another logbook question


Well-Known Member
Okay, so a flight instructor I work with got real lucky and gets to fly a Kingair in his spare time. Now since the KingAir is less than 12,500 pounds, and he has a commercial multi certificate, I know he can log it has PIC time. However, he doesn't meet part 135 mins though, so does that mean he shouldn't be logging PIC if there are passengers on board? On empty legs can he log pic though? Should he be logging PIC time at all ever? Or should he maybe log second in command time? I dunno!
If he's flying it strictly under part-91 he can log the time.
If he's flying it strictly under part-91 he can log the time.

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And it is not abnormal for empty airplanes that are normally 135, to operate under pt 91 when empty.

So if the pax are on under part 135, and not part 91, he can not log PIC. this will come back to bite him/her if he is logging it and only has 700hrs.

it would go like this.

"Mr. Smith, I see you flew for a 135 operation from time to time while you were instructing."

"yes, I fell into the job quite lucky"

"you got 200 hrs in the King Air, how is it that you have 70 of those hours as PIC"

"I only flew PIC on deadhead legs"

"did you carry pax under part 91?"

"no never"

"oh, in March that you flew 4 legs in one day, one trip, all as PIC were empty?"

"ummm, maybe that's a error on my part, I better look into it"
As Eagle says, you can only log it on empty legs. You can only log it with passengers if you have been hired by the 135 operator and meet 135 pic requirements.

Also make sure your buddy has his high performance AND high altitude signoff if that King Air is going over FL250.
AND high altitude signoff if that King Air is going over FL250.

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You'll have to have the high altitude signoff regardless. Anything thats capable of going to FL250 (svc. ceiling or max. op. alt., whichever is lower) AND pressurized, requires it. I think thats what you meant...but just to clarify...
The high altitude and high performance endorsements are not needed in this case. If he is just riding along and is not acting as PIC, he will not need those endorsements. It has to do with the difference between logging PIC and acting as PIC. The captain, who is responsible for the safety of the flight, will be acting as PIC. This is the definition of PIC in FAR Part 1. Logging of PIC is covered under FAR Part 61.51. It states that as long as the pilot is the sole manipulator of the controls of an aircraft for which he is rated, he can log PIC. In a King Air, this means he has to have his multi-engine rating and that is it. No additional endorsements are needed because he is not acting as PIC. He can only log the time when he is the sole manipulator of the controls, and during that time the captain cannot log anything (even though he is acting as PIC.) All of this assumes, of course, that the flight is operated under Part 91.
I hate to disagree, but in order to log PIC time in a King Air above FL250, under part 91, the pilot must have his/her high altitude endorsement. FAR Part 61.51(e)(i) states that a person may log PIC time if the pilot “…is the sole manipulator of the controls of an aircraft for which the pilot is rated.” Everyone I have asked about this, agrees with me that “for which the pilot is rated” includes the high altitude endorsements…61.31(d)(3) states that to serve as PIC, a person must “…have received the required endorsements from an instructor…” 61.31(e), 61.31(f), and 61.31(g) indicates these specific endorsements for the complex, high performance, and high altitude signoffs. So basically (in English), in order to log PIC in a King Air the pilot must have:

1) Multi-engine rating
2) Complex endorsement
3) High Altitude endorsement
4) High Performance endorsement

As far as SIC goes, the King Air 200 is not a required two crewmember aircraft, so unless the Captain is “under the hood” you are not a required second crew member and therefore can’t log SIC. Hope this helps.
This is a quote from the FAA Chief Counsel, which is considered the official interpretation of the regulations.

"A private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating. However, while the private pilot may log this time as pilot-in-command, he or she may not act as the pilot-in-command unless he or she has the appropriate endorsement as required under 14 CFR section 61.31."

I know this only talks about a SEL rated private pilot and complex and high performance endorsements, but it shows the FAA's opinion regarding endorsements and ratings. Just because it is legal, however, does not mean that it is a smart thing to do. The FAA will not take any action against you for logging this time without these endorsements, but potential employers will be skeptical. Also, many airlines only allow you to count the time in which you acted as PIC. These are just some things to think about before you log any time like this.

So let me see if I got this correct, since here is exactly my situation:

1) I fly right seat on a Cessna 402 on a Part 135 cargo operation. The reposition portion of the flight is under 91 rules. If I get my multi-engine rating, and if I fly the airplane (sole manipulator) throughout the empty leg, then I can LOG PIC as well?? And the 135 pilot will log PIC because he is ACTING? That seems to be how it is boiling down, which is a nice situation.

2)Until I get my multi rating, is there ANY way to log this time NOT as PIC, not as SIC... but just towards total time?? Is that even appropriate?? I know this has come up in another post, the 'gaining experience' argument. The 135 pilot I fly with does not have his MEI, so I already cannot log it as dual.

I would rather NOT log any time I would have to 'explain' later, if ya know what I mean. Conversely, I dont want to pass up any free multi time either

As long as you have your multi rating and the flight is operated under Part 91, then yes you can log the time while you were sole manipulator of the controls. The captain, however, cannot log this time as PIC even though he is acting as PIC. Part 61.51(e) covers logging PIC time. For Part 91 flying, a recreational, private, or commercial pilot can log PIC time when he is the sole manipulator of the controls of an aircraft for which he is rated, is the sole occupant of the aircraft, or is acting as PIC when more than one pilot is required by the type certificate or the regulations under which the flight is operated. Since the 402 is a single pilot aircraft, and the reposition flight is Part 91 and only requires one pilot, the captain cannot log the time in which you were flying.

I've never heard of logging flight time as total time and nothing else because you are not rated in the aircraft.

There are a couple things to keep in mind here. First of all, the FAA only requires you to log the flight time necessary to show experience needed for a certificate or rating, and to show compliance with the recency of experience regs. So really you can log flight time however you want as long as you comply with 61.51 when using your time to apply for a certificate or rating or when showing the recency of experience requirements have been met. Another thing to keep in mind is that potential employers will want to look at your logbook, and if they see multi-engine time logged before you have your multi rating they are not going to like that (except for the time logged with a MEI.)

You also want to be careful if you log this time after you have your multi rating. You said you fly right seat in the 402 and it's a cargo operation. Are you employed by the company? The FARs say that only company employees, FAA inspectors, etc. may ride along during 135 cargo operations. So you have to be employed by the company and undergo any drug testing, background checks, or anything else that is required. If you are employed by the company than you're okay.

Even though logging this time is legal, keep in mind that many major airlines, and even some of the regionals, only count the time in which you acted as PIC. So if you apply to an airline like this you'll have to remember to subtract this time. Some 135 companies will hire people with less than the 135 IFR mins and then allow them to log the dead legs in order to build up enough time to be a 135 captain. Airnet Express does this, or used to do this, but I might be wrong. It's certainly possible that a future employer will ask you how you logged this time, but as long as you can explain how you were able to legally log it you should be fine. Sorry for such a long reply, but I hope this helps you out.