Logging question - Piper Dakota

[bob loblaw]

Why are you short changing yourself?

"61.51 (c) (3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor."

Anytime you are acting as a CFI/CFII/MEI log it as PIC time!

I never said that I don't log the flight PIC for myself, I am talking about a student or private pilot who doesn't have a HP. I have the HP endorsement, so I don't get shortchanged. Lets say that you come to me as a private pilot who does not hold a high performance sign-off, and you want to get the sign-off in a Cessna 182. I will log you as dual recieved only, I will not log you as PIC. if you fly to my standards and can safely operate the HP aircraft, I will endorse your logbook for HP. I log PIC in my logbook, as well as Flight Instructor and keep a copy of your logbook showing the endorsement.

Lets say I log your training flight in your logbook as dual received and PIC as sole manipulator. I now open myself up to a FAA inspector who may interpret the rule differently than I do and try to violate me. By logging you dual only, I don't get in trouble for being conservative.

 

[Grabo172]

Lets say I log your training flight in your logbook as dual received and PIC as sole manipulator. I now open myself up to a FAA inspector who may interpret the rule differently than I do and try to violate me. By logging you dual only, I don't get in trouble for being conservative.

But, you just cheated your students out of PIC time that they might need in the future.

It's not about "I", take care of your students!

Let the FAA come and try to take action on me because I let my students log the time as PIC that they deserve... I'll just open the FARS and shove it in their face. I'm not going to cheat my students out of time on some vague notion that some FAA inspector somewhere doesn't know squat about their job and tries to violate me for no reason... I'll take that hit every time!

 

[MidlifeFlyer]

I never said that I don't log the flight PIC for myself, I am talking about a student or private pilot who doesn't have a HP.

So instead you are shortchanging your student? That's much better. I assume you explain to your student what the rule is and why you decided not to follow it before deciding for your student that he shold not be able to count legitimate time?

Lets say I log your training flight in your logbook as dual received and PIC as sole manipulator. I now open myself up to a FAA inspector who may interpret the rule differently than I do and try to violate me. By logging you dual only, I don't get in trouble for being conservative.

OMG! When I get home, I'll correct my logbook to follow the rules (unless, of course, like Mike I don't need the PIC time) and count the time the FAA has clearly and consistently said I'm entitled to count. I'll even make a note that I corrected it myself so it's clear it wasn't the work of my paranoid CFI.

BTW, that's a description of what I actually did after I received my high performance endorsement. in my case, the CFI was innocent. As is unfortunately pretty common, he didn't understand the rule and had the common difficulty separating acting from logging.

 

[bob loblaw]

So instead you are shortchanging your student? That's much better. I assume you explain to your student what the rule is and why you decided not to follow it before deciding for your student that he shold not be able to count legitimate time?

OMG! When I get home, I'll correct my logbook to follow the rules (unless, of course, like Mike I don't need the PIC time) and count the time the FAA has clearly and consistently said I'm entitled to count. I'll even make a note that I corrected it myself so it's clear it wasn't the work of my paranoid CFI.

BTW, that's a description of what I actually did after I received my high performance endorsement. in my case, the CFI was innocent. As is unfortunately pretty common, he didn't understand the rule and had the common difficulty separating acting from logging.

I thouroughly understand the rule and the difference between the definitions of PIC. The problem is that a FAA inspector could interpret the rule differently than I do and try to violate me. Also I never said that logging PIC without the HP endorsement was illegal and wrong. Don't read something that isn't there. I merely said that I take a conservative approach to this question. Logging PIC is legal, but how much trouble do you think I would have to go through to prove to a FAA inspector that I am right.

Lastly, I just filled out an application for a regional and when giving the break down of my flight experience in type, this airline doesn't count PIC logged while also logging dual. This means that this airline only wanted the time I was actually PIC ( final authority to the safety of the flight ) in each type. They did also want a break down of the dual and instruction given. So this issue really isn't that big of a deal.

 

[bob loblaw]

FAR 61.13 Additional Endorsements

(f) Additional training required for operating high-performance airplanes. (1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has—
(i) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane; and

(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane.

The problem with the highlighted text is that it is up to interpretation as to which definition the FAA has for this particular regulation. I feel that the FAA is using the definition as to the Authority and safety of the flight. However, I am not going to risk my certificate on wether I am right. I believe the intent of this regulation says that you can act as PIC ( sole manipulator) while getting the instruction for the HP endorsement. But to ensure that I can not be wrong, I log it as dual. Critically read the highlighted text.

 

[Grabo172]

The problem with the highlighted text is that it is up to interpretation as to which definition the FAA has for this particular regulation. I feel that the FAA is using the definition as to the Authority and safety of the flight. However, I am not going to risk my certificate on wether I am right. I believe the intent of this regulation says that you can act as PIC ( sole manipulator) while getting the instruction for the HP endorsement. But to ensure that I can not be wrong, I log it as dual. Critically read the highlighted text.

ACTING and LOGGING are Different!!

You are the Acting PIC as the instructor. You, as the instructor, have the final authority to the safety of the flight. You get to ACT as PIC AND LOG it as PIC time.

Your student without the endorsement cannot ACT as PIC...

However, your student can , and SHOULD, log it as PIC time in their log book because they are the sole manupulator of the controls during those training flights... (unless you are flying for them) and they also get it logged as Dual Recieved.

Words Mean Things

 

[bob loblaw]

ACTING and LOGGING are Different!!

You are the Acting PIC as the instructor. You, as the instructor, have the final authority to the safety of the flight. You get to ACT as PIC AND LOG it as PIC time.

Your student without the endorsement cannot ACT as PIC...

However, your student can , and SHOULD, log it as PIC time in their log book because they are the sole manupulator of the controls during those training flights... (unless you are flying for them) and they also get it logged as Dual Recieved.

Words Mean Things

I think you may need some things clarified. If you are giving instruction to a non-rated student pilot, you are not acting as PIC, you are PIC. But as I have said over-and- over, I fully understand the difference between both definitions of PIC. But my position still remains the same. I highlighted the area where the FAA uses the word PIC, but it is up for interpretation as to which definition the FAA is using. I say this again as well, please read this carefully. My interpretation is that a private pillot who doesn't hold a HP endorsement can log PIC ( sole manipulator ) while training for a HP endorsement. The trouble is the FAA's interpretation is the only interpretation that matters, not my interpretation. Because I am not willing to bet my certificate that my interpretation is correct, I log the flight as dual for the " student " and PIC for me.

 

[roundout]

in that scenario, you can write it in the student's logbook as both dual received AS WELL AS PIC. they're no reason why not to. the student is the sole manipulator and is rated, so he can log PIC. you are acting as PIC, so you log PIC. the student is receiving instruction, so he is also logging dual received. there is nothing wrong with this, and it's really the right thing to do.

 

[bob loblaw]

in that scenario, you can write it in the student's logbook as both dual received AS WELL AS PIC. they're no reason why not to. the student is the sole manipulator and is rated, so he can log PIC. you are acting as PIC, so you log PIC. the student is receiving instruction, so he is also logging dual received. there is nothing wrong with this, and it's really the right thing to do.

This is just my opinion and I am don't speak for all instructors. I just chose not to log the student PIC during a HP sign-off training flight. There is no violation in not logging him PIC whatsoever. There is a regulation that says no person may act as PIC of a HP aircraft unless they have received ground and flight training and a Logbook endorsement. If for whatever reason a Inspector looks at the students loogbook, he can't violate me for being conservative, he can try to violate me if he interprets the FAR differently than I do if I log the student as PIC.

We really are talking about an hour or three of time. If a student needs more training than that to safely fly a 182, than maybe a 182 isn't for him. So yes, there is a reason not to log the private pilot's logbook as PIC, in my opinion. It's kept me out of trouble thus far.

 

[casey]

I think you may need some things clarified. If you are giving instruction to a non-rated student pilot, you are not acting as PIC, you are PIC. But as I have said over-and- over, I fully understand the difference between both definitions of PIC. But my position still remains the same. I highlighted the area where the FAA uses the word PIC, but it is up for interpretation as to which definition the FAA is using. I say this again as well, please read this carefully. My interpretation is that a private pillot who doesn't hold a HP endorsement can log PIC ( sole manipulator ) while training for a HP endorsement. The trouble is the FAA's interpretation is the only interpretation that matters, not my interpretation. Because I am not willing to bet my certificate that my interpretation is correct, I log the flight as dual for the " student " and PIC for me.

you dont need to bet on your interpretation, just use the FAA's. In thier "Part 61 FAQ" (get it from thier website) there are multiple instances where they look at the differences between logging and acting as PIC, and its very clear that as long as you are "rated" (category and class only; endorsements, intrument ratings, do not matter) and meet the requirments of 61.51 you can log pic time. Its the same concept that allows an instrument student who rated (PP-ASEL for example) to log PIC time in actual conditions. He cannot ACT as PIC (thats the II's job) in actual since he is not instrument rated, but he can log it. Talking with DPE's and ASI's and reading that FAQ leaves a pretty clear impression on this issue.

here is just one example from the FAQ (written interpretation by the FAA)

QUESTION: Question about logging of pilot-in-command time. You asked whether a pilot needs to have the appropriate 14 CFR § 61.31 endorsements before he or she can properly log pilot-in-command time under 14 CFR § 61.51(e) when that pilot holds a private pilot certificate with a single-engine land rating and is receiving training in a single-engine land airplane that is also a complex or high performance airplane. Can this person log the time he or she manipulated the controls as pilot-in-command time.

ANSWER: Ref. § 61.51(e)(1)(i); § 61.51(e) governs the logging of pilot-in-command time. This section provides, in pertinent part, that a private pilot may log pilot-in-command flight time for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. (Emphasis added: “aircraft for which the pilot is rated”). The term “rated,” as used under 14 CFR § 61.51(e), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required). These ratings are listed under § 61.5 and are placed on the pilot certificate.

Therefore, based on the scenario given, a private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating.

Note, while the private pilot may log this time as pilot-in-command time in accordance with § 61.51(e), he or she may not act as the pilot in command unless he or she has the appropriate endorsement as required under § 61.31. There is a distinction between acting as pilot in command and logging pilot-in-command time. In order to act as pilot in command, the pilot who has final authority and responsibility for the operation and safety of the flight, a person must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. § 61.31 requires a person to have an endorsement from an authorized instructor before he or she may act as pilot in command of certain aircraft (a complex airplane, a high performance airplane, a pressurized airplane capable of operating at high altitudes, or a tailwheel airplane). These endorsements are not required to log pilot-in-command time under § 61.51(e). In order to log pilot-in-command time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.

 

[MidlifeFlyer]

I thouroughly understand the rule and the difference between the definitions of PIC. The problem is that a FAA inspector could interpret the rule differently than I do and try to violate me.*** Logging PIC is legal, but how much trouble do you think I would have to go through to prove to a FAA inspector that I am right.

None whatsoever. This is well-settled aviation law. I doubt the inspector with the misinterpretation would get through the internal screening process. I'm not sure how you get to do =anything= if you are always trying to avoid the possibility that some ignorant inspector played hookey during his training sessions.

So I'm curious. How do you justify logging PIC when you are not manipulating the controls when instructing? Don't quote the reg. After all, an FAA Inspector might misinterpret it and bring a certificate action against you. The likelihood is about the same.

 

[bob loblaw]

None whatsoever. This is well-settled aviation law. I doubt the inspector with the misinterpretation would get through the internal screening process. I'm not sure how you get to do =anything= if you are always trying to avoid the possibility that some ignorant inspector played hookey during his training sessions.

So I'm curious. How do you justify logging PIC when you are not manipulating the controls when instructing? Don't quote the reg. After all, an FAA Inspector might misinterpret it and bring a certificate action against you. The likelihood is about the same.

Midlifer, you are right and I am wrong! I will immediately whiteout all PIC I have logged in my logbook.

 

[MidlifeFlyer]

Midlifer, you are right and I am wrong! I will immediately whiteout all PIC I have logged in my logbook.

I wouldn't do that. I was just really wondering why you see a difference between logging legitimate time and logging legitimate time.

Wrong? Not really. What you choose to put in your logbook is your own business. If you have a personal policy about how you log your flight time, by all means follow it. That goes for your decision about not endorsing the PIC time in your student's logbook - it's your choice what you are willing to endorse.

The only problem here is that you're not being conservative with your flight time. You're being conservative with someone else's. I asked before whether you were explaining to the student what you were doing and why ("The FAA will let you log this as PIC time, but I don't want you to. Other instructors will let you log the time but I won't").

If you're not explaining this to you student, I do think that's wrong. You're deciding on your own that your student must forego logging legitimate PIC time that he could use toward future certificates and ratings. Sorry, but that's the client's choice, not yours. That may not be a big deal to some, but the pilot has to pay at least the aircraft cost for every flight hour with you twice. I just don't think that's fair unless the student agrees to it.

 

[bob loblaw]

I have looked for the FAA's interpretation to FAR 61.31 on their website under FAQ's. I even searched the FAQ section for this and the only thing that comes up pertains to privates logging PIC in instrument conditions. Someone in this thread cut and pasted what lookes like an answer to that question, but I can't find it in the search. I will change my positioin gladly if someone can find a link to the FAA's website which answeres this question.

 

[roundout]

http://www.propilot.com/doc/legal8.html

 

[bob loblaw]

http://www.propilot.com/doc/legal8.html

If it's on the internet, it must be true. I am still looking for a link to the FAA's website which shows the FAA answering the question about logging PIC for HP. If someone shows me where on the FAA website the interpretation is, I will change my position.

 

[Grabo172]

Here... :banghead:
http://www.faa.gov/about/office_org...s/afs/afs800/afs810/part_61/media/pt61FAQ.doc

It's about 1/5 of the way down in the 61.51 section... I'll paste it here too... Don't say it doesn't apply... it does.



"QUESTION: I am sorry, but it is the age old Pilot-In-Command question again. As an examiner I am required to check the applicant's log book to determine that he meets the minimum aeronautical experience requirements for a certificate or rating.

Therefore, when an applicant is training for his instrument rating and commercial pilot certificate, an applicant has logged pilot-in-command while receiving dual instruction. In accordance with § 61.51(e)(1)(i), this is perfectly acceptable. Now when that same applicant is applying for his commercial pilot certificate which requires 100 hours of pilot-in-command flight time. If I use § 61.51 for guidance, then the PIC / dual flight time can be used to satisfy the 100 hours of pilot-in-command flight time requirement.

If I use § 1.1, then I must disallow the PIC / Dual flight time from the FAA Form 8710 application, which may disqualify the applicant.

I haven't had to deal with this on a practical test. But the question has arisen from an interpretation from a local flight school. Obviously the CFI's are eager to hear the REAL answer.

ANSWER: Ref. § 61.51(e)(1)(i); A rated pilot may log PIC flight time when that person “. . . is the sole manipulator of the controls of an aircraft for which the pilot is rated . . .” [See § 61.51(e)(1)(i)].

Do not confuse the PIC flight time logging requirements of § 61.51(e) with the legal definition of pilot in command in § 1.1. Look at it this way, the only time you need to be concerned with the legal definition of pilot in command in § 1.1 is when the FAA has you in court and our attorney is trying to prove in a court of law that you were the PIC. The legal definition of PIC in § 1.1 has nothing to do with the logging of PIC flight time in § 61.51(e).

As an FAA Aviation Safety Inspector (or you as a DPE), when I’m reviewing an applicant’s FAA Form 8710 1 application and logbook, the legal definition of PIC in § 1.1 has no relevance with my ascertaining whether the applicant has met the required PIC flight time to qualify for the certificate or rating. I leave the figuring out who was the legal PIC to the attorneys and judges.

So, in accordance with § 61.51(e)(1)(i), a rated pilot may log PIC flight time when that person “. . . is the sole manipulator of the controls of an aircraft for which the pilot is rated . . .” So whether the person’s flight instructor is on board or not, if that rated pilot “. . . is the sole manipulator of the controls of an aircraft for which the pilot is rated . . .” then that person may log PIC flight time.

In the case of the applicant for the Instrument – Airplane rating and the Commercial Pilot Certificate, you needn’t disallow the “logging” of PIC flight time because you’re trying to figure out whether the applicant was or was not the legal PIC. The “logging” of PIC flight time for a rated pilot is predicated only on the basis of § 61.51(e).
{Q&A-565}"

 

[mtsu_av8er]

me get this right.

Grabo, you and I can rent a 172.

I can "say" that I'm the PIC, and you can do the flying.

We can both log the flight time?

 

[SteveC]

FAR Part 61 FAQ's

When I open this is a Word document, I see 505 pages. On page 131 is the following:

QUESTION: Question about logging of pilot-in-command time. You asked whether a pilot needs to have the appropriate 14 CFR § 61.31 endorsements before he or she can properly log pilot-in-command time under 14 CFR § 61.51(e) when that pilot holds a private pilot certificate with a single-engine land rating and is receiving training in a single-engine land airplane that is also a complex or high performance airplane. Can this person log the time he or she manipulated the controls as pilot-in-command time.



ANSWER: Ref. § 61.51(e)(1)(i); § 61.51(e) governs the logging of pilot-in-command time. This section provides, in pertinent part, that a private pilot may log pilot-in-command flight time for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. (Emphasis added: “aircraft for which the pilot is rated”). The term “rated,” as used under 14 CFR § 61.51(e), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required). These ratings are listed under § 61.5 and are placed on the pilot certificate.



Therefore, based on the scenario given, a private pilot may log pilot-in-command time, in a complex or high performance airplane, for those portions of the flight when he or she is the sole manipulator of the controls because the aircraft being operated is single-engine land and the private pilot holds a single-engine land rating.



Note, while the private pilot may log this time as pilot-in-command time in accordance with § 61.51(e), he or she may not act as the pilot in command unless he or she has the appropriate endorsement as required under § 61.31. There is a distinction between acting as pilot in command and logging pilot-in-command time. In order to act as pilot in command, the pilot who has final authority and responsibility for the operation and safety of the flight, a person must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. § 61.31 requires a person to have an endorsement from an authorized instructor before he or she may act as pilot in command of certain aircraft (a complex airplane, a high performance airplane, a pressurized airplane capable of operating at high altitudes, or a tailwheel airplane). These endorsements are not required to log pilot-in-command time under § 61.51(e). In order to log pilot-in-command time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.

{Q&A-288}

 

[SteveC]

me get this right.

Grabo, you and I can rent a 172.

I can "say" that I'm the PIC, and you can do the flying.

We can both log the flight time?

No you may not. While you might be "Acting" as the PIC (per § 1.1), you may not "LOG" PIC unless you meet one of the following qualifications (per 61.51.e):

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.

(3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor.

(4) A student pilot may log pilot-in-command time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

(ii) Has a current solo flight endorsement as required under §61.87 of this part; and

(iii) Is undergoing training for a pilot certificate or rating.

I believe that there is a FAQ on the same FAA website that pertains to this. I'll go look for it for you.