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PIC on IR Checkride
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Acting vs. Logging
So, I think you guys have hashed out that applicants for an instrument rateing cannot legally act as PIC for the parts of any examination under an IFR flight plan or in IMC unless the applicant has already 'passed' before entering the IMC. (If I'm wrong, please tell me now)
So:
- Can applicants log the whole flight as PIC (legally) if they were on a IFR FP or entered actual before 'passing'?
- How does a applicant for a ME rateing act as PIC if he/she has not yet recieved the rateing? Can they legally log the flight as PIC if they were not acting as PIC?
- If you can log PIC w/o acting as PIC, how does this impact the prearrangement flight where 2 appropriately rated pilots fly together, one as PIC to log the PIC (even though they do not manipulate the controls at all, let alone be 'sole manipulator') and the other logs the instrument? Why not just log both PIC and instrument?
So, I think you guys have hashed out that applicants for an instrument rateing cannot legally act as PIC for the parts of any examination under an IFR flight plan or in IMC unless the applicant has already 'passed' before entering the IMC. (If I'm wrong, please tell me now)
So:
- Can applicants log the whole flight as PIC (legally) if they were on a IFR FP or entered actual before 'passing'?
- How does a applicant for a ME rateing act as PIC if he/she has not yet recieved the rateing? Can they legally log the flight as PIC if they were not acting as PIC?
- If you can log PIC w/o acting as PIC, how does this impact the prearrangement flight where 2 appropriately rated pilots fly together, one as PIC to log the PIC (even though they do not manipulate the controls at all, let alone be 'sole manipulator') and the other logs the instrument? Why not just log both PIC and instrument?
Fr8DoggyStyle
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you guys are giving me a headache. When i take a checkride, the examiner is always right, no matter (almost) what. So, if you do what the examiner says, and the examiner is smoking crack, and the FAA somehow finds out that you logged 1.2 PIC or flew one flight in IMC during a checkride that shouldnt have been- Do you think they are going to go after you or the examiner? This is one of those topics that there is 8 different ways to prove right in either direction depending on your opinion.
Now, this is just my understanding and is not quotable from the regs- Examiners have told me on checkrides that i am the PIC (not just that i could log PIC). Kind of a first day of the rest of your life kind of thing. It has been my understanding that you do act as PIC and the examiner just makes sure that you fall within the guidelines. Its sort of like the examiner has the magical power to grant you the license on a one flight basis to "examine" you. I have also been told if you dont pass not to log it as PIC, because you didnt perform well enough to act as PIC. Then again maybe i am the one smoking crack
Now, this is just my understanding and is not quotable from the regs- Examiners have told me on checkrides that i am the PIC (not just that i could log PIC). Kind of a first day of the rest of your life kind of thing. It has been my understanding that you do act as PIC and the examiner just makes sure that you fall within the guidelines. Its sort of like the examiner has the magical power to grant you the license on a one flight basis to "examine" you. I have also been told if you dont pass not to log it as PIC, because you didnt perform well enough to act as PIC. Then again maybe i am the one smoking crack
cjh
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Re: Acting vs. Logging
Correct.
LOGging PIC and ACTing as PIC are two different things. The question Cook originally posed dealt with two scenarios (1) filing IFR under your name when not yet IRed and (2) flying in IMC while ACTing as PIC when you're not yet IRed. 61.3 (e) governs filing and flying under IFR or in instrument flight conditions and specifically and very clearly says "No person may ACT as pilot in command...under IFR or inweather conditions less than the minimums prescribed for VFR flight unless that person holds (1) the appropriate aircraft category, class, type (if required) and instrument rating on that person's pilot certificate". (My emphasis.)
However, as far as logging goes, 61.51 governs what you can/can't log. 61.51(e) permits you to LOG PIC time any time you are the sole manipulator of the controls of an aircraft for which you are rated. Therefore, during an instrument check ride, assumiing you are rated in the aircraft (category, class, and type if required), you may log PIC for the entire flight. The rule says nothing about whether the flight is conducted VFR or IFR or in VMC or instrument flight conditions, and says nothing about having an instrument rating. Further, if you go on to (g) "Logging instrument flight time", the rule also says that "a person" can log intrument time when operating the aircraft solely by reference to instruments under actual or simulated conditions. So, just like during you private pilot training you got to log instrument time when flying under the hood, even though you weren't qualified to act as PIC and even though you didn't possess an IRing, you can log instrument time during the IR check ride while under the hood or in instrument flight conditions. Doesn't matter whether it was actual or not, and doesn't depend on whether you are also acting or able to act as PIC.
The regs support counting "performing the duties of pilot in command" as solo flight time. See 61.129(b)(4). This is largely due to insurance and liability issues. In this day and age, it would be tough to find an FBO or insurer who would allow a multi engine student to solo the aircraft prior to receiving the rating. So, unless adjustments were made, the reguirements could never be met. At the end of this post is a Q&A from the FAA's FAQ site explaining the thinking and the reason for the tweak to the regs.
However, assuming there are two pilots in the cockpit, and assuming the one in the left seat is the pilot flying (PF), the pilot in the right seat who is not flying (PNF) and is not an instructor providing training (and excluding ATP issues), the PNF can log time for acting as PIC when BOTH ACTing as PIC AND as a safety pilot. (This might have been what you were alluding to in your question.) 61.51(e)(1)(iii) allows a pilot ACTing as PIC to log PIC time when the position is required by the regulations under which the flight is being conducted. 91.109 requires a safety pilot any time simulated instrument flight is being conducted. So, that's how both pilots get to log PIC time. Why is it done? To build time.
Hope that helped. You asked good questions. As stated in other posts in this thread, take a look at Doc's FAR Pages. If the topic of logging vs acting confuses you, he has an entire section devoted to just that subject. Obviously it confuses lots of pilots, so you're not alone! http://www.propilot.com/doc/logging2.html
-----------------
FAA Q&A
"QUESTION: Here is the scenario: An Applicant holds Private Pilot Airplane Singe Engine Land and Instrument Rating. He intends to obtain a Commercial Pilot Certificate Multi Engine Land. § 61.129(b)(4) states he must have 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor on the areas of operation listed in 61.127(b)(2) of this part. So, he must get pilot in command time but he isn't rated in the multiengine airplane, and it isn't instruction but an instructor is there. What and how do these guys log this situation?
ANSWER: The preamble of the final rule correction document the was published in the Federal Register (78 FR 20284; April 23, 1998) concerning the revision to § 61.129(b)(4) states as follows:
“Section 61.129 Aeronautical experience. In Notice No. 95-11, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. During the rulemaking process, the FAA determined that the accomplishment of solo flight time in a multiengine airplane may be impracticable because of liability and insurance concerns. Therefore, in the final rule, the FAA replaced the requirement that an applicant accomplish solo flight time in a multiengine airplane with the requirement that the flight time required under § 61.129(b)(4) be acquired while performing the duties of PIC in a multiengine airplane with an authorized instructor. However, in revising this requirement, the FAA did not consider the applicant who holds a private pilot certificate with a multiengine rating and, therefore, may already have solo flight time in a multiengine aircraft or may be able to accomplish solo flight time without the cost of acquiring the required flight time with an authorized instructor. Therefore, the FAA has revised § 61.129(b)(4) to require an applicant to accomplish 10 hours of solo flight in a multiengine airplane or 10 hours of flight time performing the duties of PIC in a multiengine airplane with an authorized instructor.
In addition, the FAA has revised § 61.129(b)(4) to permit an applicant for a commercial pilot certificate with a multiengine rating to credit the 10 hours of flight time performing the duties of PIC in a multiengine airplane required by that paragraph toward the 100 hours of PIC flight time required under § 61.129(b)(2). This revision is consistent with the provisions of § 61.129(b) as proposed in Notice No. 95-11. As previously noted, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. The solo flight time would have constituted PIC flight time; therefore, the applicant would have been able to credit that flight time toward the requirements of § 61.129(b)(2). However, under § 61.129(b)(4) as adopted in the final rule, an applicant would be performing the duties of PIC rather than acting as PIC. Consequently, that flight time does not constitute PIC flight time. Therefore, the FAA has revised § 61.129(b)(4) to permit the crediting of flight time accomplished under that paragraph toward the requirements of § 61.129(b)(2). However, this revision does not permit an applicant to log the flight time required under § 61.129(b)(4) as PIC flight time under § 61.51(e) unless the applicant holds a private pilot certificate with a multiengine rating and chooses to accomplish the requirements with an authorized instructor.
The FAA notes that if an applicant meets the requirements of § 61.129(b)(4) by logging 10 hours of solo flight time in a multiengine airplane (as permitted in this final rule), that time would constitute PIC flight time. Therefore, the applicant may count that flight time toward the requirements of § 61.129(b)(2) and log it as PIC time under § 61.51(e)”."
stillaboo said:
Correct.
LOGging PIC and ACTing as PIC are two different things. The question Cook originally posed dealt with two scenarios (1) filing IFR under your name when not yet IRed and (2) flying in IMC while ACTing as PIC when you're not yet IRed. 61.3 (e) governs filing and flying under IFR or in instrument flight conditions and specifically and very clearly says "No person may ACT as pilot in command...under IFR or inweather conditions less than the minimums prescribed for VFR flight unless that person holds (1) the appropriate aircraft category, class, type (if required) and instrument rating on that person's pilot certificate". (My emphasis.)
However, as far as logging goes, 61.51 governs what you can/can't log. 61.51(e) permits you to LOG PIC time any time you are the sole manipulator of the controls of an aircraft for which you are rated. Therefore, during an instrument check ride, assumiing you are rated in the aircraft (category, class, and type if required), you may log PIC for the entire flight. The rule says nothing about whether the flight is conducted VFR or IFR or in VMC or instrument flight conditions, and says nothing about having an instrument rating. Further, if you go on to (g) "Logging instrument flight time", the rule also says that "a person" can log intrument time when operating the aircraft solely by reference to instruments under actual or simulated conditions. So, just like during you private pilot training you got to log instrument time when flying under the hood, even though you weren't qualified to act as PIC and even though you didn't possess an IRing, you can log instrument time during the IR check ride while under the hood or in instrument flight conditions. Doesn't matter whether it was actual or not, and doesn't depend on whether you are also acting or able to act as PIC.
The regs support counting "performing the duties of pilot in command" as solo flight time. See 61.129(b)(4). This is largely due to insurance and liability issues. In this day and age, it would be tough to find an FBO or insurer who would allow a multi engine student to solo the aircraft prior to receiving the rating. So, unless adjustments were made, the reguirements could never be met. At the end of this post is a Q&A from the FAA's FAQ site explaining the thinking and the reason for the tweak to the regs.
Again refer to 61.51(e). You can log PIC time any time you meet the provisions of 61.51(e). Instructors can log PIC time any time they are acting as an authorized instructor, and an ATP may log PIC while acting as PIC IF the operation requires an ATP certificate. You do not get to log PIC just because you're a qualified pilot sitting in the other seat, whether you're acting as PIC or as a passenger with a good view.
However, assuming there are two pilots in the cockpit, and assuming the one in the left seat is the pilot flying (PF), the pilot in the right seat who is not flying (PNF) and is not an instructor providing training (and excluding ATP issues), the PNF can log time for acting as PIC when BOTH ACTing as PIC AND as a safety pilot. (This might have been what you were alluding to in your question.) 61.51(e)(1)(iii) allows a pilot ACTing as PIC to log PIC time when the position is required by the regulations under which the flight is being conducted. 91.109 requires a safety pilot any time simulated instrument flight is being conducted. So, that's how both pilots get to log PIC time. Why is it done? To build time.
Hope that helped. You asked good questions. As stated in other posts in this thread, take a look at Doc's FAR Pages. If the topic of logging vs acting confuses you, he has an entire section devoted to just that subject. Obviously it confuses lots of pilots, so you're not alone! http://www.propilot.com/doc/logging2.html
-----------------
FAA Q&A
"QUESTION: Here is the scenario: An Applicant holds Private Pilot Airplane Singe Engine Land and Instrument Rating. He intends to obtain a Commercial Pilot Certificate Multi Engine Land. § 61.129(b)(4) states he must have 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor on the areas of operation listed in 61.127(b)(2) of this part. So, he must get pilot in command time but he isn't rated in the multiengine airplane, and it isn't instruction but an instructor is there. What and how do these guys log this situation?
ANSWER: The preamble of the final rule correction document the was published in the Federal Register (78 FR 20284; April 23, 1998) concerning the revision to § 61.129(b)(4) states as follows:
“Section 61.129 Aeronautical experience. In Notice No. 95-11, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. During the rulemaking process, the FAA determined that the accomplishment of solo flight time in a multiengine airplane may be impracticable because of liability and insurance concerns. Therefore, in the final rule, the FAA replaced the requirement that an applicant accomplish solo flight time in a multiengine airplane with the requirement that the flight time required under § 61.129(b)(4) be acquired while performing the duties of PIC in a multiengine airplane with an authorized instructor. However, in revising this requirement, the FAA did not consider the applicant who holds a private pilot certificate with a multiengine rating and, therefore, may already have solo flight time in a multiengine aircraft or may be able to accomplish solo flight time without the cost of acquiring the required flight time with an authorized instructor. Therefore, the FAA has revised § 61.129(b)(4) to require an applicant to accomplish 10 hours of solo flight in a multiengine airplane or 10 hours of flight time performing the duties of PIC in a multiengine airplane with an authorized instructor.
In addition, the FAA has revised § 61.129(b)(4) to permit an applicant for a commercial pilot certificate with a multiengine rating to credit the 10 hours of flight time performing the duties of PIC in a multiengine airplane required by that paragraph toward the 100 hours of PIC flight time required under § 61.129(b)(2). This revision is consistent with the provisions of § 61.129(b) as proposed in Notice No. 95-11. As previously noted, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. The solo flight time would have constituted PIC flight time; therefore, the applicant would have been able to credit that flight time toward the requirements of § 61.129(b)(2). However, under § 61.129(b)(4) as adopted in the final rule, an applicant would be performing the duties of PIC rather than acting as PIC. Consequently, that flight time does not constitute PIC flight time. Therefore, the FAA has revised § 61.129(b)(4) to permit the crediting of flight time accomplished under that paragraph toward the requirements of § 61.129(b)(2). However, this revision does not permit an applicant to log the flight time required under § 61.129(b)(4) as PIC flight time under § 61.51(e) unless the applicant holds a private pilot certificate with a multiengine rating and chooses to accomplish the requirements with an authorized instructor.
The FAA notes that if an applicant meets the requirements of § 61.129(b)(4) by logging 10 hours of solo flight time in a multiengine airplane (as permitted in this final rule), that time would constitute PIC flight time. Therefore, the applicant may count that flight time toward the requirements of § 61.129(b)(2) and log it as PIC time under § 61.51(e)”."
cjh
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Fr8DoggyStyle said:
Apologies! My post just above this one is probably good for a full blown migraine!
What if the examiner is testing your knowledge of the regs and your ability to act as PIC - in other words the ability to say "no".
Nope. While there are areas of the regs open to interpretation, this area is quite clear. Yes, there are lots of opinions, but that doesn't make them right.
Normally you would act as PIC, and there's nothing magical about it. 61.47 specifically grants an examiner the ability to exclude himself as PIC unless he agrees to act in that capacity, and it also exempts all parties on board from being treated as passengers. However, that doesn't mean the examiner somehow has the authority to modify other areas of the regs as well, such as requiring the applicant to violate the provisions of 61.3. That would indeed be magical and is beyond the intent of the rule. Doc's comment in his discussion on this issue says it best: "FAR 61.47 is only intended to delineate the lines of authority and responsibility between the applicant and the examiner. If the applicant acts as PIC, he must be qualified in ALL respects to act as PIC - it is as if the examiner is not there with respect to passenger-carrying rules, as stated in FAR 61.47. This allows a student pilot to take the examiner along on the test, without running afoul of FAR 61.87."
Keep in mind also, assuming some DEs do require such action (and assuming pilots go along with it) that although a DE "should" know the regs, there's nothing to say they're as up to speed as they should be. Just because a DE has done it doesn't make it legal. The PTS does not require an IFR flight plan or that the practical be conducted in instrument flight conditions. In fact, it does specifically make reference to the fact that "the examiner shall use proper ATC terminology when simulating ATC clearances". If one wishes to draw conclusions, then one might conclude that statement acknowledges the applicant cannot legally be receiving IFR clearances from ATC until actually IRed.
Last edited:
bigD
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My ride was almost completely IMC, but my DE only logged the non-IMC portion of the flight as PIC. In other words the ride was 2.5 hours long, 2.0 was actual, and .5 was PIC. We were on an IFR flight plan the entire time, though. This was Part 61, for what that's worth.
Personally, I think it's strange for someone to not give checkrides in actual. It's like the DE is saying, "Well, *I* don't want to go up with the guy in actual, but I'm perfectly happy with issuing him a certificate that'll allow him to launch into IMC with his entire family on board." WTF?
Personally, I think it's strange for someone to not give checkrides in actual. It's like the DE is saying, "Well, *I* don't want to go up with the guy in actual, but I'm perfectly happy with issuing him a certificate that'll allow him to launch into IMC with his entire family on board." WTF?
cjh
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BigD,
Yeah it's pretty scary to think you could do your entire training in CAVU and then launch into soup for the first time in a solo environment or even worse, with passengers on board. Not smart, but legal. However, if actual were required, think how difficult it would be to comply and actually get an IRing.
Yeah it's pretty scary to think you could do your entire training in CAVU and then launch into soup for the first time in a solo environment or even worse, with passengers on board. Not smart, but legal. However, if actual were required, think how difficult it would be to comply and actually get an IRing.
bigD
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Oh don't get me wrong, I'm not advocating that actual be required in any way. What I meant was that I don't understand why a DE would REFUSE to give a checkride in actual. I guess I just don't understand why people shy away from it.
"I cancelled my checkride today because the ceiling was at 700 feet."
????
"I cancelled my checkride today because the ceiling was at 700 feet."
????
cjh
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Well, that brings up a question I have. I was researching the answer a couple of days ago, but getting no where fast.
What are the currency requirements for a DE? I know they periodically have to take rides in various aircraft, but what (and where) are the actual requirements?
Thanks in advance to anyone who can point me in the right direction.
What are the currency requirements for a DE? I know they periodically have to take rides in various aircraft, but what (and where) are the actual requirements?
Thanks in advance to anyone who can point me in the right direction.
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