Logging flight time

[HAL]

There was one of those Q & A things from the FAA a few years back on this, and it matched what LearLove said. Essentially, as a First Officer and PNF, you can't log instrument time. If you are a F/O PF, log the IMC time. As Captain, because you have final responsibility for the aircraft, you can log all IMC time, PF or PNF. Same goes for approaches. Night is different, because there is nothing in the regs about 'sole manipulator' for night, and as a required crew member, you can log all night time.

I would still suggest everyone keep logging all their flights, IMC, approaches, and the rest until you hit the magic number (60, 65, or whatever) and hang up the stripes. I know a couple of senior Aloha guys who hadn't logged in years, and despite 8-landing days for decades, couldn't prove to the airline they were applying at what recent & total experience they had. Yes, it's a pain. But if your airline craters, you have to have good records to be at the front of the line at your next job.

HAL

 

[Whine Lover]

"...you have to have good records to be at the front of the line at your next job."


Atlas Air specifically asks you NOT to bring your Log Books to an interview.

They are an exception to the general rule, but their philosophy is that they can verify your employment with a 121 carrier and after 10,000 hrs or so....They pretty much figure you know how to fly at night, in IMC, and can shoot an approach to mins if you need to.

YKW

 

[Caveman]

Same here, I log:

-landings when I'm the PF
-inst. apps. when I'm the PF and flown (AP or hand) from the FAF inbound
-IMC when in actual IMC and I'm the PF
-night when it is night (obviously) and I'm either the PF or NPF

Ditto.

 

[Jim]

There was one of those Q & A things from the FAA a few years back on this, and it matched what LearLove said. Essentially, as a First Officer and PNF, you can't log instrument time. If you are a F/O PF, log the IMC time. As Captain, because you have final responsibility for the aircraft, you can log all IMC time, PF or PNF. Same goes for approaches. Night is different, because there is nothing in the regs about 'sole manipulator' for night, and as a required crew member, you can log all night time.

Actually the FAA legal opinion states that any pilot operating the plane should log the IMC time whether Captain or FO, PF or PNF. The number of pilots operating the plane were defined by the planes type certificate, the FARs and the OPSPECs. You don't have to be the Captain to log actual if you're the PNF. It went on to say only the PF could log the approaches. (the "pilot operating" part is what excluded the FEs).

This was a difference of opinion between the guy that ran the old FAA Q&A website and the FAA Legal Counsel. The Q&A website also specifically said that the answers on the site had no legal standing and only the FAA General Counsel could issue legal interpretations of the FARs.

Too bad Doc's FAR Forum is history. He had the actual FAA Legal Counsel opinions.

 

[regionalcap]

Here is the answer for IMC

February 9, 1999

Bill Carpenter
12808 E. Pacific Drive, #302 Aurora, Colorado 80014

Dear Mr. Carpenter:

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 acting as pilot in command and logging of 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.

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.

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.

While it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC 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 logging of 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 serve as 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

 

[sayrejm]

I still say you can log the approach as PNF. It says "sole manipulator of the controls" and does not specify "primary flight controls" Furthermore, the PF is not the "sole manipulator of the controls." The PNF operates the gear, the radios, and the secondary flight controls as well as monitors the approach and makes all required call outs and operates the altitude pre-selector and makes required FMS entries below 10,000 feet. Neither pilot is the sole manipulator of the controls which is why the aircraft requires two pilots. I do draw the line at the landings though.

 

[Chairman]

I still say you can log the approach as PNF. It says "sole manipulator of the controls" and does not specify "primary flight controls" Furthermore, the PF is not the "sole manipulator of the controls." The PNF operates the gear, the radios, and the secondary flight controls as well as monitors the approach and makes all required call outs and operates the altitude pre-selector and makes required FMS entries below 10,000 feet. Neither pilot is the sole manipulator of the controls which is why the aircraft requires two pilots. I do draw the line at the landings though.

Log what you want. It's your logbook just be ready to defend it. Did an interview with a applicant who had logged time in the EMB 120 as PIC while not typed and tried to tell the interview board how he was allowed to log it. He didn't get hired. Log what you want but use it on an application and you might find yourself getting turned down more times than not!

 

[AC560]

I still say you can log the approach as PNF.

And that makes logical sense, however if you review the post previous to yours it is clear you cannot.

Regulations are not necessarily based on logic or what is right, they are what they are and the only persons opinion on them who matters is FAA Counsel.

 

[Sandstorm]

This may be a stupid question, but how important is it that you actually log landings in your logbook? If you are employed by a 121 carrier, you are obviously current under 121.437 and 121.439.

 

[CesnaCaptn]

This may be a stupid question, but how important is it that you actually log landings in your logbook? If you are employed by a 121 carrier, you are obviously current under 121.437 and 121.439.

How important is it that you log anything? As far as I know, a pilot only flying 121 doesn't "have" to log anything. You might want to keep a log for personal reasons, or more importantly if you ever need to apply for a job. Like the chairman said, what matters to a 121 pilot is whether or not he can defend his logbook at an interview. If you want to work for Atlas or Alaska, apparently you don't even need a logbook.