IFR Currency question ... a little different

Ron Levy said:
Not unless you're going to be PIC as well as safety pilot. Otherwise, the safety pilot only has to meet the safety pilot requirements, not the PIC requirements. While it's true that you need the applicable cat/class ratings on your PP or better certificate, you don't have to be able to act as PIC in that cat/class -- that would require a flight review and any applicable additional training endorsements, as well as currencies if you're flying IFR or with passengers.
Correct.
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Alright, so my example was completely incorrect. :)
 
dmccormack said:
No problem -- taken as intended. I think this thread is an example that the issue is clouded by nearly synonomous terms.

*I* know the difference between acting and logging, but I can't tell you a single PP I 've flown with that would do more than say "If I fly it, I log it."

:dunno:
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You're spot on with the "nearly synonymous terms" observation.

I bet those that are confused think "How can I log PIC if I didn't ACT as PIC"; to them it is the same as "how can I LOG multi-engine time if I didn't FLY multi-engine time". But they aren't the same thing; there is no corollary between the two.

If the FAA had, instead, used the terms "act as Captain" and "log piloting time", this would be easier to understand. In the meantime, mentally substitute or understand that, essentially, "act as PIC" = "act as captain" and "log PIC" = "log piloting time". You can do one without doing the other. Or two people can split those functions.
 
cfiiguy said:
first, i never said a medical was required to log flight time. it is needed to log PIC time in GA (non-LSA) aircraft. others have already pointed out your wrong on the training requirements and check requirements for instrument training. the hours required for the PP, given by a CFI, are not allowed towards the IR. (Sorry i dated myself with the ICC, old habits die hard) I guess the essay would be something like this/ if you can't log it,then it really is just "acting". kinda like the difference between being an instructor,and "acting" like one.
Please follow this link to 61.23
http://flightphysical.com/part61/61.23-Pilot-Med-Certification.htm
Clearly states must have to exercise the privledges,etc. if you can not exercise those privledges,how can it be logged?
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So, you'd say, for example, that you cannot log PIC time if you're an instrument student (PP w/o IR) on an IFR flight plan, because you don't have privileges?
 
cfiiguy said:
I guess the essay would be something like this/ if you can't log it,then it really is just "acting". kinda like the difference between being an instructor,and "acting" like one.
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If I'm reading what you wrote correction, that's a misconception; if you "acting" as PIC, you ARE the PIC responsible for the flight; you're not just "acting like" (pretending) to be one.
 
TangoWhiskey said:
If I'm reading what you wrote correction, that's a misconception; if you "acting" as PIC, you ARE the PIC responsible for the flight; you're not just "acting like" (pretending) to be one.
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Not a misconception, an intentional (although poor) attempt at humor. I stand by my original statement, to log PIC you must be FULLY qualified and have all the necessary documents to LOG it.
 
cfiiguy said:
first, i never said a medical was required to log flight time. it is needed to log PIC time in GA (non-LSA) aircraft. others have already pointed out your wrong on the training requirements and check requirements for instrument training. the hours required for the PP, given by a CFI, are not allowed towards the IR. (Sorry i dated myself with the ICC, old habits die hard) I guess the essay would be something like this/ if you can't log it,then it really is just "acting". kinda like the difference between being an instructor,and "acting" like one.
Please follow this link to 61.23
http://flightphysical.com/part61/61.23-Pilot-Med-Certification.htm
Clearly states must have to exercise the privledges,etc. if you can not exercise those privledges,how can it be logged?
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Show me where flying is a privilege of private pilots. It's not. ACTING as PIC is a privilege, but "flying" itself is not.
 
cfiiguy said:
you can not be on an IFR plan,(using your certificate) as a PP w/o an IR. However, if you are on a training flight,with a CFII,you can log pic time if you are under the hood, but not in actual.
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Are you in Florida by any chance? An instrument student down there recently posted about his CFII making an almost identical contention in this thread on the Red Board: http://forums.aopa.org/showthread.php?t=59331 The only difference is that the other (?) CFII thought that the student couldn't log PIC time under IFR whether he was under the hood or in actual. And truth be told, that seems a logical inference from your principle that if you're not fully PIC-qualified, you can't log PIC.

Others have already pointed out that this is incorrect, however logical it may sound, according to 61.51(e). The only requirements for logging PIC are (a) sole manipulator of the controls and (b) rated in the airplane. There has to be someone in the other seat if the flying pilot is not qualified to act as PIC, and that person must be fully qualified and be acting as PIC, however the flying pilot can still log all of the time during which he was sole manipulator as long as he is rated in the airplane.

I have about 0.5 hours time logged as PIC and as actual IMC, in a complex airplane before I had my complex endorsement, and during a time when my medical was in limbo. The fully qualified (and instrument rated, though we were not IFR and thus legally didn't have to be) right-seat pilot and owner of the airplane, of course, was acting as PIC.
 
if you have actually logged PIC time in a complex,without the endorsement from a qualified instructor,then you have intentionally falsefied your log book,and can be,and should be denied any additional ratings.
i am not in FL. the only other comment i will make in this thread is, people will do what they are going to do, right or wrong.
 
cfiiguy said:
it most certainly is. it is a priviledge earned!!! any damn fool can ACT, but only a few actually deserve the "priviledge" of flight. read the FAR's. they clearly use the term priviledge. it sometimes amazes me how some people sneak thru and are allowed the same priviledges as those that earn it.
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No, it's not a privilege in the regulatory sense.

Here are the privileges of a private pilot, from the FAR.
§ 61.113 Private pilot privileges and limitations: Pilot in command.
(a) Except as provided in paragraphs (b) through (g) of this section, no person who holds a private pilot certificate may act as pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft.
(b) A private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if:
(1) The flight is only incidental to that business or employment; and
(2) The aircraft does not carry passengers or property for compensation or hire.
(c) A private pilot may not pay less than the pro rata share of the operating expenses of a flight with passengers, provided the expenses involve only fuel, oil, airport expenditures, or rental fees.
(d) A private pilot may act as pilot in command of a charitable, nonprofit, or community event flight described in § 91.146, if the sponsor and pilot comply with the requirements of § 91.146.
(e) A private pilot may be reimbursed for aircraft operating expenses that are directly related to search and location operations, provided the expenses involve only fuel, oil, airport expenditures, or rental fees, and the operation is sanctioned and under the direction and control of:
(1) A local, State, or Federal agency; or
(2) An organization that conducts search and location operations.
(f) A private pilot who is an aircraft salesman and who has at least 200 hours of logged flight time may demonstrate an aircraft in flight to a prospective buyer.
(g) A private pilot who meets the requirements of § 61.69 may act as a pilot in command of an aircraft towing a glider or unpowered ultralight vehicle.

Note that nowhere in these privileges is "flying" listed, or logging time mentioned.
 
cfiiguy said:
if you have actually logged PIC time in a complex,without the endorsement from a qualified instructor,then you have intentionally falsefied your log book,and can be,and should be denied any additional ratings.
i am not in FL. the only other comment i will make in this thread is, people will do what they are going to do, right or wrong.
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So, you disagree with the Chief Counsel of the FAA on this:

http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Herman.pdf

Your letter presents a scenario in which a pilot, who holds a private pilot certificate with an aircraft single engine land rating but does not have endorsements for high-performance or complex airplanes required by 14 C.F.R. §§ 61.31(e)-(f) to act as a PIC, is flying in a highperformance and complex airplane. Another pilot, who has those endorsements, is acting as a PIC for the flight. Your letter asks whether the pilot lacking the endorsements may log PIC time for the time that pilot is the sole manipulator of the controls.

Accordingly, in your examples, the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC.
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All due respect, I'll go with the FAA on this one, and you would be well advised to understand the regulations if you're teaching your students (from your screen-name, I presume you're a CFII) these Old Wives Tales about logging. But then again, CFIIs will teach their students stuff regardless of whether they're right or not.
 
Capt. Geoffrey Thorpe said:
So, like, I can fly the airplane solo. I can act as PIC, I can log PIC, but I can't sit there and watch for traffic if someone else has a hood on?

Ya gotta wonder about the people who write these rules. :loco:
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What's to wonder.. 91.109(b) says Private Pilot or better, not Light-Sport Pilot and not Recreational Pilot.
 
cfiiguy said:
it most certainly is. it is a priviledge earned!!! any damn fool can ACT, but only a few actually deserve the "priviledge" of flight. read the FAR's. they clearly use the term priviledge. it sometimes amazes me how some people sneak thru and are allowed the same priviledges as those that earn it.
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I'm tempted to take a cheap shot and return with something about how you've managed to "sneak through" without learning the regulatory difference between ACTING as PIC and logging PIC time. But instead I'll take one more shot at turning you away from the dark side of PIC misconceptions. As explained in earlier posts this is covered by different FARs and although the confusion between the two is all too common it is perfectly legal and somewhat common to log PIC time without ACTING as PIC. To legally LOG PIC the holder of a Private Pilot Certificate only need to have the appropriate category and class ratings on that certificate and be the sole manipulator of the controls or be ACTING as PIC when more than one crewmember is required by the rules regarding the flight in being logged. This is clearly spelled out in FAR 61.51(e). To ACT as PIC you must meet various additional requirements depending on the conditions of flight and presence of passengers etc.

While it's certainly contrary to "common sense" there are circumstances where it's legal to ACT as PIC yet not be entitled to log the time as PIC and there are circumstances where it's legal to log PIC time without being qualified to ACT as PIC. An example of the both at the same time would be a Private pilot who is sitting at one set of controls and fully qualified to ACT as PIC while another Pilot actually flies the airplane without a view limiting device in VMC. If the pilot manipulating the controls doesn't meet the currency requirements (e.g. less than 3 takeoffs and landings in the last 90 days, and/or no complex endorsement in a retractable airplane) that pilot clearly cannot legally ACT as PIC but per 61.51(e) he is entitled to LOG the time in the PIC column of his logbook. In this case the pilot not flying would have to be the ACTING PIC but since he's not a required crewmember he cannot legally log the time as PIC (or anything else of value).

There are also cases where two Private Pilots can legally log PIC time and it used to be that there were situations where none of the pilots in the airplane were entitled to LOG PIC time but a somewhat recent decision seems to have eliminated that non-sequitur (the decision states that a properly qualified pilot IS entitled to LOG PIC time if he's the only pilot with the appropriate category and class ratings sitting at the controls even if he's not the one flying.
 
Wow. Just wow. Not even an opinion letter phases him. He still knows all.

<sigh>
 
cfiiguy said:
as usual, being the case with most people who only want hear what they want to hear, you took his statement totally out of context. he states you have to be rated and qualified. in this case i believe he is stating that if you are qualified (as in being grandfathered or other wise qualified) that you can log PIC time even without the endorsements. in that senerio it would be correct.
spin it anyway it suits you. take all the short cuts,and cheat all you want.
i have taught from PP thru multi instructor. 2 of my former students are now flying heavies. one a 747 400 and one an airbus 320. both recieved their introductory rides from me,and earned MEI and ATP rates under my instruction. i have over 3000 hrs of dual given, and oh by the way, a 100% pass rate from both written sign offs and flight checks. I refuse to argue about this any more. for that i am sure many will be pleased. I just joined this board last week, and have just removed the link from my browser. i obviously have nothing to contribute to the amazing flying wizards here. i do have a better understanding after only a week on this board as to why GA is becoming the fastest shrinking hobby in America.
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Instead of going away angry, please show us where in the FARs it supports your version of the argument. That is what a good CFI would try to do. They would also look at it from every angle and make sure their version is credible, standing up to the test of interpretation. If it does not, a good CFI would admit they are wrong and change what they are teaching. After all, a good CFI would not want to teach a fallacy about the FARs.

This is not usually the type of question that would typically come up at the oral, nor is it likely to keep an examiner from passing an individual if that student does not know the correct answer.

The reason GA is shrinking has more to do with economics than anything happening on this board. Stop calling everyone else foolish and prove your points with facts.
 
cfiiguy said:
first, i never said a medical was required to log flight time. it is needed to log PIC time in GA (non-LSA) aircraft.
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14 CFR 61.51(e) and the FAA Chief Counsel say otherwise. You need the medical to be the PIC, but not to log PIC time under the sole manipulator clause (as long as someone is acting as PIC for you).
Clearly states must have to exercise the privledges,etc. if you can not exercise those privledges,how can it be logged?
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Because 61.51(e) and the Chief Counsel say it can. In particular, see the last paragraph of the second letter and its discussion of the separation of being PIC and logging PIC time.
June 22, 1977

Mr. Thomas Beane

Dear Mr. Beane:

This letter is in response to your recent letters to the FAA Flight Standards Service and to the Chief Counsel inquiring about the logging of pilot-in-command (PIC) time by an airman whenever he is not the sole manipulator of the controls.


Section 1.1 of the Federal Aviation Regulations defines Pilot in Command as:

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

Section 61.51(c)(2) of the Federal Aviation Regulations provides, in pertinent part:

(2) Pilot-in-Command flight time.

(I) A private or commercial pilot may log as pilot in command time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts 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.

A pilot may log PIC time in accordance with Section 61.51(c)(2)(I) when he is not actually "flying the airplane", if the airplane is one on which more than one pilot is required under its type certificate or under the regulations under which the flight is conducted and he is acting as PIC. Also, a pilot, rated in category and class (e.g. airplane single-engine) could, as the pilot who "Has final authority and responsibility for the operation and safety of the flight" log PIC time if another pilot, not appropriately rated, was actually manipulating the controls of the aircraft.

It should be noted that more than one pilot may log PIC time for the same flight time. For example, one pilot receiving instruction may log PIC time in accordance with paragraph (c)(2)(I) for the time he is designated PIC, and another pilot may log PIC time in accordance with (c)(2)(iii) for the same time during which he is actually giving flight instruction.

We hope that we have satisfactorily responded to your inquiry on the proper logging of PIC time.

Sincerely,

ORIGINAL SIGNED BY EDWARD P. FABERMAN

for NEIL R. EISNER Acting Assistant Chief Counsel Regulations & Enforcement Division Office of the Chief Counsel -
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August 21, 2000

Mr. George E. Prasinos
413-B South Melville Ave.
Tampa, FL 33606

Dear Mr. Prasinos:

Thank you for your letter dated January 27, 2000, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding acting as pilot in command and the logging of pilot-in-command flight time.

In your letter you state that you are the holder of an airline transport pilot (ATP) certificate and a first-class medical certificate. Your ATP certificate contains the appropriate ratings (category, class, and type rating) for the operation of a Citation 560. You are employed as second in command on a Citation 560 for a part 135 operator (14 CFR part 135). You operate the Citation 560 on both part 135 and part 91 (14 CFR part 91) operations. You state that you have successfully completed a “VFR/IFR SIC Part 135 check (Citation 560)” and that you meet the second in command qualifications under § 61.55. You then ask four questions.

First, you ask whether you could act as pilot in command, and log pilot-in-command flight time, on any aircraft that your are appropriately rated, on flights conducted under part 91.

You may act as pilot in command on all aircraft that you hold the appropriate ratings (category, class, and type (if a type rating is required)) on your pilot certificate, under part 91, if your pilot certificate is current and valid, your pilot certificate authorizes the privileges you seek to exercise, and you hold a current and valid medical certificate issued under Part 67 (14 CFR Part 67) appropriate to the privileges you seek to exercise [see § 61.23(a) and (b)]. In order for your pilot certificate to be “current” for acting as pilot in command, you must meet the recent flight experience requirements under § 61.57 that are appropriate to the operation you seek to conduct, and you must meet the flight review requirements under § 61.56. In order for your pilot certificate to be “valid,” your pilot certificate must not be suspended, revoked, or expired. In order for your medical certificate to be “current,” it must meet the appropriate duration requirements under § 61.23(c) for the privileges you seek to exercise. In order for your medical certificate to be “valid,” your medical certificate must not be suspended, revoked, or expired.

You may log pilot-in-command flight time in accordance with § 61.51(e). § 61.51(e) provides, in pertinent part, that you may log pilot-in-command flight time during which you are the sole manipulator of the controls of an aircraft for which you are rated, you are the sole occupant of the aircraft, you are acting as pilot in command on an aircraft on which more than one pilot is required under the type certification or the regulations under which the flight is conducted, or while you (the holder of an ATP certificate) are acting as pilot in command of an operation requiring an ATP certificate.

Second, you ask whether you may log pilot-in-command flight time, under part 91, when you are not the acting pilot in command. The answer is yes. You may log pilot-in-command flight time for all of the flight time during which you are the sole manipulator of the controls of an aircraft for which you are rated (§ 61.51(e)(1)(i)).

Third, you ask whether you may log pilot-in-command flight time, under part 135, when you are not the acting pilot in command. The answer is yes. As stated above, you may log pilot-in-command flight time for all of the flight time during which you are the sole manipulator of the controls of an aircraft for which you are rated (§ 61.51(e)(1)(i)).

Fourth, you ask whether both the pilot in command and the second in command may log pilot-in-command flight time simultaneously. The answer is yes. If more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted then the acting pilot in command may log pilot-in-command flight time for the entire flight even though he or she may not manipulate the flight controls, and the second in command may log pilot-in-command flight time for all of the flight time during which he or she is the sole manipulator of the controls as long as he or she is rated in that aircraft [§ 61.51(e)(1)(iii)]. In addition, if the regulations require the pilot in command to hold an ATP for that operation, even if more than one pilot is not required under the type certification of the aircraft or the regulations under which the flight is conducted, then the acting pilot in command may log pilot-in-command flight time for the entire flight even though he or she may not manipulate the flight controls, and the second in command may log pilot-in-command flight time for all of the flight time during which he or she is the sole manipulator of the controls as long as he or she is rated in that aircraft [§ 61.51(e)(1)(i) and (2)].

Please note that there is a distinction between acting as pilot in command and logging of pilot-in-command flight time. In the discussions of logging of pilot-in-command flight time, I am discussing the logging of pilot-in-command flight time for purposes of § 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher certificate or rating. This is important because even though you may properly log pilot-in-command flight time, you may not be qualified to act as pilot in command. In addition, under part 135, you may be able to properly log flight time in accordance with § 61.51, even though you may not meet the pilot qualification requirements of part 135. I have attached a previous interpretation issued by this office that discusses this issue.

I hope this satisfactorily answers your questions. This opinion has been coordinated with Flight Standards.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel
Regulations Division
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cfiiguy said:
you can not be on an IFR plan,(using your certificate) as a PP w/o an IR. However, if you are on a training flight,with a CFII,you can log pic time if you are under the hood, but not in actual.
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The conditions of flight do not affect your ability to log PIC time. Even if you don't have an instrument rating, as long as someone instrument-qualified is acting as PIC, and you are "rated" in the aircraft, you can log all sole manipulator time as PIC time. 61.51(e)(1)(i) refers.
You can not be a PIC if you are not rated.
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Right, but you don't have to be PIC to log PIC time.
Let's say you have 50,000 hours as an ATP. You buy a Cub to relax in during the golden years of retirement. Until you get the TW endorsement from a qualified instructor,you can not log time in the TW as PIC. (this includes all the dual time)
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Yes, you can. The FAA Chief Counsel says that "rated" only means the ratings listed in 61.5. Additional training endorsements in 61.31 are required to be the PIC, but not to log PIC time as sole manipulator of the controls of an aircraft in which you are "rated." As long as that ATP has an ASEL rating on his pilot certificate, he can log sole manipulator time in that Cub as PIC time even while training for his 61.31 TW additional training endorsement.
Same applies to the IR.
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The Chief Counsel says "rated" means rated for the aircraft, not the operation. Thus, a PP-ASEL can log PIC time while the sole manipulator of the controls under IFR (whether in VMC or IMC) as long as someone instrument-qualified is acting as PIC.
I can see that this thread is going no where fast,and everyone is entitled to their opinion. It is headed towards the "if God can do anything,can he make a rock so heavy even he can't pick it up"? Good Luck to the original poster in finding an answer.
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The answers have already been provided by the FAA Chief Counsel -- no luck required to find them.
 
cfiiguy said:
it most certainly is. it is a priviledge earned!!! any damn fool can ACT, but only a few actually deserve the "priviledge" of flight. read the FAR's. they clearly use the term priviledge. it sometimes amazes me how some people sneak thru and are allowed the same priviledges as those that earn it.
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Nitpick pause: "Privilege"

Please resume regularly scheduled programming...
 
FlyNE said:
Wow. Just wow. Not even an opinion letter phases him. He still knows all.

<sigh>
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And he teaches new students without regard to what is actually fact, defending it with arrogance instead of references. "no wonder GA is shrinking"
 
cfiiguy said:
as usual, being the case with most people who only want hear what they want to hear, you took his statement totally out of context. he states you have to be rated and qualified. in this case i believe he is stating that if you are qualified (as in being grandfathered or other wise qualified) that you can log PIC time even without the endorsements. in that senerio it would be correct.
spin it anyway it suits you. take all the short cuts,and cheat all you want.
i have taught from PP thru multi instructor. 2 of my former students are now flying heavies. one a 747 400 and one an airbus 320. both recieved their introductory rides from me,and earned MEI and ATP rates under my instruction. i have over 3000 hrs of dual given, and oh by the way, a 100% pass rate from both written sign offs and flight checks. I refuse to argue about this any more. for that i am sure many will be pleased. I just joined this board last week, and have just removed the link from my browser. i obviously have nothing to contribute to the amazing flying wizards here. i do have a better understanding after only a week on this board as to why GA is becoming the fastest shrinking hobby in America.
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I'm not "spinning" anything. I'm simply reading the actual regulations, rather than my ingrained biases and "what I was taught", and official FAA interpretations thereof.

The fact that you have taught all these people the same OWT makes me sad. Arrogant CFI/CFIIs who refuse to admit that they might be in error is probably a bigger cause of shrinking GA than what you claim.

Here's a deal for you...pick your FSDO, and you bring your information on this interpretation and I'll bring mine. We'll see who leaves without a suggestion for remedial training on the subject.:mad2:
 
BillTIZ said:
What's to wonder.. 91.109(b) says Private Pilot or better, not Light-Sport Pilot and not Recreational Pilot.
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Well, I gotta wonder why I can fly the plane. I can carry a passenger. I can log PIC. I can act as PIC. If I was a LSA-Instructor I could even teach people how to fly in the airplane, send them off solo, give someone a tailwheel endorsement (good in ANY tailwheel airplane) or sign them off for practical tests (for sport pilot stuff). But I can't sit there if the other person has a hood on? How does that make sense?
 
TMetzinger said:
I was SOOOO tempted to go there too...

Horse, Water. No drinking going on.
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You didn't cause you're nicer than me. :D

You can make a horse drink or eat anything -- just have to hold the head up, push the tongue aside, and shove it down. Horses don't have a gag reflex so it will go down.

That's not to say the horse won't freak out when you hold its head, or lash out with forelegs.

People and horses -- very similar... :rolleyes:
 
dmccormack said:
Hmmm... I'm confused. (It's easy)

How can he legally log PIC time if he cannot act as PIC?
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And you are a CFI? Wow....just wow.
Sorry Dan, clicked the wrong quote button. cfiiguy is the one I am wowing about.

Either way, the flowchart in the bottom of my sig is the correct answer. Even the head of NAFI is using it.
 
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EdFred said:
And you are a CFI? Wow....just wow.
Sorry Dan, clicked the wrong quote button. cfiiguy is the one I am wowing about.

Either way, the flowchart in the bottom of my sig is the correct answer. Even the head of NAFI is using it.
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Have you ever thought of trying to get the FAA to put your flowchart in the AIM?:yesnod:
 
cfiiguy said:
if you have actually logged PIC time in a complex,without the endorsement from a qualified instructor,then you have intentionally falsefied your log book,and can be,and should be denied any additional ratings.
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Then the CFI who later checked me out in the same airplane and gave me the complex endorsement also falsified my logbook. He also entered the time (before the endorsement) as both flight instruction and as PIC.

FAR 61.51(e) is so clearly written that I seriously doubt the DPE is going to raise a stink about those hours when I go for my instrument checkride. I wonder how my current CFII will write in my dual IFR XC hours? I'll see in a couple of months if all goes well, but I'm pretty confident he'll put them in the PIC column since he seems to know the FARs backwards and forwards.

If you are so confident of your position, why don't you support it by at least pointing to the appropriate place in the FARs, instead of saying "people will believe what they want to believe"?

i am not in FL. the only other comment i will make in this thread is, people will do what they are going to do, right or wrong.
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That's sad, because it means that there are at least two CFIIs out there passing on this misinformation. Even sadder, I'll bet there are quite a few others.
 
cfiiguy said:
you can not be on an IFR plan,(using your certificate) as a PP w/o an IR. However, if you are on a training flight,with a CFII,you can log pic time if you are under the hood, but not in actual.
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I think you need to catch up on your reading - from 29 years ago:

==============================
OCT. 28, 1980

WINSTON SCOTT JONES

Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.

Section 61.51(c)(2)(i) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or

2. Is the sole occupant of the aircraft; or

3. Acts 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.

Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received.

Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(i) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).

There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.

You request interpretations of these regulations for situations in which:

1. The purpose of the flight is instruction in advanced maneuvers.

2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.

3. The purpose of the flight is instrument instruction in actual IFR conditions.

4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.

5. The purpose of the flight is transition from tricycle to conventional landing gear.

6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).

7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.

We trust that this discussion answers your questions.

Sincerely,

EDWARD P. FABERMAN
Acting Assistant Chief Counsel
==============================

Of course, you may not like 29 year old FAA Legal opinions, so here's one that says the same thing from, oh, last month.

http://www.faa.gov/about/office_org...nterpretations/data/interps/2009/Haralson.pdf

Don't worry about it though. This stuff really isn't intuitive. It's more about what you do when provided the correct information with references. Do you incorporate the new knowledge or simply reject it because it conflicts with your beliefs.
 
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Capt. Geoffrey Thorpe said:
Well, I gotta wonder why I can fly the plane. I can carry a passenger. I can log PIC. I can act as PIC. If I was a LSA-Instructor I could even teach people how to fly in the airplane, send them off solo, give someone a tailwheel endorsement (good in ANY tailwheel airplane) or sign them off for practical tests (for sport pilot stuff). But I can't sit there if the other person has a hood on? How does that make sense?
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I don't think anyone said it makes sense, but that's the way the rules read. Personally, I think it's one of two things:
  1. There is no flight by reference to instruments in the Sport Pilot training requirements or practical test, hence, they think Sport Pilots aren't prepared to understand the issues involved in being a safety pilot.
  2. The folks writing the Sport Pilot rules didn't even think about the issue of SP's acting as safety pilots, and the folks writing Part 91 didn't think about the addition of Sport Pilots to the ranks of people out there flying and how that would affect 91.109(b).
I've asked the FAA for an explanation (not an interpretation) on how that came to be -- we'll see if it's one of my thoughts or something else entirely. Note also that the Sport Pilot rules are written by the LSA/Sport Pilot office in Oklahoma City, not the regular Part 61 folks at HQ in DC.
 
EdFred said:
Either way, the flowchart in the bottom of my sig is the correct answer. Even the head of NAFI is using it.
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I'd add "two-pilot airplanes" to your "does not cover" disclaimer, though...
A pilot may log PIC time in accordance with Section 61.51(c)(2)(I) when he is not actually "flying the airplane", if the airplane is one on which more than one pilot is required under its type certificate or under the regulations under which the flight is conducted and he is acting as PIC.
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Greg Bockelman said:
Holy Crap. How many times to we have to cover this? :mad3:


I suppose as many times as it takes. :D
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Greg -- mine was a rhetorical response (I know the answer -- how can you not after being on POA for more than an hour!?!?)

The question was meant to show how the terms (acting PIC logging PIC) were so close that they caused confusion.
 
dmccormack said:
Greg -- mine was a rhetorical response (I know the answer -- how can you not after being on POA for more than an hour!?!?)

The question was meant to show how the terms (acting PIC logging PIC) were so close that they caused confusion.
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Yeah, I got that after reading the rest of the thread. :blush:

So shift the post over to the CFI who doesn't get it. :mad3::mad3::mad3::mad3::mad3:


Wow.
 
cfiiguy said:
I stand by my original statement, to log PIC you must be FULLY qualified and have all the necessary documents to LOG it.
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The sign of a good CFI is his ability to do the research, ask the right questions, and to admit when he is wrong.

Also, it has been my experience that if I have one view on something, and EVERYone else has the opposite opinion, I might be the one that is wrong.

It seems like there is a LOT of references in this thread that proves you are wrong. You have the resources. Including AOPA, if you are a member. Look them up yourself. Use them to prove US wrong. And keep an open mind that maybe you MIGHT need to change your opinion.
 
Hmm. This thread has lost some weight...
 
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