Logging PIC for Complx/HP Endorsements

[BYUFlyr]

Can my students log PIC during the dual flight involving a complex or high-performance endorsement?

-Thanks

 

[NYCPilot]

Sure.

PIC - as sole manipulator, since they are rated (SEL) in the AC.....they just can't ACT as PIC.

 

[Kream926]

as long as they have the endorsment, right?

must recieve groung and flight training and have a log book endorsment to log pic in complex airplnae

 

[midlifeflyer]

No, Kream. NYC had it right. You must have the endorsement in order to =act= as PIC in a comppex airplane.. All you need to =log= the time in the PIC column of the logbook is a pilot certificate with the appropriate aircerft (ASEL or AMEL) on the back.

From my PIC FAQ:
==============================
Rule 1. If you are a recreational, private or commercial pilot, you may log PIC any time you are the sole manipulator of the controls of an aircraft you are rated for. [61.51(e)(3)]

"Rated" means the category and class (and type, if a type rating is necessary for the aircraft) that is listed on the back of your pilot certificate. Nothing else matters. Not instrument ratings. Not endorsements for high performance, complex, or tailwheel aircraft. Not medical currency. Not flight reviews. Not night currency. Nothing. There are no known exceptions.
==============================

 

[nosehair]

[61.51(e)(3)]

Actually, Mark, that's 61.51(e)(1)(i).....

....and to amplify to Kream, since I have lived most of my adult life misreading this regulation: This regulation does not say, "To act as PIC...", it says "to log PIC"...
I just simply ASSUMED we talking about the PIC, the person ACTING as the PIC, and here is the rule that governs the LOGGING by that PIC....but that ain't the way it is written. It simply says a sport,recreational, private, or commercial pilot may log...when he is manipulating the controls, and the word rated in this reg has been determined to mean the ASEL(or whatever) that is typed on your certificate.

Now, I have only been converted to this new way accepting this regulation for a year or two (since I came on these message boards), and I still think it is an oversight by the regulation writers - that the INTENT of the rule was that the logging also meant acting.

Look at 61.51(2) An airline transport pilot may log PIC all the time he is ACTING as PIC of an operation requiring requiring an ATP.

That is meant to cover the Captain acting PIC on an airliner even when he's in the bathroom, but Look! he can't log PIC any other time! He is not covered in 61.51(e)(1)(i)

If you stick to the letter of this regulation (instead of the spirit - which would mean you are ACTING PIC to LOG PIC), A guy with an ATP cannot log any time except when he is PIC on a flight requiring an ATP....

even when he is solo.

 

[skyaddict]

"I still think it is an oversight by the regulation writers - that the INTENT of the rule was that the logging also meant acting."

With respect to this reg. as well as other logging vs acting questions:
Perhaps once upon a time it may have been the intent of some individual regulation writer, that acting was to mean logging, but as far as I can tell, it has never been the intent of the FAA. I once worked for a company that did some contract work for the feds, and when we (and respondents to the pertinent NPRM) brought to their attention that some regulatory re-writes were aligning logging and acting, they (FAA) basically said "oops, we didn't mean to do that", and asked us to fix the proposed re-write back. If I recall correctly, the FAA comments on the responses to the NPRMs have clarified that, over the years, as have FAA legal interpretations. If it was ever changed, all pilots after the reg change would basically be screwed compared to those who built their time before it.

 

[midlifeflyer]

Maybe, it would be interesting to find out for sure, but I really don't think it was an accident. Two reasons:

1. This interpretation has been consistently applied by the FAA for at least 20 years (I haven't seen anything earlier)

2. As early as the 1940's the old CAR certificate and rating requirements were based on "solo" time which, as used in those regs, meant (guess what?) "sole manipulator" (rather than sole occupant of the airplane), exactly the same thing as the later "logged PIC"

So, by whatever name, "sole manipulator" has been the standard for logging flight time toward certificates and ratings for 50-60 years. The name changed; the definition and what it was counted for did not.

The only "oops" I know of was John Lynch's insistence in the FAQ that it was a mistake. Of course, that was based on the 1997 re-write when they =didn't= change even one word, was after he was soundly taken on the carpet for changing official FAA policy without a reg change, and was accompanied by threats of a change that never came to be.

 

[Kream926]

ok wait im confused. there was a debate about this at my school "to log or not to log" that is the question.

here's a scenario:

im a SEL private pilot flying an RG. no complex endorsment flying with my instructor. time goes in SEL box, dual recieved box, but does it go in the PIC box? cause mine didnt until i got the endorsment.


damn these regs

 

[minitour]

an endorsement isn't a "rating" so yes...you should have logged as PIC all time you were sole manipulator of the controls.

-mini

 

[NYCPilot]

ok wait im confused. there was a debate about this at my school "to log or not to log" that is the question.

here's a scenario:

im a SEL private pilot flying an RG. no complex endorsment flying with my instructor. time goes in SEL box, dual recieved box, but does it go in the PIC box? cause mine didnt until i got the endorsment.


dang these regs

Well you have a choice, you're not required to log it, but you can. If you want to log only pure PIC as in Acting PIC, then keep that system. But there are instances where you will need to log PIC as sole manipulator such as in multi building time for insurance purposes. Insurance may require that you have X number of hours PIC, but its a catch 22. You can't get PIC (read: acting PIC) if you can't go out on your own. Flying with an MEI who is acting PIC while you LOG PIC as sole manipulator allows you to build up the time in order to meet PIC insurance minimums.

In your case, you can log PIC if you choose to. During your HP/Complex training, you are entitled to log PIC (sole manipulator in a rated AC) but do not necessarily have to. It still gets logged as dual, no matter what.

My advice is to keep a track and breakdown of the different types of PIC hours. I created my own spreadsheet in MS Excel that has PIC broken down by:

PIC - Student Pilot Solo
PIC - Acting PIC
PIC - Dual as Sole manipulator (rate in AC)

 

[Kream926]

so whats all the BS about having recieved flight and ground training to log pic all about??????????????????????????

 

[Kream926]

the way i see it it's just like a HP and an altitude endorsment. for pressurized a/c i cant pic unless i have the endorsment right??

 

[NYCPilot]

so whats all the BS about having recieved flight and ground training to log pic all about??????????????????????????

Dude, the regs. say that in order to ACT AS PIC of a HP aircraft you need to receive and log ground and flight training from an instructor. It's part of the whole package. In order to be granted the ability to ACT AS PIC, you must have met these requirements. Short of this, you can STILL log PIC as sole manipulator.

I've posted a link to Doc's website. It links you to a very informative page with the regs. of logging time in different situations. It is also backed up by letters from the FAA.


http://www.propilot.com/doc/logging2.html

 

[Kream926]

im starting to understand


thanks guys!

damn i got robbed outta 2 PIC hours........ o well

 

[midlifeflyer]

so whats all the BS about having received flight and ground training to log pic all about??????????????????????????

No one, other than the many, many pilots and instructors who don't really understand these rules that well make a connection with the training and =logging=.

But it's not BS. The receiving flight and ground training and an endorsement is in order for you to have the authority to assume the important position of being the pilot who is in command with ultimate responsibility for a flight in a complex airplane, perhaps alone but potentially with passengers.

That responsibility has nothing to do with what you write in a column of your logbook.

 

[midlifeflyer]

dang I got robbed outta 2 PIC hours........ o well

If it's that important, remember it's your logbook and you are free to correct incorrect entries. I did after my endorsement when I learned how the rule works. Made the correction, initialed it, revised the totals and wrote a short explanatory not on the page where the revised totals appeared.

 

[NYCPilot]

If it's that important, remember it's your logbook and you are free to correct incorrect entries. I did after my endorsement when I learned how the rule works. Made the correction, initialed it, revised the totals and wrote a short explanatory not on the page where the revised totals appeared.

If there's some error from an entry a few pages back with the totals already added up in the column, I use the next available entry on the current log page and record the missing time, including the reason why, the date (so who ever is concerned, can go back to that date in my logboook), and fill in the appropriate column of time and include it at the end when the page is tabulated. You only need to fill-in the necessary coulmns, not TT if not necessary.

Here's what happened to me once.

Realized that I logged everything correctly, just didnt log the X-ctry time. Since it was not possible to go back to that entry, as the page had been totalled, I just made an entry to include the missing time on the next available line, leaving out the TT. PIC, etc.

Avoid using whiteout (or greenout) - its messy and appears as some form of concealment.

 

[johnpeace]

Kream, it's sort of like how instrument students can log actual instrument PIC time...even before they have instrument ratings.

The CFII is acting as PIC, it's his ticket on the line for the flight. But since the student is rated in the airplane (PP-ASEL) AND is the sole manipulator, it's logged as PIC.

There's a GREAT FAR pt 61 FAQ by one of pt61's authors, John Lynch.
http://www.johnpeace.org/pt61FAQ.zip
This document answers a LOT of questions about logging and other regs in pt61, definitely a must read.

 

[PropsR4Boats]

Let em log it. Did you? I have never heard the FAA getting a hard on for someone logging a couple of hours when they don't have your name in a logbook.

 

[BYUFlyr]

Let em log it. Did you? I have never heard the FAA getting a hard on for someone logging a couple of hours when they don't have your name in a logbook.

I did log the hours, but the examiner said I wasn't supposed to log PIC since I wasn't endorsed for flying complex airplanes; but that didn't make much sense to me. That's why I'm asking.

 

[BYUFlyr]

Thanks.....

Thanks for the response guys.... It's all clear now.

 

[A Squared]

I did log the hours, but the examiner said I wasn't supposed to log PIC since I wasn't endorsed for flying complex airplanes; but that didn't make much sense to me. That's why I'm asking.

The examiner is wrong. As you are now aware from reading this thread, the FAA legal department has been very clear for a very long time that it is legal to log PIC time in htat situation. It is not unusual for examiners to be incorrect, it happens, perhaps more than it should. THe issue is a little conterintuitive, after all from a logical standpoint, why would you be able to *log* PIC when you are not the PIC? That (understandable) line of reasoning leads some astray.

 

[mattpilot]

The FAA has a very nice FAQ, which discusses this issue.

Its written by John Lynch and its called the Part61FAQ.doc . Either a search on faa.gov or on google.com will help you find it.

 

[nosehair]

2. As early as the 1940's the old CAR certificate and rating requirements were based on "solo" time which, as used in those regs, meant (guess what?) "sole manipulator" (rather than sole occupant of the airplane), exactly the same thing as the later "logged PIC"

So, by whatever name, "sole manipulator" has been the standard for logging flight time toward certificates and ratings for 50-60 years. The name changed; the definition and what it was counted for did not.

Now that's what I'm talkin' about! Some actual history as to the evolution of this "misnomer". So, Mark, where did you learn this tidbit of information? Do you have a reference? I am very interested in these specific "old" regs which you refer to.

 

[johnpeace]

The FAA has a very nice FAQ, which discusses this issue.

Its written by John Lynch and its called the Part61FAQ.doc . Either a search on faa.gov or on google.com will help you find it.

Or just download it here:
http://www.johnpeace.org/pt61FAQ.zip

 

[nosehair]

Look at 61.51(2) An airline transport pilot may log PIC all the time he is ACTING as PIC of an operation requiring requiring an ATP.

That is meant to cover the Captain acting PIC on an airliner even when he's in the bathroom, but Look! he can't log PIC any other time! He is not covered in 61.51(e)(1)(i)

If you stick to the letter of this regulation (instead of the spirit - which would mean you are ACTING PIC to LOG PIC), A guy with an ATP cannot log any time except when he is PIC on a flight requiring an ATP....

even when he is solo.

...what!?...no one has a problem with that??

 

[midlifeflyer]

Now that's what I'm talkin' about! Some actual history as to the evolution of this "misnomer". So, Mark, where did you learn this tidbit of information? Do you have a reference? I am very interested in these specific "old" regs which you refer to.

The FAA maintains a collection. Here's the link to old CAR Part 20

http://dotlibrary1.specialcollection.net/scripts/ws.dll?websearch&site=dot_cars


What you're looking for, for definitions is the Logging Pilot Flight Time section, 20.76, particularly 20.762(b) which says

==============================
The holder of a pilot certificate, other than a student pilot certificate, may log as solo flight time that portion of any flight during which he is the sole manipulator of the controls: Provided, That he may log as solo flight time only 50 percent of any flight time during which a certificated instructor or a certificated airline transport pilot is in the aircraft serving as an instructor for the purpose of reviewing or increasing such pilot's skill; and Provided further, That the holder of a commercial pilot certificate while serving in scheduled air transportation shall log his flight time as provided in Part 61.
==============================

And then compare that to, say the Commercial Pilot requirements in 20.14, particularly 20.146:

==============================
Aeronautical experience. Applicant shall have logged at least 200 hours of solo flight time, of which at least 5 hours shall have been logged within the 60 days immediately preceding the date of filing the application. As part of the foregoing, applicant shall have logged at least 10 hours of solo cross-country flying, which shall include at least one flight over a course of not less than 100 miles with at least three full-stop landings at different points on such course. Such experience shall be certified to by some person, other than the applicant, having direct knowledge of the same: Provided, That a graduate of a commercial pilot course of a certificated flying school shall be deemed to have met the requirements of this section upon presentation of his certificate of graduation within 30 days thereof.
==============================

Won't even find the phrase "pilot in command" in Part 20.

Interesting what you find when recuperating from surgery.

 

[midlifeflyer]

...what!?...no one has a problem with that??

Not me. I read =way= too many statutes, regulations and cases to worry about inconsequential inconsistencies in wording.

 

[A Squared]

As early as the 1940's the old CAR certificate and rating requirements were based on "solo" time which, as used in those regs, meant (guess what?) "sole manipulator" (rather than sole occupant of the airplane), exactly the same thing as the later "logged PIC"

I don't have a copy of the 1940 CAR and I haven't taken the time to register to get acess to the link you posted, but I do have a copy ofhte 1950 CAR, and it says in part 20:

20.81 Solo Flight TIme, Solo flight time shall mean the flight time during which a pilot is the sole occupant of an aircraft.

That seems fairly clear to me.

Won't even find the phrase "pilot in command" in Part 20.

THat may have been true in 1940, but it was certinly not true in 1950.

20.80 Pilot in Command Pilot in command shall mean the pilot responsible for the operation and safety of the aircraft during the time defined as flight time

 

[midlifeflyer]

Indeed. It's hard to navigate the site, but there appears to be a 1949 revision that begins using different terminology. Some of the "solo" time for the commercial becomes "pilot in command time." And the definition of PIC time you cite appears.

But on the historical logging issue? Open your book to CAR 43.43 and I think you'll find the now-famous FAR 61.51 language:

==============================
43.44 Logging of flight time

1. Pilot in command. A private *** commercial pilot may log flight time as pilot in command that flight time during which he is the sole manipulated of the controls of an aircraft for which he is rated or that flight time during which he is the sole occupant of the aircraft. A flight instructor may log flight time as pilot in command that flight time during which he is serving as a flight instructor. All flight time so logged may be credited toward the total flight time required for a higher pilot rating.
==============================

The connection between the terms "solo" and "PIC" for certificate logging purposes doesn't seem to miss a beat. Sure sounds like "logged PIC" for the purpose of qualification for certificates and ratings being different from "real" command responsibility was intentional from the very beginning.