Another logging question..

[IrishFlyer]

Hi,

Recently a friend of mine asked me if I could go and fly with him as his instructor was away and he was getting ready to do his PPL check ride and didn’t want to loose currency in his maneuvers. I jumped at the chance because I am about to do my CFI check ride and any chance to sit in the right seat is good for getting used to it.

While airborne my friend went through some maneuvers and I gave some uncertified critiques and advice and gave some demos. He wanted to practice his hood work so he covered up and I acted as safety pilot for about 0.2 hours. The total flight time was about 1.5 hours. I just wanted to make sure that I can only log the time my friend was under the hood and any time I was the sole manipulator of the controls? Do I log this time as PIC or SIC?

Thanks V Much,

IF

 

[Lead Sled]

In spite of your name, I'm assuming that this occurred here in the States; but it probably wouldn't make any difference if it happened in the UK - I don't believe the regulations are that different. You were the PIC for the entire 1.5 hours. Period. As far as your friend is concerned, none of the time is loggable - he was, legally, just a passenger that you allowed to sit in the front L/H seat and, like we frequently do, was allowed to touch the controls for a while. He can not log any of the time - you are not a CFI and, as a student pilot, he can not be PIC with another "non-CFI" occupant on board unless he is taking his checkride. (By regulation, the student is PIC during his check ride.) By the way, some insurance companies may take a dim view of a non CFI flying as PIC from the R/H seat. It depends upon the insurance carrier, the aircraft make and model, and the circumstances.

Lead Sled

 

[IrishFlyer]

Thanks Lead Sled its clearer now, one other question for you. The same student passed his private last week. He is now moving onto his commercial/instrument. He needs to do some hour building and asked me if I wanted to accompany him on some cross country flights so as I can demonstrate to him the commercial maneuvers. I am reluctant to accompany him to much as I feel it’s an important learning curve doing long solo cross country flights in anticipation of a commercial license.

I will hopefully have my CFI ticket very soon, so I presume I could log this as instruction given. But if I am still trying to grasp the FOIs holding only a CPL/IR do I only log the time I was the sole manipulator of the controls or acting as safety pilot?

Cheers,

IF

 

[avbug]

Harking back to your first question that started the thread, Leadsled was correct that your friend cannot log the flight time. As your friend was sole manipulator of the controls, you cannot log the time either. You were required to act as the pilot in command, but you are not entitled to log the time.

There is no reason why you cannot accompany your friend as he performs his cross country flights toward his commercial pilot certificate. His learning experience will not be diminished.

If you are acting as an authorized flight instructor, you may log all time spent in that capacity. However, if you are merely riding along or serving as safety pilot, you are not acting as an authorized flight instructor. In that case, you may log SIC for the time spent acting as safety pilot, and you may not log the remainder of the time unless you are sole manipulator of the controls. This assumes that your friend holds at least a private pilot certificate, and you are not actively providing flight instruction.

 

[100LL... Again!]

Avbug, somebody has to be the PIC.

While he was not sole manipulator, he was responsible for the safety of the flight - he can log PIC.


Also re: your answer to 135.267, I think you are reading too much into the singular pronoun use of 'crewmember'.

Since crews are often switched around, the singular use of the word would be expected.

Also, I would bet the FAA legal interp dept would disagree with your analysis, even though it is one way of looking at it.

 

[midlifeflyer]

Middle road. avbug and 100LL are both right.

If you read the regulations, this is one of those flights in which no one may log PIC.

LL, remember that acting as PIC - being responsible for the safety of a flight - is =never= enough by itself for logging PIC. In general, if you don't fit into a 61.51 category, there's no authority for logging PIC. Acting as PIC on a flight in which a non-pilot is flying isn't found in 61.51. Some try to fit it into a "required crewmember" doesn't cut it. That's not what 61.51 says. It says a flight operation that required more than one pilot." Sorry, a VFR flight in an airplane certified for single-pilot operations only requires one pilot. Sure, the PIC is required, but he's the =only= one that's required.

But, some years ago I was given a copy of an FAA legal opinion. I trust my source, but I have not been able to locate it in any of the usual collections, so you can take it with a grain of salt. It says that in addition to the recognizable 61.51 categories,

==============================
a pilot, rated in category and class (e.g. airplane single-engine) could, as the pilot who "Has final authority and responsibility for the operation and safety of the flight" log PIC time if another pilot, not appropriately rated, was actually manipulating the controls of the aircraft.
==============================

In other words, one may log PIC if acting as PIC on a flight in which the PIC is the only aircraft-rated pilot on board and no one else could log the time in any way.

FWIW, from my personal FAQ file, here's the full text of the opinion and the completely fictional account of how it came to be...

==============================
June 22, 1977

Mr. Thomas Beane

Dear Mr. Beane:

This letter is in response to your recent letters to the FAA Flight Standards Service and to the Chief Counsel inquiring about the logging of pilot-in-command (PIC) time by an airman whenever he is not the sole manipulator of the controls.


Section 1.1 of the Federal Aviation Regulations defines Pilot in Command as:

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

Section 61.51(c)(2) of the Federal Aviation Regulations provides, in pertinent part:

(2) Pilot-in-Command flight time.

(I) A private or commercial pilot may log as pilot in command time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted.

A pilot may log PIC time in accordance with Section 61.51(c)(2)(I) when he is not actually "flying the airplane", if the airplane is one on which more than one pilot is required under its type certificate or under the regulations under which the flight is conducted and he is acting as PIC. Also, a pilot, rated in category and class (e.g. airplane single-engine) could, as the pilot who "Has final authority and responsibility for the operation and safety of the flight" log PIC time if another pilot, not appropriately rated, was actually manipulating the controls of the aircraft.

It should be noted that more than one pilot may log PIC time for the same flight time. For example, one pilot receiving instruction may log PIC time in accordance with paragraph (c)(2)(I) for the time he is designated PIC, and another pilot may log PIC time in accordance with (c)(2)(iii) for the same time during which he is actually giving flight instruction.

We hope that we have satisfactorily responded to your inquiry on the proper logging of PIC time.

Sincerely,

ORIGINAL SIGNED BY EDWARD P. FABERMAN

for NEIL R. EISNER Acting Assistant Chief Counsel Regulations & Enforcement Division Office of the Chief Counsel -
==============================
The Unofficial, Unvarnished, and Totally Made-Up Truth About the "Only Pilot On Board" Opinion

My guess is that one day the lawyers at the FAA went out drinking after work and started talking about the logging rules. One of them said, call him Joe, said, "Can a pilot log PIC time if he lets his dog fly the airplane?"

Betty, who was a real stickler for strict readings, replied, "No. Since the dog had its paws on the controls, the pilot wasn't the 'sole manipulator of the controls.' So he can't log anything."

Peter rolled his eyes and said, "I know these rules are a bit convoluted, but really! That is the stupidest thing I ever heard! OF COURSE the pilot can log the flight! He's the ONLY ONE who can!"

"So what?" said Betty. That's what the reg says!"

"Oh BULL!" he said, "The guys who wrote 61.51 couldn't cover EVERY possible situation. A flight in which NO ONE can log PIC is ridiculous.

Fortunately, in addition to being sensible, Peter really knew his stuff. "There's a rule of law that's been around for a long, long time. It applies to both statutes and regulations." Peter continued, "'An interpretation that would lead to an absurd or unreasonable result should be avoided.' A flight on which NO ONE can log PIC is absurd."

The others had to agree.
==============================

 

[pilotyip]

Who did the dog get a job with?

I think I might know the dog, I met him the other night at LUK, is his first name Freight?

 

[avbug]

100LL is wrong on both counts.

The regulation which governs the logging of flight time, 14 CFR 61.51, provides specific circumstances under which one may log flight time.

In the case in question, in which a student pilot is flying the airplane and a commercial pilot is pilot in command, the student pilot may not log the flight time as PIC, nor SIC. The commercial pilot, while acting as PIC, may not log the flight time, either. Nobody may log the flight time.

That the commercial pilot acted as PIC is not relevant. That the PIC is responsible for the safe outcome of the flight is not relevant to the issue of logging the time. The PIC is not pilot in command of an aircraft requiring more than one crewmember, is not sole manipulator of the controls, is not acting as an authorized flight instructor, is not the sole occupant, is not an ATP acting as PIC of an operation which requires an ATP, is not a student pilot flying solo, and is not a student pilot performing the duties of PIC in an airship requiring more than one crewmember.

In short, the commercial pilot does not meet any qualification found in the regulation permitting him to log the flight time. He cannot log the time. As the commercial pilot in this case cannot log the time, and the student cannot log the time, NOBODY can log the time.

As for the issue regarding 135.267, 100LL would be best to post in that column with an informed response to the topic, and avoid dragging it into a different thread. Particularly with perephrial issues. That said, my comments were accurate, and correct.

 

[Lead Sled]

Does this mean that when I fly a 4 hour and 30 minute coast-to-coast trip to the east coast that I can only log the 30 minutes or so that I'm actually manipulating the controls? What about the 4 hours or so that my good friend Otto is doing the flying? What is the difference between letting the autopilot do the work and letting the "organic autopilot" who just so happens to be sitting in the seat next to me do the flying?

Inquiring minds want to know.

Signed (Tongue firmly in cheek),

Lead Sled

 

[avbug]

Four hours coast to coast; you're obviously in turbojet equipment. You made no identification of the circumstances but if you are acting as PIC of an aircraft requiring more than one crewmember, you log it all as PIC. If you're acting as PIC, holding an ATP, in an operation requiring an ATP, you log it all as PIC.

An autopilot is a flight control system, albeit an automated flight control system. it still requires pilot input. A student pilot manipulating the controls is not a flight control system, and was not certificated as an integral part of the airplane.

Accordingly, when operating the airplane by autopilot, the time is still loggable, as are coupled approaches, etc. However, not when allowing someone else to do the flying.

If you are flying coast to coast in an airplane not requiring a SIC per certification or the regulations under which you are operating, and you are operating per the autopilot, then the pilot flying may log the time. Only one pilot will be flying the airplane, as only one may. Who is acting as PIC is irrelevant to the issue of logging in this case; the only issue is weather one meets the criteria for logging pilot in command time as spelled out in 14 CFR 61.51(e), previously.