Logging Bonanza time with no complex/high performance endors.

CFI_Ty

New Member
Alright here is the situation. A buddy of mine who is a private pilot with no additional endorsements or ratings has been logging PIC in a bonanza. His dad (non-pilot) is buying this bonanza and his son has been flying with the owner who is a 60 year old CFI to meet the insurance requirements. (I say his age assuming he has been instructing for atleast a little while) The way I understand it is that he can not log PIC time until he is given the additional endorsements and he can only log dual received and total time. I told him this and he didn't know so he said he would talk to the instructor and he said that they couldn't find anything in the FAR's that said he couldn't log the time as PIC. The way I see it is that you cannot log PIC in a plane you are not authorized to fly until you have the proper training and endorsement regardless if there is an instructor on board. Am I right or wrong guys?
 
I believe you are wrong, but don't feel bad. This is an incredibly common misunderstanding. First, remember that there is a difference between logging PIC time and acting as PIC. You cannot act as PIC (solo the airplane) without an endorsement, but you can log PIC by being the sole manipulator of the controls. Second, remember that the term "rated" refers to category, class, and type rating, if a type rating is required. It doesn't say anything about endorsements. So as long as a pilot has a certificate for ASEL, they are good to go in a Bonanza.

Another way to remember this is to think of the requirements for being a safety pilot. Safety pilots do not need any endorsements, they only need to have category and class on their certificate. I could take somebody up as a safety pilot for my instrument currency in an Arrow without them having a complex endorsement. So does it make sense that they could log PIC time if they act as a safety pilot, yet not log it if I am giving them dual towards their complex endorsement when they are actually flying?

Here's a few references for further reading:

http://www1.faa.gov/avr/afs/afs800/docs/pt61FAQ.doc
http://www.aopa.org/members/files/pilot/2000/pc0003.html (AOPA members only)

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From the Part 61 FAQ:

QUESTION: Thank you for your letter dated April 20, 1999, to the Office of the Chief Counsel, Federal Aviation Administration (FAA), regarding the logging of pilot-in-command time. Specifically, whether a pilot needs to have the appropriate 14 CFR § 61.31 endorsements before he or she can properly log pilot-in-command time under 14 CFR § 61.51(e) when that pilot holds a private pilot certificate with a single-engine land rating and is receiving training in a single-engine land airplane that is also a complex or high performance airplane. Can this person log the time he or she manipulated the controls as pilot-in-command time.

ANSWER: Ref. § 61.51(e)(1)(i); Before discussing this issue, please note that the Frequently Asked Questions – Part 61 & 141 (FAQ’s) are provided by the Flight Standards Service (AFS) for standardization purposes. The Office of the Chief Counsel does not review the FAQ’s and accordingly, information provided on his website is not legally binding. Title 14 CFR § 61.51(e) governs the logging of pilot-in-command time. This section provides, in pertinent part, that a private pilot may log pilot-in-command time for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. (Emphasis added). The term “rated,” as used under 14 CFR § 61.51(e), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required). These ratings are listed under 14 CFR § 61.5 and are placed on the pilot certificate.

Therefore, based on the scenario given, a private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating.

Note, while the private pilot may log this time as pilot-in-command time in accordance with 14 CFR § 61.51(e), he or she may not act as the pilot in command unless he or she has the appropriate endorsement as required under 14 CFR § 61.31. There is a distinction between acting as pilot in command and logging pilot-in-command time. In order to act as pilot in command, the pilot who has final authority and responsibility for the operation and safety of the flight, a person must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. Title 14 CFR § 61.31 requires a person to have an endorsement from an authorized instructor before he or she may act as pilot in command of certain aircraft (a complex airplane, a high performance airplane, a pressurized airplane capable of operating at high altitudes, or a tailwheel airplane). These endorsements are not required to log pilot-in-command time under 14 CFR § 61.51(e). In order to log pilot-in-command time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.
{Q&A-288}
 
Some FARS for your buddy:

61.51
(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;

61.31
(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane (an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller; or, in the case of a seaplane, flaps and a controllable pitch propeller), unless the person has—
(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.


(f) Additional training required for operating high-performance airplanes. (1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has—
(i) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane.


Bottom line? There's NO WAY he can legally log PIC until his CFI buddy signs him off. There's not even a loophole. That said, your friend can have his CFI buddy endorse his logbook, and post date it so that all the entries become legal, IF said CFI buddy is willing to do that.
 
[ QUOTE ]
Bottom line? There's NO WAY he can legally log PIC until his CFI buddy signs him off. There's not even a loophole. That said, your friend can have his CFI buddy endorse his logbook, and post date it so that all the entries become legal, IF said CFI buddy is willing to do that.

[/ QUOTE ]

I disagree. This is straight from the FAA:

"...a private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating."

Reference my post above. There is a difference between acting as PIC and logging PIC.
 
[ QUOTE ]

61.51
(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;

[/ QUOTE ]

(i) is referring to Single Engine Land, Multi engine land, etc. etc. As a private pilot in SEL airplanes, you can log PIC while with an instructor in any SEL airplane.

[ QUOTE ]

61.31
(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane (an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller; or, in the case of a seaplane, flaps and a controllable pitch propeller), unless the person has—
...
(f) Additional training required for operating high-performance airplanes. (1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has—


[/ QUOTE ]


It's right there in the FAR's. You can log it, but can't ACT as PIC. The first poster said that this person is flying with a CFI, hence they can log PIC based off of 61.51. When the get the complex and high performance endorsements, then they can act as PIC and fly solo or with pax, no CFI on board required.

~wheelsup
 
Trust me, you can log PIC.

All the guy would need to be is rated, which he is since he is a private pilot.

Then he can log PIC in anything he's rated in for being the "sole manipulator" of the controls.

Endorsements for Tailwheel, High Performance, Complex, ect, have little to do with ratings. That being said, I wouldn't send an applicant up for a checkride in his 182RG without the Complex/High Performance Endorsements.
 
Alright, it seems pretty clear now that he can log the time as PIC. That's good news though, I would of hated for him to have to cross out all those hours (close to 50 I believe). I appreciate it everyone!
grin.gif
 
I think you guys are missing the last part:
[ QUOTE ]
61.51
(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 ;

[/ QUOTE ]

you're rated in for ASEL, yes, but you don't have the privileges for complex or high-performance. So you can't act as PIC, and therefore can't log it as PIC. I don't know where the idea came from that you can log PIC when you can't act as PIC, but it's not a good one. You CAN log it as dual recieved though. It dosen't have to do with ratings, it has to do with privileges.

Honestly, if the FAA came snooping around your logbook, what do you think THEY would do? Moreover, if you took that logbook on an interview, how do you think it would look? Play it safe, get the endorsments. That way you don't have to worry about it at all.
 
[ QUOTE ]
Some FARS for your buddy:

61.51
(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;

61.31
(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane (an airplane that has a retractable landing gear, flaps, and a controllable pitch propeller; or, in the case of a seaplane, flaps and a controllable pitch propeller), unless the person has—
(I) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.


(f) Additional training required for operating high-performance airplanes. (1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has—
(I) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane; and
(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane.


Bottom line? There's NO WAY he can legally log PIC until his CFI buddy signs him off. There's not even a loophole.

[/ QUOTE ]Common error to newbies on the regulations (believe me, if you're getting this wrong, you are a newbie on the regulations - the FAA has been saying the exact same thing that others pointed out) for more than 20 years).

61.31 is a rule that involves =responsibility= who is permitted to =be= in command of a flight.

61.31 is a rule that deals with what pilots may write in columns in their logbooks to be counted by the FAA toward certificates, rating and currency.

61.51 is the one that counts for logging and it says nothing about "endorsed" only that, as you said,

==============================
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;
==============================

That said, there =is= a new twist that showed up a year ago. The phrase "or has privileges" at the end of the sentence is new. The addition is part of the sport pilot amendments, but I can see where it could be read to include endorsements. But it's really just referring to sport pilots who get something akin to "type privileges." Certainly, there's nothing in the Federal Register discussion that suggests that the language was designed to override more than 20 years of consistent FAA interpretation of the regulation.
 
OK guys, I KNOW I'm right.

Here's the deal: I just called the Dallas FSDO (1-800-759-4684) for a ruling, and it's straight out of the mouths of the FAA. You can not legally log PIC for time in a high-performance or complex aircraft unless you are properly endorsed. I'm sorry, midlifeflyer, but you're wrong, and your summary of rules is not accurate.

And I'm not a newbie.
 
[ QUOTE ]
OK guys, I KNOW I'm right.

Here's the deal: I just called the Dallas FSDO (1-800-759-4684) for a ruling, and it's straight out of the mouths of the FAA. You can not log PIC for time in a high-performance or complex aircraft unless you are properly endorsed. I'm sorry, midlifeflyer, but you're wrong, and your summary of rules is not accurate.

And I'm not a newbie.

[/ QUOTE ]Sorry. The FAA legal counsel who's job it is to interpret the rules, has said you're wrong for more than twenty years. Even when John Lynch tried to say that you were right on a semiofficial FAA web site, the Legal Counsel came in to correct him.

Notice the FAA Part 61 FAQ doc that jrh quoted from.

Your FSDO guy needs recurrent training.

But that's okay.
 
Honestly, ask three FSDO inspectors the same question, and you'll get five answers. I called the Ft Worth FSDO on a logbook question, and they flat out told me they really couldn't give me a straight answer, it was up to the DE that would do my checkride. The DE asked for something from them in writing to back that up, and they more or less said that wasn't gonna happen. Now, if someone said "you can act as PIC without the endorsements," then I'd have to beat 'em down. As it stands, you can log PIC since you're ASEL rated. The endorsements let you ACT as PIC, the category/class rating let you LOG PIC. Now, if this guy's flying the Bonanza SOLO, then that would be a no-no since he wouldn't be qualified to act as PIC.
 
Guys, this is absolutely insane. A FAQ is not even remotely legally binding, but the FARs are. I've not yet got to the point of calling multiple FSDOs, but I'm getting there.

midlife, you're responses are pompous, insulting, and above all TOTALLY WRONG. I recommend you call your local FSDO to get straightened out before you advise any more students to log illegal time. I don't know what logic you used to surmise that logging PIC when you can't act as PIC is okay, but it didn't come from a little place I like to call reality.

To my point of view, I have two choices of what to believe: One, that the FARs I'm reading, and the FAA official who backed up what I read, or: Two, believe what a bunch of dudes are posting on the internet, one of which believes he's right because it says so on his website and on a non-legally binding FAQ, not to mention he thinks he's smarter than my local FSDO. (Where I come from that's known as arrogance.)

Not much of a decision.
 
CapnJim -

It may be worth noting the "or" in the reg quoted above--rated or has privileges. The "or" signifies that only one of the two conditions needs to be meet--namely being "rated" or having "privileges."

If the regulation was to be interpreted as you suggest, we would expect it to say "(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated and has privileges".
 
Here's the way I'm looking at it as far as the whole "sole manipulator or has privileges:"

The sole manipulator of the controls is a given, so why can't this guy log the Bonanza time as sole manipulator? We can log time in a 172 solo as students as PIC since we're sole manipulator and occupant, yet we don't even have a category/class rating for the aircraft we're flying. We can also log time training under IFR as PIC since we're sole manipulator, even though we don't have instrument "priviliges." You can perform the duties of and log PIC in a multi as long as an instructor is aboard in some cases, even if you aren't multi rated. In the above case, they guy is more or less getting instruction in a Bonanza, so I really don't see how it differs from getting instruction under IFR. You don't have IFR priviliges then, so you can't fly solo under IFR rules. If you don't have the HP/complex endorsement, you can't fly solo in the Bonanza. It's another one of those poorly rules written by the FAA that could be argued from both sides. If the FAA would define "priviliges" somewhere as needing the endorsements, then it would be an open and shut case.
 
Good point Jeff_S. Thanks for the input.

I'm not beyond admitting I'm wrong, unlike some, but I have yet to be convinced. Logic and commonsense dictate that a logbook is a record of accurate flying time. If you're not acting as PIC, why should you be allowed to log it as PIC? This seems so sensible as to be prosaic; I have yet to understand why everyone seems to think otherwise. All I can come up with is that it's an attempt to skirt around the rules, to get away with something for nothing. But I'll say this: we had a lot of guys with questionable time in thier logbooks on the interview, and the one thing they all had in common was this: They didn't get a job.

Seriously gang, don't put any shaky time in your logbook. It's about integrity, honesty, and getting a second interview.
 
It sounds like there are people that are 110% sure that you CAN log it as PIC and some that are 110% sure that you CAN'T log it as PIC. We definitley can't let this one end like this. I am now 50/50 on it because both sides have brought up good points but it still seems crazy to me that he could log it as PIC and use it towards his flying. Because sure he can log it, you can log PIC from the backseat if you really wanted to but of course you couldn't use it towards anything and it would be dumb to put in your normal logbook where anyone besides you can read it. But is this bonanza time actually legal time he can use? So lets figure this one out while all trying to remain friends!
nana2.gif
 
On the backseat thing, I'd so no way since it technically wouldn't be "flight time" as defined in Part 1.1 "Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing." Kinda hard to have "pilot time" in a backseat with no controls. But, that's not the issue here....

[ QUOTE ]
But is it actually legal time he can use?

[/ QUOTE ]

I'd say it is legal, but only due to a technicality in the FARs. Would I personally do it? Probably not. I don't need the PIC time. Besides, how hard would it be to get the instructor to endorse the complex and HP lines in the back of the logbook after a couple of flights anyway? If it's due to insurance requirements, I'd probably log it, but then only because insurance companies deal in theoreticals and technicalities anyway.....
 
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