Logging IMC time

[328Pilot]

Avbug,

Actually, I believe you are incorrect. Have you taken your ATP written yet? There is a question in the ATP written that asks about logging IMC time while SIC. The correct answer is that the SIC may only log IMC while at the flight controls. I'm afraid that I don't know the reference, but that would be the interpretation from the FAA.

I have never heard that the PIC may log IMC while the SIC is at the controls. Makes me wonder if maybe I'm owed some IMC time.

 

[avbug]

I obtained my ATP a long time ago, but thanks for checking.

 

[PastMmo]

Proof?

Hey Avbug,

Any documented statements OR FAA clarification on the reg's that will support what you are saying.

I remember a website devoted to FAR clarification that is/was sanctioned by the FAA, but don't remember where it was.

Also, what is the FAQ website you were referring to?

 

[avbug]

The web site to which you're referring is the AFS-640 FAQ. Both John Lynch and Allen Pinkerton who put the responses on the site are FAA employees, and in fact have written much of FAR 61 (etc.).

The web site is not sanctioned by the FAA, however. There is a disclaimer on the site that provides that the information there is not regulatory. It is in fairness to Mr. Lynch that I provided a response above, stating his opinion.

No legal interpretation has been provided on this topic. As the FAA no longer requires hours for currency, it's most likely of minimal interest from a regulatory point of view. The only regulatory interest touched on by Mr. Lynch in his response, is that of using instrument time to apply for the ATP certificate.

No further guidance is provided in the various FAA orders and handbooks, applicable to this question. However, rendering of other portions of the FAR, as touched on in previous posts here, show that a pilot who is a required crewmember is in fact operating the aircraft (and may be subject to enforcement action in the event of a violation), weather manipulating the controls, or not. Both pilots are required to operate the aircraft, and both pilots may log the conditions of flight.

The FAA does not differentiate between PIC-instrument, and SIC-instrument. Many companies ask about this in the application process, but that's a private issue, and not a logging or regulatory issue.

 

[328Pilot]

AVbug,

I didn't mean any offense, but it is a question on the ATP written, with the answer being that SIC can only log while in actual. Doesn't make any difference to me how anyone else logs it, but good luck for them explaining to an interviewer in the future if they're wrong.

 

[A Squared]

328pilot,

This is an interesting question, and I don't claim to know the answer for certain. Given the way the regulation is worded, and given the meaning that the FAA gives "operates", I would tend to side with Avbug. I would make a couple of observations about your comment that it's in the ATP knowledge exam. It is indeed, the question and answers read:

What instrument flight time may be logged by a second in command of an aircraft requiring two pilots?
A. All of the time the second in command is controlling the airplane solely by reference to flight instruments.
B. One-half the time the airplane is in actual IFR conditions.
C. One-half the time the flight is on an IFR flight plan.

Now that might seem to imply that an SIC may only log that time which he is sole manipulator of the controls, however look at it a differnt way;

Regardless of whether an SIC may log all time in imc, or only the time he is sole manipulator, answer A is correct. If you look closely, answer A does not restrict the time to OLNY the time the SIC is sole manipulator.


If it is true that the SIC may ONLY log the time he is manipulator of the controls, than answer A is obviously correct.

If it is true that the SIC may log all the time the aircraft is in IMC, then answer A is still true, as it doesn't say ONLY the time he is flying. He may log all of the time he is "controlling the airplane solely by reference to flight instruments" (answer A) PLUS he may log the rest of the time the airplane is operated solely by reference to the instruments

See what I'm saying? My point is that the test question doesn't answer the question. Remember the correct answer is the MOST correct answer, not the complete correct answer. The complete correct answer may not be listed.

From a sheer logical standpoint, if answer A is correct if "X" is true, and answer A is true if "Y" is true, then the fact that answer A is correct cannot be used to determine which is true, "X" or "Y"

Note that answer A uses the term "controlling" while the regulation uses the term "operating" these are not the same.


This is one of the pitfalls of learning by studying the test, the test questions may tend to lead one to incorrect conclustions.

Regards

 

[328Pilot]

A Squared, (and AvBug)

I can't say that you're wrong. I do see your point. However, I would also add that the most conservative thing to do would be to only log the time that you are the person physically in control of the aircraft. The fact that we have this disagreement is evidence enough that there is not a clear-cut answer. I would rather not have to deal with the question in the interview than have someone catch on that I didn't do the landing or the approach on a number of legs, yet I was able to log instrument time. Would they? Maybe not, some of these places seem to go over your logbook carefully and others do not.

Although if the interviewer was of the mind that the FAA intended only for the person physically in control of the aircraft to log the time, then it leads to questions that didn't need to be asked. Is it a deal-breaker? I don't know, but I sure don't want to find out that not knowing the regs (in that interviewers mind) or arguing about it was what killed my chances at the job. Especially when there were ten other guys who didn't log it that way and the question never came up for them.

I'm probably exagerating, but I think the point is still valid. You should still get enough instrument time that it wouldn't make a difference in the interview if your skills were up to par. I've started it the other way, I still think it's the most conservative, but I also can't tell either of you that you are wrong.

Fly safe.

 

[A Squared]

>>>>>>However, I would also add that the most conservative thing to do would be to only log the time that you are the person physically in control of the aircraft.

328Pilot, I agree. As a matter of fact, I fly in a 2 pilot cockpit and I only log instrument time when I am PF. I beleve that I should be logging all time in clouds, but because the question is so controversial, I chose the most conservative approach. I don't need the time for any certificates, and I log more than 10 % of my flight time in IMC anyway (there's a lot of bad Wx where I fly)

So, I disagree with you on the legality, but agree with you on what practial approach should be taken.

Regards,

 

[BTapsco]

Logging IMC Time

You don't have be with a CFII to log instrument time while training; you can go with an instrument rated pilot as your safety pilot (if you can find one you trust and who is willing to put his name on the flight plan) and fly in IMC and log it as such

 

[flydog]

I have an easy answer. If someone looks in your logbook and asks tell them you were PF and you logged that IMC time only. IMC time is not required for any certificates or ratings after the ATP or for any type of currency except maybe that required in an airline SOP. It should be a non issue except for airline interviews.

If the FAA ever asks to see your logbook tell them you dont own one or your dog ate it