Can I log PIC in...
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Mr_Creepy
Well-Known Member
more 2 cents change.
If the Pilot in Command designates you as Second in Command in a verbal briefing, you are now "operating under regulations that require a second in command."
The lawyers are going to see you as SIC at the very least.
My FSDO buddies agree with me.
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
If the Pilot in Command designates you as Second in Command in a verbal briefing, you are now "operating under regulations that require a second in command."
The lawyers are going to see you as SIC at the very least.
My FSDO buddies agree with me.
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
MidlifeFlyer
Well-Known Member
[ QUOTE ]
The lawyers are going to see you as SIC at the very least.
[/ QUOTE ]That's more or less true. Whether or not you have any official status, if you are given a job to do and don't do it well and something happens, you will be on the hook.
[ QUOTE ]
My FSDO buddies agree with me.
[/ QUOTE ]No offense to them, but I've seen a whole bunch of interpretations by FSDOs that have been completely wrong. Based on the surprisingly clear language of the regulation and one or two FAA legal opinions, I think they are wrong here.
One example, which is quoted in the Part 61 FAQ involves a scenario where a Part 135 operator designated a second pilot to act as SIC on an aircraft not required by type certification to have more than one pilot. Nothing in Part 135 required more than one pilot for the operation involved. The pertinent part of the opinion says:
==============================
Logging of SIC flight time is governed by section 61.51(f), which provides, in pertinent part, that a person may log SIC time only for that flight time during which that person acts as SIC of an aircraft on which more than one pilot is required by the aircraft's type certificate or the regulations under which the flight is conducted.
If a pilot designated as SIC is not required by either the aircraft type certificate or the regulations under which the operation is being conducted (e.g. 14 CFR part 135.103), as is the case in the scenario above, then the pilot designated as SIC may not log flight time as SIC.
==============================
Another example is a 1992 FAA Legal opinion in which the question came up about logging SIC in an airplane which was certificated for single pilot operation with a functioning autopilot and for two-pilot operation if the autopilot was not working. The question was whether the operation could decide not to use the autopilot and, if so, whether the designated SIC may log SIC time. In this case the answer was yes, but the reason:
==============================
Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged.
==============================
Having an airplane that is certificated for single pilot or two pilot operations depending on the circumstances and permitting the operator to decide which way to go is very different than "I feel like having an SIC in my Cessna 172"
[ QUOTE ]
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
[/ QUOTE ]FWIW, another solution. John, what do you think of this: I know that some pilots maintain a separate logbook column for "acting PIC time" to differentiate what employers are looking for (taking responsibility for flights) rather than what the FAA is looking for (numbers to put on an 8710 or show during an investigation). Why not do the same for SIC time? There's nothing wrong with logging "Non-FAA time" so long as you make it clear what you are doing.
The lawyers are going to see you as SIC at the very least.
[/ QUOTE ]That's more or less true. Whether or not you have any official status, if you are given a job to do and don't do it well and something happens, you will be on the hook.
[ QUOTE ]
My FSDO buddies agree with me.
[/ QUOTE ]No offense to them, but I've seen a whole bunch of interpretations by FSDOs that have been completely wrong. Based on the surprisingly clear language of the regulation and one or two FAA legal opinions, I think they are wrong here.
One example, which is quoted in the Part 61 FAQ involves a scenario where a Part 135 operator designated a second pilot to act as SIC on an aircraft not required by type certification to have more than one pilot. Nothing in Part 135 required more than one pilot for the operation involved. The pertinent part of the opinion says:
==============================
Logging of SIC flight time is governed by section 61.51(f), which provides, in pertinent part, that a person may log SIC time only for that flight time during which that person acts as SIC of an aircraft on which more than one pilot is required by the aircraft's type certificate or the regulations under which the flight is conducted.
If a pilot designated as SIC is not required by either the aircraft type certificate or the regulations under which the operation is being conducted (e.g. 14 CFR part 135.103), as is the case in the scenario above, then the pilot designated as SIC may not log flight time as SIC.
==============================
Another example is a 1992 FAA Legal opinion in which the question came up about logging SIC in an airplane which was certificated for single pilot operation with a functioning autopilot and for two-pilot operation if the autopilot was not working. The question was whether the operation could decide not to use the autopilot and, if so, whether the designated SIC may log SIC time. In this case the answer was yes, but the reason:
==============================
Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged.
==============================
Having an airplane that is certificated for single pilot or two pilot operations depending on the circumstances and permitting the operator to decide which way to go is very different than "I feel like having an SIC in my Cessna 172"
[ QUOTE ]
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
[/ QUOTE ]FWIW, another solution. John, what do you think of this: I know that some pilots maintain a separate logbook column for "acting PIC time" to differentiate what employers are looking for (taking responsibility for flights) rather than what the FAA is looking for (numbers to put on an 8710 or show during an investigation). Why not do the same for SIC time? There's nothing wrong with logging "Non-FAA time" so long as you make it clear what you are doing.
xdashdriver
Well-Known Member
[ QUOTE ]
more 2 cents change.
If the Pilot in Command designates you as Second in Command in a verbal briefing, you are now "operating under regulations that require a second in command."
[/ QUOTE ]
What regulation REQUIRES there to be an SIC solely when the PIC wants one?
[ QUOTE ]
My FSDO buddies agree with me.
[/ QUOTE ] FSDO buddies are usually the least informed about FARs. Sad, but true. If you want interpretation that carries any weight, make some buddies in the FAA Counsel's office, since those are the guys who will be prosecuting / convicting / sentencing you if you violate something. See my quote below, a copy of a letter that addresses this issue, in part.
[ QUOTE ]
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
[/ QUOTE ]
Since 61.55 requires logging for the purpose of meeting aeronautical experience requirements for certificates and ratings and recency of experience requirements, which come up a whole lot more frequently than an airline interview, I would suggest logging in accordance with 61.55 and making any adjustments as necessary for any airline interviews.
I think the important thing is that so long as you acknowledge that not all of your flight time necessarily meets up to airline recruiting standards, and have a method of determining which time does and which time does not match up, you'll be in good shape. It is a much better idea to conform to FAA standards and amend those as necessary.
As for there not being a restriction on logging SIC time under Part 91, I've read 61.51 over and over again, and I'm still not seeing how it can be interpreted to mean that there's no restriction.
I will stipulate that 61.51 only mentions requirements with respect to meeting aeronautical experience requirements or recent flight experience requirements, and you can therefore log anything however you want. HOWEVER...
Let's assume that you are using your 1 hour in a Cheyenne riding in the right seat, manipulating the controls to meet the aeronautical experience requirements for some rating or certificate. 61.51(f) quite plainly (which is strange for the FARs) prohibits logging ANY flight time as SIC that is not in an aircraft that is type certificated for two pilots, or the regulations under which the flight is conducted. If the REGULATIONS or the TC require an SIC, then it's loggable. If neither require an SIC, then it is not loggable as SIC.
Examples of regulations which require an SIC are certain types of 135 operations, 121 operations, and then 91.531 airplanes (large airplanes and jets, with a few exceptions).
61.51(f) is not vague at all, it is very specific. As can be seen below, in the interpretation from FAA Counsel on this matter. The situation which Counsel is addressing is different, but he covers this exact aspect of logging SIC time whe not required by TC or regulation... I have made the relevant sections bold.
[ QUOTE ]
QUESTION: Ref. § 61.51;
1. You ask whether the pilot can log PIC flight time during those portions of the flight when he or she is the sole manipulator of the controls and whether a pilot may be considered the SIC for the part 135 operation if he or she is paying the part 135 operator to conduct the flight.
Answered by: Donald P. Byrne, Assistant Chief Counsel, Regulations Division, AGC-200, Washington, DC
Mr. Jeff Karch
P.O. Box 5791
Lynnwood, WA 98046-5791
Dear Mr. Karch:
This is in response to your letter dated August 26, 1996, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), concerning the logging of pilot-in-command (PIC) time. Additionally, your letter raises questions regarding the qualifications of pilots designated as second in command (SIC) by part 135 (14 CFR part 135) operators.
In your letter you present the following scenario: A pilot, wishing to advance his or her career, pays a part 135 operator to fly in the right pilot seat during part 135 operations.
The logging of flight time is governed by § 61.51 of the Federal Aviation Regulations (14 CFR § 61.51). That section requires the logging of aeronautical experience used to meet the requirements for a certificate or rating, flight review, or the recent flight experience requirements of 14 CFR Part 61. The FAA does not require the logging of other flight time, but it is encouraged.
Logging of SIC flight time is governed by § 61.51(f), which provides, in pertinent part, that a person may log SIC time only for that flight time during which that person acts as SIC of an aircraft on which more than one pilot is required by the aircraft’s type certificate or the regulations under which the flight is conducted.
If a pilot designated as SIC is not required by either the aircraft type certificate or the regulations under which the operation is being conducted (e.g. 14 CFR § 135.103), as is the case For the scenario above, then the pilot designated as SIC may not log flight time as SIC. Although the flight time cannot be logged as SIC time, the pilot designated as SIC may be able to log part or all of the flight time as PIC in accordance with § 61.51(e).
§ 61.51(e) provides, in pertinent part, that a private or commercial pilot may log PIC flight time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated, or is acting as the PIC 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.
Accordingly, a pilot designated as SIC may log as PIC flight time all of the flight time during which he or she is the sole manipulator of the controls of an aircraft for which that individual is rated. Although the pilot designated as SIC For the scenario you provided in your letter may be properly logging flight time pursuant to § 61.51(e), the more important issue raised in your letter concerns whether or not this individual is properly qualified to be designated as SIC and to manipulate the controls of the aircraft.
§ 135.95 of the Federal Aviation Regulations (14 CFR § 135.95) provides, in pertinent part, that no certificate holder may use the services of any person as an airman unless the person performing those services holds an appropriate and current airman certificate and is qualified, under this chapter, for the operation for which the person is to be used. (Emphasis added)
§ 135.115 of the Federal Aviation Regulations (14 CFR § 135.115) governs who may manipulate the controls of an aircraft being operated under part 135. This section states, in pertinent part, that no person may manipulate the flight controls of an aircraft during a flight conducted under part 135 unless that person is a pilot employed by the certificate holder and qualified in the aircraft. (Emphasis added)
As a result, a part 135 operator may only designate a pilot as SIC and allow that individual to manipulate the controls of the aircraft if that pilot is “qualified” in the aircraft and “employed” by the certificate holder. In order to be “qualified” in the aircraft for the operation for which the person is to be used, a pilot designated as SIC must meet all applicable regulatory requirements including the eligibility requirements under § 135.245 (14 CFR § 135.245) and the initial and recurrent training and testing requirements under section 135.293 (14 CFR § 135.293).
§ 135.245 provides, in part, that a certificate holder may not use any person, nor may any person serve, as SIC of an aircraft unless that person holds at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating.
§ 135.293 provides, in part, that a certificate holder may not use any person, nor may any person serve as a pilot, unless that pilot has passed a written or oral test on the listed subjects in this section as well as pass a competency flight check.
Therefore, a part 135 operator may only designate a pilot as SIC if that pilot is properly “qualified” in accordance with the regulations including § 135.95 and § 135.115 (he or she holds the appropriate certificate and ratings pursuant to § 135.245 and that pilot has received the initial and recurrent training and testing requirements in accordance with § 135.293).
In addition to being properly “qualified,” a pilot may only manipulate the controls of an aircraft under § 135.115 if that individual is also “employed” by the part 135 operator. A pilot is considered to be “employed” by a certificate holder under part 135 if the pilot’s services are being “used” by the certificate holder. This is the dictionary definition of the word “employed”; there does not have to be a direct employer to employee compensatory relationship. While there does not have to be a direct employer to employee compensatory relationship, there does have to be an oversight relationship of the individual by the certificate holder for that individual to be considered properly “employed” (used) by the certificate holder.
As part of this oversight relationship, the part 135 operator is required, pursuant to 14 CFR § 135.63(a)(4), to keep certain records of each pilot the certificate holder uses in flight operations (e.g. the pilot’s full name, the pilot’s certificates and ratings, the pilot’s aeronautical experience, the pilot’s duties and assignments, the date and result of each initial and recurrent competency tests and proficiency and route checks, the pilot’s flight time,…). In addition, the part 135 operator is required under 14 CFR §§ 135.251 and 135.255 to provide, directly or by contract, drug and alcohol testing for each individual it “uses” in safety-sensitive positions. Flight crewmember positions, of which pilots fall under, are considered to be safety-sensitive positions as defined under part 121, appendices I and J, (14 CFR part 121, appendices I and J), which require drug and alcohol testing.
In summary, based on your scenario, a pilot, wishing to advance his or her career, may pay a part 135 operator to fly in the right pilot seat during part 135 operations provided he or she is qualified, under part 135, for the operation for which the person is to be used. In addition, this pilot may manipulate the controls of the aircraft during part 135 operations provided he or she is employed by the certificate holder. This pilot may be designated as SIC even though the aircraft being flown does not require more than one pilot and the regulations under which the flight is being conducted do not require more than one pilot. Finally, this pilot may log PIC flight time for those portions of the flight when he or she is the sole manipulator of the controls of an aircraft for which the pilot is rated, but may not log any portion of the flight as SIC time.
We hope that this satisfactorily answers your questions. This opinion has been coordinated with Flight Standards.
Sincerely,
Donald P. Byrne
Assistant Chief Counsel
Regulations Division
[/ QUOTE ]
So, as can be seen from the interpretation above, pure designation as a SIC by the company or PIC or whatever means diddly squat if the TC or regulations do not REQUIRE the SIC to be there.
Instead of logging ad hoc, log in accordance with 61.51 and adjust for any interviews. It makes it so much more standardized that way, and at least that way you can determine what's LEGAL and what's not.
Best solution...get a computer logbook and make some kind of a distinction between Part 1 PIC time, and Part 61 PIC time, and then filter out the portions with non-Part 1 PIC time, if your airline interviewers only want to see that kind of time in there.
Ray
more 2 cents change.
If the Pilot in Command designates you as Second in Command in a verbal briefing, you are now "operating under regulations that require a second in command."
[/ QUOTE ]
What regulation REQUIRES there to be an SIC solely when the PIC wants one?
[ QUOTE ]
My FSDO buddies agree with me.
[/ QUOTE ] FSDO buddies are usually the least informed about FARs. Sad, but true. If you want interpretation that carries any weight, make some buddies in the FAA Counsel's office, since those are the guys who will be prosecuting / convicting / sentencing you if you violate something. See my quote below, a copy of a letter that addresses this issue, in part.
[ QUOTE ]
My airline interview people tell me that they would rather see it as SIC than PIC. The very best solution is not logging it at all, but I know that would damage a lot of future careers!
[/ QUOTE ]
Since 61.55 requires logging for the purpose of meeting aeronautical experience requirements for certificates and ratings and recency of experience requirements, which come up a whole lot more frequently than an airline interview, I would suggest logging in accordance with 61.55 and making any adjustments as necessary for any airline interviews.
I think the important thing is that so long as you acknowledge that not all of your flight time necessarily meets up to airline recruiting standards, and have a method of determining which time does and which time does not match up, you'll be in good shape. It is a much better idea to conform to FAA standards and amend those as necessary.
As for there not being a restriction on logging SIC time under Part 91, I've read 61.51 over and over again, and I'm still not seeing how it can be interpreted to mean that there's no restriction.
I will stipulate that 61.51 only mentions requirements with respect to meeting aeronautical experience requirements or recent flight experience requirements, and you can therefore log anything however you want. HOWEVER...
Let's assume that you are using your 1 hour in a Cheyenne riding in the right seat, manipulating the controls to meet the aeronautical experience requirements for some rating or certificate. 61.51(f) quite plainly (which is strange for the FARs) prohibits logging ANY flight time as SIC that is not in an aircraft that is type certificated for two pilots, or the regulations under which the flight is conducted. If the REGULATIONS or the TC require an SIC, then it's loggable. If neither require an SIC, then it is not loggable as SIC.
Examples of regulations which require an SIC are certain types of 135 operations, 121 operations, and then 91.531 airplanes (large airplanes and jets, with a few exceptions).
61.51(f) is not vague at all, it is very specific. As can be seen below, in the interpretation from FAA Counsel on this matter. The situation which Counsel is addressing is different, but he covers this exact aspect of logging SIC time whe not required by TC or regulation... I have made the relevant sections bold.
[ QUOTE ]
QUESTION: Ref. § 61.51;
1. You ask whether the pilot can log PIC flight time during those portions of the flight when he or she is the sole manipulator of the controls and whether a pilot may be considered the SIC for the part 135 operation if he or she is paying the part 135 operator to conduct the flight.
Answered by: Donald P. Byrne, Assistant Chief Counsel, Regulations Division, AGC-200, Washington, DC
Mr. Jeff Karch
P.O. Box 5791
Lynnwood, WA 98046-5791
Dear Mr. Karch:
This is in response to your letter dated August 26, 1996, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), concerning the logging of pilot-in-command (PIC) time. Additionally, your letter raises questions regarding the qualifications of pilots designated as second in command (SIC) by part 135 (14 CFR part 135) operators.
In your letter you present the following scenario: A pilot, wishing to advance his or her career, pays a part 135 operator to fly in the right pilot seat during part 135 operations.
The logging of flight time is governed by § 61.51 of the Federal Aviation Regulations (14 CFR § 61.51). That section requires the logging of aeronautical experience used to meet the requirements for a certificate or rating, flight review, or the recent flight experience requirements of 14 CFR Part 61. The FAA does not require the logging of other flight time, but it is encouraged.
Logging of SIC flight time is governed by § 61.51(f), which provides, in pertinent part, that a person may log SIC time only for that flight time during which that person acts as SIC of an aircraft on which more than one pilot is required by the aircraft’s type certificate or the regulations under which the flight is conducted.
If a pilot designated as SIC is not required by either the aircraft type certificate or the regulations under which the operation is being conducted (e.g. 14 CFR § 135.103), as is the case For the scenario above, then the pilot designated as SIC may not log flight time as SIC. Although the flight time cannot be logged as SIC time, the pilot designated as SIC may be able to log part or all of the flight time as PIC in accordance with § 61.51(e).
§ 61.51(e) provides, in pertinent part, that a private or commercial pilot may log PIC flight time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated, or is acting as the PIC 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.
Accordingly, a pilot designated as SIC may log as PIC flight time all of the flight time during which he or she is the sole manipulator of the controls of an aircraft for which that individual is rated. Although the pilot designated as SIC For the scenario you provided in your letter may be properly logging flight time pursuant to § 61.51(e), the more important issue raised in your letter concerns whether or not this individual is properly qualified to be designated as SIC and to manipulate the controls of the aircraft.
§ 135.95 of the Federal Aviation Regulations (14 CFR § 135.95) provides, in pertinent part, that no certificate holder may use the services of any person as an airman unless the person performing those services holds an appropriate and current airman certificate and is qualified, under this chapter, for the operation for which the person is to be used. (Emphasis added)
§ 135.115 of the Federal Aviation Regulations (14 CFR § 135.115) governs who may manipulate the controls of an aircraft being operated under part 135. This section states, in pertinent part, that no person may manipulate the flight controls of an aircraft during a flight conducted under part 135 unless that person is a pilot employed by the certificate holder and qualified in the aircraft. (Emphasis added)
As a result, a part 135 operator may only designate a pilot as SIC and allow that individual to manipulate the controls of the aircraft if that pilot is “qualified” in the aircraft and “employed” by the certificate holder. In order to be “qualified” in the aircraft for the operation for which the person is to be used, a pilot designated as SIC must meet all applicable regulatory requirements including the eligibility requirements under § 135.245 (14 CFR § 135.245) and the initial and recurrent training and testing requirements under section 135.293 (14 CFR § 135.293).
§ 135.245 provides, in part, that a certificate holder may not use any person, nor may any person serve, as SIC of an aircraft unless that person holds at least a commercial pilot certificate with appropriate category and class ratings and an instrument rating.
§ 135.293 provides, in part, that a certificate holder may not use any person, nor may any person serve as a pilot, unless that pilot has passed a written or oral test on the listed subjects in this section as well as pass a competency flight check.
Therefore, a part 135 operator may only designate a pilot as SIC if that pilot is properly “qualified” in accordance with the regulations including § 135.95 and § 135.115 (he or she holds the appropriate certificate and ratings pursuant to § 135.245 and that pilot has received the initial and recurrent training and testing requirements in accordance with § 135.293).
In addition to being properly “qualified,” a pilot may only manipulate the controls of an aircraft under § 135.115 if that individual is also “employed” by the part 135 operator. A pilot is considered to be “employed” by a certificate holder under part 135 if the pilot’s services are being “used” by the certificate holder. This is the dictionary definition of the word “employed”; there does not have to be a direct employer to employee compensatory relationship. While there does not have to be a direct employer to employee compensatory relationship, there does have to be an oversight relationship of the individual by the certificate holder for that individual to be considered properly “employed” (used) by the certificate holder.
As part of this oversight relationship, the part 135 operator is required, pursuant to 14 CFR § 135.63(a)(4), to keep certain records of each pilot the certificate holder uses in flight operations (e.g. the pilot’s full name, the pilot’s certificates and ratings, the pilot’s aeronautical experience, the pilot’s duties and assignments, the date and result of each initial and recurrent competency tests and proficiency and route checks, the pilot’s flight time,…). In addition, the part 135 operator is required under 14 CFR §§ 135.251 and 135.255 to provide, directly or by contract, drug and alcohol testing for each individual it “uses” in safety-sensitive positions. Flight crewmember positions, of which pilots fall under, are considered to be safety-sensitive positions as defined under part 121, appendices I and J, (14 CFR part 121, appendices I and J), which require drug and alcohol testing.
In summary, based on your scenario, a pilot, wishing to advance his or her career, may pay a part 135 operator to fly in the right pilot seat during part 135 operations provided he or she is qualified, under part 135, for the operation for which the person is to be used. In addition, this pilot may manipulate the controls of the aircraft during part 135 operations provided he or she is employed by the certificate holder. This pilot may be designated as SIC even though the aircraft being flown does not require more than one pilot and the regulations under which the flight is being conducted do not require more than one pilot. Finally, this pilot may log PIC flight time for those portions of the flight when he or she is the sole manipulator of the controls of an aircraft for which the pilot is rated, but may not log any portion of the flight as SIC time.
We hope that this satisfactorily answers your questions. This opinion has been coordinated with Flight Standards.
Sincerely,
Donald P. Byrne
Assistant Chief Counsel
Regulations Division
[/ QUOTE ]
So, as can be seen from the interpretation above, pure designation as a SIC by the company or PIC or whatever means diddly squat if the TC or regulations do not REQUIRE the SIC to be there.
Instead of logging ad hoc, log in accordance with 61.51 and adjust for any interviews. It makes it so much more standardized that way, and at least that way you can determine what's LEGAL and what's not.
Best solution...get a computer logbook and make some kind of a distinction between Part 1 PIC time, and Part 61 PIC time, and then filter out the portions with non-Part 1 PIC time, if your airline interviewers only want to see that kind of time in there.
Ray
Mr_Creepy
Well-Known Member
Legally we all agree you have a right to log SIC. If there is an accident you will be seen as a responsible pilot in any situation where you have access to the controls.
My only concern is how it looks to an interviewer. Nobody really cares about your logbook once you get all your ratings, at least prior to the fatal accident!
I know that they don't want to see CFIs logging PIC when they are riding right seat of a king-air (etc) and they don't even have a high altitude sign off.
The whole logging of PIC issue is definitely a gray area. For example, take a B757 FO at United who has the type rating (they all do!), should that person log PIC on their legs? Emphatically not! They are not acting as "Pilot in Command" according to the airlines. The 14 CFR says they can though. So which is it?
61.51 just says "regulations" - it doesn't directly refer to which regulations although it certainly implies 14 CFR. It could be "company regulations" or maybe even "flight school regulations."
My last words on the subject (for now heh heh) - you will get in less trouble in an interview with SIC in your book than with PIC for this situation.
My only concern is how it looks to an interviewer. Nobody really cares about your logbook once you get all your ratings, at least prior to the fatal accident!
I know that they don't want to see CFIs logging PIC when they are riding right seat of a king-air (etc) and they don't even have a high altitude sign off.
The whole logging of PIC issue is definitely a gray area. For example, take a B757 FO at United who has the type rating (they all do!), should that person log PIC on their legs? Emphatically not! They are not acting as "Pilot in Command" according to the airlines. The 14 CFR says they can though. So which is it?
61.51 just says "regulations" - it doesn't directly refer to which regulations although it certainly implies 14 CFR. It could be "company regulations" or maybe even "flight school regulations."
My last words on the subject (for now heh heh) - you will get in less trouble in an interview with SIC in your book than with PIC for this situation.
xdashdriver
Well-Known Member
[ QUOTE ]
Legally we all agree you have a right to log SIC. If there is an accident you will be seen as a responsible pilot in any situation where you have access to the controls.
[/ QUOTE ]
Uh no....we do not all agree he has the right to log SIC in a Cheyenne Part 91. In this situation logging SIC would be outright illegal.
[ QUOTE ]
My only concern is how it looks to an interviewer. Nobody really cares about your logbook once you get all your ratings, at least prior to the fatal accident!
[/ QUOTE ]
Or when you get ramp checked and they want to see your recent flight experience to show you were legal to be PIC on that flight.
[ QUOTE ]
The whole logging of PIC issue is definitely a gray area. For example, take a B757 FO at United who has the type rating (they all do!), should that person log PIC on their legs? Emphatically not! They are not acting as "Pilot in Command" according to the airlines. The 14 CFR says they can though. So which is it?
[/ QUOTE ]
Yeah, but the airlines do not make the regulations and do not control what you put in YOUR logbook. As for your example, a type-rated FO, on "his leg," may indeed log PIC that time as PIC. Now, whether the company allows you to use that time to meet whatever requirements THEY may have, that's a different story, and they have the right to determine and define whatever time they want to see count towards their own requirements. They cannot regulate what you put in your logbook however.
[ QUOTE ]
61.51 just says "regulations" - it doesn't directly refer to which regulations although it certainly implies 14 CFR. It could be "company regulations" or maybe even "flight school regulations."
[/ QUOTE ]
Considering how the FAA has interpreted "regulations" in this very context, I think you'd be very hard pressed to make a case for anything else other than strictly 14 CFR.
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My last words on the subject (for now heh heh) - you will get in less trouble in an interview with SIC in your book than with PIC for this situation.
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In other words, you'd get in less trouble for logging it illegally, than for logging it legally? Does not make any sense, even if it is true.
Ray
Legally we all agree you have a right to log SIC. If there is an accident you will be seen as a responsible pilot in any situation where you have access to the controls.
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Uh no....we do not all agree he has the right to log SIC in a Cheyenne Part 91. In this situation logging SIC would be outright illegal.
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My only concern is how it looks to an interviewer. Nobody really cares about your logbook once you get all your ratings, at least prior to the fatal accident!
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Or when you get ramp checked and they want to see your recent flight experience to show you were legal to be PIC on that flight.
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The whole logging of PIC issue is definitely a gray area. For example, take a B757 FO at United who has the type rating (they all do!), should that person log PIC on their legs? Emphatically not! They are not acting as "Pilot in Command" according to the airlines. The 14 CFR says they can though. So which is it?
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Yeah, but the airlines do not make the regulations and do not control what you put in YOUR logbook. As for your example, a type-rated FO, on "his leg," may indeed log PIC that time as PIC. Now, whether the company allows you to use that time to meet whatever requirements THEY may have, that's a different story, and they have the right to determine and define whatever time they want to see count towards their own requirements. They cannot regulate what you put in your logbook however.
[ QUOTE ]
61.51 just says "regulations" - it doesn't directly refer to which regulations although it certainly implies 14 CFR. It could be "company regulations" or maybe even "flight school regulations."
[/ QUOTE ]
Considering how the FAA has interpreted "regulations" in this very context, I think you'd be very hard pressed to make a case for anything else other than strictly 14 CFR.
[ QUOTE ]
My last words on the subject (for now heh heh) - you will get in less trouble in an interview with SIC in your book than with PIC for this situation.
[/ QUOTE ]
In other words, you'd get in less trouble for logging it illegally, than for logging it legally? Does not make any sense, even if it is true.
Ray
It just seems the regs could be a little more cut and dried. Trying to delve through all the mishmash of things like "acting" versus "are" with regards to PIC is such a pain. Or the whole VMC night being instrument time issue, which has been argued ad nauseum. Or the taxi time being part of flight time if there was "intent to fly" verus taxiing from one hangar to another.
Luckily, being single seat and/or single pilot all my civilian career, the issue for PIC has been straightforward (my PIC time is only a few hundred hours different from my TT), but the night thing and taxi thing are both still something I butt heads with.
Luckily, being single seat and/or single pilot all my civilian career, the issue for PIC has been straightforward (my PIC time is only a few hundred hours different from my TT), but the night thing and taxi thing are both still something I butt heads with.
xdashdriver
Well-Known Member
Despite my strong support of legal logging, which includes some non-Part 1 PIC time, I think that the only PIC time which should be loggable and allowable at all is Part 1 PIC. It is certainly very diffcult for me to reconcile the reasoning behind the ability for two people to log PIC in the aircraft at the same time.
If the regulations were to cover every eventuality and situation they would 1) never get published because it would take to long to dream up every possible situation and provide for it and 2) be even longer and more complicated than they already are.
Having said that, when these discrepancies do arise, there should be CLEAR FAA policy guidelines which are READILY available to everyone to help through the process. A letter of interpretation here and there to individuals from an FAA lawyer hardly lends itself to creating a standardized policy or understanding of the regulations.
I'm not going to delve into it in any great detail, but if you thought the pilot regulations are a mess, don't bother with airworthiness regulations. STCs, Field Approvals, Form 337, Major Alterations....all of those regulations are a complete nightmare. The regulations reflect very little of what is actually practiced and enforced in the airworthiness realm. AND, understanding the way the system works is impossible to learn from reading the regulations.
It may be hard to standardize across such a huge organization, but the current state of affairs leaves a LOT to be desired. One wonders what exactly they do in training in Oklahoma City when they are minting new inspectors?
Stepping down off the soap box,
Ray
If the regulations were to cover every eventuality and situation they would 1) never get published because it would take to long to dream up every possible situation and provide for it and 2) be even longer and more complicated than they already are.
Having said that, when these discrepancies do arise, there should be CLEAR FAA policy guidelines which are READILY available to everyone to help through the process. A letter of interpretation here and there to individuals from an FAA lawyer hardly lends itself to creating a standardized policy or understanding of the regulations.
I'm not going to delve into it in any great detail, but if you thought the pilot regulations are a mess, don't bother with airworthiness regulations. STCs, Field Approvals, Form 337, Major Alterations....all of those regulations are a complete nightmare. The regulations reflect very little of what is actually practiced and enforced in the airworthiness realm. AND, understanding the way the system works is impossible to learn from reading the regulations.
It may be hard to standardize across such a huge organization, but the current state of affairs leaves a LOT to be desired. One wonders what exactly they do in training in Oklahoma City when they are minting new inspectors?
Stepping down off the soap box,
Ray
Mr_Creepy
Well-Known Member
Ray you missed my point COMPLETELY!!!!
By "legally" I mean in terms of LAWYERS and LIABILITY. I do not give one iota what the FARs say.
After you have your ATP - who gives a flying farkle what is in your log book EXCEPT AIRLINES???????????
Insurance companies NEVER look at your logbook. They send you a form and you tell your lies on that form
I have over 8000 hours now, been flying airlines and corporate for 17 years. I have never been asked to show currency on the 100 or so ramp checks I've been involved in.
By "legally" I mean in terms of LAWYERS and LIABILITY. I do not give one iota what the FARs say.
After you have your ATP - who gives a flying farkle what is in your log book EXCEPT AIRLINES???????????
Insurance companies NEVER look at your logbook. They send you a form and you tell your lies on that form
I have over 8000 hours now, been flying airlines and corporate for 17 years. I have never been asked to show currency on the 100 or so ramp checks I've been involved in.
xdashdriver
Well-Known Member
I see what you're saying, and to be honest with you, I'd prefer it if the FAA wrote 61.51 from your angle. It would make things a whole lot simpler.
At the end of the day it's the insurance company that matters, and as has been said already, you can tell them all your little lies on their form and they won't care (until it comes time to pony up)
Ray
At the end of the day it's the insurance company that matters, and as has been said already, you can tell them all your little lies on their form and they won't care (until it comes time to pony up)
Ray
MidlifeFlyer
Well-Known Member
[ QUOTE ]
It just seems the regs could be a little more cut and dried. Trying to delve through all the mishmash of things like "acting" versus "are" with regards to PIC is such a pain.
[/ QUOTE ]It can be. But I think, as ray pointed out, that trying to get through all the nuances by specific regulation could be more trouble than it's worth.
I tend to divide the FAR issues into two concepts. They help make the rules a little more cut and dried for me.
There are "crew" rules. Whether we're talking about the pilot in command or second in command or anyone else with some flight status, these rules involve FAA policy about who may take on official duties, authority and responsibility for a flight. "Crew Rules" have nothing whatsoever to do with writing numbers in column in a logbook.
There are "logging" rules. Here, =all= we're talking about is FAA policy about writing numbers in columns on a piece of paper while sitting at a desk with a beer in your hand so that you can count them toward certificates, ratings and currency. "Beer Rules" have nothing whatsoever to do with duty, authority or responsibility.
"Crew Rules" and "Beer Rules" have different policies and different purposes. Is it really any wonder they are different?
It just seems the regs could be a little more cut and dried. Trying to delve through all the mishmash of things like "acting" versus "are" with regards to PIC is such a pain.
[/ QUOTE ]It can be. But I think, as ray pointed out, that trying to get through all the nuances by specific regulation could be more trouble than it's worth.
I tend to divide the FAR issues into two concepts. They help make the rules a little more cut and dried for me.
There are "crew" rules. Whether we're talking about the pilot in command or second in command or anyone else with some flight status, these rules involve FAA policy about who may take on official duties, authority and responsibility for a flight. "Crew Rules" have nothing whatsoever to do with writing numbers in column in a logbook.
There are "logging" rules. Here, =all= we're talking about is FAA policy about writing numbers in columns on a piece of paper while sitting at a desk with a beer in your hand so that you can count them toward certificates, ratings and currency. "Beer Rules" have nothing whatsoever to do with duty, authority or responsibility.
"Crew Rules" and "Beer Rules" have different policies and different purposes. Is it really any wonder they are different?
C150J
Well-Known Member
Thanks for all of the responses, guys...
I have decided not to log the flight. People may consider me anal-retentive when it comes to playing "by the book," but I'd rather have a bloody-rare logbook than one's that been cooked to a crisp with "grey-area" flight time. I see this as an opportunity to network for more flights, some of which WILL be loggable once I get my high altitude endorsement.
Again, I greatly appreciate all the responses - this board is full of wonderful insight!
J.
I have decided not to log the flight. People may consider me anal-retentive when it comes to playing "by the book," but I'd rather have a bloody-rare logbook than one's that been cooked to a crisp with "grey-area" flight time. I see this as an opportunity to network for more flights, some of which WILL be loggable once I get my high altitude endorsement.
Again, I greatly appreciate all the responses - this board is full of wonderful insight!
J.
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