Logging Instrument Flight Time

mjg407

Well-Known Member
Quick question on the logging of flight time in multi crew aircraft. CFR 61.51 G states that "A person may log instument time only for that flight time when the person operates the aircraft solely by reference to instuments under actual or simulated conditions....." Elsewhere the FARs state flight time requirements as "sole manipulator of the controls". The USN/USMC governing documents state that both the Pilot and Copilot both log actual time under actual conditions and both log night time the same. How do the 121 and 135 operators interpret logging of flight time under actual conditions/ night time? I appreciate your insight in the matter.
 

NC_BE300

Well-Known Member
The way my checkairmen for IOE explained it to me quick and dirty was- (For 121):

Actual IFR - you log it when its your leg in actual IMC
Night Time- any time it qualifys as night time-no matter what who is flying
 

mjg407

Well-Known Member
I can't tell you how any operators interpret it, but can point you to how the FAA interprets it:

http://www.faa.gov/about/office_org...terpretations/data/interps/1999/Carpenter.rtf
You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

To begin, thanks for the article. But this brings up some questions, but it may just be too many hits on my head over the years. During actual IMC, both the PIC and SIC are operating the aircraft. Does the PIC log all of the actual time, and the SIC only that time which he is sole manipulator? I understand the instrument approach that only the PAC should be able to log the approach. Ahhh everything is clear as mud....:panic:
 

falconvalley

Absentee Dad of the OOTSK, Runner, Cat Frustrator
You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

To begin, thanks for the article. But this brings up some questions, but it may just be too many hits on my head over the years. During actual IMC, both the PIC and SIC are operating the aircraft. Does the PIC log all of the actual time, and the SIC only that time which he is sole manipulator? I understand the instrument approach that only the PAC should be able to log the approach. Ahhh everything is clear as mud....:panic:
I think they're referring to scenarios when you are, in fact, sole manipulator of the controls, whether PIC or SIC
 

MidlifeFlyer

Well-Known Member
You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

To begin, thanks for the article. But this brings up some questions, but it may just be too many hits on my head over the years. During actual IMC, both the PIC and SIC are operating the aircraft. Does the PIC log all of the actual time, and the SIC only that time which he is sole manipulator? I understand the instrument approach that only the PAC should be able to log the approach. Ahhh everything is clear as mud....:panic:
Here's an explanation that might (or might not) work for you:

In terms of flight =time=, both the PIC and SIC in a 2-pilot required crew get to log instrument time and night time - no matter which one is doing the flying. That's because all that's required is that the pilot "operate" the aircraft. If you look deep into the definition of "operate" you'll see that both the PIC and the SIC are considered to be "operators" of the aircraft. It's a very broad term.

It doesn't say it this way, but I think the simplest way to think about it is that, if you have logable flight time under 61.51, you also have the right to log all the conditions of flight set out in 61.51(b)(3)

But in terms of logging an instrument approach (not a "time" entry), the reg (61.57(c)) says that you need to "perfrom" the approach, not simply "operate" the aircraft. FAA Legal has taken the position that in the 2-pilot crew to "perform" an approach means to be the sole manipulator during the approach.

Does that help a little?
 

mjg407

Well-Known Member
Here's an explanation that might (or might not) work for you:

In terms of flight =time=, both the PIC and SIC in a 2-pilot required crew get to log instrument time and night time - no matter which one is doing the flying. That's because all that's required is that the pilot "operate" the aircraft. If you look deep into the definition of "operate" you'll see that both the PIC and the SIC are considered to be "operators" of the aircraft. It's a very broad term.

It doesn't say it this way, but I think the simplest way to think about it is that, if you have logable flight time under 61.51, you also have the right to log all the conditions of flight set out in 61.51(b)(3)

But in terms of logging an instrument approach (not a "time" entry), the reg (61.57(c)) says that you need to "perfrom" the approach, not simply "operate" the aircraft. FAA Legal has taken the position that in the 2-pilot crew to "perform" an approach means to be the sole manipulator during the approach.

Does that help a little?
That helps alot. That is the way the Military looked at it. You both log the actual time because you both are doing things... but only one pilot actually flies the approach, so that is the only pilot that gets to log the apporoach. I see with a lot of my pilots a confusion over logging PIC time vs logging night or actual time. I really appreciate (sp?) everyones input on this.
 

Louie1975

Well-Known Member
I am just a CFI, but if the approach is flown on autopilot, does the pilot flying log an approach? I guess 'operate' also means operating with the autopilot on. Seems to me that your scan could go to heck all while logging a bunch of instrument time.
 

kab32283

Well-Known Member
I am just a CFI, but if the approach is flown on autopilot, does the pilot flying log an approach? I guess 'operate' also means operating with the autopilot on. Seems to me that your scan could go to heck all while logging a bunch of instrument time.
Yes, the pilot can log the approach. Although you may be not physically operating the controls, you are still scanning the instruments and can turn off the autopilot if need be, and are in control of the autopilot, so thus, you're flying the approach.
 

mjg407

Well-Known Member
So in conclusion:
The way I interpret this document and FAR 61.51 is that under actual instrument conditions, both pilots may log actual time. During an instrument approach, only the pilot who is the sole manipulator of the controls may log the approach, and at night, both pilots may log the night time. Thanks again.
 

mjg407

Well-Known Member
Here's another follow on to my question and the sticky on the logging PIC in a C-90. The way I read 61.51 is that if the aircraft in question requires a Rating, on if you are typed in that aircraft can you log PIC time. So for the 121 guys that are SIC Typed, do they log PIC time for when they are sole manipulator of the controls?
 

v1valarob

Well-Known Member
So for the 121 guys that are SIC Typed, do they log PIC time for when they are sole manipulator of the controls?
No. You are not PIC typed, you cannot log PIC time. Even if you where PIC typed, if you are acting as SIC then you cannot log PIC even if your manipulating the controls.
 

tgrayson

New Member
Here's another follow on to my question and the sticky on the logging PIC in a C-90. The way I read 61.51 is that if the aircraft in question requires a Rating, on if you are typed in that aircraft can you log PIC time. So for the 121 guys that are SIC Typed, do they log PIC time for when they are sole manipulator of the controls?
Reference the letter that Midlifeflyer posted above. Excerpt:

[FONT=&quot]Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.[/FONT]
 

mjg407

Well-Known Member
Reference the letter that Midlifeflyer posted above. Excerpt:

[FONT=&quot]Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.[/FONT]
But the SIC is SIC Typed... correct, what if it is under Part 91, where you have a SIC but no type rating. The way I understand it and the way we have our pilots log it is SIC only because they are not rated as either PIC or SIC in the aircraft. I know that we are unique in how we operate.
 

tgrayson

New Member
But the SIC is SIC Typed... correct, what if it is under Part 91, where you have a SIC but no type rating. The way I understand it and the way we have our pilots log it is SIC only because they are not rated as either PIC or SIC in the aircraft. I know that we are unique in how we operate.
It's not clear from the letter whether the SIC has a SIC type rating. The date on the letter is 1999, and, as far as I know, the FAA wasn't doing SIC type ratings at that time.

That's why I don't like this interpretation. Historically, "rated in the aircraft" meant a rating on your pilot certificate. Only having SIC training doesn't, in my view, qualify as a rating, but more like an endorsement. But it seems to me that this is what the letter is referring to.
 

mjg407

Well-Known Member
I really like the way we logged flight time in the Nav. It seemed to make more sense. There was 1st Pilot, 2nd Pilot and Air Craft Commander time, therefore, when you were sole manipulator of the controls you logged 1st pilot.. etc.
 

MidlifeFlyer

Well-Known Member
That's why I don't like this interpretation. Historically, "rated in the aircraft" meant a rating on your pilot certificate. Only having SIC training doesn't, in my view, qualify as a rating, but more like an endorsement. But it seems to me that this is what the letter is referring to.
I'm actually not too fond of parts of the interpretation either. On the approach issue, 61.57 uses the phrase "perform" not "sole manipulator". In a 2-pilot crew under IFR, don't both pilots have tasks and duties involved in "performing" the approach? Isn't that the whole idea of a required 2-pilot crew? I think Legal's read on this is too restrictive.
 

mjg407

Well-Known Member
I'm actually not too fond of parts of the interpretation either. On the approach issue, 61.57 uses the phrase "perform" not "sole manipulator". In a 2-pilot crew under IFR, don't both pilots have tasks and duties involved in "performing" the approach? Isn't that the whole idea of a required 2-pilot crew? I think Legal's read on this is too restrictive.
Excellent point. What if one pilot flies the approach and the other takes over when visual......
 

Nihon_Ni

Well-Known Member
Reference the letter that Midlifeflyer posted above. Excerpt:

[FONT=&quot]Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.[/FONT]
If a type rating is required, and the pilot has a SIC limitation on his rating, then he cannot log PIC for sole manipulator time. Here's a clip from FAA notice 8000.351 (Procedures for the Second-In-Command Pilot Type Rating). Although it's now expired, it listed a variety of Q&As when the SIC ratings were first announced.


QUESTION:
How would a pilot who holds the appropriate SIC pilot type rating and is the sole manipulator of the controls log the flight time? The pilot holds a B737 SIC pilot type rating. This SIC pilot is the flying pilot (the sole manipulator of the controls) for this leg of the flight. Does the pilot log the flight time as PIC or SIC?


ANSWER:
Ref. § 61.51(f)(1). The SIC pilot may only log the time as SIC flight time. The pilot is not qualified as a PIC in the Boeing 737 and may not log the time as PIC flight time.
 

SpiraMirabilis

Possible Subversive
Nihon: The only difference is that in grayson's example the PIC is a checkairman where in your example the PIC is a regular captain.
 
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