A Squared
Well-known member
- Joined
- Nov 26, 2001
- Posts
- 3,006
HS-125,
First, I don't have a lot tied up in this debate, as I have plenty of instrument time for any certifcate I need, and I generally only log instrument time when I'm PF. I am, however inclined to beleive that I could legally log Instrument time when I am PNF (I fly as SIC in a 3 crew aircrft)
OK, so at some time in the past, 61.51 referred to "manipulating the controls", instead of "operating" regarding logging of instrument time.
Can you post the exact wording, or at least verify that what you posted above is a verbatim quote, and not a paraphrasing?
Like In Hot, I wonder if the change from "manipulating the controls" to "operating" is indicative of a change in the intent of the FAA. Certainly, there are cases where the SIC is held to be "operating" the plane when he is not manipulating the controls.
Regarding your link to the AFS 640 document: I would be extremely careful relying too heavily on this document. It is not a product of the FAA's Office of Chief Counsel. They are the only entity which may issue a binding interpretation of the regulations (them, and a judge, is suppose)
There have been times in the past when the Chief Counsel has disagreed with such a publication. I recall one instance where they issued an interpretaiton which directly contradicted a statment made in a similar FAQ sheet. If I recall correctly, it was on the AFS-840 webpages and was by John Lynch, the author of the Part 61 rewrite.
The chief counsel essentially said that the information on that site was not official, merely advisory, even though it was published on the official FAA website (by the guy who wrote the regulation, no less). I can't come up with the actual opinion letter at the moment, but I'll try to find it.
Anyway, unless an opinion, is issued from the Office of Chief Counsel, it isn't binding in any way.
Regards
First, I don't have a lot tied up in this debate, as I have plenty of instrument time for any certifcate I need, and I generally only log instrument time when I'm PF. I am, however inclined to beleive that I could legally log Instrument time when I am PNF (I fly as SIC in a 3 crew aircrft)
OK, so at some time in the past, 61.51 referred to "manipulating the controls", instead of "operating" regarding logging of instrument time.
Can you post the exact wording, or at least verify that what you posted above is a verbatim quote, and not a paraphrasing?
Like In Hot, I wonder if the change from "manipulating the controls" to "operating" is indicative of a change in the intent of the FAA. Certainly, there are cases where the SIC is held to be "operating" the plane when he is not manipulating the controls.
Regarding your link to the AFS 640 document: I would be extremely careful relying too heavily on this document. It is not a product of the FAA's Office of Chief Counsel. They are the only entity which may issue a binding interpretation of the regulations (them, and a judge, is suppose)
There have been times in the past when the Chief Counsel has disagreed with such a publication. I recall one instance where they issued an interpretaiton which directly contradicted a statment made in a similar FAQ sheet. If I recall correctly, it was on the AFS-840 webpages and was by John Lynch, the author of the Part 61 rewrite.
The chief counsel essentially said that the information on that site was not official, merely advisory, even though it was published on the official FAA website (by the guy who wrote the regulation, no less). I can't come up with the actual opinion letter at the moment, but I'll try to find it.
Anyway, unless an opinion, is issued from the Office of Chief Counsel, it isn't binding in any way.
Regards
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