Logging PIC Part 121

[Bubba Dog]

I work for a part 121 carrier as a first officer on the A320 and B737 . I have a type rating in both aircraft. While I am the sole manipulator of the controls can I log PIC time.

 

[j41driver]

As far as FAR 121 goes, I would say that unless you are assigned by the company as the PIC of the flight you should log the time as SIC only.

 

[CRJ200FO]

We were just having this conversation in the crewroom the other day. The general concensus we all came up with was that in 121 ops, you can only log PIC time if you are the one that signs the release. Only the captain can log the PIC time. I'm sure that you could find a FSDO that would have a different opinion though. If you ever plan on applying to a different airline though, the interviewers would probably have plenty of questions about it. I would stick to logging SIC.

 

[A Squared]

>>>>>>As far as FAR 121 goes, I would say that unless you are assigned by the company as the PIC of the flight you should log the time as SIC only.

Where exactly does it say this in Part 121?

As far as I know there's nothing in Part 121, nor should there be. Part 121 addresses airline operations, not personal record keeping. Personal record keeping is addressed in Part 61, specifically 61.51. According to 61.51, yes, you may log PIC in an aircraft for which you are rated when you are the sole manipulator of hte controls.

I think the real question is *should* you. I guess that would depend on what your reasons are for logging the time. The FAA accepts PIC time logged in this manner for pilot qualifications and certification requirements, but with 7500 hours, and ATP and 4 type ratings, it think it is sfae to assume that terrell has logged enough PIC for any FAA requirement I can think of. So, the only other reason to log PIC is for qualifications for employment. In that regard, it is my understanding the most major airlines will only accept PIC time which meets the part 1 definition.
I think that most airlines will only want to see PIC time in which you were actually the pilot in command.


regards

 

[The FNG]

I couldn't agree more!

 

[DarnNearaJet]

Sorry to spoil all your fun, but just because you are type-rated in an aircraft does not make you PIC in that aircraft simply by virtue of the fact that you are sole manipulator. Under FAR 121 there is only one PIC. Period. If you are not assigned to be PIC on that flight, then you are not the PIC. You can't simply say, "Well, it was my leg, and I played with the A/P, and I am typed, therefore I am PIC."

All technicalities aside, it is also simply dishonest. The FAR's (and most FOM's) put an incredible amount of responsibility on the PIC. The PIC is basically responsible for everyone's actions, including the F/A to a certain extent. The logbook, mechanical history, MEL compliance, FOM compliance, FAR compliance, ATC compliance -- all this responsibility rests with the PIC (Captain.)
For someone to sit in the right seat and surruptitiously log that unbeknownst to the genuine Captain is ... sort of like larceny. Think of it as theft of recogniztion without resonsibility.

Two questions must be asked:

1) Who signed the logbook and release under "PIC."
2) If someone screws up, who are they going to hang?

Now a Part 91 ferry flight is a different story.

 

[The FNG]

The original question was, "While I am the sole manipulator of the controls can I log PIC time."

61.51 says he can: (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;

I wouldn't say it's dishonest, but I'd be prepared to support an answer if asked whether it's logged IAW 61.51 or 1.

 

[Bubba Dog]

Thanks everyone for your inputs. The question I was trying to anwser is in regards to a FAA Air Carrier Operations Inspector application concerning the statement;

I have had Pilot-in-Command experience in large aircraft(over 12,500 pounds gross takeoff weight) in the last three years.

Yes or No

I am still not sure how to anwser this.

Thanks
Terrell

 

[flx757]

Mr FNG..

You only quoted a portion of 61.51(e). The part you left out is the part that applies in this case. Your quote mentioned a "recreational, private or commercial pilot", which does not apply.

In order to act as PIC under FAR 121 in a B-737 or A-320, which is what terrell was inquiring about, you need an ATP. Part 61.51(e)(2) states that an Airline Transport Pilot may log as pilot in command all of the flight time while acting as pilot in command of an operations requiring an airline transport certificate.

No mention of "sole manipulator". Under FAR 121 there is a designated PIC. He is listed on the flight release. He signs the flight release. He is the PIC.

So, terrell...unless you have pilot in command experience as defined above, then you must answer the question with a "no".

 

[Bubba Dog]

Thanks for the info flx757.

terrell

 

[A Squared]

Darnnearajet,

No, you're not spoiling anyone's fun, because quite frankly, you're completely incorrect.

Apparently you are not aware that the FAA makes a distinction between *acting as PIC* and *Logging PIC* This is reflected in the text of the regulations, and in legal interpretations which state the difference explicitly. For the FAA's purposes, PIC may be *logged* perfectly legally when you are not *acting* as PIC. This is recognized and accepted. Don't take my word for it, here's a link to an official FAA chief counsel interepretation which states exactly that.

http://www.propilot.com/doc/legal2.html

Like it or not, them are the facts. You may call it dishonest, larceny, theft, or whatever pejorative terms you like, but that doesn't change the fact that you're wrong. Your view of it is just an opinion, which isn't particularly relevant.

On a personal level, my opinion probably is more aligned with yours. It makes sense to me that PIC should only be logged when you are *acting* as PIC, but that's just our opinion. If you and I were writing the regulations, it would be a different story, but we aren't. Don't let your opinion of what *should* be legal cloud your understanding of what *is* legal.


terrel,

your right, all this still leaves your question unanswered. My gut feeling is that they want to know whether you have *acted* as pilot in command, but one can't be sure. I would take the most conservative route


regards

 

[Bubba Dog]

Thanks everyone for input on this ever controversial subject. I will just have to sit back and wind the clock some more.

 

[flx757]

terrell,

I wouldn't stress it too much. You seem MORE than qualified for an FAA Air Carrier Ops Inspector position.

 

[A Squared]

flx757,

you apparently posted your previous post while I was still typing mine.

You raise an interesting point with your comment about the "recreational, private or commercial pilot" It doesn't however, say that an ATP may not, and Part 61 does say that an ATP has all the priveliges of the holder of a COmmercial certificate whti an instrument rating.

At any rate, the legal opinion which I posted the link to appears not to support your view that "logging while not acting" is limited to non-atps.

cunrur that terrel seems to have plenty of qualifications, just answer no, then there is no possibility of appearing to be mis-representing his experience.

regards

 

[avbug]

14 CFR 61.51(e)(2) does not limit an ATP to logging pilot in command time in a specific manner. Rather, it provides a means by which an ATP may log time as PIC when not flyign the airplane. This is differentiated from the basic privilege of sole manipulator spelled out in 61.51(e)(1). It extends more lattitude to the ATP; it doesn't restrict the ATP.

As A Squared pointed out, there is a big difference between logging pilot in command time, and acting as PIC. One may be acting as PIC, but be unable to log PIC time under certain rules. One may log PIC time while not the designated or acting PIC of a given flight. In some cases, two pilots may log PIC at the same time.

Under 121.437(b), both pilots do not need to posess an ATP certificate. Only the pilot in command needs to posess an ATP certificate. The SIC may hold a commercial certificate, and is eligible (if qualified in the airplane according to category, class, and type) to log time as pilot in command when acting as sole manipulator of the controls, in accordance with 61.51(e)(1)(i).

The passage already discussed, regarding the ATP certificate, permits pilot in command designated by the certificate holder (who is required to hold an ATP certificate) to log the flight time as PIC regardless of who is flying. It doesn't restrict the designated PIC/ATP, but enpowers the ATP to log the time even though not flying the airplane. It speaks to his experience, authority, and responsibility in acting as pilot in command.

121.385(c) provides that the certificate holder shall designate the pilot in command. The pilot in command shall remain the pilot in command for the duration of the flight (unlike operations conducted strictly under the auspices of part 91, in which the authority of PIC may be traded at will be common agreement between the crew).

While legally a SIC may log sole manipulator time, there is little reason to do so. By general consent, the industry doesn't recognize time spent as SIC under an operating certificate to be pilot in command time. This lends the appearance of padding one's logbook, and not understanding the legality or ettiquette of logging time.

When one is a designated SIC, one should log SIC only.

For the purposes of meeting the FAA inspectors qualifications, I would show any time spent as sole manipulator of the controls, as pilot in command time. This doesn't mean you need to change your logbooks, but you can definitely answser the question yes, in the affirmative. Should an employer ask, I would identify all time operating under a 121 or 135 certificate, when not designated the pilot in command by the certificate holder, as SIC.

 

[Bubba Dog]

Thanks AVBUG for the information.

Terrell