Tailwheel endorsement

[kiwi lover]

I'm in the process of getting a tailwheel endorsement.. I already have my private and commercial; I wanted to just make sure I can legally log it as PIC even though it's dual-received, right?? I mean, I'm rated for flying ASEL which it is.. so I can log it as PIC, right??
no biggie if I can't.. just want my logbook correct -
thanks!

 

[tprops4me]

Not until you have the endorsement.

 

[ctab5060X]

Not until you have the endorsement.

:yeahthat:

CFR 14 Part 61 Sec 61.31

Type rating requirements, additional training, and authorization requirements.

(i) Additional training required for operating tailwheel airplanes.
(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.

 

[CoffeeIcePapers]

Not until you have the endorsement.

Not true. 61.51 is the only reg that deals with logging flights. 61.51(e)(1)(i)

(e) Logging pilot-in-command flight time. (1) A recreational, private, or commercial pilot may 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;

You are rated for the aircraft, ASEL. You can LOG PIC, but cannot ACT as PIC. 61.31 posted above says nothing about logging PIC, which is the question.

 

[kiwi lover]

I don't know how you guys keep those ridiculously confusing regs straight, but I thank you for the replies!!

 

[ctab5060X]

Not true. 61.51 is the only reg that deals with logging flights. 61.51(e)(1)(i)

You are rated for the aircraft, ASEL. You can LOG PIC, but cannot ACT as PIC. 61.31 posted above says nothing about logging PIC, which is the question.

Here we go again...discussing the loophole that allows you to LOG PIC, even though you legally can't ACT as PIC

This is how I was taught...

If you can legally act as PIC, then log it as PIC.
If you can't legally act as PIC, then it better be dual or something other than PIC.

Just my opinion, but I think it would look kinda funny with someone's logbook showing x number of PIC hours in a tailwheel airplane, then all of a sudden, here is the endorsement for them to be able to act as PIC in a tailwheel airplane.

I mean, we are talking 5-10 hours max on the endorsement...how big of a deal is it to just log it as dual? Are pilots so hard up for PIC these days that they will resort to using loopholes just to log a handful of hours of PIC?

If it were me, I would log it as dual received until I get the endorsement and PIC after the endorsement.

 

[CoffeeIcePapers]

Here we go again...discussing the loophole that allows you to LOG PIC, even though you legally can't ACT as PIC

This is how I was taught...

You were taught wrong.

Just my opinion, but I think it would look kinda funny with someone's logbook showing x number of PIC hours in a tailwheel airplane, then all of a sudden, here is the endorsement for them to be able to act as PIC in a tailwheel airplane.

If it were me, I would log it as dual received until I get the endorsement and PIC after the endorsement.

I posted fact, you posted opinion. It is your logbook, and you can do what you like, but the fact is that 61.51 is the ONLY reg that deals with pilot logbooks and tells you specifically that you can log PIC for any aircraft that you are the sole manipulator of the controls, that you are rated for.

And endorsement is not a rating.

 

[ctab5060X]

You were taught wrong.

All depends on how you look at things

I was taught that a long time ago. While I was told I could log it as PIC...should I log it as PIC, hence the way I was taught.

Had something to do with 61.153(c).

I posted fact, you posted opinion. It is your logbook, and you can do what you like, but the fact is that 61.51 is the ONLY reg that deals with pilot logbooks and tells you specifically that you can log PIC for any aircraft that you are the sole manipulator of the controls, that you are rated for.

And endorsement is not a rating.

Not arguing here, but the regulations are not entirely fact. They are a part of the Code of Federal Regulations, i.e. LAW...

Just like in any courtroom in America, the law is subject to interpretation, i.e. someone's opinion.

So, in essence, we are both right. That is just my opinion though.

 

[Berkut]

61.51 seems pretty clear to me in favor of logging. It's fine that you oppose it in principle, but I disagree that it's a matter of interpretation.

 

[CoffeeIcePapers]

Not arguing here, but the regulations are not entirely fact. They are a part of the Code of Federal Regulations, i.e. LAW...

Just like in any courtroom in America, the law is subject to interpretation, i.e. someone's opinion.

So, in essence, we are both right. That is just my opinion though.

The fact is that 61.51 says you can log it. Like I said, it is your logbook and you can put whatever you want in there.

 

[ctab5060X]

61.51 seems pretty clear to me in favor of logging. It's fine that you oppose it in principle, but I disagree that it's a matter of interpretation.

For the sake of the discussion...it is all a matter of interpretation.

I come from a background that mixed the legal profession with aviation, so I learned early on in my flying career that most things in the FARs are not to be taken at just face value and almost everything is open to interpretation. To me, 61.51(e)(1) is one of those that is open to interpretation...

Here is my thought process on determining that you can't need to log PIC time in a tailwheel aircraft before you have the endorsement.

CFR 14 Part 61
Section 61.51(e)(1)

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may 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;
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting 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

Notice the bold text. The word is 'may'...not 'must' as you see in 61.51(b) regarding what must be entered in the logged. To me, that is the flag that logging PIC is not clear cut. The way I was taught, 'may' means that there will be situations where you might not be able to log PIC under the provisions of 61.51(e)(1). Since we are flying a tailwheel aircraft, and there are specific regulations governing a tailwheel endorsement, let's dig a little deeper...

CFR 14 Part 61
Section 61.31(i)

(i) Additional training required for operating tailwheel airplanes.
(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.

Hmmm...here is something interesting...

Both of these sections refer specifically to pilot in command. That might be important...

I suggest a further investigation as to what exactly "pilot in command" means...

CFR 14 Part 1
Section 1.1

Pilot in command means the person who:
(1) Has final authority and responsibility for the operation and safety of the flight;
(2) Has been designated as pilot in command before or during the flight; and
(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

Now we are getting somewhere...

Notice in this definition lists three specific items for the definition of pilot in command. Notice at the end of line (2) the word 'and'. Notice it is not 'or', meaning that all three of these items need to be in place for an individual to be considered "pilot in command".

So, back to 61.31(i)...

Adding in the definition of pilot in command to this regulation makes things a lot clearer.

Although the appropriate category and class rating portion is satisfied...

No person may...
Have final authority and responsibility for the operation and safety of the flight; have been designated as pilot in command before or duirng the flight
...of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane.

Seems to me that the only person that can log pilot in command time is the instructor doing the endorsement.

Now that we have established that you are not the pilot in command (as you do not fully satisfy the definition of pilot in command per 1.1) we can revisit 61.51(e)(1) where it states...

A sport, recreational, private, or commercial pilot may log pilot-in-command time...

We will stop right there. Now that we have established that one can not be pilot in command of a tailwheel aircraft unless they have the endorsement, 61.51(e)(1) can be kicked to the curb and 61.51(h) is brought forth as this is the "flight training from an authorized instructor" as required for the tailwheel endorsement spelled out in 61.31(i).




61.51(e)(1) does seem pretty clear as long as it stands alone. However, when you put it back into the entire context of CFR 14 and use all available information and definitions, it becomes clearer that in this situation, it would be very wise not to log your training time toward your tailwheel endorsement as PIC. The less of a toehold you give the FAA, the better off you are. Just remember, when the FAA comes after you, they don't throw individual regulations at you, they throw the book at you

 

[Berkut]

Here is my thought process on determining that you can't need to log PIC time in a tailwheel aircraft before you have the endorsement.

Okay, hold on right there. No one here is saying that you need to log it as PIC, only that you may log it as pic.

Now that we have established that you are not the pilot in command (as you do not fully satisfy the definition of pilot in command per 1.1)

That was never in dispute. No one here is saying that you are the pilot in command, only that you may log it as pilot in command.

This letter addresses this exact situation:

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

 

[Hacker15e]

Holy smokes, dudes. We're talking about 5 damn hours here.

Log conservatively.

The only people who "care" are the ones who are going to hire you, and they're more interested in knowing that you logged conservatively and not in a fashion that requires "interpretation" of regs.

If you "need" those PIC hours that bad, then you've got a whole slew of other things to be concerned about with your sight picture as a professional aviator.

 

[ctab5060X]

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.

...just as long as you are not logging it solely as PIC before you have the endorsement in your logbook. Rarely is someone the "sole manipulator" for the entire time when the training starts.

I still don't think you should log it as pilot in command if you aren't pilot in command. To me, it is just asking for trouble to rear its head later.

Just curious, is there anything less than almost 30 years old on this subject?

Edit: The reason I ask is that a lot has changed in 28 years, including requiring endorsements for tailwheel, high performance, and complex aircraft that were added to 61.31 over a decade after this opinion was written. I would be curious of the interpretation using current regulations rather than ones that are nearly 3 decades old.

Holy smokes, dudes. We're talking about 5 damn hours here.

Log conservatively.

The only people who "care" are the ones who are going to hire you, and they're more interested in knowing that you logged conservatively and not in a fashion that requires "interpretation" of regs.

If you "need" those PIC hours that bad, then you've got a whole slew of other things to be concerned about with your sight picture as a professional aviator.

That is the point I was trying to make here. Tailwheel transitions can be tough for some pilots...that is why I think that not logging it as PIC (because you legally aren't) until you have the endorsement in hand is still the best course of action.

I mean, we are talking 5-10 hours max on the endorsement...how big of a deal is it to just log it as dual? Are pilots so hard up for PIC these days that they will resort to using loopholes just to log a handful of hours of PIC?

 

[BenWlson]

§ 61.51 Pilot logbooks.

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may 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;
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting 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.

This is a bit ridiculous for practical purposes, but I find it quite interesting from a technical aspect.

I do not have my CFI rating yet, so what I read from this reg. is that technically I cannot log PIC time when I let my 8 year old daughter fly the airplane (she can't reach the rudder pedals, but surprisingly, she doesn't do too bad).

The way these laws are written, I think it's possible to have a flight where no one can legally log PIC time. Gotta love the FAA.

 

[esa17]

Log it how you want but if someone comes around asking hard questions you had better be able to sell it so they don't take away your birthday.

 

[E6BAV8R]

Not true. 61.51 is the only reg that deals with logging flights. 61.51(e)(1)(i)

You are rated for the aircraft, ASEL. You can LOG PIC, but cannot ACT as PIC. 61.31 posted above says nothing about logging PIC, which is the question.

He is correct.

You are rated for the a/c, ASEL, therefore you can log PIC through the "manipulating the flight controls" but not through "ACT"ing PIC. Either way, if you are receiving instruction you can log PIC with an instructor on board. However, if you don't have the endorsement, you can not go solo in the tailwheel.

CFR 14 Part 61
Section 61.31(i)

(i) Additional training required for operating tailwheel airplanes.
(1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane. The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.
(2) The training and endorsement required by paragraph (i)(1) of this section is not required if the person logged pilot-in-command time in a tailwheel airplane before April 15, 1991.

Hmmm...here is something interesting...

Both of these sections refer specifically to pilot in command. That might be important...

I suggest a further investigation as to what exactly "pilot in command" means...

We are saying the same things here. He can not "ACT" as PIC, but he can log PIC through "manipulating the flight controls" if he is rated in category and class. That is how students with a PPL ASEL can log PIC in a C-172 while receiving flight instruction from an instructor rated in ASEL that is also logging PIC.

No person may...
Have final authority and responsibility for the operation and safety of the flight; have been designated as pilot in command before or duirng the flight
...of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane.

That covers the 'ACT'ing PIC - the student can still log PIC under "manipulating the flight controls' if he is rated category and class.

Now, I'm not saying it is smart or this is what he should do, just pointing it out that he can.

 

[CoffeeIcePapers]

Holy smokes, dudes. We're talking about 5 damn hours here.

If you "need" those PIC hours that bad, then you've got a whole slew of other things to be concerned about with your sight picture as a professional aviator.

Not necessarily. When you are flying under IFR for your instrument rating with an instructor, you aren't allowed to ACT as PIC, but you can still LOG PIC, per the reference I listed above. This could be a significant amount of flight time.

Also, safety pilot time is done the same way. If both safety pilots are rated in the aircraft, one pilot agrees to ACT as the PIC, while one is the sole manipulator under 61.51. Both can log PIC.

This is supported by multiple FAA opinions and 61.51, so I don't see what the problem is. There is a clear difference between acting as PIC and logging PIC.

 

[tprops4me]

Not necessarily. When you are flying under IFR for your instrument rating with an instructor, you aren't allowed to ACT as PIC, but you can still LOG PIC, per the reference I listed above. This could be a significant amount of flight time.

Also, safety pilot time is done the same way. If both safety pilots are rated in the aircraft, one pilot agrees to ACT as the PIC, while one is the sole manipulator under 61.51. Both can log PIC.

This is supported by multiple FAA opinions and 61.51, so I don't see what the problem is. There is a clear difference between acting as PIC and logging PIC.

Makes sense. I also just got off the phone with the local tail wheel instructor, and he said you can log PIC. He is also a DPE, so take that for what it's worth. Mojo, nice job correcting me so fast.

 

[Hacker15e]

Not necessarily. When you are flying under IFR for your instrument rating with an instructor, you aren't allowed to ACT as PIC, but you can still LOG PIC, per the reference I listed above. This could be a significant amount of flight time.

How many hours is it taking you to get your Instrument??