Initial Commercial-Multi PIC time logging question

dwe213

Well-Known Member
I'm an Instrument Rated Private Pilot now training for my initial Commercial Multi-Engine Land Airplane Rating. I do not hold any Multi-engine Rating. I want to log my time correctly and unambiguously.



I have two questions:
  • How many hours may I log as PIC during my training?
  • Is a solo flight endorsement (see 61.87) required to log any of these hours?
One of the aeronautical experience requirements for this Rating (61.129(b)(2)) includes: “100 hours of pilot-in-command flight time, which includes at least--.”



Included under “at least” is: 61.129(b)(iv)(4): “10 hours solo flight time in a multi-engine airplane or 10 hours of flight time preforming the duties of pilot in command in a multi-engine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section).”


Therefor, since “at least” refers to “10 hours”, then at least 10 hours may be logged as PIC during training for an initial Commercial, Multi-Engine Land Airplane Rating.


Also consider 61.51(2)(e): “Logging of pilot-in-command flight time: (4) A student pilot may log pilot-in-command time only when the student pilot: (ii) has a current solo flight endorsement as required under 61.87 and (iii) is undergoing training for a pilot certificate or rating.”


Thus, all Dual training received for an initial Commercial Multi-Engine Rating wherein the applicant has a current sole flight endorsement, and does not hold any Multi-Engine Rating, may be logged as PIC (assuming the applicant is always the “sole manipulator of the flight controls.”)


Fire away :rolleyes:
 

DL31082

Well-Known Member
My understanding is that you can not log PIC time until you are rated in the aircraft. That means that right now you can log PIC if you fly a single-engine aircraft but you can not log any PIC time in a multi-engine aircraft because you are not rated in that airplane. You would first have to get you private multi rating and then you can log PIC time. If I'm wrong someone please chime in.
 

dc3flyer

Well-Known Member
You CAN solo in a twin IF you can find an instructor to sign you off and an insurance company to insure you. Although, what you are looking at are the regs for getting your initial rating in a multi engine aircraft. Since you already hold a certificate, you need to look at the reg for additional certificates, I am not sure what the reg number is right off hand.
 

Jfk-Pilot

Well-Known Member
Note how it says "duties of PIC" it does not say "acting as PIC", hence in my own little world, and please do correct me if im wrong on this, but since you do not have at least a private multi -add on, on your license , you can't legally log that time as PIC, because you are not rated for that type of airplane.

So even though, you might be the sole manipulator of the flight controls, and your doing everything yourself, at the end of the day you still have to have a MEI sitting next to you.

Now lets say, after you got you private pilot rating, you went on to get your multi-add on, in that case, any further training that you receive in a twin, you can log as PIC, so in that case, all the multi-commercial flight training would be logged as PIC, and dual received.

**NINJA EDIT** Also take into consideration what DC3flyer said, and the FAR 61.63 i believe is what should be of interest for you,since this is an additional rating.
 

tgrayson

New Member
How many hours may I log as PIC during my training?
None, except in the unlikely event you will be allowed to solo this airplane.

at least 10 hours may be logged as PIC during training for an initial Commercial, Multi-Engine Land Airplane Rating.
No. The hours may be "credited towards the flight time requirement", but it is not actually PIC time.

(4) A student pilot may log pilot-in-command time only when the student pilot: (ii) has a current solo flight endorsement as required under 61.87 and (iii) is undergoing training for a pilot certificate or rating.”
You left out the all-important (4)(i):

Is the sole occupant of the aircraft
all Dual training received for an initial Commercial Multi-Engine Rating wherein the applicant has a current sole flight endorsement, and does not hold any Multi-Engine Rating, may be logged as PIC (assuming the applicant is always the “sole manipulator of the flight controls.”)
Nope, see above.
 

dwe213

Well-Known Member
However...

One of the aeronautical experience requirements for this Rating (61.129(b)(2)) includes: “100 hours of pilot-in-command flight time, which includes at least--.”

Included under at least is: 61.129(b)(iv)(4): “10 hours solo flight time in a multi-engine airplane or 10 hours of flight time preforming the duties of pilot in command in a multi-engine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section).”

Therefor, solo flight in a multi-engine plane is not required to log PIC.
 

Jfk-Pilot

Well-Known Member
However...

One of the aeronautical experience requirements for this Rating (61.129(b)(2)) includes: “100 hours of pilot-in-command flight time, which includes at least--.”

Included under at least is: 61.129(b)(iv)(4): “10 hours solo flight time in a multi-engine airplane or 10 hours of flight time preforming the duties of pilot in command in a multi-engine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section).”

Therefor, solo flight in a multi-engine plane is not required to log PIC.
but you still can't be an acting PIC.
 

tgrayson

New Member
“10 hours solo flight time in a multi-engine airplane or 10 hours of flight time preforming the duties of pilot in command in a multi-engine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section).”

Therefor, solo flight in a multi-engine plane is not required to log PIC.
I addressed this in the above post.

The time may be "credited" towards the PIC flight time requirement, but it is not PIC time. You cannot use the time as PIC time for any other requirement.

Moreover, logging PIC time is not governed by this regulation, it is governed only by 61.51(e), which requires being rated in the aircraft or being the sole occupant.
 

dwe213

Well-Known Member
How is time "credited towards the flight time requirement" any different here than time credited (logged) for any other requirement? I.e., isn't all logged time being credited towards some flight time requirement (until, I imagine, one has an ATP).
 

tgrayson

New Member
How is time "credited towards the flight time requirement" any different here than time credited (logged) for any other requirement? I.e., isn't all logged time being credited towards some flight time requirement (until, I imagine, one has an ATP).
I suppose the only relevance is that you can't use this time to qualify for the ATP or 135 minimums.

Here's something from the preambles of this regulation:
In addition, the FAA has revised § 61.129(b)(4) to permit an applicant for a commercial pilot certificate with a multiengine rating to credit the 10 hours of flight time performing the duties of PIC in a multiengine airplane required by that paragraph toward the 100 hours of PIC flight time required under § 61.129(b)(2). This revision is consistent with the provisions of § 61.129(b) as proposed in Notice No. 95-11. As previously noted, proposed § 61.129(b)(4) would have required an applicant to accomplish solo flight time in a multiengine airplane. The solo flight time would have constituted PIC flight time; therefore, the applicant would have been able to credit that flight time toward the requirements of § 61.129(b)(2). However, under § 61.129(b)(4) as adopted in the final rule, an applicant would be performing the duties of PIC rather than acting as PIC. Consequently, that flight time does not constitute PIC flight time. Therefore, the FAA has revised § 61.129(b)(4) to permit the crediting of flight time accomplished under that paragraph toward the requirements of § 61.129(b)(2). However, this revision does not permit an applicant to log the flight time required under § 61.129(b)(4) as PIC flight time under § 61.51(e) unless the applicant holds a private pilot certificate with a multiengine rating and chooses to accomplish the requirements with an authorized instructor.
 

dwe213

Well-Known Member
I appreciate your thorough and quick replies :) thank you. Looks like I'll just get my Commercial Multi now and save the cross-country trips for next month.

I'm setting up another PIC column in my logbook that includes only PIC solo time and PIC non-instructional passenger time--so if I ever make it to an airline interview I'll have a PIC total that is more reflective of acting PIC.

And while I'm thinking about how to log time properly, I'm deleting from my logbook PIC column the 9.0 actual instrument hours I flew while an instrument student because then I wasn't yet rated for actual IMC.
 

Berkut

Well-Known Member
And while I'm thinking about how to log time properly, I'm deleting from my logbook PIC column the 9.0 actual instrument hours I flew while an instrument student because then I wasn't yet rated for actual.
Keep it. You may log that time as PIC as long as you were rated for the aircraft and were sole manipulator of the controls.
 

tgrayson

New Member
And while I'm thinking about how to log time properly, I'm deleting from my logbook PIC column the 9.0 actual instrument hours I flew while an instrument student because then I wasn't yet rated for actual IMC.
As Berkut said, keep it. You just need to be rated for the aircraft. (SEL, MEL, SES, etc)

(But kudos for trying to apply new knowledge as widely as possible. Not everyone does that.)
 

dwe213

Well-Known Member
But I wasn't rated for the IMC conditions during training, only for the aircraft. Isn't that similar to not logging Multi PIC time before you're rated Multi-rated? Both cases involve logging PIC time before being legally able to fly in them (IMC, Multi-engine aircraft). :panic:
 

tgrayson

New Member
But I wasn't rated for the IMC conditions during training, only for the aircraft. Isn't that similar to not logging Multi PIC time before you're rated Multi-rated? Both cases involve logging PIC time before being legally able to fly in them (IMC, Multi-engine aircraft). :panic:

No. You must refer to the regulations. Logging PIC time is governed by 61.51(e) only. It requires you to be the sole manipulator of an aircraft for which you are rated. You do not have to be rated for the conditions of flight.

Yes, it's confusing. Read this.
 

dwe213

Well-Known Member
Concerning...
"61.129(b)(4) to permit the crediting of flight time accomplished under that paragraph toward the requirements of § 61.129(b)(2)"

My initial Commercial (multi) checkride is Saturday. I'm wondering what, specifically "crediting " (as discussed in this thread) looks like (i.e., does the DE just review the applicant's logbook to see that at least multi 10 hours were flown?) Does it just go on the IACRA form, or does it get listed somehow in the applicant's logbook?
 
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