Re: Acting vs. Logging
stillaboo said:
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
Correct.
Can applicants log the whole flight as PIC (legally) if they were on a IFR FP or entered actual before 'passing'?
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.
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?
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.
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?
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
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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)”."
Most of us are capable of reading the FAR's and understanding them.
