Logging XC Time

[Vik]

Island Air is 800/200. Thats my first choice over Xjet.

...there's hope for me yet

-mini

 

[midlifeflyer]

It seems to me that the flight instructor who gives the training should be the one who "allows or permits" the logging of PIC time on a dual flight.

I've been searching, without success, for the part where the FAA says or implies that a CFI has the right to override what the FAR says a pilot is authorized to write in his or her own logbook, with the exception of what constitutes "training received".

 

[nosehair]

*all* dual time after your Private is not PIC.

FAR 61.51(e) "A Recreational, Private, or Commercial Pilot =may= log PIC...during that time which he is the *sole* manipulator of the controls..."

Webster's Dictionary:
The word "may" : "To be allowed or permitted to"
The word "can" : "Possesion of a given power, right, or privilege"

It seems to me that most of the "time-builders" prefer to read the word "may" as if it were the word "can".

FAR 61.189(a) "A flight instructor *must* sign the logbook..."


...back to 61.51(e) "....sole manipulator of the controls." I am of the opinion that, when I am giving dual to a rated pilot, and he is actually capable of flying the airplane, all of it, the flying, the radios, the planning, the trafic, etc, and I am along for additional training, sure, he can log PIC on my signature.

Midlife...

These excerpts are an attempt to "imply" the idea of the proper logging of PIC.

Do you see the difference between "may" and "can" ?

Do you see the responsibility and authority of the instructor who "must" sign the logbook ?

And if you continue to see "may" as "can", then you should at least acknowledge that, in the case of an unskilled pilot, he would *only* be allowed to log the actual time he was the "sole manipulator*. And that's what I'm really talking about. If I can't leave the controls alone - in other words, if I can't solo you, you can't log it PIC.

 

[midlifeflyer]

Do you see the difference between "may" and "can" ?

I do. "Can" talks about ability. "I =can= log the time" means that I have the physical and mental skills and equipment to write it down in my logbook. "May" involves permission. I =may= log the time" means that something or someone with authority gives me permission to write certain things in my logbook.

Either way, FAR 61.51 (e) gives "A recreational, private, or commercial pilot" the permission to log pilot-in-command time under certain circumstances. Not the pilot's CFI.

Do you see the responsibility and authority of the instructor who "must" sign the logbook ?

Definitely. A CFI has both the authority and responsibility to endorse instruction given. That means if a student writes "power-on stalls" in the remarks of a logbook entry, or enters 1.0 "flight training received" or "0.5 ground training received" I will not sign it unless it is true. But that does not give me veto power over legitimate flight time entries. (I'm defining "legitimate" as "authroized by the regulations" not as "stuff I like")

you should at least acknowledge that, in the case of an unskilled pilot, he would *only* be allowed to log the actual time he was the "sole manipulator*. And that's what I'm really talking about. If I can't leave the controls alone - in other words, if I can't solo you, you can't log it PIC.

I acknowledge that if the CFI is handling the controls, the pilot is not the sole manipulator and may not log that part of the total flight time. But that's pretty objective and I don't acknowledge your authority to add a subjective test that says "If the pilot =is= the only one on the controls but I don't like it, the pilot is not =really= the only one on the controls"

For better or for worse, the FAA has consistently taken the view that "logging" PIC has absolutely nothing to do with proficiency, currency, or ability. The language that authorizes to write numbers on a piece of paper while sitting at a desk with a beer in the other hand contains nothing like "but only if the pilot did a good job." I don't have to like it and it would have been nice if the FAA had chosen language other than "pilot in command" to describe time that may be counted toward certificate ratings and currency. But that's the way it goes.

Sorry, but "I don't like the rules, so I'll make up my own" and "The rules permit someone to [fill in the blank of your choice], but I won't let them" is =way= too authoritarian for my tastes.

 

[nosehair]

I do. "Can" talks about ability. "I =can= log the time" means that I have the physical and mental skills and equipment to write it down in my logbook. "May" involves permission. I =may= log the time" means that something or someone with authority gives me permission to write certain things in my logbook.

Nope. That's your own personal definition. Mine is copied word for word from Webster's dictionary. But I'm not trying to mince words...that was a lame attempt to do something like what a lawyer would do in legalese.

Either way, FAR 61.51 (e) gives "A recreational, private, or commercial pilot" the permission to log pilot-in-command time under certain circumstances. Not the pilot's CFI.

Why not? Why cannot the CFI have a say in those "circumstances"?

Definitely. A CFI has both the authority and responsibility to endorse instruction given. That means if a student writes "power-on stalls" in the remarks of a logbook entry, or enters 1.0 "flight training received" or "0.5 ground training received" I will not sign it unless it is true. But that does not give me veto power over legitimate flight time entries. (I'm defining "legitimate" as "authroized by the regulations" not as "stuff I like")

It's not "stuff I like", Midlife, it's how I honestly believe the regulation was meant to read. "Sole manipulator", hmmmm...just exactly what does that mean? Each one will have an opinion on that. And the boys in Washington are not gonna even try to make a definition...it's not high enough on the list, and really, we're making much to do about nothing.

I acknowledge that if the CFI is handling the controls, the pilot is not the sole manipulator and may not log that part of the total flight time. But that's pretty objective and I don't acknowledge your authority to add a subjective test that says "If the pilot =is= the only one on the controls but I don't like it, the pilot is not =really= the only one on the controls"

How can you say that? I didn't say that. Not the way you re-wrote it. I'm talking about "touching" the controls - actually helping a bit with rudder inputs during flare to avoid a sideload touchdown, or a little bit of elevator to avoid a hard or nosefirst landing, etc,etc,etc...

For better or for worse, the FAA has consistently taken the view that "logging" PIC has absolutely nothing to do with proficiency, currency, or ability. The language that authorizes to write numbers on a piece of paper while sitting at a desk with a beer in the other hand contains nothing like "but only if the pilot did a good job." I don't have to like it and it would have been nice if the FAA had chosen language other than "pilot in command" to describe time that may be counted toward certificate ratings and currency. But that's the way it goes.

No, it hasn't been "consistant". I don't know when the idea that dual time was loggable as PIC time, but there was a time when 61.51 did not exist. Or at least exist in it's present form. PIC time was acting PIC time. Period. X/C time did not have a distance requirement. I think the original Private and Commercial X/C requirements were to have at least one long X/C of a certain distance. The general assumption was that you used navigational skills to get from A to B and that was X/C. The FAA *trusted* the CFI to determine what was X/C, and what was PIC.
That's gone. The trust is gone. We have definable parameters of what is PIC and X/C. Defined by the people who do not do the training. And even if it was me defining, I, nor anybody else, could make a rule that applies to each seperate case. The only person who can be trusted to make those decisions is...the flight instructor. Is the intended training being accomplished in a manner that produces safe, competent pilots? That is the question.

How did you ever get into the mindset that FAR language "authorizes you to write numbers in your logbook while sitting at a desk with a beer in your hand"?
I know you have used that analogy to explain the current mindset - and that's what it is, MIdlife, a "Mindset" - to mindlessly write all dual flights as PIC as long as you are hanging on to the controls.

When a person is getting into a new airplane, he is a student. I am a student when I check out in a new airplane. That's student time. Not PIC time.
You know it, and I know it, and every instructor knows it. But you have kneeled to the popular opinion that 61.51 says you "can" log PIC. Nobody wants to listen to someone who reads the "may" word.

Sorry, but "I don't like the rules, so I'll make up my own" and "The rules permit someone to [fill in the blank of your choice], but I won't let them" is =way= too authoritarian for my tastes.

Webster's Dictionary: Ethics: 1) Principles of right or good behavior. 2) A system of moral principles or values. 3) The study of the general nature of morals and the specific moral choices an individual makes in relating to others.

Sometimes legalese and ethics don't mix. You have to make your own choices.
I've said all I want to say on the subject for now, Midlife. I enjoy "bantering" with you, and I know I cannot get "trust" back into the system, and we have to eat it as it is.

 

[SATCFI]

I believe that if you look at the part 61 FAQs, you'll find that Mark's interpretation is correct. Nosehair, I've never hear anyony interpret it as you have.... Bet you have lot's of arguments on that one...ever convinced anyone?

Check out this legal opinion:



OCT. 28, 1980


WINSTON SCOTT JONES


Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.

Section 61.51(c)(2)(i) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or
2. Is the sole occupant of the aircraft; or
3. Acts 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.

Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received.

Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(i) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).

There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.

You request interpretations of these regulations for situations in which:

1. The purpose of the flight is instruction in advanced maneuvers.
2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.
3. The purpose of the flight is instrument instruction actual IFR conditions.
4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.
5. The purpose of the flight is transition from tricycle to conventional landing gear.
6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).
7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.

We trust that this discussion answers your questions.

Sincerely,


EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division

 

[PropsForward]

It fired me up enough to make another attempt at explaining that *all* dual time after your Private is not PIC.

Yes, you are right. An unrated instrument student in IMC cannot log PIC.
An unrated multiengine pilot working on getting his Multi add-on cannot log PIC.
A SEL student working on a SES add-on cannot log PIC.
etc, etc, etc...

However,
The when the student rated in the aircraft (current and qualified), then YES the student can log PIC time in addition to DUAL.

Just curious, did you come up with the 5 year old "may I" / "can I" by yourself, or is there a greater force (your flight school / old instructor) at work here.

 

[100LL... Again!]

Where do you get that from?

 

[SATCFI]

PropsForward,

All correct except there is no prohibition on an instrument student logging PIC for the time he is the sole manipulator of the controls in an aircraft he is appropriated for. So a private pilot working towards his instrument rating, flying with a CFII in instrument conditions, as the sole manipulator of the controls CAN log PIC. Re-read 61.51(c)(2)(i). It says that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or

Notice it says nothing about the conditions of flight, only that the pilot be rated in the aircraft.

Cheers,

SATCFI

 

[S2R]

Whats up Brad?

 

[avbug]

Here we go again.

Yes, you are right. An unrated instrument student in IMC cannot log PIC.
An unrated multiengine pilot working on getting his Multi add-on cannot log PIC.
A SEL student working on a SES add-on cannot log PIC.
etc, etc, etc...

A private pilot without an instrument rating, who holds an airplane category rating with a single engine land rating, who is undergoing instrument instruction in instrument conditions, can log PIC in instrument conditions. Period.

The pilot is rated for the airplane. The pilot holds category and class ratings for the airplane. Your example tries to confuse this with a pilot who is not rated for the airplane; a multi engine student without a multi engine rating, a seaplane student without a seaplane rating. This is not at all the same as an instrument student without an instrument rating.

In the case of the instrument student, so long as he or she is rated in the airplane, he or she is entitled to log PIC in actual instrument conditios if the flight is conducted in such. He or she may not be able to act as pilot in command under IFR or in conditions less than VFR, but that has no bearing on the ability to log PIC. This is borne out by numerous legal interpretations provided by the FAA Chief Legal Counsel.

As for endorsement of a student's logbook; an instructor's endorsement is a testament to the instruction given. It is not within the purview or duty of the instructor to define what the student can log so far as PIC. The instructor is endorsing the logbook for instruction given, "Dual." If the student wishes to note pilot in command time, then let the student do so. As an instructor, one is obligated, per 14 CFR 91.189(a) to sign the logbook of each person to whom he or she has given training. This does not mean that the instructor takes over the student's logbook. It means that the instructor places a signature to identify the instruction given. Period.

If the student is rated in the airplane and wishes to log PIC, then let the student. That is the student's logbook, that is the students business. Your business is providing flight instruction. You must sign for that, and that alone. It's not your logbook; it's the students.

Don't assume either that because you're the flight instructor, you're the pilot in command. I've met far too many arrogant little wannabees who think that their instructor certificate is a pilot certificate, and it's not. It grants no flying privileges, requires no medical certificate, requires no pilot recency of experience, no flight review...because it's a teaching certificate not a pilot certificate. The assumption that one holds some higher office as a flight instructor is ridiculous. If you're truly acting as pilot in command on the flight, then so be it. But don't make the assumption that because you have a flight instructor certificate you're the pilot in command, and don't be presumptive about what a student, especially a rated student, may place in his or logbook.

 

[midlifeflyer]

No, it hasn't been "consistant". I don't know when the idea that dual time was loggable as PIC time, but there was a time when 61.51 did not exist.

A rule that has existed and been officially interpreted the same way for more than 20 years (see SATCFI's paste) is good enough "consistency" for me.

And Merriam Webster is good enough for me also:

==============================
Main Entry: 1can
Pronunciation: k&n, 'kan
Function: verb
Inflected Form(s): past could /k&d, 'kud/; present singular & plural can
Etymology: Middle English (1st & 3d sing. present indic.), from Old English; akin to Old High German kan (1st & 3d singular present indicative) know, am able, Old English cnAwan to know -- more at KNOW
transitive senses
1 obsolete : KNOW, UNDERSTAND
2 archaic : to be able to do, make, or accomplish
intransitive senses, archaic : to have knowledge or skill
verbal auxiliary
1 a : know how to <she can read> b : be physically or mentally able to <he can lift 200 pounds> c -- used to indicate possibility <do you think he can still be alive> <those things can happen> -- sometimes used interchangeably with may d : be permitted by conscience or feeling to <can hardly blame her> e : be made possible or probable by circumstances to <he can hardly have meant that> f : be inherently able or designed to <everything that money can buy> g : be logically or axiologically able to <2 + 2 can also be written 3 + 1> h : be enabled by law, agreement, or custom to
2 : have permission to -- used interchangeably with may <you can go now if you like>
usage Can and may are most frequently interchangeable in senses denoting possibility; because the possibility of one's doing something may depend on another's acquiescence, they have also become interchangeable in the sense denoting permission. The use of can to ask or grant permission has been common since the 19th century and is well established, although some commentators feel may is more appropriate in formal contexts. May is relatively rare in negative constructions (mayn't is not common); cannot and can't are usual in such contexts.
==============================

 

[PropsForward]

Stand Corrected

PropsForward,

All correct except there is no prohibition on an instrument student logging PIC for the time he is the sole manipulator of the controls in an aircraft he is appropriated for. So a private pilot working towards his instrument rating, flying with a CFII in instrument conditions, as the sole manipulator of the controls CAN log PIC. Re-read 61.51(c)(2)(i). It says that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or

Notice it says nothing about the conditions of flight, only that the pilot be rated in the aircraft.

Cheers,

SATCFI

Learning is what we are here for. Thanks for the clarification!

 

[100LL... Again!]

I'm really surprised that more schools do not go into this topic in depth.

A friend of mine from Riddle had an amazing lack of knowledge on the topic of logging time.

Not gonna get ya killed, but four years is a long time to be in school and not learn that.

 

[midlifeflyer]

What makes you think the schools know it? I've seen more than one post where "The Chief Pilot of my Part 141 School" is one of the uninformed.