Another Logging Question

TMetzinger

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Tim
61.51 is silent on who may log X/C time and under what conditions.

FAR 1 defines X/C time as any flight that departs one places and lands somewhere else.

We've covered the distance requirements to use the X/C time for certain certificates and ratings.

What I want to know is - what do my fellow instructors do when they take a student on a cross-country instructional flight. Obviously you may log the flight time and PIC time under 61.51.

Do you log the X/C time?
 
I don't recall. I will have to check my books. I think I just logged it as PIC with no XC because to me it just looks weird to have 0 takeoffs 0 landings and 2.0 XC time in the book.
 
What does an airline pilot log when he's the pilot not flying?
 
I only log the landings and takeoffs I actually perform
 
Maybe you CFI types should think outside the box and log time as "instruction given".
 
Maybe you CFI types should think outside the box and log time as "instruction given".
And exactly which part of 61.51 or any of the currency or other logging regs calls for logging "instruction given"? There was some proposal about 10 or so years ago from the FAA to include "instruction given" totals on the 8710. Then someone pointed out that there was no requirement to log it.

CFI giving instruction is a basis for logging other things that are needed to be logged to count toward experience requirements. "Instruction given" by itself is meaningless.
 
I asked the question of the FAA Chief Counsel on the "safety pilot" situation with respect to XC time, and the answer was "No, only one person can log XC", but the reasoning was that the SP could not log time during the T/O and Landing portions of the flight, which a CFI can.

http://www.faa.gov/about/office_org...interpretations/data/interps/2009/Gebhart.pdf
Problem with the series of cross country opinions is that they are result-oriented to reflect a policy decision that the FAA just doesn't want a non-flying safety pilot to be able to count the flight toward the cross country requirements for advanced certificates and ratings.

That policy probably doesn't' apply to CFIs, who have certain special powers and abilities far beyond those of mortal men (like not having to be landing current with even a first-lesson student pilot or being considered to have "performed" an instrument approach when just sitting there with a certificated instrument pilot).
 
I always log the time spent teaching as instruction given (and separate ground and flight), since in order to train CFIs you have to be on your second cycle and have given at least 40 hours of ground instruction and 200 hours of flight instruction. (61.195.h)

I only log takeoffs and landings that I make as an instructor - my hands must be on the controls for me to log it (but that's just MY standard). I log total time, night time if applicable, PIC, and flight instruction given, and based on the consensus at my school I am going to log X/C time for those flights too.

I could technically log all my flights from point a to point b as X/C, but I have all the X/C time I need for any rating already, so I'll just continue to log those flights longer than 50 NM.
 
I only log takeoffs and landings that I make as an instructor - my hands must be on the controls for me to log it (but that's just MY standard).
It's the FAA's standard also. Actually, not only hands on the controls, but the only one whose hands are manipulating the controls.

I know... that's "just" for currency. But what else are you logging landings for and if it's for someone else, how can the FAA tell from you logbook which count for currency and which don't?
 
It's the FAA's standard also. Actually, not only hands on the controls, but the only one whose hands are manipulating the controls.

Is that in a reg or published counsel opinion? I don't disagree, but I don't recall seeing it in writing anywhere.
 
Is that in a reg or published counsel opinion? I don't disagree, but I don't recall seeing it in writing anywhere.

61.57(a)(1)
"that persobn has made at least three takeoffs and three landings within the preceeding 90 days, and --
(i) The person acted as the sole manipulator of the flight controls; and
..."
 
Is that in a reg or published counsel opinion? I don't disagree, but I don't recall seeing it in writing anywhere.


Its at least a counsel opinion. I forget which one, Jeff may have posted the one I read regarding safety pilots, but it seems the person doing the actual take off and landing that gets the X/C time. So, if you are an instructor logging PIC time, if you're student is manipulator the entire time, you may not log the x/c time. I think.
 
The reg. "sole manipulator" for logging landings.

but that has nothing to do with logging the flight or the cross country time.
That's the way I look at it. Cross country, night and actual are all conditions of flight which both pilots can log if two pilots are required. Landings and instrument approaches can only be logged by the pilot who did them.
 
...and how does the FAA enforce this?
Same way as for most fraudulent logbook entries - in the context of having a reason to question the pilot's credentials. The pilot may have indicated the role of "safety pilot." Or properly logged SIC and/or flight time without PIC time.

I guess the related question is - is this about understanding and choosing whether or not to follow the rules or about getting caught?
 
That's the way I look at it. Cross country, night and actual are all conditions of flight which both pilots can log if two pilots are required. Landings and instrument approaches can only be logged by the pilot who did them.

Cross country by definition requires a point of landing at a point other than the point of departure. (yes, distance varies depending on how the experience is used), but, only one pilot is doing the landing. Therefore, two pilots can not both log cross country time.

61.1 (b) 3

Without seeing an interpretation, i'm not sure there is any way in a trainer like a 172, where two pilots can both log cross country at the same time for the same flight.

During a flight which involves a safety pilot, the second the sole manipulator removes the view restricting device, there is no longer a need for a second pilot.
 
Cross country by definition requires a point of landing at a point other than the point of departure. (yes, distance varies depending on how the experience is used), but, only one pilot is doing the landing. Therefore, two pilots can not both log cross country time.

61.1 (b) 3

Without seeing an interpretation, i'm not sure there is any way in a trainer like a 172, where two pilots can both log cross country at the same time for the same flight.

During a flight which involves a safety pilot, the second the sole manipulator removes the view restricting device, there is no longer a need for a second pilot.

That's the essence of the Gebhart interpretation, yes.

However, with a CFI on board, the CFI can log all of the time from when the plane first moves under its own power for the purpose of flight to when it comes to a stop...including the time during takeoff and landing. This is the same as a aircraft type-certificated for 2 crewmembers, in that both crew members are required for the entire flight, and as such can log the entire flight time, where a safety pilot can only log while the hood is on.
 
Cross country by definition requires a point of landing at a point other than the point of departure.
That does not apply to cross countries for the purpose of meeting the aeronautical requirements for an ATP. No landings are necessary.

61.3 (b)(3)
(vi) For the purpose of meeting the aeronautical experience requirements for an airline transport pilot certificate (except with a rotorcraft category rating), time acquired during a flight—

(A) Conducted in an appropriate aircraft;

(B ) That is at least a straight-line distance of more than 50 nautical miles from the original point of departure; and

(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems.
Even if you are using the other definition of cross-country it doesn't say that you need to personally make the landings for it to qualify as cross-country. The one caveat is that both pilots must be required for the operation, though. So I would say CFI and student would count and so would safety pilot and person under the hood (as long as they were under the hood long enough to meet the distance requirement). Two pilots flying a generic flight in a 172 would not count, though.
 
I forgot about the ATP definition.

Maybe I'm misreading your post, but the Gebhart interpretation seems to state that even if there is a safety pilot, and there are two pilots onboard, only the pilot doing the physical landing can count it as cross country time.


Your letter presents an example to illustrate your questions. In the example, Pilot A and
Pilot B, who both are rated in the aircraft, take a flight between two airports that are
separated by 187 nautical miles. As agreed to prior to the flight, Pilot A flies the aircraft and
Pilot B acts as the PIC. Although the flight is conducted in visual meteorological
conditions, Pilot A operates the aircraft in simulated instrument flight with Pilot B acting as
a safety pilot. The total flight time is 2.2 hours and the total simulated instrument time is 2.0
hours. Your letter asks how much PIC flight time and cross-country flight time can be
logged by Pilots A and B.
Section 61.51(e) governs the logging of PIC time and states, in relevant part, that a sport,
recreational, private, or commercial pilot may log PIC time for the time during which that
pilot is "the sole manipulator of the controls of an aircraft for which the pilot is rated or has
privileges" or "acting as pilot in command of an aircraft on which more than one pilot is
required under ... the regulations under which the flight is conducted."
In your example, Pilot A may log the entire flight (2.2 hours) of PIC flight time because that
pilot was the sole manipulator of the controls for the entire flight. Pilot B may log the
portion of the flight during which Pilot A operated in simulated instrument flight and Pilot B
acted as the safety pilot (2.0 hours) because Pilot B was a required flight crewmember for
that portion of the flight under 14 C.F.R. § 91.109(b).
Section 61.65 requires, in relevant part, that an applicant for an instrument rating log 50
hours of cross-country flight time as pilot in command. Cross-country time is defined in 14
C.F .R. § 61.1 (b)(3)(ii) as time acquired during a flight conducted in an appropriate aircraft
that "includes a point oflanding that was at least a straight-line distance of more than 50
nautical miles from the original point of departure" and that "involves the use of dead
reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to
navigate to the landing point."
A safety pilot provides a visual reference to the ground and other aircraft during the portion
ofthe flight when the pilot manipulating the controls is flying with a view-limiting device.
As discussed above, the safety pilot is a required flight crewmember for only a portion of the
flight. Section 61.65(d) contemplates that only the pilot conducting the entire flight,
including takeoff, landing, and en route flight, as a required flight crewmember may log
cross-country flight time. Because a safety pilot does not conduct the entire flight, a person
acting as a safety pilot for a portion of the flight may not log any cross-country flight time
for the flight. In your example, Pilot A may log the entire flight (2.2 hours) of cross-country
flight time because that pilot conducted the entire flight. However, Pilot B may not log any
cross-country flight time because that pilot was a required flight crewmember for only a​
portion of the flight.

But, I have no clue whatsoever, what a CFI does when with a primary student.
 
Maybe I'm misreading your post, but the Gebhart interpretation seems to state that even if there is a safety pilot, and there are two pilots onboard, only the pilot doing the physical landing can count it as cross country time.

That's because as soon as the PF removes the hood on approach, the SP becomes a passenger and thus not required.
 
I can follow that interpretation up until the point that says
Section 61.65(d) contemplates that only the pilot conducting the entire flight,
including takeoff, landing, and en route flight, as a required flight crewmember may log
cross-country flight time.

When I look up 61.65(d) it says
(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:

(1) Fifty hours of cross country flight time as pilot in command, of which 10 hours must have been in an airplane; and

(2) Forty hours of actual or simulated instrument time in the areas of operation listed in paragraph (c) of this section, of which 15 hours must have been received from an authorized instructor who holds an instrument-airplane rating, and the instrument time includes:

(i) Three hours of instrument flight training from an authorized instructor in an airplane that is appropriate to the instrument-airplane rating within 2 calendar months before the date of the practical test; and

(ii) Instrument flight training on cross country flight procedures, including one cross country flight in an airplane with an authorized instructor, that is performed under instrument flight rules, when a flight plan has been filed with an air traffic control facility, and that involves—

(A) A flight of 250 nautical miles along airways or by directed routing from an air traffic control facility;

(B) An instrument approach at each airport; and

(C) Three different kinds of approaches with the use of navigation systems.
I think they are referring to the bolded statement. I know that some people log PIC as the safety pilot but that seems strange because then you would need to switch acting PICs as soon as the SIC's hood comes off. So in that case neither pilot has done the whole flight as PIC even though Pilot A can log it as sole manipulator. I was thinking of the more normal situation where the safety pilot is the SIC. In that case 61.65(d) wouldn't seem to apply, and that is what the interpretation uses as justification.
 
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I know that some people log PIC as the safety pilot but that seems strange because then you would need to switch acting PICs as soon as the SIC's hood comes off.

Why? If the safety pilot is acting PIC, they can be so for the whole flight - They just can't log the time the PF is not under the hood.
 
Why? If the safety pilot is acting PIC, they can be so for the whole flight - They just can't log the time the PF is not under the hood.
OK but doesn't that defeat the purpose for the PF since the reg says "Fifty hours of cross country flight time as pilot in command". To me, "as pilot in command" means the acting one, not the logging one. But then I'm not the FAA. :rofl:

Actually I've never experienced that situation (safety pilot as PIC), although I've heard that it is done.
 
Hmmm Interesting. Do people distinguish time that they "logged" versus time they "acted" PIC? Because, you're right, it does say "As PIC".
 
OK but doesn't that defeat the purpose for the PF since the reg says "Fifty hours of cross country flight time as pilot in command". To me, "as pilot in command" means the acting one, not the logging one. But then I'm not the FAA. :rofl:

Well, in the context of cross country...

Okay, this crap makes no sense any more. :crazy: :D

Actually I've never experienced that situation (safety pilot as PIC), although I've heard that it is done.

I've done it once or twice...

Hmmm Interesting. Do people distinguish time that they "logged" versus time they "acted" PIC? Because, you're right, it does say "As PIC".

I distinguish it as follows: I log the time as PIC if I'm legal to log PIC, and I don't log the time that I'm only acting PIC but can't log it. ;)

For an example of the above - Let's say I go flying with a friend in my airplane and let them fly the entire flight. I must act as PIC due to my insurance and that's made clear beforehand. What do I log in this scenario? Not a damn thing, because it's not legal for me to log anything in this scenario. You can be the pilot in command all day long, but unless you're manipulating the controls yourself, you can't log it in a one-pilot-required operation unless you're a CFI or a couple of other rare exceptions.
 
OK but doesn't that defeat the purpose for the PF since the reg says "Fifty hours of cross country flight time as pilot in command". To me, "as pilot in command" means the acting one, not the logging one. But then I'm not the FAA. :rofl:

Actually I've never experienced that situation (safety pilot as PIC), although I've heard that it is done.

The scenario presented (I have the letter somewhere) was:

Pilot A: Flying plane
Pilot B: Safety Pilot Acting As PIC

And they said Pilot A can log the XC time, but you're right...the reg doesn't really read that way does it? But then, my plain reading of the reg would allow Pilot B to log the XC time too, because the definition of Cross-Country is "time acquired in flight...that includes a point of landing other than the point of departure". There's nothing there that requires the person to log the takeoff or landing, just that the flight include such.
 
And they said Pilot A can log the XC time, but you're right...the reg doesn't really read that way does it? But then, my plain reading of the reg would allow Pilot B to log the XC time too, because the definition of Cross-Country is "time acquired in flight...that includes a point of landing other than the point of departure". There's nothing there that requires the person to log the takeoff or landing, just that the flight include such.
Exactly, and that was what I was trying to say, awkwardly. I don't see where 61.65(d), which is stated as justification, says anything about landings. Also, someone could log SIC cross country on a flight, it just couldn't be used for this purpose.

In fact if you look at 61.159 which lists the requirements for an ATP you'll see that is requires 500 hours cross country of which 100 hours must be as PIC or SIC performing the duties of PIC so some of that cross country time can be SIC.

§ 61.159 Aeronautical experience: Airplane category rating.

(a) Except as provided in paragraphs (b), (c), and (d) of this section, a person who is applying for an airline transport pilot certificate with an airplane category and class rating must have at least 1,500 hours of total time as a pilot that includes at least:

(1) 500 hours of cross-country flight time.

>snip<

(4) 250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, which includes at least—

(i) 100 hours of cross-country flight time; and
 
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If I were making the rules, planning and navigating the flight would be a requirement for logging cross country time.
 
In fact if you look at 61.159 which lists the requirements for an ATP you'll see that is requires 500 hours cross country of which 100 hours must be as PIC or SIC performing the duties of PIC so some of that cross country time can be SIC.

What does "SIC performing the duties of PIC" mean? Does it just refer to being the pilot who is doing the flying, or is there more involved?
 
I must be on a different wavelength. What difference does it really make the specific task you do when you instruct? Does it matter whether you're VFR or IFR, landing or taking off? You are instructing.

That is said in the full knowledge that there could easily be extra requirements or boondoggles in byzantine world of FAA regulations of which I am blissfully unaware.
 
What does "SIC performing the duties of PIC" mean? Does it just refer to being the pilot who is doing the flying, or is there more involved?
I think this is mostly used in conjunction with SICs who are training to be PIC of a two-pilot airplane so they are performing PIC duties while being supervised by the "real" PIC. It doesn't mean necessarily doing the flying, but doing the flight planning, making decisions, etc. That's my interpretation, anyway but it's obvious that there are times that my interpretation doesn't coincide with the FAA's.
 
Cross country by definition requires a point of landing at a point other than the point of departure.
but by definition (read it) a cross-county is a "flight" that requires a point of landing....

So it is just as good an interpretation of the regulatory language to say that anyone who can log the flight time can log the xc, just like any other condition of flight - night, actual instrument, etc. And just like the FAA has said that a "real" SIC in a 2-pilot crew may log xc, not just the pilot who has taken off and landed (see the final scenario in the Glenn opinion - http://www.faa.gov/about/office_org...rpretations/data/interps/2009/Louis Glenn.pdf )

That's why I describe the safety pilot scenarios as where the FAA made a policy decision and then worked the reg to make it fit what they wanted.
 
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