Logging Instrument SIC 121

[handsome jonny]

Can you log instrument time as pnf part 121?

 

[avbug]

Yes. You may log instrument time as a condition of flight, in accordance with 14 CFR 61.51(b)(3).

Conditions of flight apply regardless of weather you are PIC, or SIC, or the rules under which the flight is operated.

You may not log approaches or landings which you have not performed, for currency.

Remember that if you log instrument time as SIC, you may be required at a future date to separate PIC instrument time from SIC instrument time (not a big deal) as part of an application process for employment, or insurance). Some folks find it useful to keep a running tally in the margin of the difference.

 

[Cornelius]

I thought the only way the SIC can log instrument time in a two pilot crew aircraft is when the SIC is the sole manipulator of the controls?

 

[avbug]

Being sole manipulator of the controls only relates to flying time with respect to the ability to log PIC (an individual may log time as PIC when sole manipulator of the controls in an aircraft for which he or she is rated), and meeting recency of experience requirements with respect to landings and approaches.

Instrument conditions may be logged as SIC or PIC. That is, one performs the functions of pilot in command in instrument conditions, or as second in command in instrument conditions. It has nothing to do with manipulating the controls, where one sits, the designation by a certificate holder or operator, etc.

When instrument conditions are logged, one is only identifying the conditions of flight. Likewise, if one acts as SIC at night, one logs that time as night time. One certainly wouldn't log it as day time. It's either day or night. By the same token, when flying in instrument conditions, you're in instrument conditions weather acting as PIC or SIC, sole manipulator, or picking lint from one's navel (when performing that function as a required crew member). Conditions are conditions. Either one is in instrument conditions, or one is not.

For the purposes of logging, it makes no difference. Insurance companies and employers will frequently ask about instrument time as PIC and as SIC. For those pilots who have both PIC and SIC in their logbooks, it's well to keep a tally in the margin of each page, or every few pages, of the breakdown between instrument time as PIC, and as SIC.

Note that 61.51(b) identifies several specific requirements on the logging of each flight. These include the date, total flight time, location where aircraft departed and arrived, type and identification of aircraft, type of piloting experience, training received, and conditions of flight. The latter category, found under 61.51(b)(3), provides three choices, the first being a duplex choice; day or night, actual instrument, and simulated instrument conditions.

These conditions apply, regardless of weather one logs the time as PIC, or SIC. PIC or SIC is a classification of pilot time, while day, night, actual instrument, or simulated instrument, are conditions of flight. Two separate issues.

 

[Cornelius]

ok

 

[HS125]

Before the FAA rewrote FAR part 61 in the mid to late 90's. FAR Part 61 specifically stated that "Instrument Time: The pilot manipulating the controls of an aircraft during the time it is flown solely by reference to instruments under instrument weather conditions or simulated instrument flight conditions may log only that time as instrument flight time".

After the rewrite, FAR 61.51 (g)(1) states that: "A person may log instrument time only for that time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions".

I read that as only the person who is actualy manipulating the controls during IFR conditions may log that time as IFR.

Therefore, if the SIC is flying the A/C in IFR, then only the SIC gets to log IFR. And Vise-Versa, if the PIC is flying the A/C in IFR, then only the PIC gets to log IFR.

Further more, according to the ASA & Gleim ATP FAA written knowledge test prep books (1999):

FAA question # 9342

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 flight is on an IFR flight plan.

C - One-half the time the airplane is in actual IFR conditions.

Both ASA and Gleim identify the correct answer as (A).

Thus I would say that the FAA still interprets 61.51 (g)(1) as to only the sole manipulator of the controls gets to log the IFR time.

 

[InHot]

Instrument Time

"After the rewrite, FAR 61.51 (g)(1) states that: "A person may log instrument time only for that time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions"."

An aircraft that requires a PIC and an SIC can only be
operated if there are two warm bodies present.

They way I look at it if you are SIC you can log instrument time whether you are manipulating the controls, reading the USA Today or acting as the non-flying pilot.

It seems it comes down to the interpretation of what it requires to operate an aircraft.

Perhaps that is why they changed the wording from manipulating the aircraft to operating the aircraft?

In any event, I log it that way (and by the way so does all of U.S. Naval Aviation).

After all, those NFO's would never get any instrument time other wise!

And another point, who cares anyway?

 

[A Squared]

HS125,

You wrote
>>>>>Before the FAA rewrote FAR part 61 in the mid to late 90's. FAR Part 61 specifically stated that "Instrument Time: The pilot manipulating the controls of an aircraft during the time it is flown solely by reference to instruments under instrument weather conditions or simulated instrument flight conditions may log only that time as instrument flight time".

I gotta disagree I'm looking at a PPL manual I bought in 1985. It has various aviation regulations, including 61.51 (c)(4) which 15 years ago states "A pilot may log only that time during which he OPERATES the aircraft.........."

So, there was no reference to the "pilot manipulating the controls" even in 1985. This predates the rewrite of Part 61 by a wide margin.

regards

 

[HS125]

A Squared,

I stand corrected. You are absolutely correct that 61.51 was not changed in the mid 90’s revision. The copy of the reg's that I used actually dates back to the very early 70’s (Yes I’m that old). I just made the assumption (I should know better that to ASSUME) that it was changed in the 90’s revision. However, I stand by my convictions that you may only log IFR when you are the Sole Manipulator of the controls.

A big part of my current job is making sure that the company I work for is in compliance with the FAR’s along with keeping the Operations Manual and Training Manuals in compliance. While I do not claim to be an expert in the Reg’s, my position requires that I spend much more time than I would like to admit researching the FAR’s. The FAA does not make this an easy task. They write the Reg’s and then leave a lot to individual interpretation. However, the interpretation that really counts (The FAA’s) is always buried in reams of paper that would over gross a 747. After considerable time spent trying to research this subject, my Principal Operations Inspector directed me to the FAA’s web site that handles these types of questions.
http://afs600.faa.gov/search.asp?myFolder=640otherFAQ&Query=&sub=640&lev=Oth&title=FAQ .

This document is maintained by ALLAN PINKSTON PILOT EXAMINER STANDARDIZATION TEAM, AFS-640

I found the following Question and Answer that directly answer the issue of logging IFR time and have copied and posted it for those who are interested.

QUESTION: Regarding §61.51's definition of "operating an aircraft" an aircraft certified for two pilots is being operated under part 121. The PIC is "flying" the aircraft. The SIC is the non-flying pilot. Can the SIC log actual instrument flight time for those periods of actual IMC conditions when the PIC is flying the aircraft? Is the SIC considered to be "operating" the aircraft at this moment to justify logging this instrument time.

ANSWER: Ref. §61.51(f) and (g); The SIC is permitted to log the time as SIC time, as per §61.51(f). However, he is not permitted to log the time as instrument time, because as per §61.51(g), the person can only log instrument time “. . . for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions . . .” {Emphasis added “operates the aircraft”]. In your scenario, you stated the SIC was the non-flying pilot. So, the SIC crewmember was not operating the aircraft.

And even though you didn’t ask, the logged time has limited value. It cannot be used for the recency of experience under §61.57(c) because “ . . . operates the aircraft . . .” (otherwise meaning hands on, flying pilot, etc.) is required.

Nor can this SIC time be used for meeting the ATP instrument aeronautical experience requirements of §61.159(a)(3) [i.e., “75 hours of instrument flight time, in actual or simulated instrument conditions, subject to . . . .”]

InHot,

You ask; Who cares anyway?

Well a prospective employer, and the FAA do.
1. If you log flight time improperly or contradictory to the FAR’s a prospective employer is going to question it.
2. If you use this flight time for a rating or currancy, the FAA will not be happy, and this can open a whole different set of problems for the pilot.

 

[InHot]

Check your humour quotient. I was joking!

I was attempting (through humor) to show that we spend an inordinate amount of time on topics which will never be definitively decided due to the vagueness of the regulations we are required to abide by.

If you are able to defend your rationale for the way you log this time (that is, explain your interpretation) and the FAA disagrees with you then might be accused of mis-interpreting the regulations (not so bad).

If, however you cannot explain your interpretation you might be accused of an intent to decieve and misrepresent your flight time (A VERY bad thing).

Big difference.

And again I say who cares? Obviously not me as no matter how you interpret the regs I probably have the minimums.

However, I recognize (as does everyone, I think) that the folks with less time are very much concerned with this topic.

Lighten up.

Please

 

[A Squared]

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

 

[InHot]

Disclaimer

A Squared:

Here's the diclaimer from the FAQ Site:

http://av-info.faa.gov/data/640otherfaq/pt61-16.pdf

Disclaimer Statement: The answers provided to the questions in this website are not legal interpretations. Only the FAA's Office of Chief Counsel and Regional Chief Counsel can provide legal interpretations. The FAA's Office of Chief Counsel does not review this website nor does it disseminate legal interpretations through it. However, there are some answers provided in this website where the FAA Office of Chief Counsel's legal interpretations have been reprinted.
However, the answers in this website address Frequently Asked Questions on 14 CFR part 61 and represents FAA Flight Standards Service policy as it relates to this regulation. The answers are provided for standardization purposes only.

Bottom line, we're not going to definitvely decide this issue.

Thank God.

Can't wait til I have a job again and don't have time to read and create this stuff.