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Old 02-22-2011, 03:40 PM
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Default Unable to log PIC time under IFR fightplan?

I'm working on my CFI now and I remember this problem that occurred the day I went to take my IR checkride!

To gain some "actual" experience as well as learning to fly in the IFR system, my CFII took me on a bunch of trips where we filed and flew IFR flights together. Because I was still only an IR student, we would file IFR under his name to Flight Service.

On these flights I gained a lot of actual time as well as hood time, XC time, and other aeronautical requirements to qualify for the checkride - life was good!

Alas came time to take the checkride when I never came as close to a heart attack in my life : my examiner was unwilling to count nearly 10 hours of my XC time and IFR time (actual and hood time) because I flew these while on an IFR flightplan. In other words, I was "unlawfully" logging PIC time on those flights because although I flew on an IFR flightplan with a CFII, I personally was not instrument rated.

Needless to say I spent the next week filling up those requirements and passed the check ride the following week.

Lessons learned?

Actual time cannot be counted toward aeronautical experience for your instrument rating?

Even though the FARs encourage you to learn about the IFR system, if you actually file an IFR flightplan with a CFII you can't count any of the flight time and experience for your rating?


Examiner says I can't, my CFII says I can. Clear as mud.


Any help would be great - thanks!
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Old 02-22-2011, 04:06 PM
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I think your examiner is full of ****... but I am probably wrong.
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Old 02-22-2011, 05:08 PM
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In 1988, I did a 7.4 hr instrument training x/c over a weekend from OK-IA-OK. My instructor had me log almost half that time in actual conditions and the other half under the hood and about 2.4 hrs of it at night too. It was all logged as dual given. Less than 2 weeks later I had my instrument checkride and I certainly don't remember my DPE giving me any grief over that time logged (by the time of my checkride I had 4.9 of actal time).

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Old 02-22-2011, 05:50 PM
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Originally Posted by HercDriver130 View Post
I think your examiner is full of ****... but I am probably wrong.
Yeah, exactly. It would be odd that the FARs would actually FORBID instrument rating students from flying through a single cloud with a CFII during their training.

I mean, according to my examiner, they could.. but the flight time wouldn't count for ****
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Old 02-22-2011, 06:57 PM
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Originally Posted by HercDriver130 View Post
I think your examiner is full of ****
I second this!

I have never heard of any examiner or FAR that forbids instrument students logging PIC while IMC or on an IFR flight plan. If you are rated in the category/class, then you can log it. Almost all my training was on an IFR flight plan, and I had over 10hrs of actual going into my check ride.

Two of my students just passed their instrument check rides in the last month, and both had considerable amount of actual time logged which counted toward their requirements for the rating. Also, more than half of the time was on an IFR flight plan. I have never had an issue with any examiner saying you can not do this.

The only thing I have ran into is students logging simulated instrument at night. You can log them both, but you can not count both toward the experience required for a certificate. Where this usually becomes the issue is private students logging simulated instrument at night, and trying to use that time as part of the required night. Examiners will not accept that.

I would call your local FSDO to see what they say and hopefully have them talk to that examiner.
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Old 02-22-2011, 07:30 PM
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Originally Posted by mikearuba View Post
I'm working on my CFI now and I remember this problem that occurred the day I went to take my IR checkride!

To gain some "actual" experience as well as learning to fly in the IFR system, my CFII took me on a bunch of trips where we filed and flew IFR flights together. Because I was still only an IR student, we would file IFR under his name to Flight Service.

On these flights I gained a lot of actual time as well as hood time, XC time, and other aeronautical requirements to qualify for the checkride - life was good!

Alas came time to take the checkride when I never came as close to a heart attack in my life : my examiner was unwilling to count nearly 10 hours of my XC time and IFR time (actual and hood time) because I flew these while on an IFR flightplan. In other words, I was "unlawfully" logging PIC time on those flights because although I flew on an IFR flightplan with a CFII, I personally was not instrument rated.

Needless to say I spent the next week filling up those requirements and passed the check ride the following week.

Lessons learned?

Actual time cannot be counted toward aeronautical experience for your instrument rating?

Even though the FARs encourage you to learn about the IFR system, if you actually file an IFR flightplan with a CFII you can't count any of the flight time and experience for your rating?

Examiner says I can't, my CFII says I can. Clear as mud.


Any help would be great - thanks!

I think the examiner is full of it as well. I would have asked him to show you were it says to the contrary, and then asked the FSDO if it was legal. Upon being told yes, I would have then reported it to the FSDO.
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Old 02-22-2011, 07:35 PM
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The way I understand your post is that the examiner would not count your instrument time (actual and hood) and XC time towards the requirements to take your checkride. If this is correct, then the examiner is half wrong.

He is probably referring to 61.3(e), which says that you can not act as PIC under IFR or conditions less than VFR unless you have an IR. However, I think what the examiner meant was that you cannot count the XC time you flew with your instructor towards the 50 hours of XC time as PIC required for the IR (Review 61.65(d) carefully for the IR requirements). You CAN, however, count any of the instrument time you accrued on the XC flights towards the 40 hours required for the IR, as well as the 250nm XC requirement (if it applied on one of you XC's). More clearly, since you can't act as PIC under IFR or conditions below VFR (61.3(e)), you can't count that dual XC time towards the 40 hour XC PIC requirement (and thus why your CFII was PIC and had his name on the flight plan). Only the instrument time counts.

Please correct me if I completely misread your post. I hope I cleared this up a little.

Last edited by WalkOfShame; 02-22-2011 at 07:43 PM. Reason: clarified... I think.
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Old 02-22-2011, 08:30 PM
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Originally Posted by WalkOfShame View Post
The way I understand your post is that the examiner would not count your instrument time (actual and hood) and XC time towards the requirements to take your checkride. If this is correct, then the examiner is half wrong.

He is probably referring to 61.3(e), which says that you can not act as PIC under IFR or conditions less than VFR unless you have an IR. However, I think what the examiner meant was that you cannot count the XC time you flew with your instructor towards the 50 hours of XC time as PIC required for the IR (Review 61.65(d) carefully for the IR requirements). You CAN, however, count any of the instrument time you accrued on the XC flights towards the 40 hours required for the IR, as well as the 250nm XC requirement (if it applied on one of you XC's). More clearly, since you can't act as PIC under IFR or conditions below VFR (61.3(e)), you can't count that dual XC time towards the 40 hour XC PIC requirement (and thus why your CFII was PIC and had his name on the flight plan). Only the instrument time counts.

Please correct me if I completely misread your post. I hope I cleared this up a little.
It was nearly 2 years ago, so it's a bit fuzzy. You may be right, I think maybe it was only the XC time he did not want to count. I think he gave me a break on the "actual" bit....

But this guy was a bit of a hard a**. The 250nm trip I did with an IFR flightplan, THAT he was threatening to take away from me too. But he let me go on that part but still would not let me take the check ride unless I flew 10 more hours of XC time, VFR.
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Old 02-23-2011, 05:35 AM
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So according to 61.3(e), the only kind of time that I cannot count towards my IR while on an IFR flightplan is:
  • PIC
  • Cross country (XC)

Is that correct?
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Old 02-23-2011, 06:00 AM
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Originally Posted by HercDriver130 View Post
I think your examiner is full of ****... but I am probably wrong.
You are absolutely right. The Examiner need a refresher course on 61.51 - sole manipulator of the controls by a pilot who is rated for the aircraft is 100% of the requirement for logging PIC.

Mike, it's a shame you got stuck with an Examiner who doesn't know (or perhaps just didn't like) the rules that have been crystal clear for more than 30 years.

No, walkofshame, there's no difference between cross country time and any other time in this situation. The only restriction on cross country time is that the pilot who logs cross country time must be the pilot who did both the takeoff and the touchdown. The instrument student who flies an IFR cross country with his instructor may log PIC and actual, cross country, night if those conditions apply to the flight.

This isn't grey. There are people who understand and people who don't. But "I personally don't understand or like it" is not the definition of a "grey area."
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