Double Dip on PIC

[Direct C51]

We are all familiar with Part 61.51(e)(i):

"(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;"

Part 61.51(e)(iii) also sates:

"(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted;"

The aircraft flown is not type certified, but two pilots are required "under the regulations under which the flight is conducted." Could PIC time be logged both when you are the assigned PIC regardless of control manipulation per part 61.51(e)(iii) and when not assigned PIC but sole manipulator of the controls per part 61.51(e)(i)? Essentially making only the time not assigned PIC and not manipulating controls SIC? Or is it a one or the other situation?

 

[tlglenn]

There are circumstances under which two pilots can log PIC time. One scenario is a pilot building simulated instrument time as the sole manipulator of the controls while the safety pilot is acting as the legal PIC (btw, if the acting-PIC safety pilot is in the right seat make sure the insurance company approves).

 

[frfly172]

With two pilots required ,you're either pic or sic you can't be both . You can log pic as the safety pilot.

 

[flyingron]

With two pilots required ,you're either pic or sic you can't be both . You can log pic as the safety pilot.

You might actually be neither. Recent counsel opinions are that safety pilots are not "second in command" when not "pilot in command."

 

[Fearless Tower]

You might actually be neither. Recent counsel opinions are that safety pilots are not "second in command" when not "pilot in command."

Please cite....seems contrary to a very lengthy recent debate here.

 

[Greg Bockelman]

You might actually be neither. Recent counsel opinions are that safety pilots are not "second in command" when not "pilot in command."

Sort of like being able to log PIC without actually BEING PIC. A safety pilot can log SIC without actually BEING SIC.

 

[Fearless Tower]

Sort of like being able to log PIC without actually BEING PIC. A safety pilot can log SIC without actually BEING SIC.

That reminds me of an FAA interpretation a few years ago that said an Sic rated pilot could log PIC time while training for their PIC type rating.

 

[JeffDG]

There are scenarios where you can have at least 3 people logging PIC for a flight too.

 

[EdFred]

There are scenarios where you can have at least 3 people logging PIC for a flight too.

I can do you one better and go 4.

 

[JeffDG]

I can do you one better and go 4.

Yep, I can conceive of that scenario as well...

 

[Direct C51]

I understand the safety pilot thing, but it does not at all apply to my original question. My question refers to logging both time as the assigned PIC, per part 1.1 or part 61.51(e)(iii) and time not assigned PIC in an aircraft requiring two pilots under the regs in which the flight is conducted, but being the sole manipulator. This is not a safety pilot scenario. It is a 2 pilot required, not type certified aircraft.

 

[JeffDG]

I understand the safety pilot thing, but it does not at all apply to my original question. My question refers to logging both time as the assigned PIC, per part 1.1 or part 61.51(e)(iii) and time not assigned PIC in an aircraft requiring two pilots under the regs in which the flight is conducted, but being the sole manipulator. This is not a safety pilot scenario. It is a 2 pilot required, not type certified aircraft.

That is, actually, the same as a safety pilot scenario. The reason you can have two people log PIC with a safety pilot is that the regs require more than one crew-member. If a different regulation requires multiple crew members, then the same rule applies.

So, let's say you have a Part 135 flight, where the opspec requires two crew-members. The OpSpecs are approved by the FAA and have regulatory effect. The PIC for the flight does not do the flying, the SIC does the flying.

So, the PIC can log PIC time, because he was acting as PIC on a flight for which he was a required crew-member that required more than one crew-member.

The SIC can log PIC as the sole manipulator of the controls.

 

[poadeleted20]

I understand the safety pilot thing, but it does not at all apply to my original question. My question refers to logging both time as the assigned PIC, per part 1.1 or part 61.51(e)(iii) and time not assigned PIC in an aircraft requiring two pilots under the regs in which the flight is conducted, but being the sole manipulator. This is not a safety pilot scenario. It is a 2 pilot required, not type certified aircraft.

As long as you are "rated" in the aircraft (i.e., you have all the appropriate category, class, and type ratings on your pilot certificate), you can log PIC time while being the sole manipulator of the controls regardless of whether you are actually the PIC or not. That question has been asked of and answered by the FAA Chief Counsel more times than I have toes. One question which has not been asked/answered is whether a SIC type rating per 61.55 (as opposed to a PIC type rating per 61.31/61.63) makes you "rated" for this purpose -- and I can see arguments the Chief Counsel might make both ways on that, perhaps depending on what the staff attorney writing the letter had for breakfast that morning.

OTOH, if you are the PIC of a 2-pilots aircraft or when a second pilot is otherwise required by the FAA, then you can log all the time as PIC time even when the second pilot is the sole manipulator. Note that if the second pilot is required only because the pilot flying is using a vision restricting device, the PIC can only log the time the hood is on, since that's the only time two pilots are required by the FAA.

 

[poadeleted20]

So, let's say you have a Part 135 flight, where the opspec requires two crew-members. The OpSpecs are approved by the FAA and have regulatory effect. The PIC for the flight does not do the flying, the SIC does the flying.

So, the PIC can log PIC time, because he was acting as PIC on a flight for which he was a required crew-member that required more than one crew-member.

The SIC can log PIC as the sole manipulator of the controls.

Not without being "rated" in the aircraft, which would include the appropriate type rating if that aircraft requires a type rating (e.g., multi-engine jet). Since SIC's do not require a type rating, many don't have one, and those SIC's cannot log PIC time in that aircraft at all. Whether an SIC type rating per 61.55 suffices for this is unknown, but I would guess not.

 

[Fearless Tower]

Not without being "rated" in the aircraft, which would include the appropriate type rating if that aircraft requires a type rating (e.g., multi-engine jet). Since SIC's do not require a type rating, many don't have one, and those SIC's cannot log PIC time in that aircraft at all. Whether an SIC type rating per 61.55 suffices for this is unknown, but I would guess not.

With your research skills, you can probably find it quicker than I can, but there was an interpretation within the last 5-10 years that said a pilot who was already SIC typed in an airplane could log PIC time as sole manipulator as long as they were doing so as training toward the PIC upgrade. Obviously, in that situation the other seat would be occupied by an instructor who is acting PIC.

 

[taters]

So, let's say you have a Part 135 flight, where the opspec requires two crew-members. The OpSpecs are approved by the FAA and have regulatory effect. The PIC for the flight does not do the flying, the SIC does the flying.

So, the PIC can log PIC time, because he was acting as PIC on a flight for which he was a required crew-member that required more than one crew-member.

The SIC can log PIC as the sole manipulator of the controls.

Just don't try that argument in a airline interview

 

[Direct C51]

So to be more specific, let's say someone was a military pilot with 1000 PC and 1000 PI time. Both pilots are rated in the aircraft obviously. You could log as PIC all 1000 PC time in a FAR compliant logbook, as well as any time spent on the controls as the PI? I know this changes the conversation a bit. Any interpretation based on this scenario of non certified military aircraft requiring 2 pilots where a type rating does not exist?

 

[Fearless Tower]

Just don't try that argument in a airline interview

Unless you are already hired. Not quite the same as what Jeff was describing, but in the case I read, the argument was that they wanted to count the time training on the PIC type toward either PIC mins for either insurance or required mins on the 135 certificate.

 

[poadeleted20]

With your research skills, you can probably find it quicker than I can, but there was an interpretation within the last 5-10 years that said a pilot who was already SIC typed in an airplane could log PIC time as sole manipulator as long as they were doing so as training toward the PIC upgrade. Obviously, in that situation the other seat would be occupied by an instructor who is acting PIC.

That is clearly covered in 61.51 -- see paragraph (e)(1)(iv), and note that it is limited to an "approved pilot in command training program", which means a formal FAA-approved training program such as 121/135 operators have, not routine commercial operations or Part 91 flying.

 

[poadeleted20]

So to be more specific, let's say someone was a military pilot with 1000 PC and 1000 PI time. Both pilots are rated in the aircraft obviously. You could log as PIC all 1000 PC time in a FAR compliant logbook, as well as any time spent on the controls as the PI? I know this changes the conversation a bit. Any interpretation based on this scenario of non certified military aircraft requiring 2 pilots where a type rating does not exist?

IIRC from a discussion with another former Army aviator, PI time could include time as SIC without being the sole manipulator. That time could not be counted as PIC time for FAA purposes, so you'd need a breakdown of how much of your PI time was hands-on. Also, IIRC, student aviators log PI time while being trained by an instructor, and that also would not count as PIC time (only their solo time, which I'm guessing would be PC time). And I've seen no interpretations from the Chief Counsel on this point, only the regulations themselves.

 

[Velocity173]

So to be more specific, let's say someone was a military pilot with 1000 PC and 1000 PI time. Both pilots are rated in the aircraft obviously. You could log as PIC all 1000 PC time in a FAR compliant logbook, as well as any time spent on the controls as the PI? I know this changes the conversation a bit. Any interpretation based on this scenario of non certified military aircraft requiring 2 pilots where a type rating does not exist?

You're talking about 64 time correct? Yes you can log PIC in your civ logbooks as long as you're the sole manipulator of the controls. You're category and class rated and there is no FAA type rating requirment for 64s. The 60 community has been logging as such for quite some time now. It's a little more gray these days because a couple years ago the FAA created an S-70 type rating so now some are wondering if they're required to get that in order to log PIC???

Obviously guys are doing this to get the min PIC time that civ jobs require. The problem with this is your 759 not reflecting your civ logbook. Some employers don't mind while some want briefed, acting PIC and not sole manipulator PIC. You could have some dude who spent years as a PI in the Army with a crapload of PIC time in their logs. An employer should be able to see right through that.

 

[taters]

most employers will ask you to provide PIC time as "the captain signing for the aircraft" etc etc they all have ways of qualifying your logbook to reality

 

[Direct C51]

Yeah 64 time. I've heard guys talk about it both ways and am trying to figure out what is the right way. I meet the minimum PIC requirements for what I want, but don't want to lose out on a job because I didn't also count sole manipulator PI time when someone else did. I've had guys tell me not to sell myself short on this stuff, civilian pilots certainly are not, but I don't want to show up looking like I fudged my numbers and lose credibility. I can see the FARs being interpreted both ways. I guess I'm searching for an industry standard on how it is to be done.

 

[Fearless Tower]

Yeah 64 time. I've heard guys talk about it both ways and am trying to figure out what is the right way. I meet the minimum PIC requirements for what I want, but don't want to lose out on a job because I didn't also count sole manipulator PI time when someone else did. I've had guys tell me not to sell myself short on this stuff, civilian pilots certainly are not, but I don't want to show up looking like I fudged my numbers and lose credibility. I can see the FARs being interpreted both ways. I guess I'm searching for an industry standard on how it is to be done.

Caveat: I'm no hiring agent for an airline, but from what I've gathered, if it is a few hours here and there, probably isn't going to hurt you in a logbook review. On the other hand, of half of your PIC time is built that way, it probably isn't going to look too good.

 

[TMetzinger]

Yeah 64 time. I've heard guys talk about it both ways and am trying to figure out what is the right way. I meet the minimum PIC requirements for what I want, but don't want to lose out on a job because I didn't also count sole manipulator PI time when someone else did. I've had guys tell me not to sell myself short on this stuff, civilian pilots certainly are not, but I don't want to show up looking like I fudged my numbers and lose credibility. I can see the FARs being interpreted both ways. I guess I'm searching for an industry standard on how it is to be done.

Not sure there is one... but if it's not clear in the application process, no harm in asking.

 

[Velocity173]

Yeah 64 time. I've heard guys talk about it both ways and am trying to figure out what is the right way. I meet the minimum PIC requirements for what I want, but don't want to lose out on a job because I didn't also count sole manipulator PI time when someone else did. I've had guys tell me not to sell myself short on this stuff, civilian pilots certainly are not, but I don't want to show up looking like I fudged my numbers and lose credibility. I can see the FARs being interpreted both ways. I guess I'm searching for an industry standard on how it is to be done.

You'll be good man. It's legal and I wouldn't feel guilty about logging either. As I said before, I only logged Army briefed PIC in my civ logs but I know plenty of guys putting sole manipulator in there as well. In your case being an MTP I wouldn't hesitate to log it. My friend got out last year as a 60 MTP and he logged it. Company that hired him didn't even care about the difference in 759 and his civ logs.

Also, remember the logging of time is different for Army definition and FAR 1 definition. As we talked about, you could add an extra .1 for each of your flights. A lot of the helo jobs have former military as hiring managers so they should know your 759 will be higher. That is, if they even look at anything.

 

[Direct C51]

Thanks for the input Mcfly. I figured this was the case, but I have heard both sides of the argument and wanted as much input as possible. I suppose I can always include it on my resume, and if questioned, can provide my unaltered logbook which would reflect my 759. It sounds like most of the HEMS companies are mostly concerned about minimums, but there is one that bases pay on flight hours and experience. Not sure what the extra 450 PIC and maybe 200 total time would do for a pay increase, but I'd hate to miss out on it.

 

[poadeleted20]

You're talking about 64 time correct? Yes you can log PIC in your civ logbooks as long as you're the sole manipulator of the controls. You're category and class rated and there is no FAA type rating requirment for 64s. The 60 community has been logging as such for quite some time now. It's a little more gray these days because a couple years ago the FAA created an S-70 type rating so now some are wondering if they're required to get that in order to log PIC???

Not for their military flying if they are PIC-qualified by the military. However, absent that PIC qual, no logging PIC time in your civilian pilot logbook if you're in a military aircraft that has an equivalent civilian type rating. Asked and answered years ago regarding KC-135's and the B707 type rating for a KC-135 co-pilot. However, since the AH-64 has no civilian equivalent, all a non-PIC-qualified person needs is a CP-RH ticket to count any AH-64 stick time as PIC time. Asked and answered years ago for an NFO with CP-AMEL flying as a CO-TAC in S-3's. The good news, however, for H-60 pilots is that if you are PIC-qualified in the H-60 in the military, that gets you an automatic S-70 type rating on your FAA ticket just by brining the military paperwork to the FSDO.

 

[poadeleted20]

Also, remember the logging of time is different for Army definition and FAR 1 definition. As we talked about, you could add an extra .1 for each of your flights.

You'd better be able to document that extra 0.1 if the FAA ever compares your civilian logbook to your Army flight records by showing the Army aircraft first moved under its own power at least 6 minutes before the Army times started.

 

[midlifeflyer]

Just don't try that argument in a airline interview

Yeah, airlines just HATE FAA rules and regulations.

Of course, if you're talking about an interview after filling out an application that describes what the airline considered countable PIC time for the airline's qualification purposes, why would one want to tell them something else

 

[Direct C51]

You'd better be able to document that extra 0.1 if the FAA ever compares your civilian logbook to your Army flight records by showing the Army aircraft first moved under its own power at least 6 minutes before the Army times started.

I would think adding a .1 to each logbook entry would suffice. I can't imagine being able to provide proof any other way. Who's to say I didn't ground taxi for at least 6 minutes prior to takeoff? From the moment I start my taxi until takeoff is almost always longer than 6 minutes, unless it's a QRF mission in Afghanistan.

 

[Velocity173]

You'd better be able to document that extra 0.1 if the FAA ever compares your civilian logbook to your Army flight records by showing the Army aircraft first moved under its own power at least 6 minutes before the Army times started.

Well I never used the extra time on my civ logs but it's easily explainable for turbine helicopter ops. First flight of the day requires a HIT check for the engines which has to be done into the wind. Combine that with a flight join up for departure and you'll be over 6 mins. C51 being a 64 MTP guy with all the checks he has to do on the ground, he could log it as well.

The thing is, when it comes to logging flight time, a PC can easily log heavy if they choose. Not sure about 64s but the 60 has no Hobbs. If the PC wants to log heavy because they're trying to set themselves up for a civ job when they get out, they can. It's definitely not an epidemic but I've come back from a multi ship flight on more than one occasion and chalk 2 was .1 or .2 more than me. It happens. What the Army needs a weight on gear system that logs only when airborne. Of course you'd still have to add the taxi time to that somehow.

 

[taters]

Caveat: I'm no hiring agent for an airline, but from what I've gathered, if it is a few hours here and there, probably isn't going to hurt you in a logbook review. On the other hand, of half of your PIC time is built that way, it probably isn't going to look too good.

My best friend just got on at southwest, they compared his logbook directly to what he entered into pilot credentials for the last 2 years, they were checking for accuracy ...that is getting picky picky. But yes people been known to "claim" pic turbine even though they were an FO flying as SIC, things usually don't go well for these folks, yes it might get you an interview , but that's about all.

 

[poadeleted20]

I would think adding a .1 to each logbook entry would suffice. I can't imagine being able to provide proof any other way. Who's to say I didn't ground taxi for at least 6 minutes prior to takeoff?

More like who's to say you did? You're the one who has to prove you actually got more FAA-definition flight time than the Army said you flew, not the other way around.

 

[flyingron]

Sort of like being able to log PIC without actually BEING PIC. A safety pilot can log SIC without actually BEING SIC.

Bullpoop. To log SIC you just legally be the SIC.

It's only the PIC logging rules where being PIC isn't a necessary nor sufficient condition to log PIC.

 

[flyingron]

Please cite....seems contrary to a very lengthy recent debate here.

It was generally assumed that a safety pilot (when they were not acting as PIC) was the second in command. This became problematic when they revised the SIC rules a few years ago and in the process of rearranging the sections, they removed the exemption that simulated instrument safety pilots didn't need to meet various SIC rules including actually possessing an instrument rating while IFR.

Since this appeared to have been inadvertent as the NPRM didn't mention it nor did any of the commenters who wrote voluminous comments about the other changes. I petitioned the FAA to restore it to how it read before, but a damn exasperating (now retired) person wrote a completely off the wall response including his assertion that the rules read that way before.

Anyhow, I was about to fight this battle again with C'Ron managed to dig up another cousel opinion that while the safety pilot is required crew, he wasn't "second in command" at all. The other Ron can post the letter. This hence rendered my argument on the SIC-Safety Pilot-Instrument Rating issue moot so I gave up and devoted my time to successfully fixing the definition of the word "night."

 

[poadeleted20]

Bullpoop. To log SIC you just legally be the SIC. It's only the PIC logging rules where being PIC isn't a necessary nor sufficient condition to log PIC.

Not according to the FAA Chief Counsel or 61.51(f)(2). See the regulation itself:

(f) Logging second-in-command time. A person may log second-in-command flight time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of Sec. 61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.

...and the following legal interpretations:
http://www.faa.gov/about/office_org...12/trussell - (2012) legal interpretation.pdf
http://www.faa.gov/about/office_org...2013/creech - (2013) legal interpretation.pdf
http://www.faa.gov/about/office_org.../2013/beaty - (2013) legal interpretation.pdf
In particular, see the following in the Beaty letter:

Because the aircraft is type certificated for a single pilot, and because the operation does not require a designated SIC (e.g. an operation conducted under 14 C.F.R. § 135.101 which requires an SIC under IFR), Pilot B is a safety pilot and not an SIC.

Nevertheless, despite not being a SIC, per the first two letters, that non-SIC safety pilot required by 14 CFR 91.109(c) may still log SIC time IAW 61.51(f)(2).​

​

​

As for the issue of holding an instrument rating when not acting as SIC, the Chief Counsel said in the next-to-last paragraph of that Beaty interpretation that a pilot serving only as safety pilot for 91.109(c) (i.e., not serving as SIC or PIC) need not hold that rating. Since the Chief Counsel says that instrument rating is not required for that person to serve only as safety pilot, the requirement for the instrument rating to log SIC time goes away.​