Logging PIC jet time

[Beetle007]

Logging PIC turbine time

Ok...I’m going to ask a LEGAL question about logging time and would prefer LEGAL based answer. I only say this up front because I have seen many responses to previous posts with answers that are based on "attempted logic" or "would you want it in your logbook at an interview" type answers. Or, the worst answer of all "be conservative."

I have some friends who are type rated in an A320 and low time pilots (under 1000 hours with no ATP.) However, they were “allowed” to make delivery flights of the A320 from Germany to the U.S.A. and from the U.S.A to Asia as the First Officer. They were also allowed to do Maintenance flights and paint flights as First Officers. These types of flights are considered to be operated under PART 91 I believe. Therefore, could they log these hours as PIC turbine because they were appropriately rated in the aircraft and sole manipulators of the controls (for certain legs.) I am not sure what they actually logged these flights as. I would guess SIC to be on the safe side and not have to discuss it at a future interview. But, I want to know what they could LEGALLY log it as and/or the REG that would prevent them from doing so under part 91 ops by a 121 airline


Also, there must be something that prevents all the type rated SWA FOs from logging their pilot flying legs as PIC. It is clearly industry unacceptable to log this as PIC, but why is it legally unacceptable according to the FAA and PART 121 ops. What is the REG? They are certainly rated in the aircraft and “sole manipulator of the controls” during their PF legs and can log it as PIC according to FAR 61.51. I would think that legally the captain is ACTING as PIC due to the ATP requirement and designation by the airline, but the FO could LOG it as PIC due to 61.51. If not...how do we know which types of OPS 61.51 applys to?
To the best of my knowledge, REG 61.51 applies to all types of operations (PART 91, PART 135, PART 121 etc).

Regulation 61.51 Pilot Logbooks
(e) A recreational, private, or commercial pilot may log pilot-in –command time 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

However, part of me believes there is no correct answer. I would guess I could call several FAA offices and get several answers. I found this out when I was trying to figure out how to log instrument training in actual conditions as a private pilot. I was getting different answers from every person I talked to. Therefore, I called the FAA (FSDO) and they gave me the wrong answer. After an hour of them (FSDO) trying to figure it out, I was told that I could not log it as PIC because I did not yet have an instrument rating and wasnt qualified for instrument conditions. However, two years later, I figured out the difference between acting as PIC and Logging as PIC. I was rated in the aircraft and sole manipulators of the controls during the instrument training, and therefore it is still logged incorrectly in my logbook. And, the lack of knowledge about logging flight time bothers me to this day.

Cheers

 

[labbats]

I've found that the AOPA hotline, either on the internet or the phone works about 100 times more efficiently than the FAA. Call them with any and all your "is this legal?" questions. They are very prompt and professional.

As to a quick answer, I don't know myself, but I do know where to find it.

 

[freightdogfred]

The reason is because under FAR 121 ops, be it a flag, supplemental or domestic air carrier, the aircraft is "released" to the designated PIC by the director of ops, thru his designated rep, being a dispatcher, flight follower (or in the case of supplemental, he may designate the PIC to release himself.) This
"release", containing pertainent info concerning said flight, (route, wx, fuel reserves etc.) must include the SIGNATURE OF THE PIC. Therefore, he who signs the release is the PIC, regardless of who manipulates the controls, is typed-rated, sits in the left seat, etc. There can be only 1 PIC, the hombre who signed for the A/C.

 

[bobbysamd]

Re: Logging PIC turbine time

Regulation 61.51 Pilot Logbooks
(e) A recreational, private, or commercial pilot may log pilot-in –command time 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

(emphasis added)

Your friends who are type rated in the A320 can log the time as PIC on the 91 legs. The ones who are not cannot.

Do not worry in the least about how your PIC time was logged during your instrument training. The PIC time was logged correctly because you were rated in the aircraft and were sole manipulator. 14 CFR 61.51(e)(1)(i), above. Your CFI-I also logged the time as PIC because he/she could log PIC time during all the time that he/she was acting as instructor. 14 CFR 61.51(e)(3).

I agree with the above post regarding who signs for the airplane. That person would be the PIC. I also agree about not bothering to call the FAA. You'll get better advice, and faster, by calling the AOPA.

Hope that helps

 

[LAZYB]

...acting as PIC, logging PIC.

 

[Beetle007]

Labbats, Freightodogfred, and Bobbysamd....thank you for your helpful replies. LazyB, I’m still trying to figure yours out =) I was worried people might start posting angry responses about low time pilots because I forgot to mention my friends were ground instructors with the occasional perk of flying non-revenue flights. However, they were paid for these flights and didn't do them for free. So it’s not like they are cutting in line or part of a PTF gig.

I understand that whoever signs the dispatch release is acting as the PIC for the flight, and only one person may act as PIC. However, I’m trying to figure out what prevents a type rated FO from logging it as PIC under 61.51. For example, there are many situations in which the pilot who is logging PIC may not legally act as PIC. Some examples would be pilots receiving flight training for a high altitude endorsement, receiving instrument instruction while on an IFR flight plan, or receiving the flight training for a Tail-wheel endorsement. However, these pilots may log PIC because they are the sole manipulator of the controls and appropriately rated in the aircraft. Therefore, what prevents a type rated FO on 121 ops from logging PIC even though they aren’t acting as PIC? I still don’t see what REG prevents them from logging it and negates the 61.51 REG outlining the proper logging of flight time.

Maybe, the sole manipulator of the controls requirement is “impossible” to satisfy in an aircraft requiring two crewmembers. This would mean a type rated FO can’t log PIC on any aircraft certified for two crewmembers regardless of if it is being operated under PART 91, 121, 135 etc. If the Pilot Not Flying raises the gear…is the Pilot Flying the “sole manipulator” of the controls? Possibly not? This is the reason I am digging for the correct answer.

Also, what do captains Log flight time as during their Initial operating experience (IOE)?

Cheers,

 

[wil]

Beetle- When I was doing IOE on the CRJ I logged it as SIC. I'm typed, sitting in the left seat and my name is on the paperwork as Captain. But, was I really? I was in IOE and therefore not a "line Captain" with the company yet. I even got all the blocks filled in and my Fed ride done before I finished the 25 cycles and I still logged SIC cause the paper work was not turned in until I finshed my 25 t/o & landings. Call me old fashioned but why should I risk my career over 20 hours? When I'm called out to fly as a FO I log it as SIC since the is my role for the flight and I'm not listed as Captain. Now, there have been occasions when the Captain and I switched seats and we called the dispatcher to change the paperwork so I could get my PIC time. I always lean to being conservative on my times. Don't split hairs on logging hours which could end your career before it starts! For the legal interpretation I'll leave that for the bobbysamd and the others! Fly/log safe! Wil

 

[LAZYB]

How about...

LOGGING PILOT-IN-COMMAND TIME Western-Pacific Region of the FAA

First lets be clear: who is, or can be, pilot-in-command (PIC) and who may log PIC time are two separate issues and are only sometimes related.

 

[Timebuilder]

As Bobby said, you are legal under part 91 to log the sole manip time as PIC, which, as was just noted, is not the same thing as ACTING as PIC.

Isn't this great? Only a government entity could let this happen.

 

[Beetle007]

My personal opinion:

You are either Sole manipulator of the contols in an appropriately rated aircraft, or you are not. The REGs under which the operation is being conducted has no effect on this ?

How can you be the sole manipulator of the controls in an aircraft certified for two crewmembers regardless of PART 91 or PART 121?

What REG prevents you from LOGGING it under 121 if you can log it legally under 91? Because you dont have to be acting as PIC to log it.

 

[Timebuilder]

What REG prevents you from LOGGING it under 121 if you can log it legally under 91?

Because different standards define PIC for non 91 operations.

 

[msw]

Good question, Beetle007. So far, no one has actually answered it definitively. Where's AvBug when you need him?

 

[Timebuilder]

The regualtions that govern 121 and 135 are more stringent, and are more restrictive in many respects. Just because you are PIC in a part 91 operation does not in ANY way mean that you can act as PIC in a NON-91 operation.

I'll give you an example. Let's say I have a LR-JET type, and I am flying for the owner of the aircraft. Let's further say that his insurance is happy with my experience. I can be the PIC for that operation under part 91.

Now, that same airplane is on leaseback to the 135 charter company where I work. I know, bear with me. This is an example. Now, in oder to serve as PIC under 135, I must also pass a PIC checkride and hold a current 8410 for that position, and I must be assigned to the PIC postion by my company for that flight.

See?

 

[Beetle007]

"We" keeps discussing more stringent regs regarding ACTING as PIC for part 135 and part 121. However, no one has referenced a more stringent reg regarding Logging of PIC for a part 135 and part 121, or a Reg that supercedes the logging of PIC stated in 61.51.

To the best of my knowledge Reg 61.51 applys to ALL types of operations and deals with logging PIC ...not Acting as PIC. Therefore, any discussion of more stringent requirements for ACTING as pic for 121 and 135 do not conflict with the simple reg for Logging of flight time (61.51.)

 

[Timebuilder]

Well, I don't wish to be unkind, but when I had 240 hours I thought I knew what the regs said, and to me it was open to my interpretation.

It just ain't so. Otherwise, I would be eligible to just hop into a King Air as 135 PIC based on being appropriately rated in the aircraft, ie: Airplane, multiengine land.

OOps, there's that issue of the PIC checkride and the 8410 again.

You want references? Okay. Read part 135.

 

[bobbysamd]

Logging time

I was in IOE and therefore not a "line Captain" with the company yet. I even got all the blocks filled in and my Fed ride done before I finished the 25 cycles and I still logged SIC cause the paper work was not turned in until I finshed my 25 t/o & landings. Call me old fashioned but why should I risk my career over 20 hours . . .

(emphasis added)

For some people, twenty hours of jet PIC can make the difference between qualifying for a job and landing an interview or not. Having said that, these are EXTREMELY GOOD and well-thought-out comments from Wil, with which I agree wholeheartedly.

Log what you have a right to log, but it's better to err on the side of conservatism than to have questions raised at an interview or checkride.

 

[Timebuilder]

I logged NONE of my SIC training.

 

[Beetle007]

Wil… thanks for answering my question about IOE experience

Timebuilder….I have read your posts for a while now, and I respect you. However, try not to assume things about people (myself) based on purely flight time. I created this Flight Info profile over a year ago. Since then I have built a little more flight time. I have completed a 121 training program for a SIC (F.O.) checkout (AQP program)….and have taught ground school (systems and procedures) in a part 121 curriculum. However, I was laid off late last year during the downsizing of the training department, and hope to spend the next several years as a flight instructor learning as much as I can.

Also, I have read part 121 and part 135. There is no regulation I have found that treats logging of flight time for 121/135 as any different than part 91. I have only found Regulations that deal with Acting as PIC differently. I also agree that you can’t log PIC during 121/135 unless you are designated as PIC. However, I am trying to learn if this is based on regulatory reasons…or purely based on industry accepted standards/precedent.

And, my new question from a couple posts ago…..How can you be the “sole Manipulator of the controls” of an aircraft certified for more than one crewmember regardless of part 91,135, 121. Has the FAA ever defined “sole manipulator of the controls” as primary flight controls? Or does raising the Gear and other Pilot Not Flying duties prevent the Pilot Flying from being considered sole manipulator. If we can answer this question…it might answer the original question.

 

[sabreliner]

My $.02

In an aircraft requiring two crew members, it is only possible to have one PIC and one SIC. While I'm sure you could argue the regs all year long, stop and think about it. Do you really think a pilot with less than 1000 hours was acting as PIC in an Airbus? Even if typed, I highly doubt it. The other guy (probably with thousands of hours) was at all times the PIC, as far as the owner, that pilot, the insurance company, and the FAA are concerned. Your firends may think it cool to log the time as PIC, but trying to get anyone to buy it would be an excersize in futility.

When trying to get hired by an airline, they assess your PIC time the way that airlines assign PIC duties, not the way that part 91 pilots log it. Trying to squeak in some A320 PIC time will only get you a rejection letter. You'd be better off logging it as SIC time (which it really was) and pointing to that positive learning experience (which is all it was.)

While I know the ops were part91...

the definition of PIC under 121 and 135 ops is different than under 91. Under 91 it just says appropriately rated and sole manipulator. Under 121, the PIC is the person who is designated as in command of the aircraft. When I'm flying as an FO, even though I'm typed in the AC and am a current and qualified Capt, I log it as SIC because according to our regs, there can only be ONE PIC.

To really confuse the issue, consider that in our ops the Captain is not necessairly the PIC. This refers back to earlier posts about not logging PIC when conducting Captain IOE. Even though you are acting as and are designated as the Captain, and are rated in the AC, you are not the PIC. The IP, in the right seat, giving the IOE, is the PIC, and again there can only be one PIC. So, the person saying they wouldn't log that time as PIC was absoultely correct.

 

[Timebuilder]

I can only respond by both the nature of your question and the posted flight experience. If you have the 121 training, I would imagine that you already know the answer to your questions, and are looking for a specific line of regulatory directive that is clear and unequivocal. This is rarely the case in regulatory speech, and definitely not the case in 14 CFR.

Parts 121 and 135 specify standards for acting as PIC. Unlike the questionable, yet legal difference between acting and logging of part 91 PIC operations, there is no such distinction that I am aware of where these more restrictive operations are in play. As you may know, the most restrictive statutes apply in almost any legal or regulatory environment. This is the reason that you you find so many expressions of "conditions", such as "when X, then Y shall..." and "except when".

In 121 and 135, your logging is a record of service, and you are expected to appropriately log HOW you served. Were you PIC on that 135 flight? Then that is how your logbook should reflect the operation. If you the SIC, then log it as such, and so forth.

So, lacking any other indication to the contrary, you log PIC if you served as PIC under 121 and 135. You could say it is by convention, but you would be more accurate to say that there is no regulation in these parts that alters the common understanding of logging as a record of service. This is likely because so much more scrutiny is placed on which pilot is performing which part in a CRM environment, and how each pilot becomes qualified for each position.

Does that help?