Logging PIC jet time

[Beetle007]

Timebuilder

I think your last answer to my original question is probably the most logical and accurate I will find. I would also agree with sabreliner that you can only have one PIC in a multi-crewmember aircraft regardless of Part 91,121, or 135. Because, I would doubt you could argue being sole manipulator of the controls.

I am satisfied now =), and wont beating the dead horse anymore.

Thanks for your help guys,

 

[LAZYB]

The question was LEGAL logging of PIC

http://av-info.faa.gov/data/640otherfaq/pt61-16.pdf

http://av-info.faa.gov/data/640otherfaq/pt61-16.doc



ANSWER: Ref. §61.51(e)(1)(i); Yes, the pilot who holds a B737 type rating and is the sole manipulator of the controls may log the time as PIC time per §61.51(e)(1)(I); ". . . Is the sole manipulator of the controls of an aircraft for which the pilot is rated . . .". Yes, even when the pilot is employed in a Part 121 operation and is assigned as SIC, § 61.51(e)(1)(i) allows the SIC pilot who holds a B737 type rating to log the time as PIC time when that pilot ". . . Is the sole manipulator of the controls of an aircraft for which the pilot is rated . . .". Assignment of crew position and LOGGING of PIC time are totally separate and independent issues.

{Q&A-446}

QUESTION: If you are acting as second-in command of an aircraft that requires two pilots\, and are the sole manipulator of the contols\, can you log PIC for that portion of the flight?

ANSWER: Reference §61.51(e)(1)(i). The answer is yes the person may log it as PIC time, provided that person "Is the sole manipulator of the controls of an aircraft for which the pilot is rated;"



From reading your question, do not confuse "with being the legal Part 1 PIC" vs. "the logging of PIC time" under §61.51(e). In your scenario, the assigned PIC time would maintain his legal PIC status, as per §1.1, throughout the flight. However, for logging PIC time, as per §61.51(e)(1)(i), a pilot may log PIC time when that pilot ". . . Is the sole manipulator of the controls of an aircraft for which the pilot is rated."

Per §1.1:

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

And per §61.51(e)(1)(i):

"(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;"

{Q&A-243}

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.

{Q&A-288} [Replaces Q&A-228]

Acting as PIC

Logging PIC



A lot of you are arguing about what a Pt 121 airline may require/expect, not what's LEGAL.

 

[Beetle007]

LOL

I GIVE UP.

 

[Timebuilder]

If those links are to the FAA FAQ written by Lynch, I have to point out that he is often at odds with the understandings of a great many people, including FAA inspectors, DPE's, and POI's.

More importantly, he is not authorized to make ANY interpretations of the applicability of 14 CFR. Only the Office of Chief Counsel can do that.

I have yet to see anything that puts part 61 in a premminent position to permit logging that is contrary to the requirements of 121 and 135. This may require an inquiry to the chief counsel office to settle this, but I would venture my best guess that logging PIC in a commercial, certificate operation in a way that is contrary to the very nature of the operation, or the title of the position held by the crewmember, would be nothing other than a falsification of the flight record.

If you take Mr. Lynch's word, and he is wrong, you have no recourse whatsoever.

 

[bobbysamd]

Lynched by Lynch

If those links are to the FAA FAQ written by Lynch, I have to point out that he is often at odds with the understandings of a great many people, including FAA inspectors, DPE's, and POI's

. . . and experienced pilots and flight instructors, too.

If you take Mr. Lynch's word, and he is wrong, you have no recourse whatsoever.

Amen.

You have to follow black-letter law. I use that term often. It is a legal term of art which means, generally, what is accepted and settled law. Office of Chief Counsel opinions might approach the concept of black-letter law. Court cases that interpret the regs are better examples.

If you tell an ASI or ALJ that you relied upon John Lynch FAQs to base a decision, you'll be laughed right out of the courtroom.

 

[Beetle007]

I think an important issue here is that most airlines and insurance companies have different rules on flight time they will accept. "Black-letter law" would be different for each airline. If I were a type rated FO at a regional, I would get a letter clarifying if it was legal (or not legal) to log PIC as a type rated FO flying the airplane under PART 121. If the FAA said it was Legal, I would keep that letter as documentation of the legality, and start a seperate column in my logbook for (PIC as FO.)

This might seem rather retarded and pointless, however I have learned you never know what will happen next. You might get laid off from your regional gig, and get a good contact for a small 135 or 121 operation. This contact might like you a lot and want to give you the job as long as you meet the minimums for insurance. This contact tells you (X) number of hours of PIC are required to meet minimums for insurance purposes. You show him your letter from the FAA and your (PIC as FO) column of your logbook and they might just accept this. More than likely, they would call the insurance company to verify it as acceptable. They might not accept it, but more importantly, they might.

My point is. There are Many 121 and 135 operations and Many insurance companies. If the FAA allows you to legally log it, I would log it for what it really is (PIC as FO) or something similar.
Log your flight time according to the FAA regulations (usually the least restrictive), then allow the employers and insurance companies decide what they will accept.

 

[bobbysamd]

Black-letter law defined

"Black-letter law" would be different for each airline.

No. Black-letter law has nothing to do with airline hiring policy. It is a legal term of art: "An informal term indicating the basic principles of law generally accepted by the courts and/or embodied in the statutes of a particular jurisdiction." Black's Law Dictionary (Abridged 6th edition, 1991), at p. 116.

Hope that helps.

 

[LAZYB]

...YOU CAN'T HANDLE THE TRUTH

Legal Interpretation # 92-40

June 5, 1992

Dear Mr. Butler:

Thank you for your letter of March 14, 1992, in which you ask
questions about logging pilot-in-command (PIC) and
second-in-command (SIC) time when operating under Part 121 of the
Federal Aviation Regulations (FAR).

Your letter presents the following scenario: under a Part 121
operation, the air carrier has designated a pilot and a co-pilot.
The pilot is the authorized PIC and the co-pilot is the
authorized SIC. During the course of the flight, the SIC is the
sole manipulator of the controls for one or more legs.

You ask two questions. The first asks whether the pilot
designated as PIC by the employer, as required by FAR 121.385,
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.

Your second question asks if the SIC is flying the airplane, can
he 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 121 operations, at least as SIC. The
answer is yes.

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 or 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) 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 both your questions. 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 121.385, 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, under a 121 operation you 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 may not be qualified to serve as PIC
under Part 121.

An example of this difference is FAR 121.652(a), which raises IFR
landing minimums for pilots in command of airplanes flown under
Part 121 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 121 PIC.

We hope this satisfactorily answers your questions.

Sincerely,

/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division



http://www.apocalypse.org/pub/u/amb/pic-time.txt

The following information is a compendium of legal interpretations culled from the files of the FAA's Chief Counsel's Office which pertain to the subject of logging of flight time.

 

[stillaboo]

Good discussion, but it should be in the FARS section. Anyway . . .

I guess the legal is sorted out with the last post (never say never, though).

But, in all honesty, when would someone possibly log PIC of a 'Bus and only use it to represent legal PIC, since it is useless for insurance or interviewing? I don't think you could ever show up at an interview (or insurance review) with 1000 hours Turbine PIC and all of it (or any of it) be used to satisfy the employer's need to see you have experience commanding an aircraft. Being the sole manipulator of the controls is the letter of the law, not the spirit. And, I'd argue that any airplane that cannot be operated single pilot cannot be flown soley by one person's manipulation of the controls. The letter of the law would require you to do everything (including the flaps and gear). What, do you subtract .00001 hours for each time the CA touches the gear or flaps?

Shirley, you can't be serious!

-Boo!

I believe I've strayed off-topic. Sorry.

 

[Timebuilder]

Gee.

I'm still thirsty for milk...

 

[Beetle007]

I think the FAA general Council letters are pretty clear about the spirit of the law. They tell us how to log it legally. If anything, I think the "spirit" of the law is to log it according to FAA standards, but in a manner that can be destinguishable if desired. PIC obtained while manipulating the contols should probably be destinguishable from PIC obtained while ACTING as PIC. Anyone who doesnt log flight time according to FAA standards is a victim of their own ignorance.

It would disturb me if an airline frowned upon logging it according to FAA standards, as long as each type of flight time was destinguishable for their own interpretation. To expect anything else, would be an insult to the FAA and Pilots who truly seek an understand of the regulations.

 

[freightdogfred]

Dude, you are reading into the regs what you want to as it suits your needs to log 121 PIC..... The intent of logging 121 pic is when you check out as captain, you begin logging your time as PIC. Your sematics as "manipulator of the controls" while being type-rated allows you to log the time as PIC is absurd.... But hell. log it if you want to. Log some SR-71 time if you want to as well.
If some Feds interpretation suits you fine. Just remember when you show up at an interview they will ask for your training records, and if you show a bunch of 121 PIC time in a Parker P-51, yet no training records to support it (captain's sim check and IOE paperwork) you're going to look pretty silly....Perhaps you can pull out all your documentation that has been provided on this thread to support your position but airlines have their own idea what constitutes as PIC. Good luck, what ever you decide to log.

 

[Timebuilder]

It would disturb me if an airline frowned upon logging it according to FAA standards, as long as each type of flight time was destinguishable for their own interpretation. To expect anything else, would be an insult to the FAA and Pilots who truly seek an understand of the regulations.

More than one airline guy has told me to use the FAR Part 1 standard for PIC time. For instance, I can legally log PIC time as sole manipulator of a King Air. However, under the part 1 definition I am not PIC. I can't sign out or rent the aircraft, and this is reflected by my current inability to be insured by anyone for the PIC position in the airplane. Same situation in the Lear, where I DO have expereince.

I think what this comes down to is really the difference between things that you CAN do versus things that you SHOULD do as a wise, informed person.

Having a special column for Airbus PIC time might make for a humorus moment for a low time pilot at an interview, but I wouldn't point to it with a straight face and intone "Yes, I do have PIC time in the Airbus".

As for the term "spirit" of the regulations? The "spirit" of any recording of values is one of acccuracy and faithfulness to the events. In accounting, this is a basic principal of ethics, and the reason that Anderson Consulting fell so far and so hard after Enron. In logging your time, everyone expects young pilots to have a few hours of PIC time where they are logging the time as permitted under part 61. As your experience grows, I think this kind of PIC logging becomes more questionable, as if the pilot is somehow unaware of the importance of the Part 1 PIC definition, and its importance to the industry. Truthfully, I find the Chief Counsel letter shown here by LazyB to be a surprise. But then, a great many things done by government bodies are surprising and inexplicable.

Rather than letting the "letter" of the regulations be your guide, I'd say that the "spirt" of accuracy and faithfulness should be your appropriate guide in these matters.

 

[DitchDriver]

I logged NONE of my SIC training.

Are you serious? That's really odd. Was it in two pilot airplane? (I won't log it either if it was for SIC position in a 172).


Training flights were conducted under part 91 and if the airplane was certified for two pilots, then you were required to be there. Therefore you were allowed to log time under 61.51 (f)(2), see below.

In fact, 61.51 (a) requires that you log your training time. I agree, it is only for "certificate, rating, or flight review of this part" (1) and "recent flight experience" (2). I think 61.55 (b)(2) requirement fits recent flight experience category.

And for "common sense" logging, how do you explain to someone looking at your logbook that you started acting as SIC without any training logged? I am sure the company CYA'ed by having its own log of your training flights.

61.51:

(a) Training time and aeronautical experience. Each person must
document and record the following time in a manner acceptable to the
Administrator:
(1) Training and aeronautical experience used to meet the
requirements for a certificate, rating, or flight review of this part.
(2) The aeronautical experience required for meeting the recent
flight experience requirements of this part.


(f) Logging second-in-command flight time. A person may log second-
in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command
requirements of Sec. 61.55 of this part, and occupies a crewmember
station in an aircraft that requires more than one pilot by the
aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if
an instrument rating is required for the flight) for the aircraft being
flown, and more than one pilot is required under the type certification
of the aircraft or the regulations under which the flight is being
conducted.

 

[Timebuilder]

Training flights were conducted under part 91 and if the airplane was certified for two pilots, then you were required to be there. Therefore you were allowed to log time under 61.51 (f)(2), see below.

I was not yet qualified to serve as a required crewmember, and the training was permitted since the company had an FAA approved training program. I could not log the training as either PIC or SIC. As I mentioned above, I could have logged this simply as flight time, but I felt that since this undifferentiated time was being tracked by the company for all official purposes, there was no need to log it in my book.


The record of training was a separate set of documents, and the completion of the training was the completed 8410. I was not required to put any of the training in my logbook, and the check airman was not required to sign the logbook attesting to the training, since he did so on training documents.

I DO have copies of all the documents.

 

[Beetle007]

Ok, I think people misunderstood my purpose for understanding this issue. I have found that All flight instructors have different opinions regarding flight time and how to log it. In order for me to give my students their moneys worth, I need to be able to have them log time according to FAA standards, and provide accurate information about logging flight time in the future. Some Instructors don't let their students log PIC during:

1. Instrument training in actual instrument conditions
2. training for an endorsement
3. training when the student isnt current via Flight Reviews and Landings

The reason Flight Instructors don't allow their students to log this PIC time, is because they have a lack of knowledge regarding this issue. Therefore, they "play it safe" and have their students log it conservatively. Students have paid for your services, and you should allow them to get the full potential out of it.

After doing all my research, I have come to the following opinion.

1. You can log all flight time strictly according to FAA legal
interpretations and FAA Regulations in your logbooks

2. Make sure all questionable flight time is separate from commonly accepted flight time. It might even be desirable to have a seperate logbook for Legal flight time that isnt generally accepted. That way airlines dont laugh when going through your logbook. However, it is still benefitial to keep track of ALL legal flight time because you never know when it might come in handy. It might one day allow you to qualify for something that would not have been possible with your strictly "industry acceptable" flight time. However, if you think it is unlikely this would ever be a scenario, feel free to only log "industry acceptable" flight time

3. On all Applications for pilot employment (or other similar reasons), only provide flight time that you believe will be accepted by the company in which you are applying to. In other words, use good judgment in determining what type of flight time the company intends you to provide on the application. To provide anything else borders on "fraud."

Cheers,

 

[bobbysamd]

Letter of the law v. the spirit of the law

I think what this comes down to is really the difference between things that you CAN do versus things that you SHOULD do as a wise, informed person . . . . As for the term "spirit" of the regulations? The "spirit" of any recording of values is one of acccuracy and faithfulness to the events . . . .

(emphasis added)

That's the point I've been trying to make during some of the recent discussions on logging time, in particular the issue of a safety pilot logging SIC as opposed to PIC.

Of course, everyone is starved for certain types of flight time at various stages of a career, and people will stretch every possible point to be able to log it. Of course, a logbook is a record of flight time. But it is much more than that. A logbook is a diary and chronicle of one's overall flying experience. That's what will be looked at during the interview.

 

[stillaboo]

In other words, use good judgment in determining what type of flight time the company intends you to provide on the application. To provide anything else borders on "fraud."

So, if even YOU think it's fraud, then why do you want to put it in your logbook, even if it's legal?

The issue here is you're a CFI and you're asking the question as if you want the CFI answer; 'if it's legal, it must be right'. CFI's don't command 'Buses. 121 typed ATP CA's do (incidentally, these are the same guys who will be looking over your logbook for insurance and airline interviews). That's why you're unhappy with the legal answer not being the answer we're all siding with.

If you want to log this time, I'd keep 2 log books. 1 with time that is only for your own personal ego stroking (Part 61 legal), the other with time that is actually relevant (the 'spirit' of Part 1) to the rest of the world.

-Boo!

 

[Beetle007]

I don't think pilots should keep two logbooks for ego stroking purposes. That is a rather condescending remark. They should keep ALL legal time recorded for "What If" purposes. And yes, two logbooks is probably the smartest way to do it. At an interveiw, you dont want them questioning the validity of your flight time. That being said, I 100 percent agree that it is more practical to ONLY log industry acceptable flight time in a single logbook. It is easier and more practical, but should result from intential purposes and not ignorance.

If you want me to name all the "what if" scenarios I have actually seen occur, we would be here for a while. You probably wouldnt even believe half the stuff I have seen legally happen. A couple times the insurance companies freaked out, but they eventually came to an agreement.

So "What if" you get laid off from your regional and your buddy wants you to fly for his charter operation. But, the insurance company requires 3000 jet PIC or something similar to fly as a captain. And, "what if" they are willing to accept your legally logged PIC time during your tenure as a type rated FO at the regional, even though most Airlines don’t intend for you to provide this time on your application.

Also, many commercial students (being taught by CFIs like myself,) will one day become the part 121 captains operating the larger equipment. When will they learn proper logging of flight time? Via cockpit chit chat and peronal opinions? or should they have already learned this information during their primary commercial training from their original CFIs? I don’t want my students asking their PART 121 Indoc instructor how to log PIC time....do you? If they have to ask this question, I failed as a flight instructor.

When I asked the original question, the proper answer should have been:

"Yes it is legal according to FAR's, but would most likely be frowned upon if used on applications or discussed during an interview..and isnt worth the risk of logging."

But, we obviously didn't have a good understanding of logging flight time.


Cheers

 

[flx757]

If you want me to name all the "what if" scenarios I have actually seen occur, we would be here for a while.

I have a couple--

What if Spartacus had a Piper Cub?
What if Eleanor Roosevelt could fly?