Another PIC Question

[NookyBooky]

Suppose: An ASEL private pilot is recieving tailwheel instrution from two different CFI's-one in a Pitts S-2A, and one in a Super Cub. The PPL does not have a tailwheel endorsement. The Pitts CFI logs the students time as PIC and Dual Recieved, the PA-18 instructor logs only as Dual Recieved.

The Cub instructor says he does not log it because the student is not rated for a tailwheel aircraft. While another instructor states that any training beyond PPL in an ASEL will be logged as PIC for the student because he is rated for ASEL's (assuming they do not require a type rating), and a tailwheel aircraft, while it needs a endorsement, still falls under the ASEL rating. I hold both instructors opinions in high regard and find the FAR's explanaiton less than crystal clear.


FAR/AIM states:

(e) Logging pilot-in-command flight time.
[(1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person--
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;] It seems that this must be what the Cub instructor is refering to.
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting 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.
(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.
(3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor.
(4) A student pilot may log pilot-in-command time only when the student pilot--
(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;
(ii) Has a current solo flight endorsement as required under Sec. 61.87 of this part; and
(iii) Is undergoing training for a pilot certificate or rating


So, what do you all think about a required endorsement=a priveledge or required rating for logging of PIC?



FAR's give me a headache

 

[moxiepilot]

61.31 (i) additional training required for operating tailwheel airplanes

(1)...no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane AND received an endorsement in the persons logbook...

so until you get the signoff... no pic time for you.

 

[Pilot_Ryan]

61.31 (i) additional training required for operating tailwheel airplanes

(1)...no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane AND received an endorsement in the persons logbook...

so until you get the signoff... no pic time for you.

Arrrrrrrgh.

This is wrong. 61.31 specifically states that no person may act as PIC. They may, however, log PIC time so long as they are rated in category and class of aircraft... i.e. airplane, single-engine land.

I can't count the number of times I've heard this sort of scenario brought up, only to find that a flight instructor out there, somewhere, doesn't understand that his appropriately RATED student can LOG PIC time in tailwheel airplanes during training, prior to the endorsement. Frankly, it's not the instructor's place to dictate whether or not the student logs the time as PIC, unless they're signing off said student's 8710 for a practical exam.

-Ryan

 

[Pilot_Ryan]

So, what do you all think about a required endorsement=a priveledge or required rating for logging of PIC?

What we "think" is irrelevant. What the regs clearly indicate, in concert with confirmation from FSDO GA inspectors answering phone calls about this topic across the land, is that you may log PIC time in aircraft for which you are appropriately rated. "Tailwheel" isn't a rating, it's an endorsement. All of the time you spend as sole manipulator of the aircraft during training (which, for a tailwheel endorsement, should be very nearly 100% of the time) may be logged as PIC!

 

[avbug]

Pilot Ryan is quite correct. A conventional gear endorsement is not a rating, and is not a requisite for logging PIC time. A pilot who holds a private pilot certificate with an airplane category and single engine class rating, is rated in a Pitts S-2B, weather or not he or she holds a conventional gear endorsement.

Holding the endorsement has no bearing in any way with respect to logging flight time.

 

[midlifeflyer]

The Cub instructor says he does not log it because the student is not rated for a tailwheel aircraft.

As others pointed out, the Cub CFI is wrong. Even if you want to disagree on the clarity of 61.51, the FAA official position on this, through clear and consistent Legal Counsel opinions, goes back at least 20 years.

You will still come across the error by CFIs. For some reason, the disconnect in understanding 61.51 is still pretty widespread (although probably getting better as more pilots and CFIs go online). Whether it's failure to read, an inability to separate the concept of flight responsibility from the concept of counting things toward certificate and ratings, or a simple "No! I don't =want= it to be that way!" attitude, I don't know. But it's a fact of life.

(You can have some fun witrh the Cub CFI. Ask him to pull out his pilot certificate and show you his tailwheel rating on the back - that's where =all= pilot ratings are located. It won't change his mind, but it might be fun to see if it makes him think)

 

[A Squared]

(e) Logging pilot-in-command flight time.
[(1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person--
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;]

Interesting .... the last bit about "or has privileges" was added in the last year. I don't think that it changes the answer to Nookybooky's question as "Is the sole manipulator of the controls of an aircraft for which the pilot is rated" is still sufficient by itself. However, it seems like it could open a whole new can of worms. What are these "privileges" ? LOA in a warbird? One can argue that a non-type rated f/o has privileges in the aircraft ... so does that mean that f/o's without a type can start logging "sole manipulator" PIC time in transport category aircraft?

 

[transpac]

Interesting .... the last bit about "or has privileges" was added in the last year. I don't think that it changes the answer to Nookybooky's question as "Is the sole manipulator of the controls of an aircraft for which the pilot is rated" is still sufficient by itself. However, it seems like it could open a whole new can of worms. What are these "privileges" ? LOA in a warbird? One can argue that a non-type rated f/o has privileges in the aircraft ... so does that mean that f/o's without a type can start logging "sole manipulator" PIC time in transport category aircraft?

Agreed! If one is rated, the "or has privileges" change is meaningless. The lawyers are gonna' have a lot of work arguing the meaning of "has privileges".

 

[moxiepilot]

disagreed & verified my initial statement.

the FAR changed this year to add "appropriately rated AND HAS PRIVILIDGES," therefore until the endorsement is in the logbook the pilot can not log PIC time.

...when you read a reg....

you don't yet have the endoresement, nor the priviledge

 

[A Squared]

disagreed & verified my initial statement.

the FAR changed this year to add "appropriately rated AND HAS PRIVILIDGES," therefore until the endorsement is in the logbook the pilot can not log PIC time.

...when you read a reg....

you don't yet have the endoresement, nor the priviledge

Ummm, wrong again (that's 0 for 2 for you) the regulation reads:

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

That is a direct cut and paste from here: http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=da6315164685265e3ed0c2b43af70522&rgn=div5&view=text&node=14:2.0.1.1.2&idno=14#14:2.0.1.1.2.1.1.30
....which is the federal government's e-version of the regulation, current to 7/14/2005.

...when you read a reg....

YEah, when you read a reg........... Suggest you read a little more closely before posting. Getting back to your initial post, it is well established, by official interpetation from the FAA's office of chief counsel that "acting" as PIC and "logging" PIC are 2 differnt things, and that you do not necessarily need to be qualified to "act" as PIC in order to "log" PIC...... you only have to be rated in the airplane.