Logging. AGAIN. (Say it ain't SO!!!)

[Greg Bockelman]

So I thought I had this all figured out. Logging and acting, two separate things. So I ran across this post on the UAL pilot forum.

indeed. This has always produced a lot of confusion, but I'll bet ALPA's lawyers could probably answer it by referencing some FAA official interpretation. The confusion that I've always read about is that 61.51(e)(1) leaves out ATPs from its list of certificate holders, while 61.51(e)(2) specifically applies to ATPs, which seems to pretty clearly indicate the FAA didn't intend (1) to apply to ATPs. That seems to mean that PIC time in multi-crew aircraft under (1) is intended to apply to things like corporate jets and other sorts of commercial flying that doesn't require an ATP certificate.

Any flying that requires an ATP (which is certainly the case for all Part 121 augmented flights) puts you into 61.51(e)(2), and then it comes down to the definition of "pilot in command of an operation." I believe the FAA defines this as whoever signed for the release, regardless of who is operating the controls.

So does the omission of the ATP in (e)(1) preclude me from logging PIC in the 777 even though I am type rated in the airplane since logging for ATP's is addressed in (e)(2)? Would appear so.

For what it is worth, I don't log PIC anyway, but it is a wrinkle that I had not noticed before.

 

[EdFred]

So I thought I had this all figured out. Logging and acting, two separate things. So I ran across this post on the UAL pilot forum.




So does the omission of the ATP in (e)(1) preclude me from logging PIC in the 777 even though I am type rated in the airplane since logging for ATP's is addressed in (e)(2)? Would appear so.

For what it is worth, I don't log PIC anyway, but it is a wrinkle that I had not noticed before.

I am 99% sure that was a "DOH!" moment on the FAR writers,and they forgot to add "or ATP certificate to (e)(1). Because it would preclude you from logging ANY time in ANY multi engine if you are Multi-ATP - even a TwinCo or Seneca. I think there's a FAA Counsel Opinion on that saying it was an oops moment.

61.167 says an ATP has all the privliges that a commercial pilot does in regards to ratings. I would think logging time also falls under that umbrella. I'm still looking for the Letter.

 

[Greg Bockelman]

I am 99% sure that was a "DOH!" moment on the FAR writers,and they forgot to add "or ATP certificate to (e)(1). Because it would preclude you from logging ANY time in ANY multi engine if you are Multi-ATP - even a TwinCo or Seneca. I think there's a FAA Counsel Opinion on that saying it was an oops moment.

61.167 says an ATP has all the privliges that a commercial pilot does in regards to ratings. I would think logging time also falls under that umbrella. I'm still looking for the Letter.

Well, that is what I thought I had seen, but by the letter of the law... And you are right, by the letter of the law an AP couldn't log much of anything.

If you find the letter, either post it or email it to me.

Thanks, Ed.

 

[poadeleted20]

Someone in the FAA said it wasn't an issue since you only exercise your ATP priviliges when commanding an ATP-required flight, so the other paragraphs still apply when exercising lesser privileges. Sounds like a side-step, but that's what they said. Now if I can only remember who said it and where...

 

[Everskyward]

How about this?

http://bulk.resource.org/gpo.gov/register/2007/2007_05816.pdf

(25) Proposal to correct an omission of
the words ‘‘airline transport pilot’’
regarding logging of pilot in command
time.
Because existing § 61.51(e)(1) does not
include ‘‘airline transport pilots,’’ it may
appear that holders of airline transport
pilot certificates do not have the same
PIC logging privileges as recreational
pilots, private pilots, and commercial
pilots. To avoid any confusion, the FAA
proposes to add the words ‘‘airline
transport pilot’’ to § 61.51(e)(1).

 

[midlifeflyer]

Well, that is what I thought I had seen, but by the letter of the law... And you are right, by the letter of the law an AP couldn't log much of anything..

The admitted "oversight" in 61.51 aside, the answer is arguably in...

==============================
§ 61.167 Privileges.
(a) A person who holds an airline transport pilot certificate is entitled to the same privileges as those afforded a person who holds a commercial pilot certificate with an instrument rating.
==============================

Logging is one of the "privileges" of a certificate holder.