FAA interpretation help

Matt13C

Well-Known Member
I am looking for a page of FAA interpretations on common questions, if one even exists.

I need it for a discussion I have been having with the non-flying owner.

I was talking to another student who is doing IR training in the office and mentioned we could do safety pilot work for each other. I went on to explain how we can both log PIC and it would count toward her XC time, not sure if it would count towards mine, and IR training time.

The owner of the school jumped in and said it was illegal and I could not be PIC if she(student) was flying. I tried explaining to her(owner) how it works, if I am the agreed upon PIC for the flight I can log the time she spends under the hood, she logs the whole flight since she is the sole manipulator. She does not beleive me so i would like to show her the FAA ruling on it, I showed her it in the FAR's and I guess she didn't agree with how I was interpreting it.

Also, am i correct in thinking that since I am a licensed PPL in ASEL any time I spend as the sole manipulator of the controls I can log as PIC? So even if I am in actual, even though I am not IR rated, if I am manipulating the airplane I am PIC, I just need an instructor or a rated IR pilot to be in actual.

How about when I am going for my tailwheel, high performance or complex? I am still rated in Category and class I just do not have the log book endorsement to fly it solo correct? However, when I go for my Multi that can only be logged as dual received because I will not be rated in Class correct?

I know this has all been covered before and I have read many of the threads as a way to see if my understanding of the FAR's were correct. Some of them are not so conclusive so I was hoping to the FAA would have cleared it up and pit it in writing.
 
I am looking for a page of FAA interpretations on common questions, if one even exists.

http://www.faa.gov/about/office_org.../agc/pol_adjudication/agc200/Interpretations/

if I am manipulating the airplane I am PIC
No, you're not necessarily PIC, but you can log it as such.

How about when I am going for my tailwheel, high performance or complex?
Yes, log as PIC.

However, when I go for my Multi that can only be logged as dual received because I will not be rated in Class correct?
Correct.
 
No, you're not necessarily PIC, but you can log it as such.

And that is because the Instructor has filed as the PIC, so he is technically PIC, but I can log it as such since I am the sole manipulator of the controls, correct?

Thanks for the information!

I am just going to start Emailing you directly going forward ha ha.
 
There is also a book called FARS Explained. It's mostly legal stuff but it does help explain some stuff.
 
Also, don't be afraid to reference my favorite. FAA Order 8900

I'd explain more, but you wouldn't look....:bandit:
 
So even if I am in actual, even though I am not IR rated, if I am manipulating the airplane I am PIC, I just need an instructor or a rated IR pilot to be in actual.


I don't believe you are able to log pic in IMC unless you're with an instructor.

You would be able to have 3 people logging PIC time if you did it right.
 
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.

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.
 
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.

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.

All of your statements are incorrect, as demonstrated by about a million threads on this topic. I've included a number of interpretations here:

Logging PIC
 
Now how can you log PIC on a plane you are not rated in. Call the FSDO and tell them and see what they say.

Next you'll be telling me a 121 FO that is typed can log all his legs as PIC...
 
Now how can you log PIC on a plane you are not rated in. Call the FSDO and tell them and see what they say.

Tgrayson explained it throughly in his write up and also provided interpretations from the FAA.

If you click on the link provided above to the FAA website you can search for other interpretations.

This link is an interpretation for an instrument student and XC time. It explains how part of the training can be done, under the hood or in actual, be logged as PIC and count towards your XC time.
http://www.faa.gov/about/office_org...agc200/Interpretations/InterpResultsIndex.cfm
 
Now how can you log PIC on a plane you are not rated in. Call the FSDO and tell them and see what they say.

Next you'll be telling me a 121 FO that is typed can log all his legs as PIC...

Complex and HP are not ratings, they are endorsements. IMC is a condition of flight. If you are rated in the aircraft, you can log it PIC. Part 121 is a different story. Maybe you should be the one to call the FSDO.
 
Now how can you log PIC on a plane you are not rated in. Call the FSDO and tell them and see what they say.
Next you'll be telling me a 121 FO that is typed can log all his legs as PIC...

Have you never read any of these threads? Have you never read any of the posted letters of interpretations? Did you not read the link I posted, which includes the FAA Letter of Interpretations?

(What the FSDO says is irrelevant. And yes, the the regulations allow the typed FO to log his legs as PIC.)
 
Complex and HP are not ratings, they are endorsements. IMC is a condition of flight. If you are rated in the aircraft, you can log it PIC. Part 121 is a different story. Maybe you should be the one to call the FSDO.

That brings up a question I was actually wondering though. Can an FO log PIC time on a leg he flies? Or does the CA always get PIC and the FO always get SIC regardless of who is at the controls?
 
That brings up a question I was actually wondering though. Can an FO log PIC time on a leg he flies? Or does the CA always get PIC and the FO always get SIC regardless of who is at the controls?

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.
 
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.

FAR61 said:
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.
Emphasis added by me

IMHO, under iii, on any multicrew airplane, unless you are designated PIC by your company, or by mutual agreement in a Part 91 OP, you can't log PIC even if you are type rated.

Example, A captain is called for a reserve trip as an FO, the company will designate a PIC and an SIC. I interpret subparagraph iii as that designation is acting as pilot in command.

Same reason our CAs log PIC in the bunk, and the IRO is not logging PIC. Everyone on the -400 is typed, yet only the CA logs PIC.
 
IMHO, under iii, on any multicrew airplane, unless you are designated PIC by your company, or by mutual agreement in a Part 91 OP, you can't log PIC even if you are type rated.

Your own highlights show your interpretation is incorrect. The very first word you bolded is "or", which means that any of the three conditions is **sufficient** to log PIC time.

(And that ignores the fact that we have LOI's which disagree with your interpretation.)
 
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?
 
Have you never read any of these threads? Have you never read any of the posted letters of interpretations? Did you not read the link I posted, which includes the FAA Letter of Interpretations?

(What the FSDO says is irrelevant. And yes, the the regulations allow the typed FO to log his legs as PIC.)

We are definately going to have to disagree on this and Yes, I have spoken with the Feds and they didn't share your point of view.

Also you are completely out in left field one 121 question I posed to you.
 
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