Logging question - Piper Dakota
- Thread starter WindyCityPilot
- Start date
GaTechKid
Well-Known Member
Bob - You're seriously cheating your student out of legally loggable PIC time. I'd be pretty ticked if I found out my instructor had cost me a lot of money based on their interpretation of a black and white regulation, an interpretation that has been consistently proven as incorrect by the FAA themselves. It seems that you're using what the regional airlines require to support your unfounded paranoia.
MidlifeFlyer
Well-Known Member
Unfortunately, FAA Legal doesn't post their formal opinions on the Internet. If you want, you can confirm this by finding a law library that carries the $495 collection that lawyers use to research FAA legal issues, but here is the earliest of the:bob loblaw said:
==============================
OCT. 28, 1980
WINSTON SCOTT JONES
Dear Mr. Jones:
This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.
Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.
Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.
Section 61.51(c)(2)(I) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--
1. Is the sole manipulator of the controls of an aircraft for which he is rated; or
2. Is the sole occupant of the aircraft; or
3. Acts 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.
Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received.
Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(I) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).
There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.
You request interpretations of these regulations for situations in which:
1. The purpose of the flight is instruction in advanced maneuvers.
2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.
3. The purpose of the flight is instrument instruction actual IFR conditions.
4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.
5. The purpose of the flight is transition from tricycle to conventional landing gear.
6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).
7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.
In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.
We trust that this discussion answers your questions.
Sincerely,
EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division
==============================
mtsu_av8er
Well-Known Member
SteveC said:
Which is exactly my point, and it brings us back to the original question . . .
WindyCityPilot stated that there was no instructor in the aircraft, and that nobody was doing instrument training.
I'm not sure how everybody is twisting the regs around, but I'd still say he can't log that time.
Let me re-phrase that - he can log what he wants . . .
mtsu_av8er said:
But your question was not the same as the original question.
The original question (can he log PIC for time at the controls of the Dakota) is answered very plainly - Yes He Can.
I'll (re-re-re) quote the pertinent section from the FAQ I quoted above:
Lloyd, I think you're just yanking chains now. A left-handed Kingairism, if you will.
MidlifeFlyer
Well-Known Member
61.51(3)(1):mtsu_av8er said:
==============================
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;
==============================
Pretty clear English sentence. Where's the twisting?
The FAA has repeatedly said that "rated" means the aircraft ratings that appear on the back of the pilot certificate. An endorsement in a logbook is not an aircraft rating.
Of course, those that won't believe will, well, just continue not to believe and will search for "reasons."
(BTW, "or has privileges" is a recent amendment which was done for the sport pilot rule because sport pilots don't have ratings in =any= aircraft. Instead, they have "prvileges" in specific aircraft.)
bob loblaw
New Member
Based on the word document, I have concluded that I will now change my position on this subject. I will now allow private pilots to log PIC when training for the HP endoresment. I can see that I was wrong. Thank you to the people who posted exactly what I was looking for.
Grabo172
Well-Known Member
mtsu_av8er said:
Never said BOTH of them in the original question could log PIC at the same time.
In the situation where 2 private pilots (or you and I Lloyd) are in a 172 we can log the flight time that we are actually at the controls, no matter who is the PIC. The other, no matter who is acting PIC, cannot log it as PIC time when NOT the Sole Manipulator.
Unless, the other person is a CFI doing flight training. Now, if you were giving a Fight Review to me in a 172, Lloyd, and I was the Sole Manipulator the entrie time, yes we can both log it as PIC, and as the CFI you are the Acting PIC.
Same thing goes for the HP endorsement or the Dakota question. If you are flying in a buddy's 182, both of you private pilots, your buddy has a HP endorsement and you do not. Any time you are flying the plane as the Sole Manipulator, you can log that time as PIC time in your log book. Your buddy however, is the ACTING PIC for the entire flight, but may only log the PIC time the he is at the controls...
That's the answer to the original question, but since about the 4th post we've been trying to get Bob to see he's been mislogging his students for HP/Complex endorsements...
skydog
New Member
Let us not forget 91.3. Were you directly responsible for, and the final authority of, the operation of that aircraft?
Put it another way: If the engine had quit while you were flying, would you have retained control, or would the owner have taken over?
I'm guessing you were along for the ride and managed to do a little "sole manipulating of the controls" while you were there.
Don't log it.
Put it another way: If the engine had quit while you were flying, would you have retained control, or would the owner have taken over?
I'm guessing you were along for the ride and managed to do a little "sole manipulating of the controls" while you were there.
Don't log it.
Grabo172
Well-Known Member
skydog said:
AHHHHHHHHHH!
:banghead: :banghead: :banghead:
Doesn't matter who takes the controls, the owner is the Legal PIC and the final authority.
AND LOG IT if you are the sole manipulator in an aircraft in which you are RATED (catogory and class, (Type rating if the aircraft requires a type rating))
You know what, log what you all want. I'm losing the little amount of hair I have left with this thread. It's a simple concept taken WAY out of control. For us Nukes we call it "Nuking it out", in other words, don't read into what isn't there.
bob loblaw
New Member
Grabo172 said:
You guys need to understand the logic behind doing what I was doing. Because of Up to now, I have not seen an official position the FAA takes on this question. Without knowing their interpretation, I chose to log conservatively which kept me out of trouble. We also are talking about an hours worth of time. One hour won't make or break a pilot when you are talking about the level a pilot should be at to even consider going for a HP sign-off. In logging the way I did not violate any regulations. But again my position on the subject was wrong and as such has been adjusted. Some people have a hard time admitting when they are wrong, I do not.
mtsu_av8er
Well-Known Member
I've already lost all mine, brother!:buck:
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That doesn't matter as far as being able to LOG the PIC time. 61.51 is the ONLY thing that matters when asking the question if you can LOG PIC. The other regulations are all about who is in charge (ACTING PIC), but has NOTHING to do with what you put down in your logbook.
If he did give up control, then he would log PIC up until the time that he gave control of the plane back over to the owner. The owner would log PIC for the time that he had his hands on the controls of the plane ONLY, even though he was ACTING PIC (according to 1.1) during the whole flight.
During the time that he was the only one with his hands on the controls he is the only one that can log PIC (in the scenario as presented).
Log it.
Go back and read the FAA's FAQs above. They are very clear and unambiguous.
WindyCityPilot
Well-Known Member
Wow....sorry to have opened that can of worms!!! 
Thanks to everyone for their input. Like was stated in the posts above it's only an hour of time and I'll be scheduling my HP endorsement within the next week or so in my FBO's 182T. Not really worried about that hour...I was just curious about was was legal to log. So we can all stop beating the horse...it's been dead a long time! Thanks again!
Thanks to everyone for their input. Like was stated in the posts above it's only an hour of time and I'll be scheduling my HP endorsement within the next week or so in my FBO's 182T. Not really worried about that hour...I was just curious about was was legal to log. So we can all stop beating the horse...it's been dead a long time! Thanks again!
Grabo172 said:
So let me get this straight. Let's say I were onboard the space shuttle (no type rating). And during re-entry, I was seated in the left seat, the pilot was in the right seat, but the aircraft commander was in the cargo bay. I was working the roll and pitch, and the pilot was managing the speed from the right seat.....however, mission control was overall managing our entire re-entry. Could I log PIC?
Grabo172
Well-Known Member
MikeD said:So let me get this straight. Let's say I were onboard the space shuttle (no type rating). And during re-entry, I was seated in the left seat, the pilot was in the right seat, but the aircraft commander was in the cargo bay. I was working the roll and pitch, and the pilot was managing the speed from the right seat.....however, mission control was overall managing our entire re-entry. Could I log PIC?
Sure!
MidlifeFlyer
Well-Known Member
I'd definitely put in in my "cool stuff-not countable" column!MikeD said:So let me get this straight. Let's say I were onboard the space shuttle (no type rating). And during re-entry, I was seated in the left seat, the pilot was in the right seat, but the aircraft commander was in the cargo bay. I was working the roll and pitch, and the pilot was managing the speed from the right seat.....however, mission control was overall managing our entire re-entry. Could I log PIC?