Logging Bonanza time with no complex/high performance endors.

Well said CFI-Ty, and good for you. Don't take my word for it. Don't take jrh's or midlife's word wither. Find out for yourself. Ask your examiner, call the FSDO, but whatever you do don't believe what a bunch of goofballs like us are banging away on our keyboards.

And friendship comes from mutual respect, which has not remotely been extended from the arrogant, insulting responses of Mr. Midlife. So, none will be extended without apology or reconcilliation.
 
[ QUOTE ]
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.

[/ QUOTE ]Jim -

The reason why many are drawing the distinction between logging PIC and "acting as PIC" is due to a number of legal opinions issued by the FAA that state that there is a difference between the two. Unfortunately, the FAA has chosen to use the same term (Pilot In Command) for two separate concepts.

Here is a legal opinion that illustrates there is a difference between logging PIC and, as the opinion states, being the one who is "ultimately responsible":

The relevant section:
"Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. "

Here it is in toto:

OCT. 28, 1980

WINSTON SCOTT JONES

Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.

Section 61.51(c)(2)(i) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot—

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or

2. Is the sole occupant of the aircraft; or

3. Acts 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.

Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received.

Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(i) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).

There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.

You request interpretations of these regulations for situations in which:

1. The purpose of the flight is instruction in advanced maneuvers.

2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.

3. The purpose of the flight is instrument instruction actual IFR conditions.

4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.

5. The purpose of the flight is transition from tricycle to conventional landing gear.

6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).

7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.
We trust that this discussion answers your questions.

Sincerely,

EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division
 
Let me add one more thing to the Logging PIC vs. Acting PIC point above--the existence of this distinction is the reason why both a flying pilot (sole manipulator) and a safety pilot who is ACTING PIC can both log PIC when the flying pilot is under the hood.
 
Well the reason why I brought up the backseat thing is because you can log ANYTHING you want but you can't actually use all that time. To exagerate my point you can log time when you fly as a passenger on an airline flight, can you use that time? Of course not. Also remember you can log your flight time on a peice of bread using mustard and it would still be legal but you'd definitely be an idiot
wink.gif
I probably shouldn't have even brought up the backseat thing but it was just a way of saying that he can log that bonanza time as PIC if he wanted regardless if it's legal or not. It's just a matter if he can use that time and if he should even put it in his logbook. I home my dumb remarks aren't just confusing people and making you guys think i'm an idiot.
 
[ QUOTE ]
Also remember you can log your flight time on a peice of bread using mustard and it would still be legal but you'd definitely be an idiot

[/ QUOTE ]

Only if ya used wheat bread.
smile.gif
 
Jim -

Please don't take this as piling on, but I want to get you some credible references to reinforce the notion that LOGGING PIC and ACTING PIC have traditionally been held to be different. Here is another Legal Opinion that spells it out better than the one above:

_________________________________
October 30, 1992

Mr. David M. Reid


Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the logging of pilot in command (PIC) time under the Federal Aviation Regulations (FAR).

In your letter you ask four questions. First, you ask whether there are "any circumstances when, during a normal flight, two Private Pilots may simultaneously act as (and therefore log the time as) Pilot In Command?" The answer is two private pilots may not simultaneously act as PIC but they may, under certain circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 deals with logging PIC flight time, and it provides that a private or commercial pilot may log as PIC time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR 61.51 only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience.

Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51. Enclosed please find two prior FAA interpretations concerning logging of PIC time. We hope that these will be of further assistance to you.

In your second question you ask "how shall two Private Pilots log their flight time when one pilot is under the hood for simulated instrument time and the other pilot acts as safety pilot?" The answer is the pilot who is under the hood may log PIC time for that flight time in which he is the sole manipulator of the controls of the aircraft, provided he is rated for that aircraft. The appropriately rated safety pilot may concurrently log as second in command (SIC) that time during which he is acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i). Enclosed please find a prior FAA interpretation concerning the logging of flight time under simulated instrument flight conditions. We hope that this interpretation will be of further assistance to you.

In your third question you ask "during instrument training, how shall a VFR Private Pilot log the following flight time: Pilot In Command time, Simulated Instrument time, and Actual Instrument time, when that pilot is... A)...under the hood? B)...in actual instrument conditions? C)...under the hood in actual instrument conditions?" The answer is the VFR private pilot may log all of the flight time you described as PIC flight time under FAR 61.51(c)(2)(i) if he was the sole manipulator of the controls of an aircraft for which he is rated. Under FAR 61.51(c)(4) the pilot may log as instrument flight time only that time during which he operates the aircraft solely by reference to instruments, under actual or simulated instrument flight conditions. Please note that the FARs do not distinguish between "actual" and "simulated" instrument flight time. Enclosed is a prior FAA interpretation concerning the logging of instrument flight time. We hope this interpretation will further assist you.

Finally you ask "does FAR 61.57 affect how the VFR Private Pilot shall log Pilot In Command time during instrument training, either before or after meeting the 6/6/6 requirement, and if so, how?" FAR 61.57 does not affect how a pilot logs PIC time during instrument training; FAR 61.51(c)(2) and (4) govern logging of instrument flight time. FAR 61.57(e) provides currency requirements for acting as PIC under instrument flight rules (IFR) or in weather conditions less than the minimums for visual flight rules (VFR). Enclosed please find a prior FAA interpretation on instrument flight time and FAR 61.57(e). We hope this interpretation will further assist you.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations Division
________________________________________
 
[ QUOTE ]
Well the reason why I brought up the backseat thing is because you can log ANYTHING you want but you can't actually use all that time.

[/ QUOTE ]Well sort of. Not really. Remember that our logbooks are not like a diary; they are an official record of flight activity that we keep because the government requires us to keep a record of our qualifications. More than one pilot has lost certificates and ratings for logging ANYTHING.

Any answer to "what can I log" really =should= only be saying what we can log for official FAA purposes. Yes, we do log other things that are not required, but by placing them in other columns, not by using the "official" ones.

One very common example is logging "Part 1 PIC" - time as the pilot who was designated as having final authority over the flight. It's what may pilots track for employment purposes. A column separate from the FAA's PIC column in our logbooks is a good idea because there are times when you =are= the PIC, but 61.51 does =not= permit you to log it.

That's why my FAQ answers make specific reference to the regulations on which they are based.
 
[ QUOTE ]

OCT. 28, 1980

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

You request interpretations of these regulations for situations in which:

6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.

We trust that this discussion answers your questions.

Sincerely,

EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division

[/ QUOTE ]

Portions snipped. I guess that answers the question today as it did almost 25 years ago.
 
I'm going to sidestep this whole issue, because personally, I don't care if it's legal or not. If you cannot act as a PIC, then you shouldn't log PIC. Because any person you present your logbook to, whether an interviewer or a DE, they are going to dismiss anything you logged as "sole manipulator"......they don't care. They want to see who acted as PIC and who was the FINAL responsible pilot.

This begs the big question: Why has he gotten 50 hours in the plane and NOT been given an endorsement?!?! I did MANY Bonanza and Baron insurance checkouts in my time as a CFeIeio, and most insurance companies wanted between
10 and 20 hours in type (ie...A36 not F33, or B36TC not A36).
Tell you friend to just get the signoff and be done with it.

PS....Oh yea. Up until a few years ago, you could NOT log solo time as PIC. Only time flown AFTER your Pvt checkride could be logged as PIC. Solo time was a separate column in the logbook
 
[ QUOTE ]
Because any person you present your logbook to, whether an interviewer or a DE, they are going to dismiss anything you logged as "sole manipulator"......they don't care. They want to see who acted as PIC and who was the FINAL responsible pilot.

[/ QUOTE ]You are probably completely correct about the interviewer. But if a DE rejects the time, the DE would have a serious problem.

It's a business' prerogative to decide what time it wants to count for experience purposes for a job.

The FAA also has the right to decide what time it wants to count and wrote it into a clear regulation that has been consistently interpreted. A DE who decides he doesn't have to follow the FAA's rules will have to do some answering.

Many instrument rating applicants log the required "50 hours of cross-country flight time as pilot in command" [61.65(d)(1) during dual flights. It would be kinda fun to see the DE who decides to pink slip an applicant for it.

I'm never sure why folks get so bent out of shape that the FAA decided to count hands on the controls for the purpose of obtaining certificates and ratings.

Counting =logged= PIC time is all over the place in Part 61 and, best I can figure, the only pilot who can only =log= PIC when =acting as PIC= is a student pilot.

[ QUOTE ]
This begs the big question: Why has he gotten 50 hours in the plane and NOT been given an endorsement?!?!

[/ QUOTE ]That's is a heck of a good question. The answer is probably that since the pilot (1) can log the time as PIC either way and (2) can't, practically speaking, act as PIC in the airplane for insurance reasons, there no need for the endorsement until the insurance checkout is complete. Why bother?
 
You know, under ordinary circumstances I would concede the point, given all the data thrown at me. But there's two things in this situation that prevent me from doing it:

One: When I think I'm right, there's nothing I like more than standing in the middle of the ring and taking all comers. Especially when the ring is completely full.

Two: There's also nothing I like more than taking someone with a concieted, arrogant attitude and knocking them on thier butt.

So, with that in mind, I shall return.
wink.gif
 
[ QUOTE ]
You know, under ordinary circumstances I would concede the point, given all the data thrown at me. But there's two things in this situation that prevent me from doing it:

One: When I think I'm right, there's nothing I like more than standing in the middle of the ring and taking all comers. Especially when the ring is completely full.

Two: There's also nothing I like more than taking someone with a concieted, arrogant attitude and knocking them on thier butt.

So, with that in mind, I shall return.
wink.gif


[/ QUOTE ]

Pride goes before destruction, a haughty spirit before a fall.
grin.gif
LOL
 
[ QUOTE ]
Pride goes before destruction, a haughty spirit before a fall. LOL

[/ QUOTE ]

Exactly my point!
tongue.gif
 
[ QUOTE ]
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.



[/ QUOTE ]

I agree with you in one respect - a true accounting of PIC time would be if you logged it under the Part 1 definition, as the one who has ultimate responsilbity for the flight. However, like you said, the FAA put the language in to allow people "loop-holes", partly for the instrument rating requirments, I'm sure partly for insurance checkout purposes, etc. etc. I didn't log any of my complex time as PIC until I received the endorsement (going off of what the instructor told me) but did log the high performance time (all 1.1 hours of it) as PIC prior to signoff.

I really don't see how this is questionable time, and I HIGHLY doubt someone would get booted from an airline interview because they logged their time LEGALLY. I think it's been pointed out before, safety pilot time is the exact same thing (one is logging PIC based off of part 61 definition and one is logging PIC based off of part 1 definition) and I've known a bunch of people currently at the airlines after doing this. A good friend was hired at Xjet with 502 TT, and with a bunch of "safety pilot" PIC via ATP. Another was hired at eagle with about 50 hours of safety pilot PIC (sole manipulator and safety of flight). So your argument that its just shaky doesn't hold much ground, atleast with me. If this wasn't legal Ari-Ben and associated companies would be out of business.

~wheelsup

Edit: And as far as the signoff goes, I've soloed people in A36's with 20 TT. Having 50 hours in the thing without any signoff is just rediculous. My own high performance checkout was a whopping 1.1 before the signoff in a 182.
 
[ QUOTE ]
You know, under ordinary circumstances I would concede the point, given all the data thrown at me. But there's two things in this situation that prevent me from doing it:

One: When I think I'm right, there's nothing I like more than standing in the middle of the ring and taking all comers. Especially when the ring is completely full.

Two: There's also nothing I like more than taking someone with a concieted, arrogant attitude and knocking them on thier butt.

So, with that in mind, I shall return.
wink.gif


[/ QUOTE ]
I think you're reading more into Mark's posts than is really there. Mark is very well versed on these issues (take a look at the FAQ section of his website), and I read his responses in this thread as very even-keeled and factually based. He knows his stuff and is sure of his position on this issue and that comes through, but I don't read that as conceited or arrogant per se.

My opinion.

cool.gif
 
The answer you get really depends on the fsdo you talk to, and to a greater extent the PERSON you talk to at that fsdo.

For example around here our fsdo says we can log landings if the 'landing is assured' (i.e. a low approach or go around is a 'landing). Which many fsdos would call BS to.

What really counts is a) the written letter of the law to back it up and b) ntsb rulings on the issue. not necessarily in that order.

In this case to log pic per pt.61 you have to 1) be sole manip and 2) be rated in the aircraft. That is ALL! You dont have to be acting pic, in fact there are many situations where an acting pic would not be able to log ANYTHING per pt.61. Checkout propilot.com... great site and has a lot of info that should clear this up.
 
Regs aside, IMO, if you have to lawyer time in te logbook, then there might want to be second thought about the logging of that time.....generally speaking.

Personally, for me, I'm pretty conservative about how I log my time. Maybe it's because I don't necessarily need the time, or maybe not. But old school, I never logged PIC when I was a student pilot even though I was solo, and never retroactively changed the time once it did become approved. Same, I never logged PIC when I was in the WX without an instrument rating receiving dual instruction, even though I was rated in the plane. Even more same, I never logged PIC the whole time I went through USAF pilot training, even when solo (old rules, mind you), since I wasn't a rated USAF pilot at the time, wasn't typed in the jet (which has no type anyway) nor had an equivilent FAA LOA. Even when I began A-10 training, prior to being Form 8 qualified in the jet, I didn't log the solo time as PIC (again old rules still) since I wasn't rated in the jet, even though I was a mil pilot and civil-wise, possessed an ATP-ME; and never fixed those either.

On a similiar note, I never logged simple night time as actual instrument (as I see many guys do), unless it was out over the Pacific/Atlantic at night, or some other highly unusual circumstance. Actual, for me, is in the WX...apart from my description above.

Again, this is only me, but I do log conservatively, since I wish my personal logbook to be an sacred, genuine depiction of my flighttime. I don't lawyer the regs, which I'm not saying people here are doing, but I've seen people do it and I disagree with it. Part of the problem does reside with the FAA, IMO, since they don't have any real standardization of their FSDO "interpertations", and some of their regs do get confusing.
 
[ QUOTE ]
Part of the problem does reside with the FAA, IMO, since they don't have any real standardization of their FSDO "interpretations", and some of their regs do get confusing.

[/ QUOTE ]You're right. The Part 61 and Part 141 FAQ were an attempt at standardization, and with recurrent training, it's definitely getting better. I've heard more than one FSDO person answer a question with "What does the FAQ say?" But there are still feifdoms where a FSDO operative will make up the rules as they go along.

Logging issues? I think they really are pretty clear once we get past the FAA's unfortunate use of "PIC" to mean something other than the pilot who is qualified, designated, and " Has final authority and responsibility for the operation and safety of the flight." All the FAA is really doing with "logged PIC" is saying, "Here is the flight time that we will let you count for certificates, ratings and currency, whether or not you were really in command." Maybe it would have been wiser to make up a word to cover it (the old CAR used "solo" which meant "sole manipulator" not "only person on board." Probably had it's own problems), like "zupidu"

==============================
61.51(e) Logging zupidu flight time. (1) A sport, recreational, private, or commercial pilot may log zupidu 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;
==============================

Then, for example, the single-engine commercial certificate requirement could say

==============================
§ 61.129 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.
(2) 100 hours of zupidu flight time, which includes at least -
==============================

and no one would complain or argue about it.
 
Agreed with SteveC. Perhaps I've missed something, but I see nothing conceited or arrogant about MidlifeFlyer's posts, just well-researched presentations of material to support his point(s).

Is logging vs. acting PIC really a topic to try to create a virtual p*ssing match over? CaptJim, MF has said nothing in his last few posts to even address you, so clearly he's not interested in engaging.

How about dropping it already?

Sarah
 
Alright, alright.
I have returned, a little more coolheaded, and having reread the posts. I take offence at being called a 'newbie'. That's over the top, and the reason for the accusation of conceit. But the plain and simple fact is : I was wrong. I looked and looked, and there's just no way around it. My FSDO guy was was wrong too. It's all there, in black and white, right on the FAA website.
I don't mind being wrong, but I do mind having my nose rubbed in it by some one who should be mature enough to know better. So, that's the reason for all the hotheaded comments and anger. Then again, it's the nature of these online forums to have your meaning misunderstood, so maybe I'm guilty of that too. Anyways, hope there's no hard feelings, and I'm coming away a little smarter than I was going in. And I still like your website.
 
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