing” their duties, and the pilot monitoring was “performing” their duties.

I have a similar question regarding holding procedures. In a two-crew cockpit, the nonflying pilot typically builds the hold in the FMS while the flying pilot verifies and flies the hold. Could both crew members log the same hold since they are both performing their duties?

Thank you for any clarification you can provide.

That is a very good question and I hope I can present you with a very good answer . . .

Last revision:

2020-06-15

Can both pilots log the same approach or holding pattern?

I would say the answer is no, with one exception. The exception is that a CFII (certified flight instructor, instrument) may log approaches 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 conditions" and this would count for instrument currency requirements under § 61.57 (c)." (See FAA Legal Interpretation, Ronald B. Levy, 2008)

Further in the 2008 Levy interpretation, the FAA Chief Counsel states: "The regulations expressly permit an authorized instructor conducting instrument instruction in actual instrument flight conditions to log instrument flight time (61.51 (g)(2)). The only remaining issue is whether, even if properly logged, the approaches are considered to have been "performed" by the instructor within the meaning of section 61.57 (c)(1). The FAA views the instructor's oversight responsibility when instructing in actual instrument flight conditions to meet the obligation of 61.57 (c)(1) to have performed the approaches."

No such provision in the regulations permits an SIC, in an aircraft certificated for more than one crew member, to log those same "tasks and iterations" for "the purposes of maintaining instrument currency."

On the contrary, the regulations state with regards to logging instrument time: "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." § 61.51 (g)(1) and with regards to instrument experience: "Within the 6 calendar months preceding the month of the flight, that person performed and logged at least the following tasks and iterations..." § 61.57 (c)(1)

I would highly doubt the FAA would consider an SIC monitoring (and without the responsibility and oversight of instructing) an instrument approach flown by the PIC, who is operating the aircraft solely by reference to instruments under actual or simulated instrument flight conditions to have "performed" the approach (or holding pattern) within the meaning of section § 61.57 (c)(1).

The applicable regulations

[14 CFR 61, §61.51 Pilot logbooks

(g) Logging instrument time.

(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.

[14 CFR 61, §61.57 - Recent flight experience: Pilot in command.

(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:

(1) Use of an airplane, powered-lift, helicopter, or airship for maintaining instrument experience. 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, for the instrument rating privileges to be maintained in actual weather conditions, or under simulated conditions using a view-limiting device that involves having performed the following -

(i) Six instrument approaches.

(ii) Holding procedures and tasks.

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

(2) Use of a full flight simulator, flight training device, or aviation training device for maintaining instrument experience. A pilot may accomplish the requirements in paragraph (c)(1) of this section in a full flight simulator, flight training device, or aviation training device provided the device represents the category of aircraft for the instrument rating privileges to be maintained and the pilot performs the tasks and iterations in simulated instrument conditions. A person may complete the instrument experience in any combination of an aircraft, full flight simulator, flight training device, or aviation training device.


14 CFR 61, Title 14: Aeronautics and Space, Certification: Pilots, Flight Instructors, and Ground Instructors, Federal Aviation Administration, Department of Transportation

Ronald B. Levy (2008) Legal Interpretation