Question on PIC and XC time for IFR rating

Discussion in 'Cleared for the Approach' started by Blueangel, Jan 26, 2016.

  1. Blueangel

    Blueangel Line Up and Wait

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    I recently met with a local San Diego CFII to discuss accelerated IFR training and he mentioned that all PIC XC time must be SOLO without an instructor even if you were the sole manipulators of the controls. Is this true?

    I have 70+ PIC XC time but only 32 with no instructor as PIC XC.

    Thanks,
    Scott
     
  2. jordane93

    jordane93 Final Approach PoA Supporter

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    Wrong. Tell him to look at 61.65
     
  3. Caramon13

    Caramon13 Pattern Altitude

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    He's wrong. Have him re-read 61.65:

    Except as provided in paragraph (g) of this section, 50 hours of cross-country flight time as pilot in command, of which 10 hours must have been in an airplane..

    Though honestly, I would RATHER do it solo then pay some CFI to keep me company. I did my 50 mostly by myself, but I did have some trips with the family and of course I also counted my long xc IFR flight which is also required by 61.65 as part of that amount.

    By the time I took my checkride I had something like 60 PIC XC.
     
    Last edited: Jan 26, 2016
  4. coma24

    coma24 Line Up and Wait

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    Show him this:
    And then ask him for a reference that shows the XC time must be solo.

    Edit: I'm slow off the draw today.
     
  5. Blueangel

    Blueangel Line Up and Wait

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    Thanks! I have way more than 50 hrs PIC XC time when flying for additional reasons like flight reviews and mountain XC trips.
     
  6. Blueangel

    Blueangel Line Up and Wait

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    I will ask the CFII but think he is going by the FAA aeronautical experience form with the online application under cross country solo/PIC time IACRA form. I can also check with a local DPE on this to be sure.
     
  7. Caramon13

    Caramon13 Pattern Altitude

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    Having just done the Iacra on this in November I can tell you that there is a separate area for cross-country solo time, but that's not really important. I ballparked it and then after I got my rating I went back and started accounting for it. I think I put like 38 hours cross country solo and I had like 64 hours PIC XC.

    When you think of it, solo time for instrument rating training doesn't really make sense. I mean, you do sorta need a safety pilot for hood work or a CFII for training. It's not really the same as commercial where solo time can be beneficial (long xc for example).

    So, in a practical sense, why should solo time even be important for instrument?
     
    Last edited: Jan 26, 2016
  8. Blueangel

    Blueangel Line Up and Wait

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    Yeah me neither unless he misunderstand the IACRA section for XC Solo/PIC?
     
  9. asgcpa

    asgcpa En-Route

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    Big wrong
     
  10. Gucci Pilot

    Gucci Pilot Pattern Altitude

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    Your instructor is wrong. Regs say nothing about that time being solo.
     
  11. Blueangel

    Blueangel Line Up and Wait

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    Yeah he admitted as such when I asked him about it,
     
  12. Blueangel

    Blueangel Line Up and Wait

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    I spoke with a local San Diego DPE and also the FSDO answered my questions and confirmed this. As long as it is solo pre-PPL without an instructor XC and post-PPL, if you are PIC XC with instructor. So I am good to go with way more than 50 XC PIC.
     
  13. FreqFlyrJr

    FreqFlyrJr Pre-Flight

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    I'm glad this was the consensus we came to. Most of my XC is with a friend as I almost can't stand to fly alone! :lol:
     
  14. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    Correct answers to questions that have a real answer are not based on consensus.

    1+1=2 even if everyone disagrees.
     
  15. apr911

    apr911 Pre-takeoff checklist

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    I have received similar feedback from San Diego area Part 61 CFII's and having read the Regs and discussed it further with the CFII's, the issue comes down to being "PIC." Technically, prior to receiving your PPL, all time falls into 2 categories: Dual non-PIC or Solo PIC.

    As such, your non-licensed student cross-countries flown dual with an instructor get logged as XC time but not PIC. Since you are not the PIC, you cannot count them towards the instrument rating.

    Thus the follow-up interpretation you posted is correct which can be simplified as: Dual XC time logged as a student non-licensed pilot is excluded from counting towards the aeronautical experience requirement of 50 hours. All other PIC XC time counts.
     
  16. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    The result aside, the issue never* comes down to "being" PIC. The issue always comes down to being able to "log" PIC. Student pilot dual flights are not PIC to the student pilot for only one reason - there is no logging PIC box in 61.51 it fits in.

    [*The only exception to "never": if the logging rule itself says you have to be PIC]
     
  17. scottfromboston

    scottfromboston Pre-takeoff checklist

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    Wrong.

    Bad instructor.

    No ramen for you.
     
  18. Greg Bockelman

    Greg Bockelman Administrator Management Council Member

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    Which post are you referring to?
     
  19. scottfromboston

    scottfromboston Pre-takeoff checklist

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    The original post. I just went through this a few weeks ago; the DPE explained the IACRA process to me and my instructor.

    I think that the other posters here highlighted the confusion involving the IACRA form, but there's no requirement to be solo (or even that the flight isn't dual).

    Pretty straightforward, but makes the IACRA accounting pretty time-consuming.

    In my case, I lost a little bit of time thanks to doing part of my IFR X/C in actual instrument conditions, but everything else since my PPL I was able to count.
     
  20. JeffDG

    JeffDG Touchdown! Greaser!

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    Why?

    If you were the sole manipulator of the controls, even in IMC, you can log PIC, and if the distance is OK, XC.

    If you're ASEL, and you're flying a single engine without floats and without the need for a type rating, you can log it as PIC.
     
  21. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    Yep, there are no exceptions, ifs, ands or buts to the rule as stated in 61.51(e)(1)(i).
     
  22. Caramon13

    Caramon13 Pattern Altitude

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    This is the second or third time I've heard that. I had instructors tell me I can't log PIC time in actual either (before I got my rating). They are all wrong.

    For the reason that Mark already stated. I had to argue that point with my instructor. Apparently one of the DPE's locally is also misinformed and will back out PIC time where there's an "actual" IMC number by the actual amount. Tell you what, if I had that DPE I'd get a refund..

    You do not stop being PIC when you fly into a cloud on an IFR flight plan, even when you don't have your instrument rating. Unless you take your hands off the yoke and give the plane to the instructor, it's your time if you are sole manipulator.
     
  23. JeffDG

    JeffDG Touchdown! Greaser!

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    Well, on your IFR cross-country for your instrument rating, you are not "acting" as PIC at all. You can't. Since you don't have an instrument rating, you cannot act as PIC on a flight conducted under Instrument Flight Rules.

    That said, if you're the one flying the plane, you are 100% able to log PIC time for that flight. Regardless of conditions of flight.

    See:
    http://www.faa.gov/about/office_org...09/speranza - (2009) legal interpretation.pdf

    and

    http://www.faa.gov/about/office_org...2009/herman - (2009) legal interpretation.pdf
     
  24. Caramon13

    Caramon13 Pattern Altitude

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    Jeff, yes I agree you can't be the legal PIC on the flight plan. I believe the protocol is to file the flight plan yourself and put somewhere in the notes that the legal PIC is the CFII.

    We are both saying the same thing. I just said the last bolded part without saying the first. If you fly as sole manipulator on an IFR flight plan, you CAN log PIC time throughout all phases of flight that you are sole manipulator.

    Backing out PIC time for the amount you flew in actual is not necessary.
     
  25. JeffDG

    JeffDG Touchdown! Greaser!

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    Yep, we're at the same conclusion.

    Kind of the point I was getting at is that your status as "acting" as PIC does not change because you're in a cloud on your IFR XC. You cannot act as PIC for any of it. I don't get why the OWT that if you're in a cloud, you can't log as PIC comes from.
     
  26. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    If that DPE gave me a discontinuance because of something the FAA has said is proper logging for more than 30 years, I would definitely get a refund.

    If not, no harm, no foul and I'd let him enjoy his bliss.
     
  27. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    Really? That's easy. Many people have an understandably difficult time with abstract concepts. In this case, the the term "pilot in command" is referring to two completely different and independent things, one of which has absolutely nothing to do with being "in command." If the FAA had used the term "flugbap" instead of logged PIC,

    61.51(e) Logging flugbap flight time.
    (1) A sport, recreational, private, commercial, or airline transport pilot may log flugbap flight time for flights-
    (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;​

    61.65(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:
    (1) Except as provided in paragraph (g) of this section, 50 hours of cross-country flight time as flugbap, of which 10 hours must have been in an airplane; and​

    the issue probably wouldn't exist.
     
  28. luvflyin

    luvflyin Final Approach PoA Supporter

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    Hmm. There is PIC, pilot in command. And there is PIC, pilot in charge. The "acting PIC" is the important distinction in some cases. I went through all this last year when I was medically grounded but still doing a lot of flying dual. I legally logged PIC time because I was the sole manipulator of the controls. I even logged it when I was the sole manhandler of the controls, lol.
     
  29. scottfromboston

    scottfromboston Pre-takeoff checklist

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    Interesting discussion guys. Thanks! I'll research and talk to my CFII's and am seeing the DPE soon (CPL ride coming up).

    It's only ~2.7 in actual so far, but I may as well take credit ;).
     
  30. apr911

    apr911 Pre-takeoff checklist

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    Still confused. I see nothing there that says you cant log PIC time for actual IMC or even SIM IMC while on (or not on) your IFR XC. I think the issue is more with the use of the term rating than PIC.

    61.65(d) merely spells out that you need 50 hours of which 10 needs to be in an airplane.

    61.51(e) however states that your "rating is appropriate" in which case I can see the argument that you aren't "rated" for IFR so you cant log your IFR XC as PIC but the key to that terminology is "class rated." An instrument "rating" is not a "class rating."

    Private pilots wander in to IMC conditions all the time accidentally, by themselves with no one rated for that operation... If they manage to get themselves out of the situation without getting themselves killed and the FAA doesn't violate their certificate (the weather is predictably unpredictable at times) for operating outside of their rating, they are entitled to log that time as PIC & IMC.

    This also answers why your PPL XC with instructor doesn't count because you aren't rated for the class of aircraft. Using your solo time is somewhat nebulous because though you aren't fully rated, there is no one else in the plane to assume responsibility and you're responsible for the operation (though Im sure some lawyer could and would make a civil case attaching liability to your CFI but I digress).

    In addition, technically when you are signed off for solo you are signed off for a restricted "student pilot's license" and thus are "rated" for operation of the class of aircraft so your Pre-PPL solo XC(s) count but your Pre-PPL dual XCs do not. Sort of like the "restricted" or "junior" driver's licenses many states issue now for drivers between 16 and 18 that require they be off the road between certain hours among other potential restrictions.

    I think this is a large part of why the FAA is making changes to the student pilot license. It's no longer just get a medical, get medical and endorsement in log book signed by instructor, go fly solo. The FAA now processes student license requests.

    Frankly, I the FAA needs to overhaul the terminology used. I hear certificates, ratings and type ratings used interchangeably when they are all different and they're often used semi-interchangeably within the Regs (i.e. the regs say "type rated" or "class rated" or "category rated") and all people see is the "rated for operation." The same goes for their XC, Night and PIC definitions. I shouldnt have to check 14 (hyperbole but not far off; their are at least 3 different regs for night and 3 different regs for xc time plus a multitude of others for PIC definitions and certificate/rating definitions) different regs to determine what counts as night or xc or PIC. If the definition doesn't fit than they need to use more than 1 term or decide which standard they want to follow. There's no reason I should be able to log night flight but then not have my night flight count for night currency.

    Perhaps an extreme example but in parts of Alaska, its possible to log night flight but never be able to get night current for the purpose of passengers. While it may be an extreme, it highlights quite clearly the issue with having multiple definitions for a term for regulatory purposes. Multiple definitions of night might work for common usage but not for legalese.

    Flying a SEL tailwheel or complex or high perf or aircraft >12,500lb or pressurized cabin/high altitude or et al, doesnt mean I cant log PIC time for that aircraft as my class is SEL and as long as Im with an appropriately type-rated pilot, I can be the sole manipulator and log PIC.

    There's nothing stopping me from solo flying a T182 (the turbo version of the C182) or the T182RG (retractable gear) if I have my high-performance rating and in the case of the later my complex as long as I dont try to take it to altitudes where the pressurization system becomes important... And even at mid-level altitudes, it'd be easy to skirt the type rating to a degree (though uncomfortable) by flying the plane unpressurized with supplemental oxygen.

    Similarly, I can fly a amphib plane solo all day long as long as I limit myself to land based landings as that is what my rating permits. A C182 with floats is slower and more difficult to handle on account of the additional drag of the floats but landing it on land is ultimately not any different from a similar aircraft...

    For that matter, I can replace my landing gear or floats with Ski's... Last time I checked there is no endorsement, type, class or category rating for Ski based landing gear.

    At the end of the day, an instrument rating and a commercial rating are more stringent type ratings for which the requirements are specifically spelled out and you need to "retake the driver's test" to a higher standard where as a High-Perf or other type endorsement just requires you receive training and be deemed proficient by a rated instructor. A SEL vs SES or MEL/MES on the other hand are like private automobile vs private motorcyle, the rules of the road are the same but you aren't "retaking the test" because the tests are testing a completely different driving methodology.


    50 hours is what you need for most of your ratings and certificates. If you plan on going for your ATP then you need 500 hours but at that point, I wouldn't stress over 2.7 hours; 3 hours is only 0.6% of your total XC time at that point and really is losing those 3 hours really going to make a difference? Yeah you have to go put 3 more ours in a plane but in the grand scheme of things you've already put 1500 hours and 497 hours XC in the plane what's 3 hours? Especially since the ATP requirement is easier to obtain since XC time is logged any time your route takes you greater than 50NM straightline distance; per the regs, you dont need to land 50NM away which suddenly makes flying really long STAR's look appealing.
     
    Last edited: Feb 3, 2016
  31. apr911

    apr911 Pre-takeoff checklist

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    As noted in the Herman interpretation, for the purpose of PIC time, category and class are what matters. If you meet the category and class requirements than you can log PIC time anytime you are the sole manipulator of the controls.

    The Herman interpretation draws upon Speranza which states "for the purpose of logging PIC time under ยง61.51(e), a pilot must hold ratings for the aircraft rather than for the conditions of flight."

    Both interpretations really only address logging of PIC time as it pertains to an specific aircraft and not necessarily to XC time.

    However, there are interpretations that can help here as well. In Jeff Gebhart (2009), the question was posed who can log XC time under 61.51(e) for the purposes of fulfilling aeronautical experience requirements for 61.65(d). The interpretation ruled that the safety pilot is unable to log XC time however as long as the safety pilot operates solely in the role as the safety pilot and does not assume PIC duties by taking over the controls during the flight (I would interpret this as an "except as necessary to avoid a safety issue" because a momentary change over of controls to avoid a safety issue seems to me within the spirit of the regulation and purpose of having a safety pilot), the pilot operating under SIM Instrument may log XC time.

    Additionally, in Gareth Gordon (2006), the FAA spoke directly to PIC XC time with an instructor counting towards the 50 hours also while logging SIM or ACTUAL IMC. It specifically states that 61.65(d)(1) and 61.65(d)(2) can be accrued concurrently. It might not specifically state that your previous non-solo XC time counts but between these interpretations, I dont know how an instructor or DPE could conclude that it must be "solo"
     
  32. Blueangel

    Blueangel Line Up and Wait

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    The tricky part is that if you have (60 hours XC) - (5 hours of XC SOLO) as private pilot then you can only count 5 hours XC PIC toward the 50 for the IR. In my case, I only have 42.8 XC PIC out of 75 hours XC so in reality I need another 7.2 hours XC PIC before the check ride!

    So what I finally did was to add a new column in my logbook called SOLO XC PIC to account for this to avoid mistakes later when completing the IACRA form for the required aeronatical experience. Right now, I have 75.2 hours as PIC however only 42.8 counts as XC SOLO PIC!
    Fortunately I am in the early stage of training so I can fly a few long XC solo PIC trips this year and get the hours in before the checkride and a few for the IFR XC.

    - Scott
     
  33. mkosmo

    mkosmo Pattern Altitude

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    I'm having a tough time parsing your post here. Since when does solo PIC have anything to do with the required aeronautical experience for your instrument?
     
  34. Blueangel

    Blueangel Line Up and Wait

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  35. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    Scott, the "solo" in IACRA is for the purpose of ensuring one meets the "solo" requirements for, as examples, the private and commercial certificates. A solo xc is properly recorded in both columns.

    And, I don't believe it is a required field. The only fields that must be filled in are those that show qualification for what is being applied for. So, for the instrument rating, since there is no solo requirement, no solo time needs to be entered.

    If you are not listing cross country flights in which you are properly logging PIC time under 61.51 as meeting the 50 hour requirement, you are welcome to do so, but you are reading a "tricky part" into the rules that simply isn't there.
     
    Last edited: Feb 4, 2016
  36. JeffDG

    JeffDG Touchdown! Greaser!

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    You have a citation for that?

    If you have more solo XC as a private pilot, you can count all of it.
     
  37. Caramon13

    Caramon13 Pattern Altitude

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    Yeah, hell you can count your student pilot cross countries towards your IR requirements Scott. Since you are PIC when you are solo on those.

    Everything counts, in large amounts as a popular rock group once said :)
     
  38. midlifeflyer

    midlifeflyer Touchdown! Greaser!

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    i know you said "solo" at the end but just in case, a minor edit.
     
  39. Caramon13

    Caramon13 Pattern Altitude

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    Right, thanks Mark :D
     
  40. Blueangel

    Blueangel Line Up and Wait

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    Ok so my total PIC XC would be 45 hours out of the 88 hours XC total since I subtracted the XC that was not solo time during PPL training. So that leaves 5 hours left to complete XC PIC before the check ride.