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PIC on IR Checkride
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Timebuilder
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All the previous posters are correct if it is a part 61 checkride. However, if you are enrolled in a 141 school and are taking the "final lesson"/checkride part 141, then the flight can be conducted in IMC conditions. I've seen it happen many times where a 141 ride was taken in IMC when the student was not insturment rated yet.
Hope this clears it up for you a little.
Hope this clears it up for you a little.
Timebuilder
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The General Aviation Operations Inspectors Handbook allows for the inspector to act as PIC during a practical test by "prior arrangement with the applicant or other pilot in command."
I've only trained/instructed under Part 61 (& the military), and my observation is that--even though the examiner may act as PIC-- the overwhelming majority of examiners won't conduct an instrument practical test in IMC.
When I got my initial FAA CFII, the head of the school I was attending & I had to plead with the examiner to allow me to take the CFII ride in actual conditions. He finally agreed--though reluctantly--after learning that I had recently been a military flight instructor and questioning me at length about the syllabus the Navy, Marine Corps & Coast Guard use.
I've only trained/instructed under Part 61 (& the military), and my observation is that--even though the examiner may act as PIC-- the overwhelming majority of examiners won't conduct an instrument practical test in IMC.
When I got my initial FAA CFII, the head of the school I was attending & I had to plead with the examiner to allow me to take the CFII ride in actual conditions. He finally agreed--though reluctantly--after learning that I had recently been a military flight instructor and questioning me at length about the syllabus the Navy, Marine Corps & Coast Guard use.
thanks for the replies . . .
The examiners here are very clear that they won't fly in IMC. However, what makes me curious is how even in VMC they want the applicant to act a PIC and get an IFR clearence. Part 61.3 says no person can act as PIC of an aircraft under IFR unless they have an instrument rating. Since IFR means instrument flight rules and not neccesarily IMC, if I'm trying to earn my instrument rating, then I obviously don't meet this requirement.
What exception allows for an applicant to operate IFR (in VMC) as PIC without having an instrument rating. As a non-IR private pilot, I couldn't call for an instrument clearence if I were up alone. Is there some stipulation that allows this when the examiner is on board?
thanks.
The examiners here are very clear that they won't fly in IMC. However, what makes me curious is how even in VMC they want the applicant to act a PIC and get an IFR clearence. Part 61.3 says no person can act as PIC of an aircraft under IFR unless they have an instrument rating. Since IFR means instrument flight rules and not neccesarily IMC, if I'm trying to earn my instrument rating, then I obviously don't meet this requirement.
What exception allows for an applicant to operate IFR (in VMC) as PIC without having an instrument rating. As a non-IR private pilot, I couldn't call for an instrument clearence if I were up alone. Is there some stipulation that allows this when the examiner is on board?
thanks.
3
350DRIVER
Cook-
YOU are NOT flying "actual" IMC on the checkride, YOU are appropriately rated in the aircraft so you log it as PIC. On the checkride YOU have the DE who is instrument rated onboard.
Under part 61 it is not unusual for DE's to do the checkride in solid IMC up here.
c h e e r s
3 5 0
sorry for the "lack" of explanation per the FAR's ( tired today !) but you do log it as PIC.
YOU are NOT flying "actual" IMC on the checkride, YOU are appropriately rated in the aircraft so you log it as PIC. On the checkride YOU have the DE who is instrument rated onboard.
Under part 61 it is not unusual for DE's to do the checkride in solid IMC up here.
c h e e r s
3 5 0
sorry for the "lack" of explanation per the FAR's ( tired today !) but you do log it as PIC.
flyboy
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350driver is right. You are rated in the airplane and are the sole manipulator of the controls. You are PIC. You couldn't go up by yourself under actual but b/c the examiner is instrument rated you can do it in IMC AND log PIC. I knew several guys when I was in Florida that took their initial instrument ride under IMC. This was done under part 61 and I don't know much about 141. As for whether or not it is the smartest thing to do, I say absolutely not. The checkride is not the place to try and gain IMC conditions and try to impress the examiner. Pass the checkride in VMC and then go fly in the clouds. But if it's what you want to do, It's not against the rules.
14 CFR 61.3
(e) Instrument rating. No person may act as pilot in command of a civil aircraft under IFR or in weather 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 for any airplane, helicopter, or powered-lift being flown;
_______________
I understand what everyone is trying to say about VMC vs. IMC. However, the regs say even if it is VMC, no person can act as PIC under instrument flight rules (which would presumably include operating on an IFR clearence) unless that person is instrument rated. If the examiner is not acting as PIC then his instrument rating has no bearing on the legality of the flight.
If a checkride is going to include flying on an IFR clearence, wheter it is IMC or VMC, then it is being conducted under instrument flight rules and therefore for the flight to be legal the examiner must be the PIC.
Is there an exception in the regs?
Thanks.
P.S. There is a dramatic difference between logging PIC and acting as PIC. If the examiner and I agree that I am to be acting as PIC (i.e. I am responsible for the safe and legal operation of the flght) I must be instrument rated. If we agree that he will act as PIC then the flight is legal due to his instrument rating, but I may continue to be the sole manipulator of the controls and log the flight as PIC despite not being the acting PIC.
(e) Instrument rating. No person may act as pilot in command of a civil aircraft under IFR or in weather 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 for any airplane, helicopter, or powered-lift being flown;
_______________
I understand what everyone is trying to say about VMC vs. IMC. However, the regs say even if it is VMC, no person can act as PIC under instrument flight rules (which would presumably include operating on an IFR clearence) unless that person is instrument rated. If the examiner is not acting as PIC then his instrument rating has no bearing on the legality of the flight.
If a checkride is going to include flying on an IFR clearence, wheter it is IMC or VMC, then it is being conducted under instrument flight rules and therefore for the flight to be legal the examiner must be the PIC.
Is there an exception in the regs?
Thanks.
P.S. There is a dramatic difference between logging PIC and acting as PIC. If the examiner and I agree that I am to be acting as PIC (i.e. I am responsible for the safe and legal operation of the flght) I must be instrument rated. If we agree that he will act as PIC then the flight is legal due to his instrument rating, but I may continue to be the sole manipulator of the controls and log the flight as PIC despite not being the acting PIC.
3
350DRIVER
on your private check ride then "how" can you log the flight as PIC since in reality you have a "passenger" onboard ex> DE who is not acting as PIC ( you are ).??!!
(one must remember that you cannot carry passengers as a "student pilot" )- "0"
I think you are looking into this deeper than you should, if you continue then many of the FAR's can be turned around and you will continue to question the legality of many issues.. Bottom line is you CAN LEGALLY LOG the flight as PIC, pretty much the bottom line.
cheers
3 5 0
IF you fly the ride in "actual" then it is filed under the DE's name.
(one must remember that you cannot carry passengers as a "student pilot" )- "0" I think you are looking into this deeper than you should, if you continue then many of the FAR's can be turned around and you will continue to question the legality of many issues.. Bottom line is you CAN LEGALLY LOG the flight as PIC, pretty much the bottom line.
cheers
3 5 0
IF you fly the ride in "actual" then it is filed under the DE's name.
flyboy
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Once again, 350driver is right. When I completed my private checkride, the examiner logged my time as PIC. When I completed my Instrument rating (done under an IFR FP), the examiner signed it as PIC. When I took my COM multi checkride, the examiner logged it as PIC. 3 different exminers, same result. If you will dig a little deeper into the regs you will find 61.47 which states the examiner's status on a checkride. (b) states that the examiner is not PIC unless he agrees to act as such for the flight or for a portion of the flight by prior arrangement with the applicant. If the examiner is not PIC then guess who has to be? YOU, the applicant, regardless of IMC, VMC, multi, etc, etc, etc. Know what you are looking for when you read your regs.
cjh
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Until you are instrument rated, you may NOT act as PIC on any flight being conducted under an IFR flight plan. You may not file an IFR flight plan until you are an instrument rated pilot. There are no exceptions to 61.3 for check rides. 350 is in error to suggest otherwise.
61.3(e) is quite specific that no one may act as PIC under IFR unless they hold an instrument rating. Since you are not yet rated at the point you are taking the practical you may not file the flight plan, nor may you act as PIC if the flight is being conductged under an IFR flight plan. The DE would have to do the filing and agree to act as PIC for that portion of the flight for it to be legal. If the IFR flight plan is cancelled, you may then act as PIC.
Now, as for the other responses indicating DEs logged PIC time in their logbooks when signing them, there are explanations backed by the FAR. Let's take a look.
1. PPC - first of all, *someone* has to be acting as PIC on board every plane. 61.51 allows students to log PIC time and to act as PIC during solo flight. The prohibition for student pilots is that they can't carry passengers. However, 61.47(c) takes care of that by waiving this requirement for the check ride. Thus, 61.51(e) allows you to log PIC time. You are acting as PIC under the regulations governing the flight.
2. Commercial and Instrument - again, 61.51(e)(1)(i) allows you to log PIC time when you are sole manipulator of the controls of an aircraft for which you're rated. As a commercial pilot or a pilot seeking an IR, you are typically already at least a private pilot, so there's no great mystery here. The only potential problem arises on an instrument check ride when an IFR flight plan needs to be filed. The applicant can't legally do it until AFTER successful completion of the instrument check ride. Neither 61.51, 61.47, nor 61.3 (or any other reg) provides an exception.
Bottom line, 350 is in error, and you Cookmg are absolutely correct in questioning the upcoming situation. There is NO exception to the regulation requiring you to be instrument rated to file an instrument flight plan or to fly under IFR before you pass the practical.
-----------
61.47 Status of an examiner who is authorized by the Administrator to conduct practical tests.
(a) An examiner represents the Administrator for the purpose of conducting practical tests for certificates and ratings issued under this part and to observe an applicant's ability to perform the areas of operation on the practical test.
(b) The examiner is not the pilot in command of the aircraft during the practical test unless the examiner agrees to act in that capacity for the flight or for a portion of the flight by prior arrangement with:
(1) The applicant; or
(2) A person who would otherwise act as pilot in command of the flight or for a portion of the flight.
(c) Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter.
-------------------------
61.51 Pilot Logbooks
(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;
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting 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.
61.3(e) is quite specific that no one may act as PIC under IFR unless they hold an instrument rating. Since you are not yet rated at the point you are taking the practical you may not file the flight plan, nor may you act as PIC if the flight is being conductged under an IFR flight plan. The DE would have to do the filing and agree to act as PIC for that portion of the flight for it to be legal. If the IFR flight plan is cancelled, you may then act as PIC.
Now, as for the other responses indicating DEs logged PIC time in their logbooks when signing them, there are explanations backed by the FAR. Let's take a look.
1. PPC - first of all, *someone* has to be acting as PIC on board every plane. 61.51 allows students to log PIC time and to act as PIC during solo flight. The prohibition for student pilots is that they can't carry passengers. However, 61.47(c) takes care of that by waiving this requirement for the check ride. Thus, 61.51(e) allows you to log PIC time. You are acting as PIC under the regulations governing the flight.
2. Commercial and Instrument - again, 61.51(e)(1)(i) allows you to log PIC time when you are sole manipulator of the controls of an aircraft for which you're rated. As a commercial pilot or a pilot seeking an IR, you are typically already at least a private pilot, so there's no great mystery here. The only potential problem arises on an instrument check ride when an IFR flight plan needs to be filed. The applicant can't legally do it until AFTER successful completion of the instrument check ride. Neither 61.51, 61.47, nor 61.3 (or any other reg) provides an exception.
Bottom line, 350 is in error, and you Cookmg are absolutely correct in questioning the upcoming situation. There is NO exception to the regulation requiring you to be instrument rated to file an instrument flight plan or to fly under IFR before you pass the practical.
-----------
61.47 Status of an examiner who is authorized by the Administrator to conduct practical tests.
(a) An examiner represents the Administrator for the purpose of conducting practical tests for certificates and ratings issued under this part and to observe an applicant's ability to perform the areas of operation on the practical test.
(b) The examiner is not the pilot in command of the aircraft during the practical test unless the examiner agrees to act in that capacity for the flight or for a portion of the flight by prior arrangement with:
(1) The applicant; or
(2) A person who would otherwise act as pilot in command of the flight or for a portion of the flight.
(c) Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter.
-------------------------
61.51 Pilot Logbooks
(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;
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting 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.
3
350DRIVER
cjh-
Then I guess many many DE's are in "error" as well for doing this flight in actual IMC.. - I think not, look at the regulations once again more closely then go back and re-read what I wrote. The DE can (if he is willing) file IFR and act as PIC to do the ride in "actual"- perfectly legal and pretty common practice. As in most cases certain stipulations are applicable.
Suggest otherwise.?? Looks like you neglected to read what I wrote initially- Everything that I stated was not in error, ( I just neglected to go into a full explanation) and you are a CFII.?? I have yet to meet one pilot who did not log the checkride as PIC that was done under simulated conditions.
Pretty much common sense, now go back and read what I wrote.... Obviously the flight in "actual" must be filed by the DE and under his name BUT the applicant can and DOES log the ride as PIC "still" under certain situations. WHY?? Because the DE can state that the checkride was passed at a certain point during the flight and IF this happens before (prior to) entering IMC then guess what?? - HE is now "authorized" to fly into IMC. Many DE's will state that an applicant has passed the ride and for the "added" experience he will take the "applicant" into actual. This is a pretty common practice in the northeast due to the large amounts of "actual" that we get yearly.
Most of the DE's will still have want a flight plan filed regardless of if it is "actual" or severe vfr, in the remarks section some will want different remarks put in there. In simulated conditions (under the hood or foggles) the applicant is still PIC since he is appropriately rated in the aircraft.
3 5 0
Then I guess many many DE's are in "error" as well for doing this flight in actual IMC.. - I think not, look at the regulations once again more closely then go back and re-read what I wrote. The DE can (if he is willing) file IFR and act as PIC to do the ride in "actual"- perfectly legal and pretty common practice. As in most cases certain stipulations are applicable.
Suggest otherwise.?? Looks like you neglected to read what I wrote initially- Everything that I stated was not in error, ( I just neglected to go into a full explanation) and you are a CFII.?? I have yet to meet one pilot who did not log the checkride as PIC that was done under simulated conditions.
Pretty much common sense, now go back and read what I wrote.... Obviously the flight in "actual" must be filed by the DE and under his name BUT the applicant can and DOES log the ride as PIC "still" under certain situations. WHY?? Because the DE can state that the checkride was passed at a certain point during the flight and IF this happens before (prior to) entering IMC then guess what?? - HE is now "authorized" to fly into IMC. Many DE's will state that an applicant has passed the ride and for the "added" experience he will take the "applicant" into actual. This is a pretty common practice in the northeast due to the large amounts of "actual" that we get yearly.
Most of the DE's will still have want a flight plan filed regardless of if it is "actual" or severe vfr, in the remarks section some will want different remarks put in there. In simulated conditions (under the hood or foggles) the applicant is still PIC since he is appropriately rated in the aircraft.
3 5 0
cjh
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350,
Why yes I am a CFII, thank you. And let me point you to Doc's (Doc of Doc's FAR Pages) take on the same question Cook posed here. Seems my opinion agrees with his. That's pretty much all the vindication I need.
http://www.propilot.com/doc/bbs/msgs//8666.html
It was never my intent to offend you. I merely wanted to get Cook some correct information because he was getting quite a bit of bad advice or at the very least advice that was irrelevant to what he asked. Cook has undoubtedly read Doc's opinion, so he's happy. I find no contradiction between what I believed to be the case and what Doc reported so I'm certainly happy. If your opinion agrees with Doc's then welcome to the party. If not, you can either research further to see where your understanding is off, or you can continue with your current beliefs. Either way, the best of luck to you.
Why yes I am a CFII, thank you. And let me point you to Doc's (Doc of Doc's FAR Pages) take on the same question Cook posed here. Seems my opinion agrees with his. That's pretty much all the vindication I need.
http://www.propilot.com/doc/bbs/msgs//8666.html
It was never my intent to offend you. I merely wanted to get Cook some correct information because he was getting quite a bit of bad advice or at the very least advice that was irrelevant to what he asked. Cook has undoubtedly read Doc's opinion, so he's happy. I find no contradiction between what I believed to be the case and what Doc reported so I'm certainly happy. If your opinion agrees with Doc's then welcome to the party. If not, you can either research further to see where your understanding is off, or you can continue with your current beliefs. Either way, the best of luck to you.
3
350DRIVER
cjh-
I got a good laugh from you- wasn't offended at all. I am sorry you need to depend on that site for "knowledge".
Most of us are capable of reading the FAR's and understanding them.
hang in there-
3 5 0
ps>>> I guess all the inspectors/examiners are wrong as well, BUt you are the "right" one- lol
I got a good laugh from you- wasn't offended at all. I am sorry you need to depend on that site for "knowledge".
Most of us are capable of reading the FAR's and understanding them.hang in there-
3 5 0
ps>>> I guess all the inspectors/examiners are wrong as well, BUt you are the "right" one- lol
Thanks CJ for helping me out here . . . I thought I was the only one on this board who didn't think I could ACT as PIC. Now that 350 has clarified his position, it sounds like he agrees that the examiner must act as PIC. I am well aware that I can LOG PIC on the ride. That was never my question.
That being said, I appreciate all of these forums because as a young pilot there are many things I can learn from those more experienced. I am not ashamed that I look to Doc's site for guidance regarding the FARs. He backs his opinions with solid evidence and cares enough about his advice to do the grunt work of looking up the regs and legal opinions to back his position. I feel very fortunate to have such an invaluable resource. Still, I try to ask for others' ideas, but often find unsupportable opinions rather than backed fact. That is fine. No one on this site or any other has any responsibility to do that extra work for me. I'm only saying that it helps explain why I appreciate Doc's website. I am greatly in debted to him for helping understand things that many experienced pilots still do not.
I think that I have decided that I will ask the DE to allow us to conduct the approaches as practice VFR approaches. This way I can ACT as PIC and meet the club's insurance requirements and we can still be legal per part 61.
Thanks to EVERYONE for their input.
Mike
That being said, I appreciate all of these forums because as a young pilot there are many things I can learn from those more experienced. I am not ashamed that I look to Doc's site for guidance regarding the FARs. He backs his opinions with solid evidence and cares enough about his advice to do the grunt work of looking up the regs and legal opinions to back his position. I feel very fortunate to have such an invaluable resource. Still, I try to ask for others' ideas, but often find unsupportable opinions rather than backed fact. That is fine. No one on this site or any other has any responsibility to do that extra work for me. I'm only saying that it helps explain why I appreciate Doc's website. I am greatly in debted to him for helping understand things that many experienced pilots still do not.
I think that I have decided that I will ask the DE to allow us to conduct the approaches as practice VFR approaches. This way I can ACT as PIC and meet the club's insurance requirements and we can still be legal per part 61.
Thanks to EVERYONE for their input.
Mike
cjh
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Cook,
Glad to have helped in some small way! This board is a popular one. The up side is when you ask a question you're apt to get lots of opinions from a lot of well meaning folks. The down side is that often it's just that - opinion. When dealing with the regs one should always be able to reference the reason for the opinion. You'll quickly learn to ignore those who can't. If you hang around here much you'll figure out pretty quickly who knows their stuff.
Doc's site is terrific. Any time you have a question concerning the FAR he is *THE* person to ask, and you're right, he does the research and leg work when needed. You can trust his answers, and you can trust that your question will be treated with respect. The regs are complicated, and as you can see from the varying opinions you got, an awful lot of pilots don't know as much about them as they think they do. Don't be embarrassed that you are interested in getting it right, be embarrassed for the pilots who aren't.
All through your involvement with aviation, keep asking questions, and best of luck on your check ride.
Glad to have helped in some small way! This board is a popular one. The up side is when you ask a question you're apt to get lots of opinions from a lot of well meaning folks. The down side is that often it's just that - opinion. When dealing with the regs one should always be able to reference the reason for the opinion. You'll quickly learn to ignore those who can't. If you hang around here much you'll figure out pretty quickly who knows their stuff.
Doc's site is terrific. Any time you have a question concerning the FAR he is *THE* person to ask, and you're right, he does the research and leg work when needed. You can trust his answers, and you can trust that your question will be treated with respect. The regs are complicated, and as you can see from the varying opinions you got, an awful lot of pilots don't know as much about them as they think they do. Don't be embarrassed that you are interested in getting it right, be embarrassed for the pilots who aren't.
All through your involvement with aviation, keep asking questions, and best of luck on your check ride.
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.
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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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