Logging pic in IMC as a private pilot IR training

Discussion in 'Cleared for the Approach' started by Fabio, Oct 2, 2019.

  1. Fabio

    Fabio Pre-Flight

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    Hello
    I am a private pilot training for IFR . Today we flew the whole lesson in hard IMC.
    My CFII said I could not log PIC time since I am not rated.
    Is this correct?
    I logged several PIC time with a safety pilot flying under the hood.
    Why is this different?
    Thx for the help.
     
  2. crash7

    crash7 Pre-takeoff checklist

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    Were you rated for the type of plane (ASEL)? Were you the sole manipulator of the controls? If so, log PIC.
    There are around 8 billion threads on here about logging vs acting PIC. Have your CFI look them up...


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  3. Fabio

    Fabio Pre-Flight

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    Yes I am rated ASEL and I was the only manipulator of the controls, he assisted with some radio work.
     
  4. crash7

    crash7 Pre-takeoff checklist

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    There ya go. 61.51(e). Sooooooo many CFIs don’t understand this one.

    Have fun with the training!


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  5. benyflyguy

    benyflyguy Pattern Altitude

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    I think you can. But I had the same discussion with my CFII during all of my instrument training. In fact I think you can log it with a safety pilot if you were IMC and the safety pilot was properly rated. :popcorn:
     
  6. Brad Z

    Brad Z En-Route

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    You were sole manipulator of the controls and rated in category and class. It's loggable as PIC time, even though you were not ACTING as PIC. Time to give your flight instructor some ground instruction on part 61.
     
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  7. RingLaserGyroSandwich

    RingLaserGyroSandwich Pre-Flight

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    I'm in the same position and my CFII agrees with me logging the time as PIC.
     
  8. mryan75

    mryan75 Ejection Handle Pulled

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    IR student here (with a competent instructor). YES, you can log that time as PIC.
     
  9. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    Yes. 1980 Chief Counsel letter specifically covers this one. That's not available on the FAA website, but this 2011 version is.

    This is the text of the 1980 one.

    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 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
    Regulations and Enforcement Division

     
    Last edited: Oct 3, 2019
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  10. jordane93

    jordane93 Final Approach

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    Your CFI needs more training.
     
  11. azure

    azure Final Approach

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    Agree with everyone here. And if possible, find a more knowledgeable CFII... being wrong on this point makes me wonder how much other misinformation he is passing along to his students.
     
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  12. Tantalum

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  13. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    It's a sticky!!!!
     
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  14. Tantalum

    Tantalum En-Route

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  15. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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  16. crash7

    crash7 Pre-takeoff checklist

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    I’m a CFI and have certainly been wrong on a great many things as I continuously learn how to teach. This topic though, comes up so much, I’m still amazed when CFIs get it wrong.



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  17. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    I disagree. Not having paid much attention to the rules around what you write down in a column of a logbook does not necessarily reflect on ability to teach instrument skills and procedures.

    If provided official references to what the rule actually is, the instructor rejects it in favor of his own beliefs, then I would be concerned.
     
  18. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    It might mean the CFI is so good, busy, and successful he hasnt time to hang out in internet forums and doesnt need to do an FIRC.
     
  19. James331

    James331 Touchdown! Greaser!

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    And he’s a CFII?
     
  20. azure

    azure Final Approach

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    I agree that even a CFII doesn't necessarily know everything. Nevertheless, he needs to give correct instruction on rules and regs, not just skills and procedures. Does he know what instruments are required for IFR flight? Does he think you have to do a RAIM check with a WAAS GPS? I might not immediately fire him, but I would definitely be skeptical of everything he tells me in that area. And if there was another instructor available with a reputation for knowing these things cold AND being a good teacher in the skills department, I would strongly consider switching.
     
  21. bobmrg

    bobmrg En-Route

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    If I have said it once I have said it a hundred times...."Show me where it says that it writing." Also note the caveat in my sig block.

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  22. lancie00

    lancie00 Line Up and Wait

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    Log it.
     
  23. danhagan

    danhagan Pattern Altitude

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    Maybe DPE's doing the oral for the CFI and CFII exams should include the above logging scenario?:confused::confused::p
     
  24. TommyG

    TommyG Cleared for Takeoff

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    Find a new CFII.
     
  25. MauleSkinner

    MauleSkinner Final Approach

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    Amazing how many people are offended by the fact that you don’t believe they know everything.
     
  26. coma24

    coma24 Line Up and Wait

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    Don't mean to be harsh to the CFII here, but this is IFR Instruction 101. It's 100% relevant to the task at hand of training an instrument pilot and preparing them for the checkride. I'd be concerned, although not quite ready to pull the plug. Ask them for clarification on LOGGING vs ACTING as PIC. If that doesn't jog their memory or spur them into action (ie, check FAR references), then I'd be legit concerned.

    We're not talking about places where you can do aerobatics, O2 limitations for crew vs pax on a Part 91 flight or parachute packing requirements....we're talking about logging IMC time during your instrument training! If he/she isn't well-versed in this reg, then there's a good chance that other regs of a similar nature or not well-understood either (15 hours with a CFII doesn't have to be in an airplane, for example, or ability to log IMC time with an instrument-rated PIC who is not a CFII, etc)

    These are not new issues/questions in the industry. I'm not a CFI (not even close) and I have a reasonable grip on these things. When I don't, I know where to go and double check. Your CFI should have more of a grip on these things than an ASEL IR PPL.

    For those who would defend the CFII, saying that they can't know everything, I agree. However, this is not an obscure, infrequently-encountered scenario.
     
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  27. SbestCFII

    SbestCFII Line Up and Wait

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    Then you can log PIC time. The instructor can always log PIC while providing the instruction and is acting PIC as required pilot in IMC, but you can also log PIC as the sole manipulator of the controls.
     
  28. BrianNC

    BrianNC Pattern Altitude

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    Exactly. So when you get in actual IMC and with an instructor it's suddenly not loggable as PIC? How does that make sense?