Logging PIC in a Tail Wheel without endorsement.

R Banger said:
By definition you can log it, but from what I have heard it can depend on your local FSDO. Here in Salt Lake none of the DPEs will count it as such, and from what I have heard this goes for a lot of airlines as well. The example used was when an applicant had logged time in an aircraft that required a high altitude endorsement, airlines started to ask question about their multi time. Sometimes better to err on the safe side.
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I'm not much into arguing with the FAA but if I had a problem with a DPE making an issue of this I would print out the letter previously referenced on this thread and show it to him. He would submit to my superior knowledge on the subject and then fail me for something else. Ahahaha.

I have logged PIC while not having the ability to legally act as PIC in the aircraft I was flying. If I were ever asked about this in an interview I would not be worried as I only have probably 5-10 hrs that falls in this category. Thousands of hours of working a plane as the only pilot on board kind of overshadow any interview worries about things like this. Now if you logged say, more then 10 hours PIC in an aircraft, and never gained the ability to act as PIC during that process then I might question you about it in an interview. If you have hundreds of hours doing this then you should be very worried in an interview with me.
 
R Banger said:
By definition you can log it, but from what I have heard it can depend on your local FSDO. Here in Salt Lake none of the DPEs will count it as such,
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If that's true then all I can say is thank goodness that there are still DPEs and FSDOs around that, when they don't personally like the FAA's rules, they make up their own! :beer:

what I have heard this goes for a lot of airlines as well.
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That's not relevant to the discussion. An employer, aviation or not, has an absolute right to decide what experience qualifications it wants from job applicants.
 
poser765 said:
he internet lawyers didn't make the interpretation. The FAA did. Are we not to believe the FAA on their interpretation of their own rules?
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Not if you don't like them. Then you can pretend that they don't exist and roll your own. :bandit:

A lot of these discussions end of being philosophical discussions about what should be as opposed to what is. I don't have a horse in the "should be" race. I don't really care whether the FAA wants to count non-endorsed pilot time or safety pilot time or time in United 235 seat 23A toward the certificates and ratings that the FAA issues. It's just not a "panties in a bunch" issue for me. And I don't quite understand those who wring their hands about it and try to create ways to get around rules they don't like and force them on others.

Sorry nosehair, but your, "He's not really the sole manipulator until I decide that he is" interpretation is simply a lot of nonsense. Of course, that's between you and your student. If, after understanding what the rules really are, he's willing to forgo those few extra hours of PIC time and have to pay for them as second time later, that's OK with me. To each his own.
 
MidlifeFlyer said:
Not if you don't like them. Then you can pretend that they don't exist and roll your own. :bandit:

A lot of these discussions end of being philosophical discussions about what should be as opposed to what is. I don't have a horse in the "should be" race. I don't really care whether the FAA wants to count non-endorsed pilot time or safety pilot time or time in United 235 seat 23A toward the certificates and ratings that the FAA issues. It's just not a "panties in a bunch" issue for me. And I don't quite understand those who wring their hands about it and try to create ways to get around rules they don't like and force them on others.

Sorry nosehair, but your, "He's not really the sole manipulator until I decide that he is" interpretation is simply a lot of nonsense. Of course, that's between you and your student. If, after understanding what the rules really are, he's willing to forgo those few extra hours of PIC time and have to pay for them as second time later, that's OK with me. To each his own.
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What Mark wrote.
Just to add, every employer I have dealt with instructs applicants how to count PIC time and there are as many attitudes about PIC time among potential employers as there are... well, potential employers. Some only count PIC time when you sign for the aircraft. So even if you are rated and endorsed by JC himself they won't count the time if you did not "sign" for the aircraft. This has nothing to do with how you can legally log time, but it is the way some employees want to see your flight time. Heck, there are differences between my logbook and my military time as the military only lets you log one mode of flight (such as night or WX, not both), and there are instances where the military lets you log time but the FAA does not or visa versa.
I too have run into a DE who initially did not believe the training time in a TW or HP/complex airplane counted as PIC, yet when I showed him the letter he corrected himself and said it counted. He personally did not think it should, but he went with the FAA's interpretation. I will also say that my local FSDO interprets it this way since this letter was published.
There are many things I disagree with in the FAR/AIM. Yet I comply with the regulation and advise other pilots on what the official FAA interpretation is when available. If I disagree strongly enough there is a way to change the regulation.
 
With stuff like this you just have to remember that government entities aren't necessarily logical.

The regs should have been written in a way that only "acting" PICs can log PIC, but they weren't written that way. As a result we have many ways to log PIC even if we aren't the "acting" PIC.

Whoever is telling you that companies don't accept perfectly legal Part 61.51 flight time is off base. The 10 hours you get during all of your endorsements wont be a problem.
 
aloft said:
Funny thing is, I've never seen a specific number of PIC hours (other than turbine) on a list of requirements for any job.
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The "theft" I'm referring to is the PIC time needed to meet FAA minimum requirements for certificate, ratings, currency* and operating privileges.

I'm not surprised if employers don't list general PIC requirements (although isn't there a thread here about pilots who may not know the FAA minimums for the job?).

*I'm trying to figure out whether there are any FAA currency requirements that involve a certain amount of PIC time. Part 91 instrument and passenger currency don't and I don't recall seeing one in Part 135.
 
aloft said:
Funny thing is, I've never seen a specific number of PIC hours (other than turbine) on a list of requirements for any job.
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I have seen a few jobs where they have listed "500 PIC" as a requirement. It actually weeds out furloughed airline FOs that were hired at 250TT
 
It's too bad the FAA uses PIC in two different definitions. If they followed the military example there wouldn't be so much confusion. In the military, Part 1 PIC = Aircraft Commander while Part 61.51 PIC = First Pilot. Easy!
 
Yeah, the original FAA definition was exactly the same. "...for which he is rated" meant just what you think it means on the surface: Rated to be PIC.

In those days there were no additional "endorsements" after certification, so it was logical that "rated" meant what was on the FAA certificate, or the military pilot's orders.

Then, GA airplanes became complex, and high powered, and tricycles were the common first experience, and the whole training/GA environment changed, but the FAA did not change, or focus, the meaning of the word 'rated' in 61.51 to encompass the changing environment of the GA airplanes that a newly minted PP can be PIC of.

Another big difference in military and FAA logging time is the actual flight time. Forward movement for the purpose of flight was originally meant to be the take-off roll, as it still is in the military, and was originally the FAA interpretation.

But that has been re-defined by civilians being charged flight time from engine start to engine shut-down, so that is what has been 'decided' by legal interpreters to be the FAA legal definition.

It's all about the money. In a court of out 'peers', if we consider our 'peers' to be non-pilots, they would understand flight time as actual flight time, and PIC time to be actual PIC time, but...
In a court with our 'peers' to be aspiring young pilots who are paying big money to get this time, they would mostly go for the block-to-block time definition and all of it PIC even when an instructor is instructing how to.

I get it. I just don't have to agree with it. ;)
 
Nihon_Ni said:
It's too bad the FAA uses PIC in two different definitions. If they followed the military example there wouldn't be so much confusion. In the military, Part 1 PIC = Aircraft Commander while Part 61.51 PIC = First Pilot. Easy!
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Sometimes the military is logical, sometimes the FAA is logical. For example, in the military I could log IMC, night, or NVG. Not all three. If someone is observing the flight from the jump seat they can log observer time. Heck, I logged IP time evaluating from the jump seat but I never carried this time into my civilian logbook although no one could have told the difference. Military never even tracked cross country time so I just swagged that. Of course according to the FAA if I flew several hundred miles but could not land due to an attack on the FAB and returned to base that did not count as cross country time. The FAA changed the rules after the Gulf War when some B-52s flew from the US to Iraq, dropped their bombs, then returned to base in the US but it was not a cross country flight as they did not land at a point other than the origination but the rules where never changed for RW.
 
nosehair said:
Yeah, the original FAA definition was exactly the same. "...for which he is rated" meant just what you think it means on the surface: Rated to be PIC.
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Happen to have a reference for the "original" FAA definition in the logging context? I've managed to look at various regs going back to 1929 and, while the use of the term "PIC" in the logging context has changed (at one time it was called "solo" which then meant "sole manipulator" and probably caused its own problems), the underlying concept of counting sole manipulator time toward certificates and ratings has been relativity consistent, at least back to 1940.

Logging PIC appears to have made its start in the 1950s.

The "modern" version of the reg interpretation goes at least back to a 30-year old Chief Counsel interpretation.

One would think that an FAA interpretation that is older than many pilots and certainly older that the most of the pilots who actually care about how much time they log would stop being argued about so much. Frankly, I think it's a sign of old age ("when I was a youngster, I needed to walk five miles in deep snow to get to school. And that's the way it should be!!!"_.
 
MidlifeFlyer said:
I've managed to look at various regs going back to 1929 and, while the use of the term "PIC" in the logging context has changed (at one time it was called "solo" which then meant "sole manipulator" and probably caused its own problems), the underlying concept of counting sole manipulator time toward certificates and ratings has been relativity consistent, at least back to 1940.

Logging PIC appears to have made its start in the 1950s.
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I solo'ed in 1961, and of course, all my instructors of that time were of the 50s and 40s when, as you say, the phrase "sole manipulator" was "solo".

So, it stands to reason that the meaning of sole manipulator is that the pilot is flying as if he were solo. If an instructor is aboard, and saying and doing nothing, but evaluating, that would be my definition of sole manipulator.

I don't believe the term sole manipulator can possibly apply to some of the initial time in a tailwheel check-out, or a high powered, or complex, or otherwise hands-n-feet full o' airplane.
The "modern" version of the reg interpretation goes at least back to a 30-year old Chief Counsel interpretation.
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The modern version does not give blanket approval for logging all post-PP time as PIC; the modern version still says "sole manipulator".

I think our difference of opinion is the meaning of 'sole manipulator', and until you see a legal definition that is different than the original version, which is "as if solo", I think the CFI can legally define it, and he/she is morally bound to do so.
One would think that an FAA interpretation that is older than many pilots and certainly older that the most of the pilots who actually care about how much time they log would stop being argued about so much. Frankly, I think it's a sign of old age ("when I was a youngster, I needed to walk five miles in deep snow to get to school. And that's the way it should be!!!"_.
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Well, now, you young whippersnapper, there's something to be said about having a good long walk to school. :rolleyes:

Things aren't going so well in America's schools these days are they?
 
nosehair said:
I solo'ed in 1961, and of course, all my instructors of that time were of the 50s and 40s when, as you say, the phrase "sole manipulator" was "solo".

So, it stands to reason that the meaning of sole manipulator is that the pilot is flying as if he were solo. If an instructor is aboard, and saying and doing nothing, but evaluating, that would be my definition of sole manipulator.

I don't believe the term sole manipulator can possibly apply to some of the initial time in a tailwheel check-out, or a high powered, or complex, or otherwise hands-n-feet full o' airplane.
The modern version does not give blanket approval for logging all post-PP time as PIC; the modern version still says "sole manipulator".

I think our difference of opinion is the meaning of 'sole manipulator', and until you see a legal definition that is different than the original version, which is "as if solo", I think the CFI can legally define it, and he/she is morally bound to do so.
Well, now, you young whippersnapper, there's something to be said about having a good long walk to school. :rolleyes:

Things aren't going so well in America's schools these days are they?
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Don't worry. Some day I will be king then things will be logical. After all, my opinion is the correct opinion.
 
nosehair said:
I think the CFI can legally define it, and he/she is morally bound to do so.
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Well... no. You can chose not to log whatever you want, but in many letters from the FAA clarifying the matter, it doesn't mater what the CFI thinks, the pilot can still log it.
In fact CFIs think a lot of things wrong from time to time. They are not a regulating authority on anything. Awesome little tidbits passed down from other people that don't know what they are talking about. Somehow they get interpreted as fact, and get really hard to stamp out.
Oversquare comes to mind, just off the top of my head.
 
nosehair said:
I solo'ed in 1961, and of course, all my instructors of that time were of the 50s and 40s when, as you say, the phrase "sole manipulator" was "solo".

So, it stands to reason that the meaning of sole manipulator is that the pilot is flying as if he were solo.
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Maybe, except, like logged PIC, solo time was counted toward certificates and ratings and , at the time, the FAR took care of the instruction issue since only 1/2 of "sole manipulator" time with an instructor counted as solo.

No need for a CFI to make up junk, It was there.

It's not not, so it "stands to reason" that they took away the limitations on purpose.
 
Wait a minute! Are all you guys ganging up and saying you believe that the term 'sole manipulator' means something like, "as long as I don't have to take the controls to avoid a crash",..is that what you are inferring?

Is there an official LOI that says that? Did I miss that, too. (or forget?)
 
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