Logging Multi time

[BoDEAN]

I have a chance to fly a 340 tonight with the gentlemen and was wanting to log the time. I am not current in a mutli but if I am the sole munipulator of the controls, I am able to log it. From what I read and what I heard, it is a gray area. I am multi rated and an MEI. Thanks in advance

 

[wilky10]

The other flight instructor was logged in when I posted the above message. This message was for me. Sorry about the confusion.

 

[midlifeflyer]

I have a chance to fly a 340 tonight with the gentlemen and was wanting to log the time. I am not current in a mutli but if I am the sole manipulator of the controls, I am able to log it. From what I read and what I heard, it is a gray area. I am multi rated and an MEI. Thanks in advance

Assuming that the 340 does not require a type rating, you may write the time that you are sole manipulator of the controls in the PIC and Total Flight Time columns of your logbook.

Absolutely nothing in the least bit grey about it.

 

[350DRIVER]

above is correct..

Log the time that you are sole manipulator of the controls as PIC & Total time.


3 5 0

 

[jspilot]

Now if he wasn't PIC, could he just log it as total time?? Thanks and sorry i am making more to this post

 

[Timebuilder]

That's a good question.

If a pilot cannot log time as PIC or SIC, then what kind of time would his "total time" be? Traffic watcher time? Radio operator time? Chart reader time?

We had a discussion that involved this question before, and no one was able to explain how a particular company has SIC's log "total time" when not logging PIC under part 61. Maybe it is under "wishful thinking time." I'll bet most of us have a lot of that.

 

[350DRIVER]

Some people on interview boards will question this if it is just logged as "total time" and nothing else. You can do this and some do but I suggest not going this route since it will raise questions down the road most likely for you. The total time needs to be defined as either PIC/SIC , etc, etc.


3 5 0

 

[jspilot]

Thanks a lot for those replies. I was just curious because I have a internship this summer flying right seat on a king air 200, c90, and a baron. And having potential to upgrade once i finish college. I'll keep all this time on a separate sheet of paper just to show i have the experience but i wont log it in my logbook unless i get some PIC. Thanks for clearing that up for me. James

 

[350DRIVER]

jspilot,

If the guy in the left seat has his MEI or ATP and it is a 135 leg then just have him endorse your logbook as dual, you will also log this as total time. The ATP can give instruction on 135 legs so you should take advantage of this if he is willing to sign your logbook. This is perfectly legal to do so... If the aircraft does not require a type rating then you are able to log the 91 legs as PIC time since you are appropriately rated in the aircraft. Obviously the 300 and 350 require a type rating so you cannot log it as PIC time. If the internship is strictly a 91 gig then you would log the legs as PIC/TT on the legs that you are flying the aircraft.


3 5 0

 

[avbug]

If the guy in the left seat has his MEI or ATP and it is a 135 leg then just have him endorse your logbook as dual, you will also log this as total time. The ATP can give instruction on 135 legs so you should take advantage of this if he is willing to sign your logbook. This is perfectly legal to do so...

Oooh...absolutely not so. You're going to get someone busted with that kind of advice, grasshopper. Both the ATP in the left seat, and the "student" in the right. Unless the right-seater in your scenario is a fully qualified pilot employee of the company, not only may he not receive instruction during a part 135 flight, but he may not touch the controls, nor occupy a seat at a pilot station. Visit 135.113, and 135.115.

Simply holding an ATP does not entitle one to provide any instruction, except to other pilots in air transport service, under limited conditions.

In 2000, various cases came to bear on the subject 9Administrator v. Vecchie, Administrator v. Holland, Administrator v. Richardson, Administrator v. Luginbuhl, etc. These cases bore out the foundation (previously established) that the ATP may not provide instruction outside air transport service, and addressed the provisions of 14 CFR 61.157(b).

 

[CDVdriver]

Interesting discussion here..
135.113 deals with more than 8 seats.
But 135.115 is crystal clear that nobody except the PIC may manipulate the controls unless you're employed by the company AND qualified in the aircraft.
Now for the logging of total time:
By 61.51 you are REQUIRED to log the time necessary for another license or rating and the time to meet the recency requirements.
Don't you love the regulations open to interpretation?
As far as I can tell you can log any time as total time, even if you're in row 44 in a 757. Just not as PIC or SIC.
In Europe it is fairly common to log passenger time if you're flying with a buddy and you just sit there and help him out with nav/radio's. It is aeronautical experience after all.
You just CAN NOT use it to apply for any cerftificate or rating so it's absolutely USELESS for anybody aspiring a commercial career.
Meaning leave it out of you're logbook because it will only look a little silly...
Hope it helps..

 

[labbats]

When flying part 135, you may have only certain legs that have passengers or cargo, the other leg(s) may only involve moving the plane to set up for picking up/dropping off the goods. These moving legs without cargo or passengers are considered part 91 and can be logged.

 

[350DRIVER]

avbug,

You have misunderstood what I am saying. If the aircraft does NOT require a SIC to be onboard the aircraft (ex.> King Air's) then the person in the right seat can log the time as instruction recieved and TT as long as the guy in the left seat has either his ATP or MEI. There is nothing illegal about that from the regulation standpoint as long as this individual (in the right seat)is employed by the company and has the other qualifications.

A local 135 company has qualified sic's to be onboard the aircraft due to insurance reqt's, not ops specs, not by reg, so how does this person log the time? Even though he is qualified as SIC he cannot log the time as such because the insurance reqt's do NOT over-ride the ops specs nor the regs. In reality he can have the ATP sign the log book and this is what the POI told the CP to do since the logging of "sic" time is incorrect even though they are qualified as such since the captains are ALL 135 single pilot qualified, ops specs does not require them to be onboard.


This has been asked to the FAA on many occasions....


3 5 0

Yes, the ATP is authorized to be able to give instruction during the 135 legs in some air carrier operations.

 

[Timebuilder]

It seems to me, and there are as many opinons about this as there are pilots, it seems, that the best way to approach this is to get company permission for instruction to be given by the captain on the part 91 legs, with the right seat pilot logging part 61 PIC time. If you can get the company to agree to it, that is.

I wouldn't want to try and justify "total time" without an identifiable position to justify just why I was on board the airplane, other than the customer or an insurance company wanting a second warm body in the airplane.

 

[avbug]

You have misunderstood what I am saying. If the aircraft does NOT require a SIC to be onboard the aircraft (ex.> King Air's) then the person in the right seat can log the time as instruction recieved and TT as long as the guy in the left seat has either his ATP or MEI. There is nothing illegal about that from the regulation standpoint as long as this individual (in the right seat)is employed by the company and has the other qualifications.

No. I understood exactly what you said. If the aircraft does, or does not require a SIC, the person in the right seat cannot be there if the operation is being conducted under Part 135...unless that person is a fully qualified pilot, and fully qualified under the company's operating certificate. In other words, a pilot employee of the company.

In that case, there is no need to be receiving instruction...the person is already a qualified pilot. However, unless that right seater is a fully qualified pilot for the company, they may not even occupy a seat at a pilot station while the aircraft is being operated under Part 135. Period.

If the right seater is SIC qualified and has received the company training, tests, checkride, and all that goes with it, then he or she may receive all the instruction he or she desires. In such a case, an ATP may provide instruction...but again, this is being provided to another pilot in air transport service. This instruction cannot be toward a certificate or rating unless the holder of that ATP also holds a flight instructor certificate with the proper ratings, however.

With that in mind, there is no particular value in logging instruction received from an ATP who does not hold an instructor certificate...certainly not as a time building function. (a reprehensible act in it's own right).

A local 135 company has qualified sic's to be onboard the aircraft due to insurance reqt's, not ops specs, not by reg, so how does this person log the time? Even though he is qualified as SIC he cannot log the time as such because the insurance reqt's do NOT over-ride the ops specs nor the regs. In reality he can have the ATP sign the log book and this is what the POI told the CP to do since the logging of "sic" time is incorrect even though they are qualified as such since the captains are ALL 135 single pilot qualified, ops specs does not require them to be onboard.

Some very common misunderstandings there. To begin with, the fact that an operator is qualified for single-pilot-with-autopilot authorization does not mean that the company cannot use a second in command. Where an exemption to the two pilot rule is given for use of an autopilot, the company is always authorized to use a SIC in place of the autopilot, provided the company has established a training program, and has qualified second-in-command's available to fulfill the position. Therefore, if the company is required to have an autopilot exemption to avoid using a SIC, the company already has provision requiring a SIC...they just aren't using it. A very common misconception.

And yes, it's been asked of the FAA many times, and that has always been the answer.

The concept of flying around as a SIC and having the ATP PIC sign it off as "dual" is a stupid one. Just what has the PIC been teaching, the whole time? This is obviously a bone head idea for capitalizing on logging flight time. The purpose of permitting an ATP the privilege of instructing other pilots in air transport service is limited...it's not to permit time building, or scamming flight time.

In a Legal Interpretation by the FAA Chief Legal Counsel on March 26, 1992, the Administrator clarified the fact that while the single-pilot-with-autopilot exemption permits use without a SIC, it doesn't preculude the use of a SIC. The operator can elect to fly trips with two pilots; the SIC is therefore required.

The letter is as follows, due to length here, in the next post...

 

[avbug]

The letter:

March 26, 1992
Mr. Michael G. Tarsa

Dear Mr. Tarsa:

Thank you for your letter of April 3, 1991, in which you ask questions about logging pilot in command (PIC) and second in command (SIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR). We apologize that staff shortages, regulatory matters, and interpretation requests received prior to yours prevented us from answering your questions sooner.

Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.

You correctly state that while the SIC is flying the airplane, he can log PIC time in accordance with FAR 61.51(c)(2)(i) because he is appropriately rated and current, and is the sole manipulator of the controls. Additionally, he has passed the competency checks required for Part 135 operations, at least as SIC.

You then ask two questions. The first asks whether the pilot designated as PIC by the employer, as required by FAR 135.109, can log PIC time while the SIC is actually flying the airplane. The answer is yes.

FAR 1.1 defines pilot in command:

(1) Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time.

FAR 91.3 describes the pilot in command:

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

There is a difference between serving as PIC and logging PIC time. Part 61 deals with logging flight time, and it is important to note that section 61.51, Pilot logbooks, only regulates the recording of:

(a) The aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of this part.

FAR 61.51(c) addresses logging of pilot time:

(2) Pilot in command flight time. (i) A recreational, private, or commercial pilot may log pilot in command time only that flight time during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or when the pilot is the sole occupant of the aircraft, or, except for a recreational pilot, when 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.

(ii) An airline transport pilot may log as pilot in command time all of the flight time during which he acts as pilot in command.

(iii) (omitted).

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second 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.

As you can see, there are two ways to log pilot in command flight time that are pertinent to your question. The first is as the pilot responsible for the safety and operation of an aircraft during flight time. If a pilot is designated as PIC for a flight by the certificate holder, as required by FAR 135.109, that person is pilot in command 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 second way to log PIC flight time that is pertinent to your question is to be the sole manipulator of the controls of an aircraft for which the pilot is rated, as you mention in your letter. Thus, a multiengine airplane flown under Part 135 by two pilots can have both pilots logging time as pilot in command when the appropriately rated second in command is manipulating the controls.

We stress, however, that here we are discussing logging of flight time 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 second pilot in your example 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 has not qualified to serve as a PIC under Part 135.

An example of this difference is FAR 135.225(d), which raises IFR landing minimums for pilots in command of turbine powered airplanes flown under Part 135 who have not served at least 100 hours as PIC in that type of airplane. Served and logged are not the same in this context, and no matter how the SIC logs his time, he has not served as a PIC until he has completed the training and check rides necessary for certification as a Part 135 PIC.

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division

 

[350DRIVER]

avbug,

Let's take a King Air 300 & 350 for example, common type. The aircraft is type certificated for single pilot operations and does not require a sic as long as the guy in the left seat has the single pilot type rating and has met the numerous 135 regulations as previously discussed. This particular 135 operation's ops specs do not require a sic to be onboard the aircraft at any time although they provide a fully trained and checked out sic to meet insurance reqt's and to make passengers feel that much more comfortable. The inspectors that I have spoken to at the numerous different fsdo's have said time and time again that as long as the aircraft does not require a sic to be onboard, as long as the ops specs do not require a sic to be there, as long as the regulations do not require the sic to be there then you cannot log the time as sic time no matter the fact that you are "sic qualified". If the ops specs were to state that a sic was required to be onboard then "yes" you would legally be able to log the flight time as sic, not the case here in my opinion since the "insurance reqt's" cannot over-ride the ops specs, regulations, or aircraft's certification.

I have met numerous pilots who were part 135 "sic qualified" on a King Air C90B in which the company did this for no other reason that to make pax feel more comfortable since instead of one qualified pilot up front now they now have two. Can they "legally" log this as sic time? I tend to say no since they are not "required" to be onboard the aircraft per the ops specs, regulations, aircraft reqt's.

So how would they log the time then, that was the only point that I was trying to make. Does "dual" mean anything at this point? Maybe and maybe not but I personally would not start logging sic time in these types of aircraft since you are probably setting yourself up for some trouble at some point down the line. Most on interview boards are going to know this time would be "questionable" at best, if even that. Express Jet recently excused two applicants during the interview process in Houston due to this very reason. Apparently the applicants were "qualified" as sic on their company's aircraft but they were legally not required to be there nor were they needed per that particular company's ops specs.


If your ops specs, aircraft, regulation require you to be onboard as a sic and you are qualified then log the time as sic, simple. I just think people do this in many cases where they are going to set themselves up for trouble down the line.

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second 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.

So... He/she is unable to log the time as sic if it is not required by the aircraft's type certification, ops specs, regulation. Once again the company in particular I mentioned has pilots logging time in a King Air as SIC. How does this "qualified" pilot then log the flight time? I think "dual" is going to be the only option left and they can log the 91 legs as pic time if they are flying those legs.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization.

Why would a company not exercise this option? Most of the 135 operators that I have come in contact with want this "flexibility" to be able to fly the aircraft single pilot. This is more economical as well since it avoids having to pay a second pilot.



3 5 0

av- when did Markette give you your Sabre type? (just curious)

 

[Timebuilder]

Why would a company not exercise this option? Most of the 135 operators that I have come in contact with want this "flexibility" to be able to fly the aircraft single pilot. This is more economical as well since it avoids having to pay a second pilot.

I think for most, it is a matter of simple economics, in the face of rising insurance costs. If you can place a second person in the cockpit, and not have to make them a required crewmember, not have to pay them as much as the PIC, not have to either train them yourself or send them to school, and simply have a fuctioning autopilot to cover the crew requirement, then you have the best of both worlds. You pay a few dollars to someone to placate your insurance and your passengers, and you don't have to make them an integral part of your operation.

It's a shame those guys were dismissed from the interview. It pays to know how a carrier feels about SIC programs and logging before you get that far.

 

[avbug]

The inspectors that I have spoken to at the numerous different fsdo's have said time and time again that as long as the aircraft does not require a sic to be onboard, as long as the ops specs do not require a sic to be there, as long as the regulations do not require the sic to be there then you cannot log the time as sic time no matter the fact that you are "sic qualified".

Well there's your problem...you are seeking information at the FSDO level. You should know by now that it's frequently wrong, conflicted, and is most certainly not authoritative. You have just been given an interpretation by the FAA Chief Legal Counsel, however, which clarified it for you, and IS authoritative.

You would rather go on heresay by asking the lowest rungs of the Administration, rather than going to the source for making such a determination. Why is that? Read the letter again. I highlighted and italicised it for you.

If the ops specs were to state that a sic was required to be onboard then "yes" you would legally be able to log the flight time as sic, not the case here in my opinion since the "insurance reqt's" cannot over-ride the ops specs, regulations, or aircraft's certification.

Again, READ THE LETTER! It's right there. If the operation is authorized single pilot with autopilot by the Opspec, then that operation is also authorized the use of two pilots...the operation may use a SIC in lieu of an autopilot. Read the letter.

In part, it states:

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

I have met numerous pilots who were part 135 "sic qualified" on a King Air C90B in which the company did this for no other reason that to make pax feel more comfortable since instead of one qualified pilot up front now they now have two. Can they "legally" log this as sic time? I tend to say no since they are not "required" to be onboard the aircraft per the ops specs, regulations, aircraft reqt's.

But you would be wrong in that bet, as already established. The SIC is required by regulation, period. That the PIC is authorized to use an autopilot in lieu of a SIC is not relevant; he's using the SIC in lieu of the autopilot. Again, read the letter.

Express Jet recently excused two applicants during the interview process in Houston due to this very reason.

They're better off. Why on earth would they want to pucker up their careers or pollute their lives by working for a company like that anyway?

So... He/she is unable to log the time as sic if it is not required by the aircraft's type certification, ops specs, regulation. Once again the company in particular I mentioned has pilots logging time in a King Air as SIC. How does this "qualified" pilot then log the flight time? I think "dual" is going to be the only option left and they can log the 91 legs as pic time if they are flying those legs.

Negative. Asked and answered, repeatedly.

Why would a company not exercise this option? Most of the 135 operators that I have come in contact with want this "flexibility" to be able to fly the aircraft single pilot. This is more economical as well since it avoids having to pay a second pilot.

Obviously not. You've cited examples of operators who are doing just the opposite...using a SIC when they don't need to. Looks to me as though you've answered your own question.

 

[SkyWestCRJPilot]

Since the 340 is a pressurized airplane with a service ceiling greater than 25,000 feet you would need a high altitude endorsement in order to log PIC. Do you have a high altitude endorsement?