logging APIC for comm. amel

hattrick

Well-Known Member
quick question here that i got to thinking about after reading another forum. lets say i am a private pilot ASEL, IA. now i want to get a commercial AMEL but do not want to bother with getting a comm. ASEL first. i have never flown a multi-engine aircraft before so i do not have a pivate AMEL. now 61.129b says that i need 10 hrs solo or performing the duties of PIC with an authorized instructor on board. ok so the question is can i log APIC with an instructor onboard while not having a private AMEL. does this make sense. i would not be rated in the category yet but im simply performing the duties of PIC so do i need to be. can i meet that requirement or do i have to go get a private AMEL first.
anyway this really doesnt apply to me at all but as a cfi it really bugs me when i dont know something.
 
well what i did was got my private asel, ifr addon, then when i started my comm multi training, for all of the long x/c flights my instructor gave me supervised solo (PIC), and that counted for the ten hours of acting as pic. hope it helps
 
yeah thats what i thought and couldnt find any reason why not. others however disagreed so i just thought id see if i were the only one that thought it was perfectly legal.
 
NO, you can not log it as PIC. Remember in order to log PIC you must be rated in Category and Class. The 10 hours needed for the commercial AMEL as PIC is what they call "performing PIC duties" and should be logged as so in the remarks section. Check the part 61 FAQ's you will find the answer in there.

Hopefully midlifeflyer will weigh in on this, he's pretty good with the legal stuff
FOD
 
There is an endorsment you could recieve from your instructor to fly the airplane solo when your not rated in that aircraft and then log that as PIC.
 
FOD said:
NO, you can not log it as PIC. Remember in order to log PIC you must be rated in Category and Class. The 10 hours needed for the commercial AMEL as PIC is what they call "performing PIC duties" and should be logged as so in the remarks section. Check the part 61 FAQ's you will find the answer in there.

Hopefully midlifeflyer will weigh in on this, he's pretty good with the legal stuff
FOD
You don't need me. Your answer was just fine.

But, just for an explanation, let's look at what the reg says:
==============================
61.129(b)(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section),
==============================

(b)(2) refers to the 100 hours PIC time that's required for the commercial certificate in a multi.

The time "performing the duties of PIC" is a special regulation that the FAA was nice enough to put in since, as a practical matter, insurance is not going to cover solo flight in a multi and FBOs won't let you do it.

You can use it =as a replacement= for solo and you can "credit it toward" PIC requirements, but it is really neither solo nor really PIC - it doesn't override what 61.51 says about logging time. It doesn't belong in the PIC or solo columns. Most CFIs probably mention it in "remarks" as you suggested, although using a spare column temporarily is probably done also.

There is an endorsment you could recieve from your instructor to fly the airplane solo when your not rated in that aircraft and then log that as PIC.
You're right Ace. And if you have a place where they will rent a multi for solo flight with low hours, that's exactly what you would do.
 
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