Logging Approaches

[Explosive]

Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)

You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.

Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.

There is a distinction between actingas pilot in command and loggingof pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:



2

(e) Logging pilot-in-command flight time.

(1) A 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_ (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 whileacting as pilot-in-command of an operation requiring an airline transport pilot certificate.

While it is not possible for two pilots to actas PIC simultaneously, it is possible for two pilots to logPIC flight time simultaneously. If the pilot is designated as PIC by the certificate holder, as required by FAR 121.385(c), that person is PIC for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft. The pilot who is the sole manipulator of the controls of the aircraft for which the pilot is rated may also log that flight as PIC.

It is important to remember that we are dealing with loggingof flight time only for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the SIC is fully qualified as a PIC, or only as an SIC. This is important because even though an SIC can log PIC time, that pilot may not be qualified to serveas PIC under Part 121.

I hope this satisfactorily answers your questions. If we can be of further assistance, please contact us.

D. Brent Pope
Attorney, ANM-7H

http://www.faa.gov/about/office_org...terpretations/data/interps/1999/Carpenter.rtf


Even though you hold an ATP certificate, you are only exercising commercial privileges while acting as SIC.

 

[Rekks Inbound]

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;
(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.

This is straight from the FAA site. It says i or ii or iii etc. Unless you are signing for it, you can't log it as PIC, even if typed.

Peace.

Rekks

 

[twighead]

Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)

You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.

Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.

There is a distinction between actingas pilot in command and loggingof pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:



2

(e) Logging pilot-in-command flight time.

(1) A 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_ (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 whileacting as pilot-in-command of an operation requiring an airline transport pilot certificate.

While it is not possible for two pilots to actas PIC simultaneously, it is possible for two pilots to logPIC flight time simultaneously. If the pilot is designated as PIC by the certificate holder, as required by FAR 121.385(c), that person is PIC for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft. The pilot who is the sole manipulator of the controls of the aircraft for which the pilot is rated may also log that flight as PIC.

It is important to remember that we are dealing with loggingof flight time only for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the SIC is fully qualified as a PIC, or only as an SIC. This is important because even though an SIC can log PIC time, that pilot may not be qualified to serveas PIC under Part 121.

I hope this satisfactorily answers your questions. If we can be of further assistance, please contact us.

D. Brent Pope
Attorney, ANM-7H


Well I stand corrected then if that information is accurate.

 

[AC560]

To throw another curvball. A type rated SIC can only log PIC if they have a commerical certificate or less. Reference 61.51

If you have an ATP you can not log PIC unless you are the captain.

The reason for this is that PIC requirements are used to meet the requirements of a ATP. Once you have an ATP, the FAA doesn't see any reason for you to log PIC unless you are the captain.

Sec. 61.167 - Privileges.
(a) A person who holds an airline transport pilot certificate is entitled to the same privileges as those afforded a person who holds a commercial pilot certificate with an instrument rating.


Sec. 61.51 - Pilot logbooks
(e) Logging pilot-in-command flight time. (1) A 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;

(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.

If you have an ATP rating and are acting as PIC (part 1) of an operation requiring an ATP you log PIC regardless of whether you are the sole manipulator or not. If you ATP rating and are not acting as PIC (part 1) of an operation requiring an ATP you can log in the FAA's view all time which you are th e sole manipulator.

 

[Rekks Inbound]

Keep reading, specifically (e) (ii) and (iii). The semicolon after (i) is treated as a comma, signifying and or or.

Peace.

Rekks

 

[AC560]

Keep reading

Keep reading what? The answer is clear in the FAR's and certainly clear in the legal interpretations posted.

 

[Beetle007]

Sec. 61.167 - Privileges.
(a) A person who holds an airline transport pilot certificate is entitled to the same privileges as those afforded a person who holds a commercial pilot certificate with an instrument rating.

Logging of flight time is not considered a privilege. You will find commercial pilot privileges under FAR 61.133. Did you ever flight instruct?

 

[AC560]

Logging of flight time is not considered a privilege. You will find commercial pilot privileges under FAR 61.133. Did you ever flight instruct?

Ok you win, if you have an ATP you can never ever log PIC time again unless you are a captain for a part 121/135 carrier. I wonder how the corporate pilots flying part 91 with an ATP manage to stay current but I guess it is just a mystery of the FAR's which I will never understand.

 

[Amish RakeFight]

PF and PNF can both log ACTUAL and NIGHT as these are recognized as conditions of flight by the FAA.

Only the PF may log an instrument approach or a landing.

Instrument time may also be logged with the AP.

Simple as that.

 

[Beetle007]

Ok you win, if you have an ATP you can never ever log PIC time again unless you are a captain for a part 121/135 carrier. I wonder how the corporate pilots flying part 91 with an ATP manage to stay current but I guess it is just a mystery of the FAR's which I will never understand.

I am tempted to say I am wrong. The only thing keeping me from saying I am wrong is that the FAA doesn't require you to log PIC to stay current. The only purpose of PIC is for the aeronautical experience requriements of certificates and ratings. Once you have your ATP, the FAA doesn't see the need for you to log PIC.

The only purpose of PIC after you get your ATP is to satisfy high min requirements or other regs that require you to have acted as a captain. Remember that PIC logged under the sole manipulator clause can't be used towards high mins.

 

[AC560]

I am tempted to say I am wrong. The only thing keeping me from saying I am wrong is that the FAA doesn't require you to log PIC to stay current. The only purpose of PIC is for the aeronautical experience requriements of certificates and ratings. Once you have your ATP, the FAA doesn't see the need for you to log PIC.

That isn't all the FAA requires you to log

Sec. 61.51 - Pilot logbooks.

(a) Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:

(1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.

(2) The aeronautical experience required for meeting the recent flight experience requirements of this part.

61.51(a) tells you what you must to log. You need to log time to comply with various things such as 61.57(c). If I have an ATP rating and I go a fly approaches in a C-172 how would I log those approachs? I would refer to 61(b).

(b) Logbook entries. For the purposes of meeting the requirements of paragraph (a) of this section, each person must enter the following information for each flight or lesson logged:

(1) General --

(i) Date.

(ii) Total flight time or lesson time.

(iii) Location where the aircraft departed and arrived, or for lessons in a flight simulator or flight training device, the location where the lesson occurred.

(iv) Type and identification of aircraft, flight simulator, or flight training device, as appropriate.

(v) The name of a safety pilot, if required by §91.109(b) of this chapter.

(2) Type of pilot experience or training --

(i) Solo.

(ii) Pilot in command.

(iii) Second in command.

(iv) Flight and ground training received from an authorized instructor.

(v) Training received in a flight simulator or flight training device from an authorized instructor.

The only purpose of PIC after you get your ATP is to satisfy high min requirements or other regs that require you to have acted as a captain. Remember that PIC logged under the sole manipulator clause can't be used towards high mins.

That is going to be dependent upon the operator in question. Which is why many airlines define PIC time differently the FAA does. As I said in my original post being PIC under part 1 has little to do with logging PIC under part 61. Logging PIC under part 61 often has little do with a job application or an upgrade with a carrier. Regardless of how many hours you have though you are required to log time for the purposes of currency and you are required to log that in a method which complies with 61.51(b), if you aren't you are failing to comply with the regulations.

 

[Beetle007]

First - These posts are too long.

Second - The regs only require/allow you to log time used for recency or to meet the requirements of a certificate/rating. Once you have your ATP, you don't need to log PIC to satisfy either.

In the FAAs eyes why are you logging PIC time after you have your ATP? After you have your ATP, the only flight time requirements reference time served as a captain (not sole manipulator).

 

[AC560]

First - These posts are too long.

Sorry to bore you with the facts that explain why your assumptions are wrong. We will just leave the conversation as you having very misguided beliefs in regards to this topic.

I hope this was short enough for you.

 

[Beetle007]

Sorry to bore you with the facts that explain why your assumptions are wrong. We will just leave the conversation as you having very misguided beliefs in regards to this topic.

I hope this was short enough for you.

Just tell me why an ATP pilot would need to log PIC in the eyes of the FAA. An ATP pilot doesn't need to log PIC for recency or currency.

An ATP only needs to log PIC to meet the requirements of time served as captain for certain regs (like high minimum captains). An ATP can still log PIC, just not under the provision of sole manipulator of the controls. Once you have an ATP the FAA only cares about your captain experience.

 

[John Pennekamp]

I think it is important for us to know the difference between what is legal, and what Southwest requires. It is a slippery slope to let each individual operator decide what is legal and what isn't. The FAR's are the FAR's, they are the final word in what is legal and what isn't. If for example, I were flying a Lear for a 135 operation, and I was typed on that Lear, I would log PIC time. However, when I applied to Southwest, or whoever, I would not include that time as PIC.

Its important to know what is legal and what is custom.

YGBFKM. It doesn't matter what the FARs say. A company can hire whomever they choose on whatever criteria they decide. If they choose to define PIC for hiring purposes by FAR 1 or any other way, that's up to them. We all know that what they want is 121 PIC time. It sounds like some of you are advocating cheating the system and trying to use the FAR definition of PIC to back yourself up. That's not what the airline industry is all about. Captain is Captain. Period.

 

[John Pennekamp]

Show me your argment then. It's pretty black and white to me. Tha sole manipulator reg specifies in the first line that it applies only sport, recreational, private, and commercial pilots. The ATP portion is a separate line.

I think that only an Administrative Law Judge can interpret the FARs. But keep trying there. Chachie. Sooner or later you'll find a self serving definition that means nothing in real life, but inflates your logbook.

 

[Beetle007]

It sounds like some of you are advocating cheating the system and trying to use the FAR definition of PIC to back yourself up. That's not what the airline industry is all about. Captain is Captain. Period.

So if you were a flight instructor, you would never let your students log PIC? even if they are rated and the flying pilot?

 

[John Pennekamp]

Ok you win, if you have an ATP you can never ever log PIC time again unless you are a captain for a part 121/135 carrier. I wonder how the corporate pilots flying part 91 with an ATP manage to stay current but I guess it is just a mystery of the FAR's which I will never understand.

And that goes for you too.

 

[John Pennekamp]

So if you were a flight instructor, you would never let your students log PIC? even if they are rated and the flying pilot?

We're not talking about general aviation here. We're talking about a 121 airline.

But to answer your question, I am a CFI and of course I would "allow" my student to log whatever he/she's legally entitled to log. In fact, it's none of my business what he/she logs unless its a student pilot flying on my ticket (solo).

Does that mean anything in the industry? Of course not. United defines PIC as "aircraft commander of a 121 operation or sole manipulator of the controls of a multi engine airplane" and then tells you not to include any PIC time before your commercial license. So could you creatively interpret this to include PIC as the SIC? Probably. But you will be quickly shown the door.

The point is that if you're a Commercial rated SIC in a 121 airplane, you may legally log PIC/sole manipulator and use it to meet the requirements of a certificate or rating, but nothing else. And your SIC time meets the same purpose. So basically, this entire discussion is totally meaningless. Once you're a pilot for a 121 airline, the only reason to keep a logbook is to demonstrate currency, meet the requirements of an ATP certificate, and "build time" for a better job. Creatively interpreting PIC does not benefit either of those needs.

 

[AC560]

In the FAAs eyes why are you logging PIC time after you have your ATP? After you have your ATP, the only flight time requirements reference time served as a captain (not sole manipulator).

The FAA's opinion (or eyes as you call it) on this topic has already been stated on this thread. For you reference here it is again.

I think that only an Administrative Law Judge can interpret the FARs.

You are right here is that interpretation.

We're not talking about general aviation here. We're talking about a 121 airline.

No we are talking about part 61 (61.51 in particular) which covers how all pilots are required and allowed to log their time.

How individual airlines view logged time for application or promotion purposes has nothing to do with the FAR's.

 

[Amish RakeFight]

A designated SIC should not be logging PIC. The captain is ALWAYS the PIC. It will just muddy your logbook. You're not flying Cessnas anymore.

 

[Rekks Inbound]

OK, look at it this way. Is there a single, transport category airliner (other than a 1900) that is single pilot? No. They all require two pilots for heir operation. Therefore the designated SIC is NOT the sole operator of the controls (he/she shares the controls with the PIC) and therefore cannot log that time as PIC.

Or here is another arguement against. A CA upgrade has not completed OE. Can that type-rated future CA log the time he/she flys as PIC? No, because he/she is not qualified in the eyes of the FAA to act as PIC. Just as the SIC is not qualified, even if they hold an unrestricted type rating.

I believe the interpretation given is wrong/incomplete.

Peace.

Rekks

 

[AC560]

A designated SIC should not be logging PIC. The captain is ALWAYS the PIC. It will just muddy your logbook. You're not flying Cessnas anymore.

I don't think anyone is debating for the purposes of advancing a 121 career it is the prudent thing to do.

The idea though at an ATP pilot can longer log PIC unless a Captain on 121/135 carrier, that the regulations themselves don't allow for it, etc. are fallacies.

In short the answer should be yes this is what the regulations allow for, this though is how you should account your time if you wish to get a job or advance for an airline.

 

[John Pennekamp]

I don't think anyone is debating for the purposes of advancing a 121 career it is the prudent thing to do.

The idea though at an ATP pilot can longer log PIC unless a Captain on 121/135 carrier, that the regulations themselves don't allow for it, etc. are fallacies.

In short the answer should be yes this is what the regulations allow for, this though is how you should account your time if you wish to get a job or advance for an airline.

You're missing the point. WHY would you want to log PIC time in an airliner when you were the SIC? What does it get you?

 

[AC560]

You're missing the point. WHY would you want to log PIC time in an airliner when you were the SIC? What does it get you?

None of my comments on the thread if you review it were directed at doing such. My first post was very clear in that being PIC under part 1 has nothing to do with logging under part 61 has nothing to do with getting a job on a 121 carrier.

My comments were to correct the various people who made factually incorrect statements about what is in fact legal to log, nothing more.

 

[John Pennekamp]

None of my comments on the thread if you review it were directed at doing such. My first post was very clear in that being PIC under part 1 has nothing to do with logging under part 61 has nothing to do with getting a job on a 121 carrier.

My comments were to correct the various people who made factually incorrect statements about what is in fact legal to log, nothing more.

I agree that you are correct in that it's legal to log such time. My question to you is why do it? what use is it to anyone?

 

[twighead]

I think that only an Administrative Law Judge can interpret the FARs. But keep trying there. Chachie. Sooner or later you'll find a self serving definition that means nothing in real life, but inflates your logbook.

My interpretation was anything but self serving. According to the letter that was published here, I would be shorting my logbook under my interpretation. And if you bothered to read further you would have seen that I admitted that I was wrong.

The only thing being inflated is your ego from all the hot air comong out of your mouth, Chachie.

 

[John Pennekamp]

My interpretation was anything but self serving. According to the letter that was published here, I would be shorting my logbook under my interpretation. And if you bothered to read further you would have seen that I admitted that I was wrong.

The only thing being inflated is your ego from all the hot air comong out of your mouth, Chachie.

Oh, he slams me! You're messin' with a pro, Cessna boy. Go ahead.

No wait, riddle me this first... what use to you is the PIC time logged as SIC? Going to get that coveted Delta job with it? Or that coveted ATP certificate? Or just trying to meet the insurance requirements so that you can fly a Baron solo?

PS, how's the ass end of an ATR look in HXD?

 

[twighead]

Read again. I was the one who said that you can't log PIC time when you are an SIC. Nothing more needs to be said.

 

[John Pennekamp]

Nothing more needs to be said.

That should have happened on the first page of this asinine thread!