2-pilot crew ("dual Captains") - logging "Signing" PIC vs "sole manipulator" PIC - Part 91/135

RussR

RussR

En-Route
Joined
Jan 12, 2011
Messages
4,053
Location
Oklahoma City, OK
Display Name
Display name:
Russ
In my flight department, we fly under both Part 91 and 135. We mostly fly with two fully-PIC-qualified pilots (as we are required to do by the regulations or type certificate of the airplanes), swapping PF/PM duties (and seats) on a daily basis.

However, for each itinerary, one of the pilots is designated the "PIC" (i.e. signing for the airplane and in charge of the operation) and one the "SIC". The next trip the duties may be reversed.

I know this is the case for other 2-pilot crews under Part 91 and Part 135 where there are "co-Captains".

If you have flown in this type of environment, how did you generally log time?

For example, if I am the "signing PIC", then I can log PIC for the flight whether I'm PF or PM. If I'm SIC, then I should log SIC when I'm PM, but could also log "sole manipulator" PIC when I am PF. So it seems likely that about 75% of my time should be PIC and about 25% SIC. Which seems weird, but that's how I read 61.51.

If you do log it this way, do you differentiate between the types of PIC in your logbook?

EDIT - added the bold part above for clarification
 
Last edited:
The FAA has no concept of "signing" pilot. You either are PIC or not (and PF/PM really is immaterial, the PIC may be PM or PF). Your operation may designate the "signing pilot" as doing the PIC role, than that is the case. However, being PIC is not a necessary nor sufficient condition to log it.

Once you get to operations requiring an ATP, then it pretty much is the PIC logs PIC and SIC logs SIC . Before you get to operations requiring ATPs, the standard rules apply:

1. Log PIC as sole manipulator.
2. Log PIC when you are PIC in operations requiring two pilots by regulation or TC.
 
fly what you want log what you need.. -er, Oops, wrong forum. :D

In the crew mil side it gets even more TLAR'd pencil-whipped. Since crews log primary and secondary regardless the seat title, the flight records can't differentiate "airline FAR 1 TPIC" between IP/EPs and ACs (or worse, multiple ACs in jumpseat) when they're all on board and doing their respective roles. As such they have to split primary time, and when it comes to the airlines there's no way to hair-split it, which means people either undercount or overcount their TPIC.

Normal accepted WAG for the airlines was to take all your primary time after the date your code upgrade to aircraft commander or higher, take 90% of it and call that your TPIC. Super sketch but there ya go. That whole FAR 1 vs 61 PIC definition kerfuffle has always been a clownshow for non-standard time loggers like crew military or govco. Hated that about the buff, 10-17 hour sorties, 30% of it PIC because of 3 other A-code qualified *uckos crammed in that clown car and diluted your seat time. All hat no cattle. Eff that noise, started flying with my favorite captain since 2011 and never looked back. Not that TPIC means anything anymore but at least I don't get my PIC stick time stolen.
 
If I were logging PIC for a non-FAA purpose, I would create a custom column or field for it. We do that all the time. People log complex, high performance, tailwheel hours, and more recently, glass. Mostly to fill out non+FAA applications.
 
flyingron said:
Once you get to operations requiring an ATP, then it pretty much is the PIC logs PIC and SIC logs SIC . Before you get to operations requiring ATPs, the standard rules apply:

1. Log PIC as sole manipulator.
2. Log PIC when you are PIC in operations requiring two pilots by regulation or TC.
Click to expand...
why would standard rules not apply to ATPs?
 
RussR said:
In my flight department, we fly under both Part 91 and 135. We mostly fly with two fully-PIC-qualified pilots, swapping PF/PM duties (and seats) on a daily basis.

However, for each itinerary, one of the pilots is designated the "PIC" (i.e. signing for the airplane and in charge of the operation) and one the "SIC". The next trip the duties may be reversed.

I know this is the case for other 2-pilot crews under Part 91 and Part 135 where there are "co-Captains".

If you have flown in this type of environment, how did you generally log time?

For example, if I am the "signing PIC", then I can log PIC for the flight whether I'm PF or PM. If I'm SIC, then I should log SIC when I'm PM, but could also log "sole manipulator" PIC when I am PF. So it seems likely that about 75% of my time should be PIC and about 25% SIC. Which seems weird, but that's how I read 61.51.

If you do log it this way, do you differentiate between the types of PIC in your logbook?
Click to expand...
If you plan on going to the airlines, all they care about is “signing for airplane PIC,” which isn’t really a thing but they don’t want you logging PIC unless you’re the skipper. Of course you can log PIC when you’re sole manipulator but that time won’t count for pretty much any airline application you apply to.
 
jordane93 said:
but they don’t want you logging PIC unless you’re the skipper.
Click to expand...
You can log it any way you want, consistent with the FAR’s. An airline doesn’t really care how you log PIC, whether sole manipulator or acting so long as you document what they are looking for. Once you get hired, the airline couldn’t care less how you log it because they have a record of your flight time with the airline.
 
Greg Bockelman said:
You can log it any way you want, consistent with the FAR’s. An airline doesn’t really care how you log PIC, whether sole manipulator or acting so long as you document what they are looking for. Once you get hired, the airline couldn’t care less how you log it because they have a record of your flight time with the airline.
Click to expand...
Pretty sure almost every airline only wants you to put down turbine PIC time that you were actually “signing for the plane PIC time.”l I’m talking about the application. Of course they don’t care what you log after you get hired.
 
Last edited:
So, if you have an SIC type rating but happen to be flying in a Citation 560 with a pilot who is qualified as a single pilot in the C560, if you are manipulating the controls then you get to log PIC time right.... What if he was under the hood? :biggrin:
 
Greg Bockelman said:
You can log it any way you want, consistent with the FAR’s. An airline doesn’t really care how you log PIC, whether sole manipulator or acting so long as you document what they are looking for. Once you get hired, the airline couldn’t care less how you log it because they have a record of your flight time with the airline.
Click to expand...
This.

I've seen this discussion of "what the airlines want" as long as I have participated in online aviation forums, as though they somehow supersede the FAA rules.

it's really no different than what most of us do when we annually report flight time to our insurer. Our logbooks are a data repository. In addition to 61.51 stuff, we use extra columns to collect unofficial data we will need to report. Then we query the data to report what the requester wants to know.

Bear in mind that if you are putting "signing for the airplane" in the FAA PIC column when you don't meet the 61.51 requirements for doing so, you are technically making false entries.
 
jordane93 said:
Pretty sure almost every airline only wants you to put down turbine PIC time that you were actually “signing for the plane PIC time.”l I’m talking about the application.
Click to expand...
if you are talking about the application only, I agree. If you are saying the airlines want to see ONLY turbine PIC that the pilot was “signing for the airplane” in the logbook, on that, I strongly disagree.
 
midlifeflyer said:
This.

I've seen this discussion of "what the airlines want" as long as I have participated in online aviation forums, as though they somehow supersede the FAA rules.

it's really no different than what most of us do when we annually report flight time to our insurer. Our logbooks are a data repository. In addition to 61.51 stuff, we use extra columns to collect unofficial data we will need to report. Then we query the data to report what the requester wants to know.

Bear in mind that if you are putting "signing for the airplane" in the FAA PIC column when you don't meet the 61.51 requirements for doing so, you are technically making false entries.
Click to expand...
How is it possible to “sign for the airplane” and not meet 61.51?

I think it’s more likely to go the other way. The “sign for the airplane” column would be more restrictive than 61.51.
 
Thanks all so far. Hopefully somebody who has also flown in this kind of a "two-Captain" environment will share their experiences or policies - "yes, that's exactly what we do at FlexNetJetsUp", or "no, we do this, because...".

flyingron said:
The FAA has no concept of "signing" pilot. You either are PIC or not (and PF/PM really is immaterial, the PIC may be PM or PF). Your operation may designate the "signing pilot" as doing the PIC role, than that is the case. However, being PIC is not a necessary nor sufficient condition to log it.
Click to expand...

That statement is in direct contradiction to 61.51e1iii, which allows the person acting as PIC of a two-pilot operation to log PIC. The "acting as PIC" is the 1.1 definition of PIC as "Has final authority and responsibility for the operation and safety of the flight". So, okay, the words, "signs as PIC" isn't in there, but that's what's usually meant in these discussions - the person designated the PIC by the company, responsible for the flight, i.e. "signing" for the airplane (I don't know about other operations like this, but we actually do physically "sign" for the airplane in the airplane logbook.)

midlifeflyer said:
If I were logging PIC for a non-FAA purpose, I would create a custom column or field for it. We do that all the time. People log complex, high performance, tailwheel hours, and more recently, glass. Mostly to fill out non+FAA applications.
Click to expand...

Mark, while I understand what you're saying, I'm not exactly sure how it's applicable here. After all, after logging for currency and any requirements for additional ratings, pretty much ALL additional logging could be called "for non-FAA purposes". And certainly most people in the situation I pose are beyond having to log time to meet requirements for a rating. So in that sense, there's no need to log anything, or I could call it all "I'm an awesome pilot" time. But I want to make sure I'm logging it correctly.

jordane93 said:
If you plan on going to the airlines, all they care about is “signing for airplane PIC,” which isn’t really a thing but they don’t want you logging PIC unless you’re the skipper. Of course you can log PIC when you’re sole manipulator but that time won’t count for pretty much any airline application you apply to.
Click to expand...

No desire or intention to go to the airlines. I know that's rare to hear these days!
 
RussR said:
Mark, while I understand what you're saying, I'm not exactly sure how it's applicable here. After all, after logging for currency and any requirements for additional ratings, pretty much ALL additional logging could be called "for non-FAA purposes". And certainly most people in the situation I pose are beyond having to log time to meet requirements for a rating. So in that sense, there's no need to log anything, or I could call it all "I'm an awesome pilot" time. But I want to make sure I'm logging it correctly.
Click to expand...
I'm not sure you understand what I am saying. What I mean is that there are columns dedicated to logging for FAA purposes - qualification and currency. No, you don't have to log everything, but if you log anything in those columns, they should contain only what is stated in the regulation. If you put something in the PIC column, is should meet 61.51(e). If you want to call something else PIC. it should go somewhere else. If you want to limit the column to "signing for" and leave out things, that's OK too.
 
RussR said:
That statement is in direct contradiction to 61.51e1iii, which allows the person acting as PIC of a two-pilot operation to log PIC. The "acting as PIC" is the 1.1 definition of PIC as "Has final authority and responsibility for the operation and safety of the flight". So, okay, the words, "signs as PIC" isn't in there, but that's what's usually meant in these discussions - the person designated the PIC by the company, responsible for the flight, i.e. "signing" for the airplane (I don't know about other operations like this, but we actually do physically "sign" for the airplane in the airplane logbook.)
''
Click to expand...

Nothing I said is in contradiction. As I clearly stated "signing for" isn't part of the regs, but if the airline considers the PIC to be the one who signs for it, then that is the PIC (and has all the rights and responsibilites of the same).

But again, being PIC is not a necessary or sufficient condition to log PIC (you have to understand what that term means in logic). If you you want to log PIC because you are PIC then it has to be in one of the situations that the reg also describes (ATPs in ATP operations, multipilot ops under the regs or type certificate, etc...). And as always, there are a number of ways to log PIC without being PIC (sole manipulator, sole occupant, instructor giving instruction).

In the situation described here, the pilot as not in ATP operation (part 135/91 was the basic premise). So the ATP stuff is out. Next you have to see if either the aircraft or the operation requires two pilots. It probably does, but there's all sorts of boundary cases such as single pilot 135 and part 91 ops in single pilot aircraft. Just because the operator CHOOSES to dump another body in the right seat doesn't make it a multipilot operation under 61.51(e).
 
flyingron said:
Nothing I said is in contradiction. As I clearly stated "signing for" isn't part of the regs, but if the airline considers the PIC to be the one who signs for it, then that is the PIC (and has all the rights and responsibilites of the same).

But again, being PIC is not a necessary or sufficient condition to log PIC (you have to understand what that term means in logic). If you you want to log PIC because you are PIC then it has to be in one of the situations that the reg also describes (ATPs in ATP operations, multipilot ops under the regs or type certificate, etc...). And as always, there are a number of ways to log PIC without being PIC (sole manipulator, sole occupant, instructor giving instruction).

In the situation described here, the pilot as not in ATP operation (part 135/91 was the basic premise). So the ATP stuff is out. Next you have to see if either the aircraft or the operation requires two pilots. It probably does, but there's all sorts of boundary cases such as single pilot 135 and part 91 ops in single pilot aircraft. Just because the operator CHOOSES to dump another body in the right seat doesn't make it a multipilot operation under 61.51(e).
Click to expand...

Okay, I see the issue, I did not mention that our two-pilot crew is not two pilots by choice, but by regulation. I had intended to make that clear, but failed to do so. The "choice" here is that we could operate with a PIC-rated and a SIC-rated pilot, but generally operate with two PIC-rated pilots.
 
midlifeflyer said:
I'm not sure you understand what I am saying. What I mean is that there are columns dedicated to logging for FAA purposes - qualification and currency. No, you don't have to log everything, but if you log anything in those columns, they should contain only what is stated in the regulation. If you put something in the PIC column, is should meet 61.51(e). If you want to call something else PIC. it should go somewhere else. If you want to limit the column to "signing for" and leave out things, that's OK too.
Click to expand...

Probably confusion resulting from the same answer I just gave in the previous post - I had intended to make it clear that this is a two-pilot required crew, not an optional second pilot. With that in mind, all "acting PIC" time IS 61.51e PIC time.
 
Tarheelpilot said:
How is it possible to “sign for the airplane” and not meet 61.51?

I think it’s more likely to go the other way. The “sign for the airplane” column would be more restrictive than 61.51.
Click to expand...
I'm taking "signed for the airplane" to mean you have PIC authority over the flight.

1. It's a single pilot operation. No SIC or other pilot crewmember required. You sign for the airplane and are PIC. Your not-required copilot flies the entire leg. You are PIC. You may log nothing under 61.51.

2. You and a friend rent an airplane from an FBO. You are authorized to rent. Your friend is not. You rent the airplane let your friend do all the flying (no hood). You have signed for the airplane. You are PIC. You may log zero under 61.51.

3. You are an instrument-rated pilot. Your friend is not. You go up into actual together. You let your friend do the flying in actual. You are PIC. You may not log any of the time your fiend is flying, not even the time in actual.
 
RussR said:
Thanks all so far. Hopefully somebody who has also flown in this kind of a "two-Captain" environment will share their experiences or policies - "yes, that's exactly what we do at FlexNetJetsUp", or "no, we do this, because...".



That statement is in direct contradiction to 61.51e1iii, which allows the person acting as PIC of a two-pilot operation to log PIC. The "acting as PIC" is the 1.1 definition of PIC as "Has final authority and responsibility for the operation and safety of the flight". So, okay, the words, "signs as PIC" isn't in there, but that's what's usually meant in these discussions - the person designated the PIC by the company, responsible for the flight, i.e. "signing" for the airplane (I don't know about other operations like this, but we actually do physically "sign" for the airplane in the airplane logbook.)



Mark, while I understand what you're saying, I'm not exactly sure how it's applicable here. After all, after logging for currency and any requirements for additional ratings, pretty much ALL additional logging could be called "for non-FAA purposes". And certainly most people in the situation I pose are beyond having to log time to meet requirements for a rating. So in that sense, there's no need to log anything, or I could call it all "I'm an awesome pilot" time. But I want to make sure I'm logging it correctly.



No desire or intention to go to the airlines. I know that's rare to hear these days!
Click to expand...
I used to fly for a fractional ownership outfit.
The company always designated a captain, and as such always logged PIC. There were never two *fully* Capt qualified pilots together.
The second guy, although ATP and fully typed, did not do an annual line check, therefor was not qualed on live legs. I have no idea what they logged on empty repositioning legs.
 
RussR said:
Probably confusion resulting from the same answer I just gave in the previous post - I had intended to make it clear that this is a two-pilot required crew, not an optional second pilot. With that in mind, all "acting PIC" time IS 61.51e PIC time.
Click to expand...
Yes it is.

I think the issue in your situation is not for the PIC but for the SIC. The flying SIC is in the situation of being able to log SIC by virtue of 61.51(f) and PIC by virtue of 61.51(e). There's a discussion of this (among other things) in the 2015 Murphy interpretation. Apparently the Chief Counsel doesn't like it because of the (very remote) possibility a pilot might double count the time by adding them together in some application, but there's really nothing preventing if the pilot thinks both are worthwhile for something.

1700412091370.png

But I still don't know what you mean by "co-Captains."
 
midlifeflyer said:
I'm taking "signed for the airplane" to mean you have PIC authority over the flight.

1. It's a single pilot operation. No SIC or other pilot crewmember required. You sign for the airplane and are PIC. Your not-required copilot flies the entire leg. You are PIC. You may log nothing under 61.51.

2. You and a friend rent an airplane from an FBO. You are authorized to rent. Your friend is not. You rent the airplane let your friend do all the flying (no hood). You have signed for the airplane. You are PIC. You may log zero under 61.51.

3. You are an instrument-rated pilot. Your friend is not. You go up into actual together. You let your friend do the flying in actual. You are PIC. You may not log any of the time your fiend is flying, not even the time in actual.
Click to expand...
None of those apply to the discussion with the exception of perhaps number one but even that is a stretch. Opportunities to have someone not required to be in the seat doing all the flying are rare in commercial ops especially if an operating certificate is required.

But you are correct. If we were talking about any scenario imaginable they would be germane but we are not. The OP was asking about the specific scenario that exists at his part 135 job.
 
Kritchlow said:
I used to fly for a fractional ownership outfit.
The company always designated a captain, and as such always logged PIC. There were never two *fully* Capt qualified pilots together.
The second guy, although ATP and fully typed, did not do an annual line check, therefor was not qualed on live legs. I have no idea what they logged on empty repositioning legs.
Click to expand...
135.299 is an “acting” PIC reg (”serve as pilot in command”), not a logging reg.
 
t
MauleSkinner said:
135.299 is an “acting” PIC reg (”serve as pilot in command”), not a logging reg.
Click to expand...
Whatever. It was a required two pilot jet and the other guy was not qualed to be pic on live legs.

Point is we were asked how we did it, and I told them.
 
Kritchlow said:
t

Whatever. It was a required two pilot jet and the other guy was not qualed to be pic on live legs.

Point is we were asked how we did it, and I told them.
Click to expand...
He wasn’t qualified to bePic, but he was qualified to log it if he flew the leg, live or repositioning.
 
MauleSkinner said:
He wasn’t qualified to bePic, but he was qualified to log it if he flew the leg, live or repositioning.
Click to expand...
Again, I wasn’t asked about a reg. I was asked how we did it. That’s how we did it.
 
midlifeflyer said:
Yes it is.

I think the issue in your situation is not for the PIC but for the SIC. The flying SIC is in the situation of being able to log SIC by virtue of 61.51(f) and PIC by virtue of 61.51(e). There's a discussion of this (among other things) in the 2015 Murphy interpretation. Apparently the Chief Counsel doesn't like it because of the (very remote) possibility a pilot might double count the time by adding them together in some application, but there's really nothing preventing if the pilot thinks both are worthwhile for something.

View attachment 122491

But I still don't know what you mean by "co-Captains."
Click to expand...
Co-captains is often used to describe flight departments where everyone is dual seat qualified on the certificate. Whether or not that was the OP’s situation is an assumption. That was the case for me at one of my 135 jobs. I didn’t make it complicated. When I was in the right seat I logged SIC regardless of PF/PM. If I was in the left seat and signed the weight&balance in the crash envelope then I logged PIC.

The side bar discussion nestled in this thread about airline applications really comes down to this: When HR people at airlines ask how much PIC turbine an applicant has they want to know when you were the captain of the operation. They don’t give a hairy **** if you were sole manipulator and rated. They want to know when you were the final authority for the safe operation of an aircraft.

The regulations allow the logging of PIC when you are not the final authority of the flight. I, personally, did not log PIC in those scenarios because I’m lazy and did not want to keep a separate accounting of PIC for the purposes of an airline application.

And yes. People make this way more complicated than necessary.
 
Tarheelpilot said:
The side bar discussion nestled in this thread about airline applications really comes down to this: When HR people at airlines ask how much PIC turbine an applicant has they want to know when you were the captain of the operation. They don’t give a hairy **** if you were sole manipulator and rated. They want to know when you were the final authority for the safe operation of an aircraft.
Click to expand...
Part of the problem is that the airlines are not consistent about it. I've seen multiple discussions through the years about safety pilot PIC time. Its obvious why the airlines don't give a hairy *** about your safety pilot PIC time in a Cessna 152, but it is, by FAA definition, time "when you were the final authority for the safe operation of an aircraft."

Which is exactly the point of saying that your logbook is data and you (a) log for the FAA per 61.51, (b) log non-FAA variations separately, and (c) report what the request asks for. The asker not giving a hairy *** about the FAA's rules of logging is not a reason to avoid them.
 
midlifeflyer said:
Part of the problem is that the airlines are not consistent about it. I've seen multiple discussions through the years about safety pilot PIC time. Its obvious why the airlines don't give a hairy *** about your safety pilot PIC time in a Cessna 152, but it is, by FAA definition, time "when you were the final authority for the safe operation of an aircraft."

Which is exactly the point of saying that your logbook is data and you (a) log for the FAA per 61.51, (b) log non-FAA variations separately, and (c) report what the request asks for. The asker not giving a hairy *** about the FAA's rules of logging is not a reason to avoid them.
Click to expand...
Just because the regulations allow me to log PIC does not mean I have to log PIC.

Airlines would not have a problem with you logging PIC as a safety pilot.

No one is talking about safety pilot time in a bug smasher.

You keep bringing up the little airplane stuff and it’s not relevant to this discussion.
 
Tarheelpilot said:
You just made me very jealous. I’m glad you had the opportunity to fly with your Dad. That’s awesome
Click to expand...
It was pretty good most of the time, but he is the only person I’ve ever gotten into an argument with rolling down the runway prior to V1. :eek:
 
You must log in or register to reply here.
Back
Top