PPL x-ride = PIC?

tgrayson said:
I read it and the author incorrectly summarizes his own article. Everything else seems correct, but that last sentence is unsupported by anything that comes before it. In science it's called "extrapolating beyond the data." :)
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Funny why the FAA would have that on their website then...


tgrayson said:
That regulation would hardly be needed, would it, if it were universally true that we could log as PIC any time we acted as PIC?
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Not correct... that regulation is specific to a multi-crew operation of an aircraft requiring an ATP cert... where there may be confusion as to who can log PIC due to an SIC pilot being onboard.

We are simply talking the world of general aviation and appropriately rated pilots here. A student pilot IS an apporpriately rated pilot for a Private Pilot Checkride (with an instructor sign-off stating that the instructor finds them proficient to perform in each area of operation as a private pilot)... and the Examiner is giving the full authority of PIC over to that student.

Regardless... using the ATP example above... If my Captain becomes incapacitated... and I have to fly and land the aircraft myself... guess what? Even though I am not an ATP... and even though it is a 2 person required aircraft... I can still log that time as PIC.

Bob
 
Captain_Bob said:
Funny why the FAA would have that on their website then...
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For goodness sake, the FAA has thousands of employees and not every one if them is qualified to speak for the organization. Most of them have far less knowledge of the regulations that the average member of this board.

The logging of PIC is law, and it's specified in 61.51(e). You're jumping all over the internet to avoid accepting what is clearly spelled out in that regulation.

Captain_Bob said:
I can still log that time as PIC.
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Then you're inventing your own regulations, because there is not one iota of support in 61.51(e) that allows you to log that time.
 
Alright... I'll concede to interpretation by the FAA.

I just sent the question off to them as stated:

Customer (Bob Moyer)05/02/2007 01:14 AM

During a PPL Practical Test that a student pilot has passed successfully... may that student log the checkride flight as PIC time given the examiner's authority under 61.47 to designate the student pilot as PIC? Or... is the student pilot bound to the rule of logging as noted in 61.51(e)?

In other words... is this a scenario in which a pilot is the "designated PIC" but can not log it as such?

Thank you.

Reference # 070502-000002 / Category: Pilots
Licenses and Certificates / Date Created 05/02/2007 01:14 AM / Last Updated 05/02/2007 01:14 AM / Status Unresolved
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I tried to word the question without bias... hopefully you agree.

Typically takes 1-3 weeks to get a response the last several times I've asked questions.

We'll see what happens.

Bob
 
Captain_Bob said:
Funny why the FAA would have that on their website then...
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tgrayson said:
For goodness sake, the FAA has thousands of employees and not every one if them is qualified to speak for the organization. Most of them have far less knowledge of the regulations that the average member of this board.
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tgray is right. Call the Fort Worth FSDO at 817 491 5000 and ask them this. Then call the Dallas Love FSDO and ask them this. I guarantee you will get different answers.

Guys, in the grand scheme of things, I don't think the 1.6 you put in your logbook on your checkride as PIC or not PIC will make that big of a difference. tgrayson and myself obviously are on one side, and Bob is on the other. Hopefully, the FAA will straighten it out, but until then, does it really matter?
 
:yeahthat:

Yep... I got caught up in the emotion of trying to "prove" myself right last night... but... I may not be. ;)

We'll get the clarification and see where it goes from there.

Bob
 
Captain_Bob said:
I tried to word the question without bias... hopefully you agree.
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Yes, I think you worded the question well.

Captain_Bob said:
Alright... I'll concede to interpretation by the FAA.
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I would grant the General Counsel's Office a limited right to "reinterpret" the regulation to allow the logging of this time, but it's not clear to me to whom your question is being sent, their expertise in interpreting the regulation, or their authority to do so. The Part 61 FAQ's made some errors in interpretation that had to be corrected by the General Counsel's Office. Even the General Counsel's Office hasn't always had a stellar performance. :rolleyes: Were they to say the time was loggable, it would be a significant deviation from the general thrust of all their earlier interpretations.

My own experience in getting answers from low-level FAA employees is that I have to spend time educating them before they can even understand the question I'm asking. If successful, then I can usually persuade them to pass me on to someone more knowledgeable, where the process repeats itself. Funny, but the chain only ends when I'm passed to someone outside the FAA. :)

That's why you did well to point out the pertinent regulations to the recipient of your email; at least they know how to start thinking about the question.
 
I can't believe it - an argument about one of the very few true holes in the FAR logging rules - the common - probably almost universal - practice of stuident pilots logging PIC during the private checkride.

61.47(c) takes care of the authority of the student pilot to act as PIC with the Examiner on board, but 61.51 (the universal rule of logging) indeed says nothing to give the student pilot authority to =log= it as PIC. You can come up with all sorts of creative arguments to try to twist 61.51 to say that it does authorizing the logging. If pressed, the FAA may even accept one of them (heck there are more than one legal logging scenario where the language of FAR 61.51 doesn't =really= authorize logging - the FAA's interpretation of it does).

Nevertheless, it is the common practice to do so. The FAA has pretty much gone along with it for decades, and there's no evidence to suggest that it's about to go after thousand of pilots to "flasifying" their logbooks on their private checkrides.

But it is pretty funny to watch. :D
 
Hmm, I wonder. . .

My examiner did my logbook entry for my PP checkride, and you know what. . . he put piloting time as PIC.

:insane:
 
BTW, that guy at the FAA who wrote that nonsense?

It was nice of him to make some of the other parts of 61.51 completely unnecessary. After all, why do you even need a regulation to say that the PIC on a flight that requires more than one pilot may log PIC if the PIC can log PIC regardless of whether the flight requires more than one pilot or not?

Too bad he wasn't available for the two CFIs who pretended to give eich other instruction so they could take advantage of the rules allowing dual logging by the "sole manipulator" and the instriuctor giving instruction and had had al of their certificates and ratings revoked for logbook falsification. After all, according to him all they =really= had to say was that the not-flying pilot was the PIC, right? he could have been their defense expert.

I like his rule. two private pilots go up in a CE-152. One is designated as PIC. The other does all the flying, and they both get to log it!! No silly safety pilot issues. just go up with a buddy and both log it! Cool!! Now =that's= time building!!
 
MidlifeFlyer said:
Nevertheless, it is the common practice to do so. The FAA has pretty much gone along with it for decades, and there's no evidence to suggest that it's about to go after thousand of pilots to "flasifying" their logbooks on their private checkrides.
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Yup, I never even thought about it (as far as I remember) until this thread started. But given how so few people understanding logging vs acting, it shouldn't be surprising that the practice has gone unchallenged, so I wouldn't put much stock in the significance of the FAA going along with it; it probably hasn't come to the attention of anyone who understands the issue. Still, it's only about 1.5 or so for the private, and maybe an equivalent for a ME checkride, so it doesn't amount to much time.
 
I don't even think it's a matter of understadning or not. I think it's more a matter of either not caring or simple acceptance of the practice. I would be very surprised if, if FAA Legal ever botherd to look at it, came down with an opinion that didn't support the practice.

Most of this is a matter of interpretation than a required reading of the regulatory language. I have to laugh sometimes about posts that chide someone because they don't understand somehting that is "clearly" in 61.51 when, unless you already knew the way FAA Legal interpreted it, it wouldn't be very clear at all.

The sole manipulator clause of 61.51(e) is a great example:

==============================
A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person

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

What is clear under that section is that being the sole manipulator of the controls or an aircraft you have the proper ratings for is a =required= condition to log PIC. But I really don't see where it says that being the sole manipultor is a =sufficient= condition.

Unless of course, one thinks the sign on the supermarket door that says

"Only persons with shirts and shoes may enter"

means that it's perfectly fine to enter without pants.

Want to have some fun? The combination of 61.51(e)(1)(iii) and 91.109 doesn't =really= authorize a safety pilot to log PIC. (Of course they do - FAA Legal says so, but the reasoning behind it doesn't stand up to much scrutiny)
 
Whoa! Beep, beep, beep, beep....back that truck up, Mark! Don't you be bringing no logic type stuff into an FAA discussion, you hear?

Sheesh. Coulda had a train wreck...




:bandit:
 
Captain_Bob said:
:yeahthat:

Yep... I got caught up in the emotion of trying to "prove" myself right last night... but... I may not be. ;)

We'll get the clarification and see where it goes from there.

Bob
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No matter if you are right or not, Bob, it takes a real man to back off and admit that you were trying to prove yourself right. Mucho kidos to you man....MAD MAD respect. :)
 
MidlifeFlyer said:
I would be very surprised if, if FAA Legal ever bothered to look at it, came down with an opinion that didn't support the practice.
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They could not support it without creating a new right that could have other ramifications, not to mention undermining all of their previous analyses about logging issues.
 
SteveC said:
Whoa! Beep, beep, beep, beep....back that truck up, Mark! Don't you be bringing no logic type stuff into an FAA discussion, you hear?
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Actually, I think there is a weird sort of logic that gets followed, and always thought of the statement that there is one as an excuse for not understanding what is going on.

Then again, my brain has been know to follow some strange pathways also. ;)
 
tgrayson said:
They could not support it without creating a new right that could have other ramifications, not to mention undermining all of their previous analyses about logging issues.
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The checkride already has a 15-gazillion hour pilot-examiner on board who we all know is really in charge but who we pretend is just a passenger. Oh yeah, that's right. We also pretend he's not even a real passenger.

In this context, you're worried about a little logic-twisting to let the private pilot applicant log one of the most important flights of his life?

I think they'd find it real easy.
 
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