Logging PIC again (Still?)

Greg Bockelman

Greg Bockelman

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Greg Bockelman
In another thread, I mentioned that I was sparing with JC Boylls of Plane and Pilot about whether a pilot with a high performance endorsement who is the legal PIC of a flight in which another pilot who did not have the HP endorsement could log PIC for the entire flight. In otherwords the contention was that both pilots could log PIC for the entire flight.

I came in to possession of several letters of interpretation, written mostly by Mr. Donald Byrne addressing this issue. The letters indicated that the legal PIC could in fact log the time as PIC, but they were addressed to the 121/135 side of the regulations, not 91. Mr. Boylls' contention is that since it wasn't specifically prohibited, then it was allowed.

Quite frankly, I can see how Mr. Boylls comes to his opinion. Having said that, I don't agree with it. I am in the process of writing a letter seeking clarification in this matter. I have two requests here.

First, Mr. Donald P. Byrne was the Assistant Chief Council on the letters I have read. I don't see him listed in the Regulations Division any more. Has he retired? I see Rebecca MacPherson listed as Assistant Chief Council. Who do I address the letter to?

Second. This is a copy of the letter I intend to send. Is there any way to make it understood better? How can I change it so that I have a reasonable chance to get a response?

Thanks for your patience and assistance.

I have a question regarding the logging of Pilot in Command time. I have several letters issued by Mr. Donald P. Byrne addressing this issue, but they seem to only apply to 14CFR parts 121 and 135.

Here’s the scenario. Pilot A and Pilot B go fly in Pilot A’s airplane, a Cessna 182. Pilot A has the High Performance endorsement and all of the other qualifications and currencies to act as legal Pilot in Command. Pilot B has a Private Pilot license and is otherwise legal to fly with the exception that he does not have the High Performance endorsement. Pilot A lets Pilot B fly his airplane as sole manipulator of the controls for the entire flight. It has been established in various letters of interpretation that Pilot B may log the time that he is sole manipulator of the controls in accordance to CFR14 Part 61.51(e)(1)(i).

What, if anything, can Pilot A log? In the various letters of interpretation that I have read, it says that the legal Pilot in Command may log the entire flight for which he is acting as PIC. But they are references to Part 135 and 121 only. Nothing is specifically mentioned about Part 91.

Thank you for your assistance in this matter.
 
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Greg Bockelman said:
Second. This is a copy of the letter I intend to send. Is there any way to make it understood better? How can I change it so that I have a reasonable chance to get a response?
Click to expand...

Greg, did you intend to attach something?

Ed
 
Greg Bockelman said:
I have a question regarding the logging of Pilot in Command time. I have several letters issued by Mr. Donald P. Byrne addressing this issue, but they seem to only apply to 14CFR parts 121 and 135. One specific letter written by Mr. Bryne, date October 30, 1992, and addressed to Mr. David M. Reid states in part:

"Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51."


As there are no qualifications or limitations associated with this stament, it appears that a pilot who is acting as legal PIC in accordance with FAR 1.1 may log PIC time regardless of any other factors or conditions.

Here’s the scenario. Pilot A and Pilot B, both holders of private pilot certificates, go fly in Pilot A’s airplane, a Cessna 182. Pilot A has the High Performance endorsement and all of the other qualifications and currencies to act as legal Pilot in Command. Pilot B has a Private Pilot license with airplane category and single engine land class. Pilot B does not have the High Performance endorsement. Pilot A lets Pilot B fly his airplane as sole manipulator of the controls for the entire flight. Neither pilot is a CFI providing flight instruction, and neither pilot is flying with a view limiting device nor acting as a safety pilot.

It has been established in various letters of interpretation that Pilot B may log the time that he is sole manipulator of the controls in accordance to CFR14 Part 61.51(e)(1)(i). What, if anything, may Pilot A log? Since Pilot A was legal PIC for the entire flight may Pilot A log PIC time for this flight (this appears to be the outcome of the October 30, 1992 letter)? In the various letters of interpretation that I have read, it says that the legal Pilot in Command may log the entire flight for which he is acting as PIC. But they are references to Part 135 and 121 only. Nothing is specifically mentioned about Part 91 except for examples of one pilot acting as sole manipulator while wearing a view limiting device, and the second pilot acts as safety pilot and legal PIC. However, this example does not fall within those specific situations.

Thank you for your assistance in this matter.
Click to expand...


Greg,

I offered a few delimiting statements/editorial comments (shown in red). Use them or loose them as you see fit.

Ed
 
Don Byrne was still working there the last time I called him last winter. And anyone relying on that 1992 letter had best read the later NTSB opinion that revoked the tickets of two pilots for simultaneously logging PIC time on a Part 91 flight when only one pilot was required -- look for Administrator v. Pearson and Crow, NTSB Order EA-4008.
 
Ron Levy said:
Don Byrne was still working there the last time I called him last winter. And anyone relying on that 1992 letter had best read the later NTSB opinion that revoked the tickets of two pilots for simultaneously logging PIC time on a Part 91 flight when only one pilot was required -- look for Administrator v. Pearson and Crow, NTSB Order EA-4008.
Click to expand...

See JC's reply to that in my post in the Ask P&P thread.
 
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