Logging PIC time during Instrument training

[juxtapilot]

1. The regs aren't law. Laws are law, regs are regs. I know its just symantics but there is a difference and one should never be confused for the other IMO.

2. Be careful about questioning the professional integrity of anyone before you've walked a mile in their shoes.

Law or reg.. does it really matter? Breaking either can get you in trouble. In any case, regulations are technically "administrative" law... so I guess they are in fact, law.

 

[shdw]

65.51 1(e) Logging pilot-in-command flight time
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

The endorsement sounds an awful lot like privileges to me.

You seem to be crossing some wires here, believing the endorsement is a PIC endorsement, it is not, it is a solo endorsement unless applied to type ratings as the section you mentioned implies (poser this should answer your question). Privileges by definition is merely the ability to perform certain actions. In the case of a solo endorsement you have the privileges to fly solo and the act of flying solo gives you the privilege to log PIC.

Having the solo endorsement does not give you the privilege to log PIC, it gives you the privilege to fly solo, period. Therefore having that solo endorsement does not fall into the "privileges" in this regulation. In the case of this regulation a privilege that would permit you to log pic w/o a rating would be taking your practical test with the FAA examiner.

Be careful with wording when you get into regulations, a simple cross of the word PIC with solo with regards to an endorsement completely changes the implications. You likely know someone in your life who always took things for their literal meaning, apply that mind set to regulatory material. It isn't perfect, but it will get you on the right track 99 percent of the time, the other 1 percent is up to the lawyers digging through trial excerpts.



Midlife: Was that last paragraph a better way to put it than just read it literally every time and you'll always be right? I altered that definition slightly from some of my past posts.

 

[juxtapilot]

You seem to be crossing some wires here, believing the endorsement is a PIC endorsement, it is not, it is a solo endorsement. Privileges by definition is merely the ability to perform certain actions. In the case of a solo endorsement you have the privileges to fly solo and the act of flying solo gives you the privilege to log PIC.

Having the solo endorsement does not give you the privilege to log PIC, it gives you the privilege to fly solo, period. Therefore having that solo endorsement does not fall into the "privileges" in this regulation. In the case of this regulation a privilege that would permit you to log pic w/o a rating would be taking your practical test with the FAA examiner.

Be careful with wording when you get into regulations, a simple cross of the word PIC with solo with regards to an endorsement completely changes the implications. You likely know someone in your life who always took things for their literal meaning, apply that mind set to regulatory material. It isn't perfect, but it will get you on the right track 99 percent of the time, the other 1 percent is up to the lawyers digging through trial excerpts.



Midlife: Was that last paragraph a better way to put it than just read it literally every time and you'll always be right? I altered that definition slightly from some of my past posts.

Nice post... As far a pre-private solo flight, that time would be considered solo, and not PIC correct?

 

[shdw]

Nice post... As far a pre-private solo flight, that time would be considered solo, and not PIC correct?

It is PIC and solo. When you fly solo you may log pic as per 61.51(e)(1)(ii): "Is the sole occupant of the aircraft."

 

[juxtapilot]

It is PIC and solo. When you fly solo you may log pic as per 61.51(e)(1)(ii): "Is the sole occupant of the aircraft."

Gotcha thanks!

 

[shdw]

Question: Does the PIC time for the solo XC flights performed during pre private training count towards 61.65(d)(1) requiring 50 hours PIC XC?

I cannot see anything that would say otherwise but recently had someone tell me their school didn't allow it and made them fly extra hours. I am not an II so I have not really dug into the regulations with regards to this beyond the reg mentioned in the question. Thanks.

 

[Old Pete]

Link to the legal decision mentioned earlier upholding a 60 day suspension of a CFI certificate for failure to endorse a logbook.
Again, I don't care how a university or any other entity counts flight time; the logbook is the pilot's logbook, not the university's. A pilot should legally log the time then present it to the CFI for endorsement and for the entry of the instruction given, not the type of flight time. Any CFI who refuses to endorse the logbook does so at their own risk.
http://www.ntsb.gov/alj/alj/O_n_O/docs/aviation/5213.PDF

http://www.nj.com/news/index.ssf/2009/03/nineteen_charged_in_alleged_in.html

The pilots -- Louis Luyten, 71, and Paul Robinson, 51 -- live in Connecticut and are accused of flying 10 kilos of cocaine from Florida to Ocean City Airport in exchange for $15,000. They are charged with conspiracy to distribute cocaine, methamphetamine and Oxycodone.

I'm guessing this guy now has bigger problems than violating 61.189.

 

[mshunter]

Question: Does the PIC time for the solo XC flights performed during pre private training count towards 61.65(d)(1) requiring 50 hours PIC XC?

I cannot see anything that would say otherwise but recently had someone tell me their school didn't allow it and made them fly extra hours. I am not an II so I have not really dug into the regulations with regards to this beyond the reg mentioned in the question. Thanks.

Come on shdw, you should be able to figure this one out on your own.:crazy: I know you know the answer to this question. Say you are solo on a solo x-country, and log it in the solo/pic column. Does this answer your question.


P.S. I have my students do it, and have never had an examiner balk at it. I also see nothing in the regs that says "excludes time built while excersing student pilot privilages."

 

[Old Pete]

Question: Does the PIC time for the solo XC flights performed during pre private training count towards 61.65(d)(1) requiring 50 hours PIC XC?

I cannot see anything that would say otherwise but recently had someone tell me their school didn't allow it and made them fly extra hours. I am not an II so I have not really dug into the regulations with regards to this beyond the reg mentioned in the question. Thanks.

Yes, it does count toward the 50 xc pic requirement. But, I think the confusion might be that before the last big rewrite of part 61 it did not count. As MikeD mentioned student solo time was not counted as pic before the the last rewrite of 61. I think that student xc time at one time did not count toward that 50xc requirement, but I'm not sure.

 

[Blackhawk]

http://www.nj.com/news/index.ssf/2009/03/nineteen_charged_in_alleged_in.html

I'm guessing this guy now has bigger problems than violating 61.189.

Often when precedence is set there are other factors involved- such as the famous "a watch is not a clock" case. Still, the precedence is set and the NTSB is on record as suspending a CFI certificate for failure to endorse a logbook for flight and ground training. A CFI would be ill advised to follow the steps of this man.

 

[Blackhawk]

1. The regs aren't law. Laws are law, regs are regs. I know its just symantics but there is a difference and one should never be confused for the other IMO.

2. Be careful about questioning the professional integrity of anyone before you've walked a mile in their shoes.

Part 61 is actuall 14 CFR part 61. CFR stands for Code of Federal Regulations. Legal definition of code:

code n. a collection of written laws gathered together, usually covering specific subject matter.

Some might argue that since the regulation was created by a regulatory agency and not the legislature that they are not laws; while this can be rightfully debated on technical grounds what is beyond a doubt is that the CFR does have the force of law. Don't think so? Try violating one and see what happens.

 

[MidlifeFlyer]

Midlife: Was that last paragraph a better way to put it than just read it literally every time and you'll always be right? I altered that definition slightly from some of my past posts.

Beats me. Whatever way lets someone get their minds around it so they really understand it is the right way.

 

[Holocene]

I'm currently a Private Pilot training for my Instrument Rating. I've had several flights under the hood performing instrument approaches, holding, and intercepting and tracking. According to my instructor, I should not log this as PIC time apparently because the airlines frown upon it since there is more than one PIC which is "impossible". I know for a fact that two pilots can log PIC time when one is acting as a safety pilot, so I know that it is possible, but do the airlines really frown upon it for some reason?

My understanding is, that after I have completed/logged 6 approaches (in an airplane/sim/FTD), I may begin logging PIC time while under the hood, as long as I remain current.

Am I mistaken?

All my instrument training flights were PIC.

 

[shdw]

Come on shdw, you should be able to figure this one out on your own.:crazy: I know you know the answer to this question. Say you are solo on a solo x-country, and log it in the solo/pic column. Does this answer your question.

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

 

[drunkenbeagle]

You seem to be crossing some wires here, believing the endorsement is a PIC endorsement, it is not, it is a solo endorsement unless applied to type ratings as the section you mentioned implies (poser this should answer your question).

A PIC endorsement is an endorsement to act PIC. If the FAA intended it to be solo and not PIC time, they would have called it a solo endorsement. AC61-65E, sec 62.

For several ratings, there are both PIC and solo time requirements, of differing amounts.

 

[MidlifeFlyer]

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

It did at one time. The part of 61.51 that permits a solo student pilot lo log PIC was added in 1997. Before then, soloing student pilots could not log PIC time, and so had nothing to count from it toward advanced certificates and ratings.

Maybe the schools that don't "allow" pilots to properly log their time just don't like change – even 12 year old change.

 

[MikeD]

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

newbies.....

 

[Joe Gremlin]

while this can be rightfully debated on technical grounds what is beyond a doubt is that the CFR does have the force of law. Don't think so? Try violating one and see what happens.

Actually that's kind of what I was talking about.

Get caught driving a car without a license and compare that to what happens to you when you get caught flying a plane without a certificate. They might both 'carry the force of law' but I know which group I'd rather get caught violating if given the choice.

 

[shdw]

A PIC endorsement is an endorsement to act PIC.

I understand what a PIC endorsement is, I also understand that it is applicable to type ratings, not a pre private student.

A regulation is nothing more than an outline, meaning each subpart of a given regulation (indented sections below) is bound to the wording of the regulation it lies in. Here is the regulation in question:

61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must​

(3) Have received training required by this part that is appropriate to the aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received the required endorsements from an instructor who is authorized to provide the required endorsements for solo flight in that aircraft.​

Notice your endorsement is under the part regarding type ratings and additional training. It does not and cannot be applies to a pre-private student. I would question its application to any other rating as well, with the exception of, as tgray mentions, some of the new sport pilot ratings for which I am unfamiliar.

Think of it this way, if you could do this you would be able to completely circumvent 61.51 for any pre private student, as well as logging for multi engine as PIC without a rating, which is also not allowed.

 

[drunkenbeagle]

Think of it this way, if you could do this you would be able to completely circumvent 61.51 for any pre private student, as well as logging for multi engine as PIC without a rating, which is also not allowed.

No one said this was for a student, it only applies to certificated pilots.

Nothing stops you from logging multi PIC without a rating (other than maybe insurance companies). If you hold a pilot certificate and get a PIC AMEL endorsement, you can act PIC and log multi PIC time solo.