Mark, in all honesty, isn't that
your personal opinion?..or interpretation?
Really, is there an LOI that specifically says that?
Just English isn't good enough in the area of regulations.
"Just English" would define "rated" as fully capable of acting as PIC. It is the technical definition which adds the technical knowledge that the meaning does not include the qualification to act as rated that makes regulations not behave in accordance with "just English".
Just English would make FAR 1.1 the operative definition.
We both know that changing regulations causes a domino effect. Each regulatory change creates a slight shift in meanings of related regulations, and this is an excellent example of that phenomena.
...and I don't really have a problem with your definition, as long as the instructor makes that determination.
Inferring that a student, a certificated pilot, who is learning a new airplane or procedure, can call himself sole manipulator when the instructor says he isn't, is against basic teaching principles.
Of course, this line of reasoning only works when the instructor is making the judgments for the good of the student.
Allowing 100% PIC time when the instructor is significantly helping is
not in the best interest of the student.
The student needs to know precisely what he is doing and what he is not doing. And that needs to be reflected in the logging of his training.
Employers need to know this too. Recent accidents have focused our attention on the fact that multiple checkride failures are an indicator of potential hazardous pilots.
There is much to be improved in our training/logging system to better reflect training proficiency and knowledge.
We don't do
real stalls and spins, and we don't test knowledge.
We do a
rote approach to a partial stall with a
rote recovery procedure.
That doesn't prepare a pilot to encounter a real stall in a weird situation.
We teach the knowledge test. Back in the day, we studied all the FAA books, the AFH, the PHAK, the AIM, and the FAR's, and we took a test on those subjects. We didn't have the test questions to memorize.
That's why the knowledge test has become a joke.
And so has the concept of logging PIC, if you let joe pilot wiggle the sticks in your Superhummer 409 with no knowledge of what he's doing other than keeping it level, and log PIC, ..ok, a couple hours of that is ok, ..because a couple/few of the initial hours can be just orientation, or 'getting the feel'.
But my problem is the guy who logs 20 - 30 or more of these hours
towards a certificate or rating.
After the Commercial with IR, it doesn't really matter. But the minimum hours required for certification are minimum training standards, and I think the CFI has some responsibility to mentor and supervise the conduct of the training.
Of course, teachers and students are all different. The bottom line here is that the teacher and student agree, at least in principle, on the course and conduct of his/her training.
One of the subjects (way down on the list, but still there) is the logging of time. I always teach the FAR 61.51 logging PIC, and we always have an agreement on when the student is sole manipulator.
Way back, before aircraft endorsements were invented, I used the concept of sole manipulator to decide when to let the student log PIC. And quite frankly, when endorsements became a regulation, I and my peers thought the endorsement was a part of the meaning of the word "rated", so we thought that the endorsement was a regulatory requirement to log PIC.
So, I would usually make the endorsement on or after the first flight in an airplane that required an endorsement, so the student could log PIC, just as I did before the endorsement requirement.
Nothing really changed; I just thought the regulatory endorsement was the FAA way of making every instructor do a more complete check-out by signing an 'endorsement' for that student.
It has been the internet, where I see "I logged all my T/W time as PIC" that tells me the privilege of logging PIC has become diluted like our knowledge tests and a dozen other training requirements.
Mark, consider this: If you owned a T/W, and wanted to hire a pilot to fly it, and you knew from experience that you wanted a pilot with 10 hours of PIC T/W time because you know it takes 10 hours of sole manipulator time on the stick and rudder doing landings, wouldn't you really rather have a pilot who logs real sole manipulator time as authorized by his reputable instructor than the guy who has been sturggling to keep it straight, and getting a little help from his cfi in the back seat but he doesn't know it, or doesn't want to acknowledge it, 'cause he has been told on the internet that he can make the call, not his instructor?
Or the guy who flew a 5 hour trip and back keeping it level on course, but only 2 landings.
Talk to me about application, not rote FAR speak.
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.I love this stuff...

keep'em coming..