Logging instrument time

[MtrHedAP]

I know this may be a silly question. When are you allowed to log actual time when flying 2 crew is required? Can you log it regardless of who is flying, or do you need to be the pilot flying for that leg? I have heard both sides and not sure which is correct. The only thing I could find is instrument flight time is when you operate the aircraft solely by reference to flight instruments. - Part 61.51

 

[Andy Neill]

61.51e(2) says:
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.
******
The way we worked it was that the FO would log instrument time when acting as the flying pilot and the CA would log all instrument time whether the flying pilot or not.

 

[eagle06]

Dear Mr. :

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.

(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 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.


Attorney, ANM-7H

 

[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.

 

[Amish RakeFight]

You can log ACTUAL and NIGHT if you are the SIC and the PIC is the flying pilot.

Just don't log the time as PIC if you're the company designated SIC (even with a type) in a 121 environment.

 

[MtrHedAP]

Thanks everybody. So i understand that i can log the instrument and night time while acting as SIC no matter who is flying.
Now I am curious from Eagle 06 post can I log PIC for the time I am the sole manipulator of the controls - I am type rated on the Beech 1900 with SIC privileges only. This means i cannot ACT as PIC but can I LOG PIC? Amish mentions I cannot in 121 but I am operating under Part 135, and this also contradicts Eagle06's post. Thank you

 

[regionalcap]

Thanks everybody. So i understand that i can log the instrument and night time while acting as SIC no matter who is flying.
Now I am curious from Eagle 06 post can I log PIC for the time I am the sole manipulator of the controls - I am type rated on the Beech 1900 with SIC privileges only. This means i cannot ACT as PIC but can I LOG PIC? Amish mentions I cannot in 121 but I am operating under Part 135, and this also contradicts Eagle06's post. Thank you

According to the interpretation listed above, you can log it. Would I log it? No.

 

[avbug]

Amish mentions I cannot in 121 but I am operating under Part 135, and this also contradicts Eagle06's post. Thank you

Yes, you can log it. No you should not.

Under part 61, you can log the time, regardless of whether the operating rules for your flight are Part 91, Part 121, or Part 135. However, you really should't, if you're operating for a certificate holder, for a three reasons.

When you're logging time as a professional, working for a certificate holder, you're going to be using that time at some point in the future to represent yourself to a prospective employer. The prospective employer wants to know about your real experience, not what you could legally get away with logging. The new employer will have the ability to question your old employer, even see your records, and will know how much flight time the old employer says you have. If you claim 1000 hours of PIC time, but your old employer shows 500 hours of PIC and 500 hours of SIC, then it doesn't look good for you; you appear to be inflating your logbook.

In the 121 and 135 world, PIC means time when you're really the PIC. This isn't regulatory; this is an understanding industry-wide. While the regulation does indeed say that there will only be one PIC and that's the one assigned by the employer, and that the PIC remains the PIC for the duration of the flight...Part 61.51 still provides that you can log it as PIC...but the industry at large doesn't see it this way.

If you're logging time as PIC when you're not the person who signed for the airplane, and who was the designated PIC for the operation, it reflects badly on you. You will appear to be inflating your times or padding your logs. You will also appear to not understand the relationship between PIC/SIC and 121/135...which suggests a certain level of ignorance to a prospective employer...at a minimum it leaves a bad impression. Finally, it may cost you a job, or when the prospective employer learns of this perceived deception, the times you have listed will be devalued or reduced.

Having said that, many employers use varying means to record times in their applications...what one counts, another doesn't. Some will consider military time plus an additional factor, for example, others won't. Some will lump all time in piston airplanes into one category, even if it's a large, four engine airplane. One thing that's universal, however, is that if you haven't signed for the airplane (if you're not the legal PIC), the employer doesn't count the time as PIC. If you've logged it as such, it will reflect badly on you.

The chief purpose for the rules allowing the logging of time the way they do under Part 61.51 is to permit recognition for various types of flying while pilots work on their certificates or ratings. While it's perfectly legal to log the time as sole manipulator while employed as SIC under Part 135, it's viewed as an inappropriate act and exploiting a "loophole." It's best to bide your time, log SIC when you're SIC, and the when you upgrade, log PIC.

 

[PURPLEHAZE21]

At this point in your career you should be able to fly to the standards of the certificate you hold. Whether it be day or night, IMC or VMC becomes irrelevant. Just fly "safe".........

 

[avbug]

That's not particularly relevant to the question at hand, which is an issue of legality, and partially of propriety.

Unfortunately, employers generally don't, (and aren't able to) quantify "out to be able to" without some measure of experience as a standard, and time logged becomes applicable to measuring that standard. Total time, PIC time, etc...all things that employers consider.

Even the regulation recognizes that approaches used to meet currency requirements be performed in simulated or actual instrument conditions, and logged accordingly.

 

[ksu_aviator]

Thanks everybody. So i understand that i can log the instrument and night time while acting as SIC no matter who is flying.
Now I am curious from Eagle 06 post can I log PIC for the time I am the sole manipulator of the controls - I am type rated on the Beech 1900 with SIC privileges only. This means i cannot ACT as PIC but can I LOG PIC? Amish mentions I cannot in 121 but I am operating under Part 135, and this also contradicts Eagle06's post. Thank you

If I understand you, you have an SIC Type Rating? If that is the case, that is worth a little more than the paper it is printed on. It only allows you to act as an SIC and that is only needed if you leave the US Airspace.

An SIC Type rating does not qualify you to act as PIC.

If I misunderstood you, then ignore everything I just said.

In any case, I always log flight time by how it best represents my experience as a pilot. When logging instrument, I usually only logged the time when I was flying the aircraft in the clouds. However, I would not question someone that logged time when the other pilot was at the controls.

In a few years you will look back and realize how insignificant that extra .1 of actual instrument time is. My advice, don't log it. You won't need it.

 

[skyaddict]

Back in early 2001, I remember being disqualified as a candidate for hiring at Comair at an AIR Inc seminar because they had a rule requiring a minimum of 10% of total time to be instrument time (I can't remember if it allowed sim and hood time), which they claimed was a hard rule. At the time I had over 2600 hours TT but less than 150 hours of actual. Anyway, the moral of the story is that most people being hired by a place like this have to either be very generous in their definition of instrument time (I know people who have logged any flying on an IFR day, or any flying on top as instrument!), or they simply parker it up to total 10%. Comair was striking at the time so it was a non-issue for me really, but many companies have arbitrary instrument requirements, and if you only include time as pilot flying, even though as SIC you were "operating" the aircraft along with the PIC in an aircraft and/or operation requiring more than one pilot, you will lose a whopper of time that I think is legitimate according to the FARs and really, in terms of your pilot monitoring duties when you think about it. I wouldn't log approaches or landings when pilot not flying though, because there the definition specifies "sole manipulator" not "operator".

 

[MtrHedAP]

Ksu_aviator,
Yes I only have a SIC type rating, I know that means squat, in the States but I do operate in african countries. Now for those countries I dont know if any of them actually require it, but i feel that i spent alot of time and hard work earning that SIC rating. It was the same ground school, just less sim sessions and of course money. I did not pay for it.

Thanks for all the advice everyone has given. I am new to this game and have questions. I have always logged conservative but wanted to know what was standard or acceptable. Thanks again.

Cheers

 

[avbug]

To expand a little more on what's been previously said, there are really two parts to your questions in this thread. One asks if you can log time as PIC when you're not the PIC...and the answer as previously discussed is yes.

In this particular case, however, where you have only a SIC type rating, you can't log the time as PIC regardless of the rules under which the flight is being operated...be it 91, 121, or 135, even if you're sole manipulator of the controls.

In order to log PIC as sole manipulator, you need to be rated in the airplane, which means category (airplane), class (multi-engine land), and type, where a type rating is required. In this case, you don't hold a PIC type rating, and can't operate the airplane as PIC, and aren't rated for the airplane...and can't log PIC as sole manipulator.

If you were to hold the type rating, however, even when not acting as PIC, even under Parts 121 or 135, you could still log the time as PIC legally...it's just that for the professional reasons previously discussed, you shouldn't.

 

[QueensPilot]

Hey All:
Slightly different but related...I am a CFI out here in the San Joaquin Valley. You may know about the fires we have had here this summer. Earlier in the summer we were having days where the visibility was 3 miles due to smoke/haze. Well on a couple of days the reported vis was like 1 -2 miles, I cannot remember the exact number, but not legally VFR. As I had to conduct a part 141 instrument stage check on one of these days, my choices were to either cancel or file. We filed and did the 3 approaches and some other stuff required on the check. Here is my question:
I know that as a CFII I can log 'actual' and the approaches if I am teaching in actual instrument conditions. On that particular day I could see the ground but I could not see the horizon in front of me at all. I felt I was not in actual because I was not 'in the clouds.' But some colleagues told me that they would have logged actual and the approaches. So I am not sure what to do.
Regarding the above poster who said the .1 here and there does not matter: I think you are right, but early in your career, it might matter more. I am a CFI in an area that doesn't get much IMC for a good portion of the year. I am at around 1300 hours and am starting to think about the ATP. The total time is easy to come by, I hav the night, the x-c is a little harder to come by(I have 400ish) but by far the 75 actual or simulated instrument is.

 

[Amish RakeFight]

Log it. If you're controlling the aircraft by referencing the instruments (no horizon, btwn layers, etc). That's what the FAA regs allow. For instance, one could legally log instrument on a night flight in VFR conditions, if it is necessary to maintain control by use of the instruments. This could be due to a moonless night, lack of lights on ground, etc.

What is really not ALLOWED is logging instrument time just cause you're on an IFR plan. Sounds obvious, but there are some pilots that do.

Hey All:
Slightly different but related...I am a CFI out here in the San Joaquin Valley. You may know about the fires we have had here this summer. Earlier in the summer we were having days where the visibility was 3 miles due to smoke/haze. Well on a couple of days the reported vis was like 1 -2 miles, I cannot remember the exact number, but not legally VFR. As I had to conduct a part 141 instrument stage check on one of these days, my choices were to either cancel or file. We filed and did the 3 approaches and some other stuff required on the check. Here is my question:
I know that as a CFII I can log 'actual' and the approaches if I am teaching in actual instrument conditions. On that particular day I could see the ground but I could not see the horizon in front of me at all. I felt I was not in actual because I was not 'in the clouds.' But some colleagues told me that they would have logged actual and the approaches. So I am not sure what to do.

Regarding the above poster who said the .1 here and there does not matter: I think you are right, but early in your career, it might matter more. I am a CFI in an area that doesn't get much IMC for a good portion of the year. I am at around 1300 hours and am starting to think about the ATP. The total time is easy to come by, I hav the night, the x-c is a little harder to come by(I have 400ish) but by far the 75 actual or simulated instrument is.

 

[Amish RakeFight]

61.51 (g)

(g) Logging instrument flight time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

 

[Amish RakeFight]

As you can see above, the term "operates" is inclusive of the SIC as well as the PIC as both are required to operate the flight. The plane can not be legally operated without BOTH crewmembers. Therefore, both may log ACTUAL and NIGHT under conditions of flight, regardless of whether you are the FP or NFP.


Oh, and I always thought that 10% rule was ridiculous.

 

[QueensPilot]

Thanks Amish!!