Multi Commercial PIC Fiasco

caliginousface

caliginousface

Frank N. Beans
Hello esteemed CFI's,
Have a buddy whose question I couldn't give a definitive answer, so here goes.

He did his multi-engine as his initial commercial, and in his logbook, the instructor logged it as PIC, under the "...10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor..." as the reasoning. Checkride passed, blah blah, and he went on get his MEI using those 10 hours to fulfill the requirement of 61.183(j) where you must "Log at least 15 hours as pilot in command in the category and class of aircraft that is appropriate to the flight instructor rating sought."

So to sum up the above, he had about 5 hours of instruction in the twin to prepare for his MEI, and used the 10 hours to get to the 15 as required by reg. Since then, he's taught in it and has over 100 hours multi, most of it as instruction given.

Depending on who you talk to, some say yes you can use it, and some say no you can't use the 10 hours. If anyone has a solid answer, that'd be sweet. I told him he could surrender his multi engine instructor rating, not count any of the time since his MEI checkride, and start over if he thinks the present situation would screw him in an interview.

Any thoughts?
 
It is allowed. They recently updated 61.51 to match 61.129(b). Before, even though 61.129(b) said you needed to be performing the duties of PIC, there wasn't a provision in 61.51 to allow it to be logged as PIC. Here is the relevant part from 61.51.
(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

( 1 ) Preflight preparation;

( 2 ) Preflight procedures;

( 3 ) Takeoff and departure;

( 4 ) In-flight maneuvers;

( 5 ) Instrument procedures;

( 6 ) Landings and approaches to landings;

( 7 ) Normal and abnormal procedures;

( 8 ) Emergency procedures; and

( 9 ) Postflight procedures;

(C) The supervising pilot in command holds—

( 1 ) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

( 2 ) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.
Click to expand...
 
Mojo, you left out an important paragraph.


(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;
Click to expand...


PDPIC may not be logged as PIC in AMEL unless you already have a commercial AMEL or ATP AMEL certificate.
 
caliginousface said:
Any thoughts?
Click to expand...

1. This is the last day of Bacon Month and tomorow is the start of Cheese Month. Not sure what the featured food is for March

2. Do a seach with the terms "Logging PIC" and "Job Interview". I'll bet you'll find that almost nobody had their logbook examined in a job interview.
 
This area has been confused enough long enough that it is probably ripe for someone to write the FAA Chief Counsel's office for an opinion. I've received guidance on it from sources I trust, but the gold standard is an opinion from the Chief Counsel's office, and as far as I know, they have never issued one on that subject.
 
adk said:
PDPIC may not be logged as PIC in AMEL unless you already have a commercial AMEL or ATP AMEL certificate.
Click to expand...

You are reading the reg correctly.

Now for the question that remains. What is the point of this reg when the "sole manipulator" reg takes care of this already?

The only time you will read "performing the duties of pilot in command" is when you are getting an initial commercial certificate under 61.129.
 
Maurus said:
You are reading the reg correctly.

Now for the question that remains. What is the point of this reg when the "sole manipulator" reg takes care of this already?

The only time you will read "performing the duties of pilot in command" is when you are getting an initial commercial certificate under 61.129.
Click to expand...
Nope. The regs overlap but they cover different things.

61.51(e)(1)(iv) is a long subsection of the reg with all the subparts being connected by "and." Let's take one of those:

==============================
(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation--
==============================

What the reg is really contemplating is a pilot in an carrier's training program who is undergoing an approved PIC training program. That type of program may well include CRM trainiing for a two pilot crew. "Perfomring the duties of PIC" may involve training in supervising the flight crew with the instructor (the actual PIC) playing copilot.

The FAA has apparently decided to allow the trainee to log PIC time for playing the PIC role even though he is neither manipulating the controls nor the acting PIC in a 2-pilot crew.

Check out the Final Rule for it in the Federal Register. I think I linked to or quoted from it in another post on the topic, but you can see this type of scenario discussed.
 
You must log in or register to reply here.
Back
Top