CFI Logging Cross Country Time

9 Answers

1. 
   

   
   

   John D. Collins on Mar 19, 2012

    

   I log the time I act as an instructor on a cross country flight as Pilot in Command, Dual given, and Cross Country.  I don’t log the landings for the purpose of my own currency unless I actually perform the landing. I agree with your understanding with respect to a saftey pilot.

   From part 61.1 definitions:

   (4) Cross-country time means–

   (i) Except as provided in paragraphs (b)(4)(ii) through (b)(4)(vi) of this section, time acquired during a flight–

   (A) Conducted by a person who holds a pilot certificate;

   (B) Conducted in an aircraft;

   (C) That includes a landing at a point other than the point of departure; and

   (D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

   FAR 61.51 on logging reads in part:

   ***

   (e) Logging pilot-in-command flight time.

   ***

   (3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

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2. 
   

   
   

   Earl Kessler on Mar 21, 2012

   I have never argued with John or even found him in error, however I question the landing issue. I believe that every landing that your student makes, as a CFI, you also may log. Same with instrument approaches. Please show me if I am in error.

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3. 
   

   
   

   John D. Collins on Mar 22, 2012

   Earl,
    
   Thanks for questioning, I haven’t seen anything definitive on the subject.  I agree that there is a FAA Counsel Opinion that a CFII may log instrument approaches under actual instrument conditions and count it towards their own IFR currency (see quote below).  Using the same logic, one could argue that a CFI could log landings performed by a pilot receiving dual instruction. Even so, it is up to the CFI whether or not they choose to log the landings for their own currency.  It is probably a good question to ask the Chief Counsel for clarification.
    
   From the FAA August 7, 2008 legal opinion answering Ron Levy’s question:
   “The Chief Counsel’s office agrees that the earlier guidance reflects the appropriate interpretation of the regulations. The regulations expressly permit an authorized instruct or conducting instrument instruction in actual instrument flight conditions to log instrument flight time (61.5 1(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)(l). 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.”

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4. 
   

   
   

   Bill Trussell on Mar 22, 2012

   Point of logic here:
   If the instructor is acting as PIC for the flight, including the landing(s) and would ultimately be held responsible for the satisfactory outcome of any or all of the landings, would it not make sense that they be logged by the PIC?  I log them all, and if I ever question my own comptetency from a currency perspective, I go out and do more. 
   That said the rules are fairly clear on the subject:
    
   61.57 Recent flight experience: Pilot in command.
   (a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and—
   (i) The person acted as the sole manipulator of the flight controls; and
   This rule would counter the landing argument, but is not intended to address the x-c issue.

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5. 
   

   
   

   John D. Collins on Mar 22, 2012

   Bill,
    
   Good point. It is still worth obtaining a Chief Counsel opinion, but you make a good argument.

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6. 
   

   
   

   Dan Chitty on May 22, 2013

   Great discussion.

   Since cross country time must involve a landing (ATP defination excluded) and since the CFI is not manipulating the controls, can the CFI log the cross country time? I ask since a landing must be performed as part of cross country time and only one person can be manipulating the controls to perform a landing.

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7. 
   

   
   

   Mark Kolber on May 22, 2013

   Bill asked:

   > If the instructor is acting as PIC for the flight, including the landing(s) and would ultimately be held responsible for the satisfactory outcome of any or all of the landings, would it not make sense that they be logged by the PIC?

   No. As a byproduct of “logging” and “acting” being different for FAA purposes, “Ultimately responsible” has nothing to do with logging. As you point out, “sole manipulator” is what the currency reg says.

   Dan, you asked:

   >since the CFI is not manipulating the controls, can the CFI log the cross country time?

   Good question. The FAA is on record in a number of written interpretations that only the pilot performing the takeoff and landing, or a crewmember required for the entire flight (for example, a required part 135 SIC on an IFR passenger flight; not a safety pilot) may log cross country time.

   There has been no written interpretation on how a CFI fits in. My guess is that, if asked, the FAA would allow the CFI to log it, but it’s only a guess.

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8. 
   

   
   

   John D. Collins on May 23, 2013

   I asked the FAA Chief Counsel regarding logging the landings for currency purposes and this was the answer which agrees with my first post. http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/collins%20-%20(2012)%20legal%20interpretation.pdf

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9. 
   

   
   

   Don Kelly on Oct 01, 2015

   Interesting question regarding the logging of landings by a CFI, as well as the dubious opinion of the FAA councils office. First, while the definition of cross country (with the exception of military service credit for ATP) must include a landing it does not specify who must perform the landing. If one crew on a trans Pacific flight takes off, and another lands, does the first crew not get to count the flight as cross country? Logically, you may count cross country time as a CFI if the aircraft is being flown on a mission that meets the definition of cross country and you are performing the duties of a CFI, even if you don’t land the plane. Second, with regard to the less than stellar opinion from the councils office, short of taking it to an administrative law judge, you are now presented with being sanctioned for counting student landings as your own. Using the lawyers logic, if you assist a student with a landing, then neither of you could count it, since neither would be the sole manipulator of the controls. For my part, if I’m flying with a pilot who could fly the aircraft without me, and I don’t touch the controls, I don’t count the landing.

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