Logging PIC in a Complex/HighPerformance

[MasterFly]

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.

 

[Wiggums]

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.

 

[Timebuilder]

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.

 

[jaybird]

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.

 

[Timebuilder]

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.

 

[Timebuilder]

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.

 

[Buzo]

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.

 

[Timebuilder]

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?

 

[Jetpup]

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.

 

[FlyinBrian]

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?

 

[ksu_aviator]

I can't believe some one believes that you can log PIC in IFR without an IFR rating. It can't be done! Who is the pilot in command...its simple...the PIC is the one that the FAA will violate when something goes wrong. So the PIC during IFR training, while IFR is the CFII. Same goes for a high perf. and complex, until you actually have an endorsement for high perf. and complex you can not log pic time, however you can log acting as pic. I had to do this for my initial multi-engine commercial students.

 

[puddlejumper]

I'm sure many of us have experience with pilot job applications and insurance paperwork. I've noticed that several of these forms will breakdown the PIC time column into FAR part 1 and FAR part 61. Part 1 is time as acting or serving as PIC. This would be as the one whom is responsible for the flight, or the one the aircraft was dispatched to. Part 61 PIC would be time spent as a sole manipulator in an aircraft you, (a recreational, private or commercial pilot) are rated in, or a student as sole occupant. ATPs technically can't log part 61 PIC time unless they are actually acting as PIC of an operation requiring an ATP, otherwise they are part 1 PIC.
Now, just to see if I've got everything straight, back when I was a Commercial pilot, if I was flying a King Air during a 135 deadhead flight (part 91), I could log that as PIC per part 61. The insured, listed PIC was actually the part 1 PIC. Now as an ATP, I can't legally do that since the part 61 PIC only applies to rec, pvt or comm pilots. Well, that's my take on it.
There were several good threads on this subject in the old board. I believe AvBug led most of the discussions.

-PJ

 

[Timebuilder]

I admit it, I usually take Brian's "logical sense" approach to logging.

So, from a regs standpoint, a person working towards his endorsement may log the time where they are the sole manipulator. Not very difficult for a HP/complex student, but much of the time spent landing a tailwheel aircraft might have to be deducted from the flight time in order to eliminate that time where the student was not the sole manipulator, in other words, getting help to avoid ground looping, etc.


Have you hugged a bureaucrat today?

 

[JimNtexas]

Jetpup is 100% correct

Jetpup is 100% correct. Jeppensen's book "Fars Explained" provides additional background information explaining the difference between "logging" and "acting" as PIC.

This is the way it is in the United States.

How some future employer will react to logging PIC "sole manipulator" time is unknown, but the FAA is very clear that this time is logable PIC if you are qualified in the:

catagory (airplane), class( single engine land) and type (if a type rating is requred). Endorsements and Instrument ratings are not required to log sole manipulator pic time that can be used to satisfy FAA time requirements.

Jim

 

[Simon Says]

Ask yourself this..........Am I logging time for my own records or am I logging time to get hired with an airline. Even though the FAR says you can log PIC if you are the sole manipulators of the control can you explain to someone in an interview how you logged that time PIC when you did not have an endorsement. Tough question. I was asked how I logged PIC time when I was a CFI teaching another rated pilot in that A/C. I gave him the FAR answer, then he asked me if I needed a medical to teach students that are rated in the A/C. I said no which is correct then he asked me what the student logged. I said PIC. He then asked me how you can have 2 PIC flying a single engine piper. He went on and on about how he doesnt like people logging PIC time when they are really not PIC.

My recommendation would be to if you are logging time for the hopes to get hired at an airline be as conservative as possible. Whatever time you log you should be propared to answer for at an interview.

 

[skeezer]

He then asked me how you can have 2 PIC flying a single engine piper.

Easy, the student (even though he/she is rated in the aircraft) is NOT acting as PIC as per 14 CFR 1.1. He/She is obivoulsy the sole manipulator of the controls and thus can log that time as PIC per 14 CFR 61.51(e).

The CFI is the one who has the final authority and responsibility for the operation and safety of the flight (along with the other two parts of the PIC definition). Thus, the CFI is the PIC per 14 CFR 1.1. Additionally, as we all know, the CFI can log that time as PIC per the FARs as well.

So, If you asked me who the true PIC (in terms of responsibility) was, it would be the CFI. Thus, if only one person would log PIC, that person would be the CFI.

However since both can log the time as PIC, I say log it. Thats what I have done in the past, and that is what I will continue to do. When in doubt, just follow what the regs say and you will be right.

Some airlines, as pointed out before, want only certain types of PIC time. If I remember correctly, United makes you subtract your Dual received from your time (thereby eliminating the time spent as non Part 1 PIC).

I know some people do the Dual PIC thing to split the cost of multi time, but unless you are really giving instruction or doing hoodwork I would not try that. That type of situation might be what the airlines are trying to avoid. Of course, a discussion on that would start a whole new thread, so I digress.

If my interviewer had questioned me on logging PIC I would have backed it up with the regs, then probably got into a pissing contest if he tried to tell me not to log something that the FARs specifically tell me I can log.

Oh well, hopefully that made sense (probably not but I try ). We could probably argue about this forever, but I say follow the regs and log what 14 CFR 61.51 allows.

Skeezer

PS Consider this Scenario: You take your girlfriend flying for 1.5 hours and let her take the controls for .2 hours. How much PIC can you LEGALLY log?

The technical answer would be that, even though you are ACTING as PIC, you can only legally log 1.3 hours as PIC. Now, I can pretty much garauntee (sp?) that nobody does that but you can't go wrong if you follow the rules (well, this one at least). AOPA did a good article on logging PIC and used this as an example. I can't remember when they did it and I am too lazy to look it up .