61.129 (b)(4)

[tathepilot]

The flight school is telling me I should sign the logbook of the student (inital COM/ME) as PIC time.

COM/ME Aeronautical experience 61.129 (b)(4) specifically states performing the duties as PIC, so regular dual given should be enough.

Logging of PIC flight time 61.51 (e)(i) also states "Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges. What does 'has privileges mean?


COM/ME Aeronautical experience 61.129 (b)(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in §61.127(b)(2) of this part that includes at least—

What are your thoughts?

 

[puddlejumper]

Somewhere in there, I believe the FARs say for solo pilot time to also be logged as PIC. Dual received in an aircraft the student (Sole Manipulator) is not rated in ie: Multi-Engine, should not be logged as PIC.

Another example would maybe be an IFR student getting trained in a single (an aircraft they are rated in) on an IFR flight plan, in IMC. The student in this instance is rated but doesn't have an instrument rating for the condition of flight. I would say, he should log it as PIC. Just be sure the CFI is rated, current and able to ACT as PIC.

Clear as mud?

 

[nosehair]

No. It is not PIC time. The regulation allows this type of dual instruction, "performing the duties of PIC" to substitute and replace the 10 hours of solo that is normally required of the commercial applicant, but it is not loggable as actual PIC time.

Your "School" is actually a "Business", more interested in pleasing "customers" than actually researching regulations.

 

[A Squared]

[/COLOR][/SIZE]61.51 (e)(i) also states "Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges. What does 'has privileges mean?

"has priveliges" is something that was added at the same time as the regs for sport pilots. I'm not sure why it was added, but I'm guessing that it's because the sport pilot certificate doesn't have ratings, so from a strict legal definition, a Sport pilot isn't "rated" in any aircraft. Like I said, that's speculative. I'd be interested to hear form anyone who has a different/better understanding of that nuance.

 

[A Squared]

Oh, and to answer your primary question:

Not 100% sure what your asking, but it seems you're saying that your school is telling you to log a students multi-engine instuctioln time as PIC time, when that student does not have a multi-engine rating.

If that is the question, the answer is absolutely not. No multi-engine rating, no PIC.

 

[tathepilot]

OK, problem solved. Met with the examiner yesterday and a simple statement in the remarks section to the tune of 'performing duties of PIC' will suffice..

 

[midlifeflyer]

"has priveliges" is something that was added at the same time as the regs for sport pilots. I'm not sure why it was added, but I'm guessing that it's because the sport pilot certificate doesn't have ratings, so from a strict legal definition, a Sport pilot isn't "rated" in any aircraft. Like I said, that's speculative. I'd be interested to hear form anyone who has a different/better understanding of that nuance.

You are correct. As I recall, there is some mention of that in the Federal Register preambles to the sport pilot regs. But you can go into the regs themselves to see it. All of the language in Part 61, Subpart J, talks in terms of "privileges" rather than "ratings."

For example:

==============================
§ 61.317 Is my sport pilot certificate issued with aircraft category and class ratings?

Your sport pilot certificate does not list aircraft category and class ratings. When you successfully pass the practical test for a sport pilot certificate, regardless of the light-sport aircraft privileges you seek, the FAA will issue you a sport pilot certificate without any category and class ratings. The FAA will provide you with a logbook endorsement for the category, class, and make and model of aircraft in which you are authorized to act as pilot in command.
==============================

and

==============================
§ 61.321 How do I obtain privileges to operate an additional category or class of light-sport aircraft?

If you hold a sport pilot certificate and seek to operate an additional category or class of light-sport aircraft, you must--
(a) ...
==============================

 

[A Squared]

You are correct. As I recall, there is some mention of that in the Federal Register preambles to the sport pilot regs. But you can go into the regs themselves to see it. All of the language in Part 61, Subpart J, talks in terms of "privileges" rather than "ratings."

Thanks for the follow up, Mark.

As an aside, it seems that they could have thought this through a little better, as the term "has privileges" is a little ambiguous. I've already seen attempts to be exploit this in the (what else?) logging PIC arena. Specifically, pilots who are FOs claiming that they can log sole manipulator PIC time while flying as FO, because they "have privileges" in the aircraft.

Same goes for the "SIC type rating"....." I'm "rated" in the airplane, therefore I can log Sole manipulator PIC time

 

[midlifeflyer]

As an aside, it seems that they could have thought this through a little better, as the term "has privileges" is a little ambiguous. I've already seen attempts to be exploit this in the (what else?) logging PIC arena. Specifically, pilots who are FOs claiming that they can log sole manipulator PIC time while flying as FO, because they "have privileges" in the aircraft.

I've seen a couple of those discussions also.

It's called the "law of unintended consequences."

 

[Amish RakeFight]

Another example would maybe be an IFR student getting trained in a single (an aircraft they are rated in) on an IFR flight plan, in IMC. The student in this instance is rated but doesn't have an instrument rating for the condition of flight. I would say, he should log it as PIC. Just be sure the CFI is rated, current and able to ACT as PIC.

An instrument student (w/SEL) flying in IMC with a CFII may log PIC as sole manipulator and ACTUAL.

As for the MEL, PIC CANNOT be logged by the MEL student during training unless flying solo. The dual will count towards the 10 hour requirement, come the practical.