May a CFII Log Student Approaches Flown in Actual IMC?


The long-argued controversy over this question is ended.

In this 2008 FAA Legal opinion, the FAA Chief Counsel’s office formally adopted the officially disowned Part 61 FAQ’s response to the question, saying:

The Chief Counsel’s office agrees that the earlier guidance reflects the appropriate interpretation of the regulations. 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)(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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