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Logging PIC in a Complex/HighPerformance

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MasterFly

Member
Joined
Nov 27, 2001
Posts
14
If a person does not have a complex/HP sign-off in their logbook, can he still log it as PIC, since he is rated in that aircraft and class?

My understanding is that there is a difference between logging and acting as PIC. So that when initially receiving training in a single-engine complex or HP airplane, one can still log it since he is simply rated in a ASEL. He just can't fly by himself or with passengers until he has an endorsement.

Am I right?

Thanks.
 
Correct, see 61.51(e). You may log that time as PIC since you were a sole manipulator of the controls for an aircraft that you are rated in. Whenever your instructor is in the aircraft, acting as an authorized instructor, you can expect them to act as PIC.
 
Maybe these posts will bring Avbug back.


It is my understanding that in order to log PIC time, you must be "appropriately rated in the aircraft". I don't have time to research this now, but it makes sense that in order to log time as PIC in HP/Complex, you have to have the authorization for a HP/Complex aircraft, ie: the signoff. While working on it, I log my students as receiving instruction, or "dual", but not "PIC".

When I get to the school and check the rgs, I may have time to ammend this post.
 
PIC

My understanding of this situation is if the aircraft you are flying is an airplane single-engine land and you are a private pilot, you can log it as PIC b/c you are appropriately rated in the aircraft (ASEL). I have signed off a handful of commercial students logged all complex time as PIC and the DE's have not said anything in regards to this. Additionally just after I had recieved my PPL, I flew with the DE in an acro course in a 7KCAB (citabria)(sp?) and it was a taildragger. I had no tailwheel signoff and he logged it as PIC.
 
Sorry this took so long, it's been a day!

(1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane (an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller; or, in the case of a seaplane, flaps and a controllable pitch propeller), unless the person has –

(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) (ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.

Ditto for HP, except for those who date back to a time when the complex/HP signnoff was a single entry.

Pretty much as I expected. Of course, we could argue about the diference between "logging" as PIC versus "acting" as PIC, but I subcribe to the notion of only logging PIC if I was acting as PIC.
 
Here's the PIC stuff:

(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.
 
You can log PIC while you are getting your endorsements. They are not ratings, thus you are rated in category and class. It is the same concept of a non instrument rated private pilot logging PIC in the clouds while with a CFI or II. They cannot not act as PIC, but they are sole manipulator of the controls. I was asked the question on my CFI oral and this is the answer I gave and I was told I was right. You can also look on the AOPA page and it clarifies it pretty good.
 
I'm a little curious about a pilot who is working on a tailwheel endorsement being the "sole manipulator" of the controls. This suggests to me that he might act as PIC during the ride directly before he receives the endorsement. I don't know too many people who will give instruction "hands off" in many situations, allowing the student to be the "sole manipulator". Perhaps that is what you meant to say?
 
MasterFly -

You’re understanding is correct – you may log the time. At the bottom of this post I’ll tack on an excerpt from the FAA FAQs – but what you said is exactly what they say. The FAA does differentiate between acting as PIC and logging time as PIC.

Since Timebuilder was kind enough to provide excerpts from the FARs, I won’t repeat his work; but in his second post, he provides the applicable FAR for ACTING as PIC in – until you get the signoff, you cannot act as PIC – we’re all in agreement on that.

In his third post, he gives you the applicable FAR for LOGGING PIC time in a high performance and/or complex aircraft. As Wiggum posted, you qualify under the first case – you are “the sole manipulator of the controls of an aircraft for which the pilot is rated.” Assuming you are rated in category and class, and no type rating is required, you may log the time as PIC.



This excerpt is from the FAA FAQs; I’ve added the highlights. BTW, although this appears on the FAQ site, it is actually an opinion from the Office of Counsel, apparently revising the previous FAA position:


QUESTION: Thank you for your letter dated April 20, 1999, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding the logging of pilot-in-command time. Specifically, whether a pilot needs to have the appropriate 14 CFR section 61.31 endorsements before he or she can properly log pilot-in-command time under 14 CFR section 61.51(e).

In your letter you state that you are "concerned with the answers given by John Lynch, AFS-840, through his Frequently Asked Questions 14 CFR, PARTS 61 & 141 website," regarding the 14 CFR section 61.31 endorsements and the logging of pilot-in-command time under 14 CFR section 61.51(e). In this website, Mr. Lynch was given the following scenario: a person holds a private pilot certificate with a single-engine land rating. This pilot is obtaining training in a single-engine land airplane that is also a complex or high performance airplane. The question asked was whether this person could log the time he or she manipulated the controls as pilot-in-command time. Mr. Lynch stated that this person could not log pilot-in-command time under 14 CFR section 61.51(e) in a single-engine land airplane that is also a complex or high performance airplane, without having the appropriate endorsements required under 14 CFR section 61.31. This answer is incorrect.

ANSWER: Ref. § 61.51(e)(1)(i); Before discussing this issue, please note that Mr. Lynch's website is an informational website provided by the Flight Standards Service (AFS). It is not a legal site and the Office of the Chief Counsel does not review it. Accordingly, information provided on his website is not legally binding.

14 CFR section 61.51(e) governs the logging of pilot-in-command time. This section provides, in pertinent part, that a private pilot may log pilot-in-command time for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. (Emphasis added)

The term "rated," as used under 14 CFR section 61.51(e), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required). These ratings are listed under 14 CFR section 61.5 and are placed on the pilot certificate.

Therefore, based on the scenario given to Mr. Lynch, a private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating. Note, while the private pilot may log this time as pilot-in-command time in accordance with 14 CFR section 61.51(e), he or she may not act as the pilot in command unless he or she has the appropriate endorsement as required under 14 CFR section 61.31.

14 CFR section 61.31 requires a person to have an endorsement from an authorized instructor before he or she may act as pilot in command of certain aircraft (a complex airplane, a high performance airplane, a pressurized airplane capable of operating at high altitudes, or a tailwheel airplane). These endorsements are not required to log pilot-in-command time under 14 CFR section 61.51(e).

As you stated in your letter, there is a distinction between acting as pilot in command and logging pilot-in-command time. In order to act as pilot in command, the pilot who has final authority and responsibility for the operation and safety of the flight, a person must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. In order to log pilot-in-command time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.
 
I hate the legal profession. For a moment, forget about the regulations and just ask yourself... Does it make sense that you can log time as pilot in command time if you aren't the pilot in command? Can you log multiengine time in an aircraft without multiple engines? FAA legal has read the reg and determined that you CAN log this time because of the word "rated." While I do not dispute that the letter of the law allows the logging of this time, I question whether or not this makes any logical sense.

Have you hugged your lawyer today?
 

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