FAA interpretation help

[tgrayson]

I have spoken with the Feds and they didn't share your point of view.

Well, you have no documentation to support your point of view, but I (and the others) do. This seems to undermine your position.

I'm still puzzled you haven't bothered to read any of the letters of interpretation. The lawyers writing these letters give the marching orders to the "feds" you mention. If your "feds" disagree, then they are mistaken.

 

[MidlifeFlyer]

Well, you have no documentation to support your point of view, but I (and the others) do. This seems to undermine your position.

I'm still puzzled you haven't bothered to read any of the letters of interpretation. The lawyers writing these letters give the marching orders to the "feds" you mention. If your "feds" disagree, then they are mistaken.

You should know by now that you cannot win an argument with a "true believer" using reality.

So what if the FAA Chief Counsel said you can log PIC in these situations in formal letters of interpretation going back 25 years. He won't accept it and won't believe it, so it cannot possibly be right.

 

[tgrayson]

You should know by now that you cannot win an argument with a "true believer" using reality.

I'm a perpetual optimist. Every now and then, someone will experience a paradigm shift, just when you think they're a lost cause.

Doug should require a written test before advancing to "Old Skool".

 

[MikeOH58]

This is kind of off topic, but this is something I've wondered about. Lets say you're an FO in a type-rating required airplane. You're flying and the captain has a heart attack and dies while you're aloft. You take the controls and land the plane safely. Do you log the time from after the captain dies as PIC, since you are both the sole manipulator and the acting PIC, even if you don't have the type rating?

:banghead::banghead::banghead::banghead:

 

[SteveC]

Part 61 applies to *everybody*, regardless of whether the flight is Part 91, 121, 135, 125, etc. The FO, if he has the appropriate type rating, can log PIC as the sole manipulator.

However, the Part 121 guys will be quick to point out that when looking for a job, most employers have no interest in knowing about this sort of PIC time. They want to know the time spent as Captain.

Correct.

The information in the second paragraph is exactly why I have another column in my logbook that I label "Part 61 PIC". I log the time there that I am sole manipulator in an aircraft that I am typed for but not the PIC of record. There are some...er, very few...instances when that PIC time can by useful.

Shoot, I know of a POI (granted, 135 not 121) and probably a whole FSDO office that not only agrees that sole manipulator (if typed) can log PIC, but he goes so far as to say that that kind of PIC time even counts towards things like "high-mins" captain qualifications (an interpretation that I don't agree with, by the way).

 

[PGT]

I told my instructor about me being able to log PIC while doing hood work to qualify for the 50hrs xc pic and he replied with yes you can but it will hurt when trying to find a job if they see you're logging pic while not instrument rated. Any truth to this?

 

[tgrayson]

will hurt when trying to find a job if they see you're logging pic while not instrument rated

Absurd. People have a tendency to project onto others what in reality are their own beliefs. Combine that with low experience as an employed adult, and you will hear all sorts of bizarre things. (Referring to your instructor here.)

Another instructor told one of my students he'd never get a job because I had used a blue pen on all my log entries, so he went back and overwrote them in black. He later acknowledged that this was ridiculous.

Having spent 25 years in the working world, I've never observed or heard of anyone make hiring decisions on such silly criteria. If they like you and you're qualified for the position, the odds are high you will be offered the job. If they like you enough, it may not matter whether you're qualified.

That's not to say that there aren't random idiots who would turn you down based on the color of your tie, but I don't think that statistically it's something to base your planning on.

 

[meritflyer]

You may not log PIC in actual IMC even with an instructor since you are not Instrument rated. You may only log it as DUAL received and total time. The instructor would log it as PIC.

[Dr. Evil voice] Riigghht.. [/Dr. Evil Voice]

You may not log PIC time in any plane you are not appropriately rated for for. e.g. a PPL without Complex or H.P. endorsements may not log PIC in those planes even if he is the sole manipulator of the controls.

See previous response.

 

[butt]

:banghead::banghead::banghead::banghead:

Whats that supposed to mean? The way I see it, you can for the same reason you can log PIC time when a student pilot does his solo flights. I'v never seen the topic come up, so I thought I'd ask.

I told my instructor about me being able to log PIC while doing hood work to qualify for the 50hrs xc pic and he replied with yes you can but it will hurt when trying to find a job if they see you're logging pic while not instrument rated. Any truth to this?

What he might have meant was that some airlines don't like to see PIC time logged while you're with a CFI. I think United, or one of those legacy carriers has a hiring minimum of 1000 PIC hours, which they exclude any PIC time when you're with an instructor.

When I was doing training, I didn't even realize you could log PIC until I was studying for my CFI. None of my instructors filled in the PIC column when I flew with them, probably because they heard that airlines don't like it, so I assumed you couldn't do it.

That's not to say that there aren't random idiots who would turn you down based on the color of your tie, but I don't think that statistically it's something to base your planning on.

Don't under estimate the pettiness of hiring board members. I read on internet message boards all the time peopel claiming to be in charge of hiring who will admit to turning down an applicant because "well if they can't manage to wear a tie that doesn't look cheesy, how can I be sure they can manage a airline cockpit?"

I remember reading on this very forum a while ago a guy who claimed to turn down prospective applicants if they ever had bought time in a multi-engine airplane. That particular pilot had a CFI job where his boss paid for his multi-comm and his MEI. As a result he now feels that anyone who paid for any time in a twin is no better than a Gulfstream pilot, and he won't hire them.

 

[tgrayson]

Don't under estimate the pettiness of hiring board members.

I'm making a statistical argument. There are people out there who may turn you down for any number of reasons, but the reasons are all different, so you can't know what they are. Don't worry about them. All in all, they are a small percentage of the hiring population.

It generally reflects a lack of confidence to worry excessively about stuff like that, which is quite understandable when the candidate has probably never had a job interview in his life.

Be worthy of hiring and you will be hired by somebody.

some airlines don't like to see PIC time logged while you're with a CFI.

This seems to be more common with the majors than with the regionals, particularly these days. Even so, it's not an argument not to log it, but they may choose not to consider it when looking at your PIC time.

 

[Bandit_Driver]

Tgrayson,

After having done some additional research you appear to be correct in the logging of PIC under Part 61 and I was incorrect.

I still agree with Polar in regards to the 121 logging of time and SIC shouldn't be logging PIC, regardless of the FAA's view on. It will only get you more grief at a major airline interview than it will help IMHO.

Also as others have said, some majors will throw out all PIC time as a CFI. UAL is one prime example of this. Also other majors will go as far as to only count PIC in which you signed for the aircraft (e.g. FedEx).

I personally will continue to log time in a more conservative mannor than the FAA allows.

 

[tgrayson]

After having done some additional research you appear to be correct in the logging of PIC under Part 61 and I was incorrect.

Thank you for looking at the evidence and being open to changing your mind. My faith in humanity soars.

I still agree with Polar in regards to the 121 logging of time and SIC shouldn't be logging PIC, regardless of the FAA's view on. It will only get you more grief at a major airline interview than it will help IMHO.

Note that I have made no argument about whether you *should* log the time, only what it's legal to do. I do understand that many of the majors aren't interested in "sole manipulator" time, although some people have reported that some carriers allow it. SteveC said he keeps a separate column for this time.

 

[MidlifeFlyer]

I told my instructor about me being able to log PIC while doing hood work to qualify for the 50hrs xc pic and he replied with yes you can but it will hurt when trying to find a job if they see you're logging pic while not instrument rated. Any truth to this?

I would be very concerned if an employer told me that they don't follow the rules. What other rules do they decide not to follow.

That said, there may very well be a difference between what you may log as FAA experience and what an employer might view as experience for the job. Let's take an extreme example that's not even a "PIC" issue.

You need a certain amount of cross country hours to meet various Part 135 minimum requirements. And all you need to have a flight counted as a cross country for 135 purposes is a landing somewhere other than when you started. No minimum distance. So you go into that interview with a qualifying number of cross country hours, but except for the ones you needed to get you private, instrument and commercial, they are all short hops to the airport with the restaurant 15 NM away.

The employer would be wrong in saying - "You can't count these as cross country to meet Part 135 minimums."

The employer would be perfectly within it rights in saying - "You're kidding? You call this 'experience'?!! Get out and get some 'real' cross country time!"

 

[PGT]

so what you're saying (I am a bit drunk) is that even though I CAN log that PIC time, I shouldn't?

 

[tgrayson]

so what you're saying (I am a bit drunk) is that even though I CAN log that PIC time, I shouldn't?

No. The minor point being made is that when you try to get a job with a major, many of them are probably only interested in the time you've spent acting as the PIC of the aircraft. This would exclude some of the "sole manipulator" time.

Regardless, you should log all the time as PIC that you're entitled to, because that's what everyone else is doing. If any airline wants to see your time differently, just be prepared to give it to them. Not really a big deal.

 

[Bandit_Driver]

I am going to have to disagree Tg. Just because one can do something doesn't mean they should do it. And you cannot honestly say everyone else is doing it. I for one log time in a more conservative matter and I am sure there are others out their too.

 

[tgrayson]

I for one log time in a more conservative matter and I am sure there are others out their too.

Are you working on your instrument rating? I suspect not.

 

[Polar742]

After reading the Carpenter interpretation from 1999, I just have to laugh.

The first part I agreed with. I logged PIC and dual rec'd while attaining instrument and commercial ratings, as well as in KingAirs operated under Part 91. (Note to noobs....figure out away to separate the PIC time to be used for future jobs (i.e.: You need 100 hrs BE90 PIC for a job. Or you need the PIC time to do MEI work [ya know, Mr. Rich Dude bought a BE200 cash money, and wants someone to be there, or insurance requires it.)

However, I know this guy is a lawyer, and went to law school, and is in a politically appointed job. How can I tell? Reading the 121 interpretation.

I still can't see how in a professional environment, you can be PIC under Part 1, but not part 61. Or you can't be PIC under Part 1 but you can under part 61. If you are at a 121 carrier, you have no need to log experience toward a future rating. Say you're a commercial/inst/multi as a lot of F/Os are. Once you meet ATP mins, you meet them. If you don't have a certain ratio of PIC to Total time you get an ICAO restriction, as I did. Then you fly a month or 2, go to the FSDO and get a new license cut.

Let's say everyone gets typed at Airline "A" (not WN, because you have to have 1000 turbo PIC). You get hired at 550TT, after 10 years, you never upgraded and the doors close. I'm sitting at the interview table with your log book. I look and you have 5000 PIC (hypothetical 1000 hrs/yr and you fly 1/2 the legs). I laugh.

We've also read all the AOPA stories of ATP rated much experienced guy riding with his PPL buddy. The ATP is enjoying the view, but hasn't flown GA in years, so isn't up on the TFRs and other crap that makes GA so enjoyable these days sarcasm. PPL guy pops some airspace. All of a sudden the guy who was sitting and relaxing in the airplane is designated PIC since he was in the right seat.

So while, yes, I agree you are correct in the reading of the interpretation, I still wouldn't do it. When the next lawyer takes the place of the guy writing the interpretation and the "view" is changed, you have alot of logbook shuffling to do.

Just like the rest requirement reversal issued via the Whitlow letter, what's true today, might not be tomorrow.

Just food for thought.

And yes, grayson, I still think you're the smartest dude on the board.

 

[tgrayson]

So while, yes, I agree you are correct in the reading of the interpretation, I still wouldn't do it.

And that's fine. That's the sort of advice that people want from this board.

However, I do think it's important to emphasize to people asking the question that it is legal, because it demonstrates that they understand the regulation. It's a validation of their reasoning processes. Telling them they can't do it confuses them because they see a regulation that plainly says they can.

I think it's also important to separate logging advice for someone already flying for a 121 operation from that of a guy working his way through his ratings. Telling the OP that he shouldn't include over half of his flight time as PIC is bad advice at his stage. Once he's ready to move to the majors, with a few thousand hours of turbine, that couple of hundred hours in a C172 probably won't matter.

 

[butt]

Let's say everyone gets typed at Airline "A" (not WN, because you have to have 1000 turbo PIC). You get hired at 550TT, after 10 years, you never upgraded and the doors close. I'm sitting at the interview table with your log book. I look and you have 5000 PIC (hypothetical 1000 hrs/yr and you fly 1/2 the legs). I laugh.

I would laugh too. Not because he did something illegal or immoral. I'd laugh for the same reason if I saw someone who had 5000 TT and 4900 Night.

There are 4 ways he FAA has determined you can log PIC:

1. Sole occupant
2. Sole manipulator and properly rated
3. Safety pilot
4. Captain in part 121 or 135.

If at least one of those conditions have been met, the time can be legally logged as PIC. If an airline posts their minimums as "1000 PIC" or whatever, then it's assumed they mean PIC time as defined by the regs, meaning one of those 4 conditions as been met. If they have another definition in mind, then they really shouldn't be using the term "PIC". If all they care about is PIC time when you're an airline captain, then they should post it as "1000 airline-captain-PIC".

We've also read all the AOPA stories of ATP rated much experienced guy riding with his PPL buddy. The ATP is enjoying the view, but hasn't flown GA in years, so isn't up on the TFRs and other crap that makes GA so enjoyable these days sarcasm. PPL guy pops some airspace. All of a sudden the guy who was sitting and relaxing in the airplane is designated PIC since he was in the right seat.

Do you have a link? I was always under the impression if before the flight the two pilots agree the lesser rated pilot is PIC, the ATP guy is off the hook.

So while, yes, I agree you are correct in the reading of the interpretation, I still wouldn't do it. When the next lawyer takes the place of the guy writing the interpretation and the "view" is changed, you have alot of logbook shuffling to do.

If the FAA were to change the sole manipulator clause to exclude 121 and 135 flights, wouldn't it not be retroactive?