Logging PIC 135

determined2fly

Well-Known Member
I just recently got a PIC type on airplane but don't have 135 mins. I'm currently flying right seat to get to the mins. I was under the impression I can log the 91 as pic but not the 135 since I don't have the mins. I was just told I can log both regardless I just can't act in the capacity of pic...can anyone clarify this ? Thank you.
 

SteveC

Really?
Staff member
If you're typed you can log it. You can't ACT as PIC, but you can log it.

On my phone now so I won't go into details, but I recomend a custom column in your log book (mine is labeled "61 PIC". More later if needed.
 

determined2fly

Well-Known Member
Thanks Steve...so a seperate column for 61 PIC as opposed to just placing it in PIC until I am at 135 mins and ACTING as PIC?
 

SteveC

Really?
Staff member
Many companies (and most airlines from what I've heard) will define (on their applications for employment) PIC time specifically as ACTING PIC time, and don't want this kind of logable time included. A seperate column just makes it easier to sort out down the road - for some situations you count it as PIC time, for others it goes in the SIC column.

By the way, I still log some of my time in that column, specifically when another captain is listed as PIC on the flight.
 

Inverted25

Well-Known Member
I may be wrong but if its a 135 leg and you don't have a 135 checkride you can't log it. That's how we do it where I work.
 

undflyboy06

Well-Known Member
If you have not been checked under 135 to Act PIC under 135, you won't be able to legally log it as PIC. With 135 under 2 crew, 1 person is designated as PIC and the second is designated as SIC.
 

Inverted25

Well-Known Member
If you have not been checked under 135 to Act PIC under 135, you won't be able to legally log it as PIC. With 135 under 2 crew, 1 person is designated as PIC and the second is designated as SIC.
It is possible that they are flying with two pilots but in a one pilot airplane. We fly our king airs with two pilots because that what the customers want. But only one pilot usually has a 135 PIC ride in the king air. Sometime both will be 135 PIC qualified but not usually. Usually we just use one our flight instructors to fill the second seat. So in that case only the one pilot can log the time during 135 legs. Part 91 the other guy can log it if he is the sole manipulator. At least thats how we do it
 

SteveC

Really?
Staff member
If you have not been checked under 135 to Act PIC under 135, you won't be able to legally log it as PIC. With 135 under 2 crew, 1 person is designated as PIC and the second is designated as SIC.
Sorry, but I disagree. While I agree that the person cannot ACT as PIC, they can LOG PIC.

Allow me to quote from MidlifeFlyer 's website:

When may I log PIC time?

The "golden key" to understanding the rules of logging PIC is to always keep in mind that the FAA treats "acting as pilot in command" and "logging pilot in command time" under FAR 61.51 as completely different concepts. It's the difference between (1) having final authority and responsibility for the operation and safety of a flight (commonly referred to as "acting as PIC") and (2) writing numbers in columns on a piece of paper while sitting at a desk with a beer in your hand. They never mean the same thing and they have completely different rules. A pilot can be responsible for a flight and not be permitted to write those numbers down. A pilot can be technically nothing but a passenger in the FAA's eyes and be permitted to write time in that PIC column. In some circumstances, two pilots may sit at that desk and write numbers in their logbooks, even though, quite obviously, only one can bear the ultimate responsibility for a flight.

The known universe of rules for logging to show qualification for certificates, ratings and currency is contained in FAR 61.51. Unless 61.51 specifically directs you to it, answering a logging question by including the word "acting" or pointing to any other FAR is always a mistake. This is a simplified version of the rules of Part 61 PIC logging as they have been written in the FAR and repeatedly and consistently interpreted by the FAA Legal Counsel since at least 1980. It's limited to student, recreational, private, and commercial pilots. CFIs and ATPs can fend for themselves. If they don't know the rules, tough.

Rule 1. If you are a recreational, private or commercial pilot, you may log PIC any time you are the sole manipulator of the controls of an aircraft you are rated for. [61.51(e)(1)(i)] "Rated" means the category and class (and type, if a type rating is necessary for the aircraft) that is listed on the back of your pilot certificate. Nothing else matters. Not instrument ratings. Not endorsements for high performance, complex, or tailwheel aircraft. Not medical currency. Not flight reviews. Not night currency. Nothing. There are no known exceptions.

...
 

determined2fly

Well-Known Member
ok, so I can log both legs 135 and 91 as long as i am sole manipulator of the controls with the understanding that I am not acting PIC just logging it since I am typed as such in the airplane.
 

determined2fly

Well-Known Member
I just wanted to know what your thoughts are on this post I got:

From another post:
"
Do a search, you'll probably find 50 threads related to this. If you want to keep life simple, if you are not checked out as a PIC don't log it PIC, that's what the SIC column in your logbook is for. I promise in the end you'll have more
PIC/TPIC than you'll know what to do with. A few hours at this point while your working toward 135 PIC mins isn't going to matter one bit...

I've always done it that way, and have never had to explain anything in an interview, which is the only time that what you put in that book really matters...

My .02...

I know someone is going to talk about legal/acting/whatever... If you aren't the acting PIC, why would you want to log it as PIC... You're just going to end up making a mess in your logbook out of what is a very simple issue. Look at SIC as a good thing. It show's you can work in a crew environment..."
thank you
 

SteveC

Really?
Staff member
I suppose that's one way to look at it, but I don't think it stands up to what happens in real life, at least if the time is recorded in the manner that I suggest. Three columns in the log book: PIC; SIC; sole manipulator PIC.

Case 1; a company allows the use of "sole manipulator" PIC time on their application, maybe because their insurance company accepts it towards required minimums to act as PIC (such as the company that I work for). Simply add the PIC and Part 61 PIC columns together. Or that same kind of PIC time can be used when an F/O is upgrading to captain a couple years down the road - he already has the insurance company required "PIC time-in-type" box checked off.

Case 2; a company only wants to see "acting PIC" time because, well, that really is true PIC time by the definition of the word. OK, that's perfectly understandable (and in fact I wish the "logging PIC" rules had been written to match the "acting PIC" rules), so in those cases the Part 61 PIC column gets added to SIC time when filling out that company's application. I have a very hard time believing that an interviewer would look askance at that practice, and the worst that I could see happening is that they are flipping through a logbook and pop up with a nasty-toned question about the "Part 61 PIC" column: Interviewer asks; "What the hell is this? PIC time when you weren't really in charge of the flight? Are you trying to pull something here?" Interviewee; "No sir, that is simply loggable PIC time where I was not the acting PIC. There are situations where being able to provide that data is useful, but it is obvious that I am not trying to fool anyone since it is not hidden in the regular PIC column, and it is not included on the application in front of you under PIC time, but rather in the SIC time totals that I have provided." I have a hard time imagining that a company would be upset that a candidate actually understands "loggable" versus "acting" PIC.

*shrug*

This is not a "gray" area, it is simply true that certain kinds of pilot time are loggable PIC time in some circumstances, and those very same hours are not considered PIC time in other circumstances. Knowledge is power. I think that knowing the difference between acting PIC and logging PIC time, and understanding when it's appropriate to use it to my advantage (and also understanding when it would work against me) only makes sense.

I'm not trying to convince you, or anyone, to log time the way that I do. I'm just on a crusade to counter all of the wrong information out there and lay out the options so people can make informed decisions. I fully understand why people talk so negatively about logging PIC time where the pilot was not truly the Pilot In Charge - but I also think it's silly to throw out the baby with the bathwater.
 

MidlifeFlyer

Well-Known Member
ok, so I can log both legs 135 and 91 as long as i am sole manipulator of the controls with the understanding that I am not acting PIC just logging it since I am typed as such in the airplane.
If you are not typed in the airplane, you can't log PIC. The "sole manipulator" clause in 61.51 requires that you have the applicable ratings for the aircraft, including type ratings where a type rating is required. To be clear, a "type rating" appears on the back of your pilot certificate.

I agree with Steve on the multi-column idea. He uses the low insurance scenario. The one I like is the CFI at a mom and pop FBO that has a small 135 charter. Their last pilot is going away and they want to give you the job but, too bad, you never bothered to log legitimate time and don't meet the Part 135 minimums for the job.

If you're on a career path, you are logging for two purposes: (1) the official FAA one, to show qualification and currency and (2) the job one, to be able to easily pull and show time the company wants to see. With enough columns and at least some consistency among companies about what they want, no reason not to log in a way that keeps it straight for both.
 

determined2fly

Well-Known Member
Just to clear things up here...as stated in my original question I AM PIC single pilot typed in the SA227 and understand you can not log time in an aircraft you are not typed in. I just have not been signed off by my company and don't have the 135 mins yet. My question was just in regards to logging the PIC time on the 135 legs...i understand the sole manipulator stuff, etc.
 

SteveC

Really?
Staff member
Just to clear things up here...as stated in my original question I AM PIC single pilot typed in the SA227 and understand you can not log time in an aircraft you are not typed in. I just have not been signed off by my company and don't have the 135 mins yet. My question was just in regards to logging the PIC time on the 135 legs...i understand the sole manipulator stuff, etc.
The fact that you do not have 135 minimums nor have been assigned as PIC is not applicable to the question of logging the PIC time.
 

SteveC

Really?
Staff member
My take on it is that if you really have to split hairs that closely, then you shouldn't be logging it.
I would agree with you if it were truly a matter of splitting hairs. As I said before this is not a gray area, it is a very clear black/white answer. The only reason people THINK it is splitting hairs is because they don't understand it.

Again, I'm not saying that the rulings make sense to me, nor do I agree with them, but at least I understand them and it is what it is. As much as I dislike the "acting PIC" versus "logging PIC" dichotomy, I'm a realist and know that actually understanding and using the system the way it exists makes more sense to me then just saying "this is stupid so I'm going to just shoot myself in the foot instead".

YMMV.
 

A-300F4-622R

Well-Known Member
I would agree with you if it were truly a matter of splitting hairs. As I said before this is not a gray area, it is a very clear black/white answer. The only reason people THINK it is splitting hairs is because they don't understand it.

Again, I'm not saying that the rulings make sense to me, nor do I agree with them, but at least I understand them and it is what it is. As much as I dislike the "acting PIC" versus "logging PIC" dichotomy, I'm a realist and know that actually understanding and using the system the way it exists makes more sense to me then just saying "this is stupid so I'm going to just shoot myself in the foot instead".

YMMV.

What I mean is that if people are having to use every technicality to try and justify themselves as PIC, then they shouldn't log it. Because even if there are circumstances where you may legally log PIC, you are not truly the PIC.
 

MSUDAWG

Well-Known Member
If you are wanting to log PIC now, obviously it is for some job qualification for later on down the road. Regardless if you are "sole manipulator" of the controls or not, 99.9% of companies after the one you work at now dont care if you were the sole manipulator, rather the Captain of record. This means that if you didn't sign the logbook, ie: sign for the airplane, you are NOT the PIC. So if you have 200 hours of PIC time as the "sole manipulator" they know right off the bat that you were not the Captain and will want you to explain how you were the PIC. Most 135 companies consider the flight prior (meaning to be in position) to a revenue and the leg afterward a revenue leg a 135 leg.

Now with that said, you also dont sound like you have completed a 135.299 either. Without the .299 you absolutely cannot be the PIC. Just wait till you get the mins and actually upgrade because in the grand scheme of things that extra 20 or 30 hours of PIC you want to log right now will mean absolutely NOTHING in the end..
 

Hubbs

Well-Known Member
I don't see it as a technicality, it is a regulation.

Personally, I am a PIC-rated FO on a multi-pilot jet. I log PIC on every leg I am PF. On my résumé, I list my total PIC time and I include this 61.51 PIC time, however, I do not advertise that I have 400 hours of Turbine PIC.
 
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