Logging PIC in a Complex Airplane

Tristar said:
Let me point out that I encountered the same situation. I was not allowed to log PIC (since logging = acting as stated earlier) in the complex airplane until after the logbook endorsement.

This is what my endorsement says:

PIC - Complex Airplane: 61.31(e)

I certify that I have given ground and flight training in a complex airplane to [First name, MI, Last name] holder of pilot certificate# [certificate number] and find him/her procicient in the operation and systems of a complex airplane.

Signed Dated
CFI # Expiration

Now this could go one of two ways; either extremely obvious that you can only LOG pic once you're Endorsed for PIC complex aircraft, or incredibly vague and something should be worded or explained in a different manner.
Click to expand...
Go back and log the PIC and complex time before you were endorsed, if you want. Your instructor was wrong.

Geez, there's an FAA counsel opinion in this and other threads that spells out that:
Logging and acting are two different things
Rated and endorsed are two different things

My commercial ride was with a DPE and Inspector - the fact that I had logged ALL my complex time as PIC was something they BOTH looked for (this was 2000) as they'd had to correct other student's logs and counsel their CFI's in the past. The only complex time I didn't log as PIC until the ride was the multi-engine time, because that is a RATING.

PS - you can log your student solo time as PIC... everyone agrees on that, don't they? (I stipulate that this was not always true).
 
Tristar said:
Let me point out that I encountered the same situation. I was not allowed to log PIC (since logging = acting as stated earlier) in the complex airplane until after the logbook endorsement.

This is what my endorsement says:

PIC - Complex Airplane: 61.31(e)

I certify that I have given ground and flight training in a complex airplane to [First name, MI, Last name] holder of pilot certificate# [certificate number] and find him/her procicient in the operation and systems of a complex airplane.

Signed Dated
CFI # Expiration

Now this could go one of two ways; either extremely obvious that you can only LOG pic once you're Endorsed for PIC complex aircraft, or incredibly vague and something should be worded or explained in a different manner.
Click to expand...

Did you go back in your logbook and change all the sole manipulator time to PIC time? It is your logbook after all.
 
EdFred said:
Did you go back in your logbook and change all the sole manipulator time to PIC time? It is your logbook after all.
Click to expand...
My logbook has two options; "solo and PIC." I've logged everything I can as PIC after my PP checkride.
 
Tristar said:
My logbook has two options; "solo and PIC." I've logged everything I can as PIC after my PP checkride.
Click to expand...

Good. After your private ride, any time you touched the controls in a SEL you would log it as PIC time. The only time since my private I have not logged PIC was when I was in Doc Bruce's twin (0.7) and for my training in the seaplane (5.0) because I was not rated in either plane at the time.
 
Tristar said:
My logbook has two options; "solo and PIC." I've logged everything I can as PIC after my PP checkride.
Click to expand...

The two aren't exclusive, even before your PP checkride. Your student solo time is PIC time - you're the sole occupant. 61.51.e.4:
(4) A student pilot may log pilot-in-command time only when the student pilot -
(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;
(ii) Has a current solo flight endorsement as required under § 61.87 of this part; and
(iii) Is undergoing training for a pilot certificate or rating.
 
EdFred said:
Good. After your private ride, any time you touched the controls in a SEL you would log it as PIC time. The only time since my private I have not logged PIC was when I was in Doc Bruce's twin (0.7) and for my training in the seaplane (5.0) because I was not rated in either plane at the time.
Click to expand...

Ed, just to clarify, was that because both were considered Dual Received? Or can you log total time while you were the sole manipulator in a category/class for which you are NOT rated, but not count it as either PIC or Dual Received?

I hate to open another can of worms here...
 
"Prior to providing a specific response to your inquiry, it is appropriate to note here the distinction between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 pertains to the logging of PIC flight time, and it provides that a private or commercial pilot may log as PIC 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 PIC 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."

So would that mean that a commercial student if flown with a CFI and the CFI flew half the flight then the commercial student could only log half of it?
 
TMetzinger said:
The two aren't exclusive, even before your PP checkride. Your student solo time is PIC time - you're the sole occupant. 61.51.e.4:
(4) A student pilot may log pilot-in-command time only when the student pilot -
(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;
(ii) Has a current solo flight endorsement as required under § 61.87 of this part; and
(iii) Is undergoing training for a pilot certificate or rating.
Click to expand...
You're right and I did log it that way.
 
t0r0nad0 said:
Ed, just to clarify, was that because both were considered Dual Received? Or can you log total time while you were the sole manipulator in a category/class for which you are NOT rated, but not count it as either PIC or Dual Received?

I hate to open another can of worms here...
Click to expand...

FLOWCHART!!!! :D :D :D

61.51(e) says you need to be rated in the category and class to log PIC time if you are not solo. I was not rated in Class (Multi) with Dr Bruce's Seneca, nor was I rated (seaplane) when I was receiving instruction. So I could not log it as anything except training received and flight time. Just like I was a student pilot all over again.
 
Tristar said:
"Prior to providing a specific response to your inquiry, it is appropriate to note here the distinction between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 pertains to the logging of PIC flight time, and it provides that a private or commercial pilot may log as PIC 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 PIC 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."

So would that mean that a commercial student if flown with a CFI and the CFI flew half the flight then the commercial student could only log half of it?
Click to expand...

As PIC, YES. He could log ALL the flight time, and ALL of it as instruction received, but he can only log as PIC the time he was actually flying the airplane.
 
Tristar said:
"Prior to providing a specific response to your inquiry, it is appropriate to note here the distinction between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 pertains to the logging of PIC flight time, and it provides that a private or commercial pilot may log as PIC 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 PIC 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."

So would that mean that a commercial student if flown with a CFI and the CFI flew half the flight then the commercial student could only log half of it?
Click to expand...

Technically yes, but since it would be with a CFI, they would probably log it all as training received and PIC.
 
So that means if you really wanted to get picky, each time an instructor demonstrates a manuever before the student tries it himself would also need to be deducted.
 
He should only log the time he flew as PIC. Which is why you should never let your CFI fly the airplane unless he's saving your butt, or demoing something:D. Make him pay his share of expenses if he's touching the yoke otherwise!
 
Tristar said:
So that means if you really wanted to get picky, each time an instructor demonstrates a manuever before the student tries it himself would also need to be deducted.
Click to expand...

That is true. Since that time comes into minutes, usually, it's ignored.
 
Tristar said:
So that means if you really wanted to get picky, each time an instructor demonstrates a manuever before the student tries it himself would also need to be deducted.
Click to expand...

To be super-uber-anal...yes.

"I have 589 hours 26 minutes and 42.6 second of PIC time."

I would detest adding up those hours at the end of the page. :D
 
Heck we could get even more into this. I've had examples of where instructors will ask you to follow along on the controls. Although you're following along, is there really a "sole" manipulator? This sounds silly but sometimes I wonder how silly things can get.

Haha, I sure wish I could make them pay for flights at times! Thankfully I haven't ran across too many CFIs I've had to tell to back off and let me fly.
 
Just for fun, I went back and looked at my logbook.

Turns out, my CFI did not log the time as PIC when going for the complex endorsement. I'm almost tempted to not fix it, as I'll have to update times on like 20 pages after it.
 
Nick, I suggest you Add up the time, and then on the current log, add a line with just the PIC time in it, and note that it's added from flights XXXX-YYYY earlier.

Then go back to the original pages and put a note in the PIC column and say "time added on page ZZZZ". Initial the changes.

Or, don't count the time. PIC time once you've got the ratings counts in intervals of 100, so being "short" by 3 or 4 hours may not matter.
 
SkyHog said:
How can you say it is harsh?
Click to expand...
Because I know some very old, very experienced CFIs who I would be thrilled to have teach me 1% of what they know about flying who are not particularly savvy about how many pilots can log PIC while flying on the head of a pin.

It's very easy for folks who have been in online forums, where exposure to the way the rules have been interpreted is there for all to see, to think that this all "so basic" or is "obvious" from the words of 61.51 or is the only way it could be interpreted. And then to be completely intolerant of those who did not have that same exposure.

So you think that

==============================
A person sport, recreational, private, or commercial pilot may be in our store log pilot-in-command time only for that flight time during which that person--
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges wearing a shirt;
==============================

has to mean that pants are not required?
 
KennyFlys said:
Okay, I'm sold. Thank you for the effort.

Ed and Mark, If you by chance have those letters in PDF format, I'd appreciate a copy posted on the thread. I like to keep a file of print outs of such letters that are provided and have done so on a couple Ron has received and posted.
Click to expand...
Hicks is on the FAA Legal website in rtf:

http://www.faa.gov/about/office_org...0/interpretations/data/interps/1993/Hicks.rtf

The 1984 great grandaddy of the logging opinions that I posted is beyond their date line.

Easy enough to put anything into pdf if you want to:
http://www.primopdf.com/
 
midlifeflyer said:
Because I know some very old, very experienced CFIs who I would be thrilled to have teach me 1% of what they know about flying who are not particularly savvy about how many pilots can log PIC while flying on the head of a pin.

It's very easy for folks who have been in online forums, where exposure to the way the rules have been interpreted is there for all to see, to think that this all "so basic" or is "obvious" from the words of 61.51 or is the only way it could be interpreted. And then to be completely intolerant of those who did not have that same exposure.
Click to expand...
Exactly, Mark. I'm pretty sure if I were to ask all the CFIs I know who do not hang out on internet forums the same question they would come up with the technically wrong answer. Up until a few years ago I would have given the wrong answer too. In fact, I never knew there was any kind of controversy until then.
 
midlifeflyer said:
So you think that

==============================
A person sport, recreational, private, or commercial pilot may be in our store log pilot-in-command time only for that flight time during which that person--
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges wearing a shirt;
==============================

has to mean that pants are not required?
Click to expand...

Yes, unless pants are explicitly called for by another reg.
 
EdFred said:
FLOWCHART!!!! :D :D :D

61.51(e) says you need to be rated in the category and class to log PIC time if you are not solo. I was not rated in Class (Multi) with Dr Bruce's Seneca, nor was I rated (seaplane) when I was receiving instruction. So I could not log it as anything except training received and flight time. Just like I was a student pilot all over again.
Click to expand...

Ed, I know the flowchart... I've studied it and used it enough that I know it like the back of my hand. It's a great resource and I thank you for it. :D

Now, being that I understand the flow chart, and 61.51(e), I know that you could not log it as PIC time as you were not rated in category/class. My curiosity pertained to whether it was logged as training time (i.e., Dr. Bruce was acting as a CFI and signed your logbook entry), or if you just logged it as Total Time, without an entry in the PIC or Dual Received columns. You did answer my question in your post, that it was in fact logged as training time, so I thank you for that. Everyone may now resume the somewhat uncalled-for bashing of CFI's who didn't fully study this particular reg.
 
My .02 is that if a student questioned the CFI as the OP did. Then it was the DUTY of the CFI to say "lets look it up"! Instead of "because I say so".
Lost count of the number of times one of my CFI's and I sat down with a FAR to FIND the correct answer when neither one of us were SURE!

For their own knowledge, but to also TEACH their students how to find the answers they are looking for when a CFI isn't standing there to give them an off the cuff answer.

Mark B
 
Most times I answer a student question it's with assisting them in where to find it. I never outright answer a student's question but rather turn it back on them. If they have to find the answer, they are more likely to remember the answer and where to find it again.
 
TMetzinger said:
Yes, unless pants are explicitly called for by another reg.
Click to expand...
You mean like 61.31?

I think that FAA Legal could have just as easily gone the route of saying that "only" in 61.51 meant referred to "necessary" but not "sufficient" conditions for logging. IOW, you must =at least= be a private pilot rated in class, but are still subject to other qualification regs. The interpretation would have made just as much (some would argue, more) sense.

I think there are a lot of reasons they didn't, including some (interesting or boring) history that may be a part of it. But I don't buy that the interpretation we've come to know is mandated by the words of the regs.
 
midlifeflyer said:
You mean like 61.31?

I think that FAA Legal could have just as easily gone the route of saying that "only" in 61.51 meant referred to "necessary" but not "sufficient" conditions for logging. IOW, you must =at least= be a private pilot rated in class, but are still subject to other qualification regs. The interpretation would have made just as much (some would argue, more) sense.

I think there are a lot of reasons they didn't, including some (interesting or boring) history that may be a part of it. But I don't buy that the interpretation we've come to know is mandated by the words of the regs.
Click to expand...

Sigh... 61.31 talks about acting as PIC. In your analogy 61.31 is a reg that specifies that pants must be worn in another store, or in a bar..

It would certainly be easier if you could only log PIC when you were ACTING as PIC. But if that's what the FAA wanted, they'd have made 61.51 say just that. Regardless of whether you think it's a "loophole" (and many do feel that way - see the discussion on how the major airlines define PIC time for their purposes), it DOES exist, you CAN log PIC when you're not ACTING as PIC, and you've been able to do so for at least 28 years.
 
Last edited:
markb5900 said:
My .02 is that if a student questioned the CFI as the OP did, then it was the DUTY of the CFI to say "Lets look it up"! instead of "because I say so". Lost count of the number of times one of my CFI's and I sat down with a FAR to FIND the correct answer when neither one of us were SURE!

For their own knowledge, but to also TEACH their students how to find the answers they are looking for when a CFI isn't standing there to give them an off the cuff answer.
Click to expand...

This is an awesome response. If I ever make it to the point of becoming a CFI, that's what I will do!
________
Ducati 998
 
Last edited:
markb5900 said:
My .02 is that if a student questioned the CFI as the OP did. Then it was the DUTY of the CFI to say "lets look it up"! Instead of "because I say so".
Lost count of the number of times one of my CFI's and I sat down with a FAR to FIND the correct answer when neither one of us were SURE!

For their own knowledge, but to also TEACH their students how to find the answers they are looking for when a CFI isn't standing there to give them an off the cuff answer.

Mark B
Click to expand...

This is the way all CFIs should be.
 
dmccormack said:
...and all I have dealt with in the past three years have been, as well.

The broad swipe "All CFIs are idiots" nonsense sounds like sour grapes.
Click to expand...

I certainly never said that. CFIs, on the whole, are good people (just like almost every other type of pilot).

But I will say that I never hold CFIs to be the gods that some of them think they are. They are pilots, like me, except they have a certificate that lets them teach. I know the same amount of stuff, as should any other pilot, since we all have the same text books, I just don't teach it.

But if I did, and I was asked a question I didn't know the answer to, I wouldn't guess.
 
TMetzinger said:
Sigh... 61.31 talks about acting as PIC. In your analogy 61.31 is a reg that specifies that pants must be worn in another store, or in a bar..

It would certainly be easier if you could only log PIC when you were ACTING as PIC. But if that's what the FAA wanted, they'd have made 61.51 say just that. Regardless of whether you think it's a "loophole" (and many do feel that way - see the discussion on how the major airlines define PIC time for their purposes), it DOES exist, you CAN log PIC when you're not ACTING as PIC, and you've been able to do so for at least 28 years.
Click to expand...
I guess you miss the point.

I don't disagree with you. There's no question at all that that's the way the FAA has interpreted it forever. I'm just saying that FAA Legal could have interpreted the words the other way just as easily, and those who put down people for not knowing the interpretations and not knowing how the words should be read are sighing at others and acting superior with no reason.
 
midlifeflyer said:
I guess you miss the point.

I don't disagree with you. There's no question at all that that's the way the FAA has interpreted it forever. I'm just saying that FAA Legal could have interpreted the words the other way just as easily, and those who put down people for not knowing the interpretations and not knowing how the words should be read are sighing at others and acting superior with no reason.
Click to expand...

Agreed.

If this question was answered so simply there would be no concern for the interpretation by whatever administrative body the accident pilot is facing.
 
You must log in or register to reply here.
Back
Top