Logging long IFR XC - caveat aviator/instructor

poadeleted20

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Just ran into this today -- my instrument trainee completed his long IFR XC with a local CFI-IA before he hired PIC. When I checked his log today (48 hours prior to the practical test -- should have done this on Day 1), the only things in the remarks for the flight are ""40N-RDG-MIV-ESN-40N, 2 GPS, 1 ILS, 1 VOR" and the instructor's signature. The point-to-point round-robin distance for that route adds up to only 226nm, although if you use the airways that DUATS gives you with the Low Altitude Auto-router, you get 257nm. How many miles did they really fly? Nobody knows for sure, there's no way to tell based on the log entry (which doesn't even meet 14 CFR 61.51 standards since it doesn't tell which approach was done where), and the instructor failed to refer to the regulation for which this flight is flown (14 CFR 61.51(d)(2)(iii)) when he signed the log entry (and of course he is out of town and unreachable).

I'm not enthustiastic about reflying the long XC (that would essentially waste a training day, cost the trainee about $1000 for a day of my time/expenses and 3+ hours of flying, and put off the practical test another 24 hours), but absent an appropriate log entry or demonstrable distance of over 250nm between the airports, how do we prove the flight covered "A distance of at least 250 nautical miles along airways or ATC-directed routing "? Will the DPE accept the applicant's word that his flight went the extra 24nm? Gonna find out...

...and just spoke to the examiner. I asked how he measures the mileage, and he asked why. I said, "Well, if you go on DUATS and check the round-robin mileage for the airports logged using the IFR auto-router, it comes to 257nm, but..." and he interrupted me and said, "STOP. I'll see you and your trainee on Monday." WHEW!

In any event, since the regs do not specifically address this issue, it's never been addressed by the FAA Counsels, and there's no hint of AFS-800's thinking on paper anywhere, my suggestion to all IR trainees and instructors is either to make sure the straight line distances between the airports visited adds up to 250nm, or for the instructor to specifically say in the remarks line that the flight meets the requirements of 14 CFR 61.51(d)(2)(iii) (I do that regardless). If you do neither, the examiner may refuse to accept the flight as meeting those requirements (and thus the applicant fails to meet the aeronautical experience requirements for the rating), and that could end the practical test before it starts.

And before anyone says, "Well, the pilot's signature is certification of the accuracy of what's in the logbook," it ain't always so. An examiner told me how he rejected an application for an IR since the instrument training flights all had the same total time and simulated instrument time and there was only 40.0 hours of instrument time total. Were they taxiing around, taking off, and landing with the hood on? I don't think so, and the examiner said he suggested the trainee revise the log before the FAA saw it. Another time a trainee submitted a log for an ATP with 1600 hours total time and 1500 hours of actual instrument time all flown in the fair-weather Caribbean and logged as "day" time -- "But it was all flown under IFR!" Not.
 
Ron,

Thanks for posting that. I'll toss it in my file and show it to my CFII so we make sure there is no question when the time comes. Posts like yours make the time I spend of this board totally worthwhile.

Thanks.
 
I don't get it. If a DE refuses to accept an entry that is signed as being accurate by the applicant for this, where does it end?

"Well, i don't really think you flew those .3 hours under the hood as a primary student. You'll have to fly again."

Absent some sort of action taken by the FAA, I think DEs should just shut up and do the test if the logbook shows the requirements....

This gives too much power to DEs.
 
I don't get it. If a DE refuses to accept an entry that is signed as being accurate by the applicant for this, where does it end?
I don't think you understand the question. There is no question that the examiner accepts that the pilot flew an XC between those listed airports -- the question is whether the flight as described in the log meets the requirement as stated in the regulation.

"Well, i don't really think you flew those .3 hours under the hood as a primary student. You'll have to fly again."
Again, there's no question that the trainee flew 0.3 under the hood as a primary student -- the question is whether that time counts as "instrument flight training" towards the requirements of 14 CFR 61.65(d).

Absent some sort of action taken by the FAA, I think DEs should just shut up and do the test if the logbook shows the requirements....
I agree. The problem is that the regulations do not make it clear what that test is.

This gives too much power to DEs.
Again, I agree -- that's why I liked having the FAQ file as "official policy guidance." It provided a handy reference for all examiners and instructors. Since its demise from "official" status, we are again left without any standardized guidance short of asking for an official legal interpretation, which takes four to six months. The only option currently available is to ask the local FSDO, and the record is clear that the same question asked of two different FSDO's is likely to obtain three different answers. That creates real problems for an instructor like me who's teaching in a different district every week.
 
While I understand Nick's concern, I agree with Ron above. But, I can understand a DE going with the conservative decision. He has his own ticket on the line just like the CFI who sent the applicant to him.

Heck, if a DE has what the FSDO may view as an overly large number of successful check rides on first try, they can take a closer look-see at him. No DE wants that any more than the CFI would want question by the DE for irregular log book entries.
 
The only option currently available is to ask the local FSDO, and the record is clear that the same question asked of two different FSDO's is likely to obtain three different answers. That creates real problems for an instructor like me who's teaching in a different district every week.
Worse than that, asking the same question of two different examiners in the same FSDO can also lead to different answers, so all CFI's run into the quandary, not just those who, like you, are dealing with many. Standardization can be a good thing. :yes:
 
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