Tailwheel endorsement

[OldTownPilot]

I love it when people are bickering and/or worrying about 5 hours of single engine PIC time.

Like it matters.

 

[tprops4me]

I love it when people are bickering and/or worrying about 5 hours of single engine PIC time.

Like it matters.

Then feel free to find another thread. How much PIC time do you have anyway?

 

[Berkut]

Just curious, is there anything less than almost 30 years old on this subject?

While John Lynch's old part 61 FAQ was not a legal interpretation, he did in fact quote legal interpretations in his answers. Here is one of those legal interpretations he quoted in his FAQ:

QUESTION: Thank you for your letter dated April 20, 1999, to the Office of the Chief Counsel, Federal Aviation
Administration (FAA), regarding the logging of pilot-in-command time. Specifically, 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); Before discussing this issue, please note that the Frequently Asked Questions –
Part 61 & 141 (FAQ’s) are provided by the Flight Standards Service (AFS) for standardization purposes. The
Office of the Chief Counsel does not review the FAQ’s and accordingly, information provided on his website is not
legally binding. Title 14 CFR § 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 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). 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 14 CFR § 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 14 CFR § 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 14
CFR § 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.
Title 14 CFR § 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 14 CFR § 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.

That's from the Office of the Chief Counsel, as quoted in the old part 61 faq.

 

[Hacker15e]

I love it when people are bickering and/or worrying about 5 hours of single engine PIC time.

Like it matters.

Shack.

Then feel free to find another thread. How much PIC time do you have anyway?

What difference does it make?

If you don't have very much time, then the fact that people are saying that 5-10 hours is meaningless should be something to pay attention to.

If you do have a bunch of time, then you should all ready understand that.

 

[OldTownPilot]

Then feel free to find another thread. How much PIC time do you have anyway?

Probably less than you.

 

[ctab5060X]

We are saying the same things here. He can not "ACT" as PIC, but he can log PIC through "manipulating the flight controls" if he is rated in category and class. That is how students with a PPL ASEL can log PIC in a C-172 while receiving flight instruction from an instructor rated in ASEL that is also logging PIC.

A PPL ASEL does not have to have any endorsement for flying a plain old C-172 so regardless he can act as PIC even with and instructor on board. So, to me, this is irrelevant.

Now, I'm not saying it is smart or this is what he should do, just pointing it out that he can.

You are correct. It is not smart. Just because you can do something, doesn't mean that you should.

Not necessarily. When you are flying under IFR for your instrument rating with an instructor, you aren't allowed to ACT as PIC, but you can still LOG PIC, per the reference I listed above. This could be a significant amount of flight time.

Let me see here...from the way that is worded, I gather you are logging PIC while in actual (no reference to view limiting device) without and instrument rating?? That is bending the regulations to the extreme. I can see this under simulated, but not actual.

Also, safety pilot time is done the same way. If both safety pilots are rated in the aircraft, one pilot agrees to ACT as the PIC, while one is the sole manipulator under 61.51. Both can log PIC.

For me, this is the reason that 61.51 exists with the sole manipulator clause...not so someone can log PIC when they can't act as pic. In a safety pilot situation, both pilots must be capable of legally acting as PIC.


Again, just because you can do something doesn't mean that you should do something.

 

[CoffeeIcePapers]

...
Let me see here...from the way that is worded, I gather you are logging PIC while in actual (no reference to view limiting device) without and instrument rating?? That is bending the regulations to the extreme. I can see this under simulated, but not actual.

...

What reg, exactly, would you be "bending to the extreme?" The instructor is ACTING as the PIC of the IFR flight, while the PPL student may still LOG PIC, under 61.51

Again, just because you can do something doesn't mean that you should do something.

The original question was "can I legally log this tailwheel time as PIC?"

The answer, per 61.51, as quoted above, is a resounding YES. The reg specifcally addresses this and says that you MAY log the time as PIC. Again, do with your logbook what you will, but 61.51, which again, is the ONLY reg that deals with PILOT LOGBOOKS, says that you MAY do so.

 

[tprops4me]

Shack.



What difference does it make?

If you don't have very much time, then the fact that people are saying that 5-10 hours is meaningless should be something to pay attention to.

If you do have a bunch of time, then you should all ready understand that.

.

Hacker, the reason I told him to go find another thread was because the topic of this thread was to determine the how to log the time. It had nothing to do with the hours involved to get the signoff. It was a learning experience for me. I thought you could not. Turns out legally you can. All old town pilot was doing was repeating what you said in an earlier post. If not interested in what was been said here, then there are plenty of threads that may suit him better. Calling him out on his hours was wrong, and I posted angry. Sorry Old Town Pilot. I am not a high time veteran, so to act like one is wrong. Anyway, I just feel that if we want to hash out this thread thats our choice.

 

[ctab5060X]

What reg, exactly, would you be "bending to the extreme?" The instructor is ACTING as the PIC of the IFR flight, while the PPL student may still LOG PIC, under 61.51

Since there was no clarification as to whether or not the flight was in actual, I will still consider that you are logging PIC in actual conditions without an instrument rating. You can't...

CFR 14 Part 61
Section 61.51(e)(1)

(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;

Now, if we are talking simulated instrument conditions, then yes, you can log it as PIC (consider the instructor a safety pilot) as you are both appropriately rated in the aircraft.

As far as the OP question. Yes, you can log it as PIC, but it does not mean that you should log it as PIC. It is still my opinion that if you can not act as PIC, then you should not log it as PIC. Just keep this in mind...if tough questions about your PIC time come up, you might want to have more than... "well 61.51 said I could" in your answer.

 

[Nihon_Ni]

More fuel for the fire!

You are rated for the a/c, ASEL, therefore you can log PIC through the "manipulating the flight controls" but not through "ACT"ing PIC. Either way, if you are receiving instruction you can log PIC with an instructor on board. However, if you don't have the endorsement, you can not go solo in the tailwheel.

FWIW, you don't even have to have a CFI on board. If I go flying in my buddy's RV and he has a TW endorsement and I don't, and he let's me be the sole manipulator of the flight controls for any portion of the flight, I may log it as PIC.

Let's not forget that 61.51 says may because I don't have to log all of my flight time. I only have to log:

Section 61.51 Pilot Logbooks.
(a) Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:
(1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.
(2) The aeronautical experience required for meeting the recent flight experience requirements of this part.

For example, if I don't intend to carry passengers or change ratings and only fly VFR, then I only need to log one flight every 24 months. (My flight review) All other flight time I may log.

 

[OldTownPilot]

As far as the OP question. Yes, you can log it as PIC, but it does not mean that you should log it as PIC. It is still my opinion that if you can not act as PIC, then you should not log it as PIC. Just keep this in mind...if tough questions about your PIC time come up, you might want to have more than... "well 61.51 said I could" in your answer.

That is exactly how I have kept my logbook.

Story time: Had a guy that had 100 hours of "multi PIC" from CASW listed as his employer apply for a scenic pilot position. Asked him how he has "multi PIC" flying for a Part 135 company, when he could not be PIC of the flight. He didn't even have 500 hours to be a 135 VFR PIC. He didn't seem to be the brightest one in the bunch for other reasons too and didn't get the job, it wasn't just from how he logged his time, but the whole CASW SIC program is a sham.

Tailwheel flying is freaking cool, and everyone should fly one for a bit at some point.

 

[ctab5060X]

That is exactly how I have kept my logbook.

Story time: Had a guy that had 100 hours of "multi PIC" from CASW listed as his employer apply for a scenic pilot position. Asked him how he has "multi PIC" flying for a Part 135 company, when he could not be PIC of the flight. He didn't even have 500 hours to be a 135 VFR PIC. He didn't seem to be the brightest one in the bunch for other reasons too and didn't get the job, it wasn't just from how he logged his time, but the whole CASW SIC program is a sham.

The manner in which it was conceived was a good idea, but the way it has become lately, it makes me wonder sometimes. Let's face it...today it is nothing more than PTF (even though it works out cheaper per hour than renting sometimes). Some of the SICs I have seen come through training lately only makes me shake my head.

Tailwheel flying is freaking cool

I'll drink to that!

 

[BenWlson]

Tailwheel flying is freaking cool, and everyone should fly one for a bit at some point.

:yeahthat::yeahthat::yeahthat:

 

[Berkut]

Since there was no clarification as to whether or not the flight was in actual, I will still consider that you are logging PIC in actual conditions without an instrument rating. You can't...

These interpretations are getting a workout today.

October 30, l992


Mr. David M. Reid


Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the
logging of pilot-in-command (PIC) time under the Federal Aviation
Regulations (FAR).

In your letter you ask four questions. First, you ask whether
there are "any circumstances when, during a normal flight, two
Private Pilots may simultaneously act as (and therefore log the
time as) Pilot-In-Command?" The answer is two private pilots may
not simultaneously act as PIC but they may, under certain
circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC
time. PIC, as defined in FAR 1.1, means the pilot responsible
for the operation and safety of an aircraft during flight time.
FAR 61.51 deals with logging PIC flight time, and it provides
that a private or commercial pilot may log as PIC time only that
flight time during which he is the sole manipulator of the
controls of an aircraft for which he is rated, or when he is the
sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR 61.51 only
regulates the recording of PIC time used to meet the requirements
toward a higher certificate, higher rating, or for recent flight
experience.

Therefore, while it is not possible for two pilots to act as PIC
simultaneously, it is possible for two pilots to log PIC flight
time simultaneously. PIC flight time may be logged by both the
PIC responsible for the operation and safety of the aircraft
during flight time in accordance with FAR 1.1, and by the pilot
who acts as the sole manipulator of the controls of the aircraft
for which the pilot is rated under FAR 61.51. Enclosed please
find two prior FAA interpretations concerning logging of PIC
time. We hope that these will be of further assistance to you.




2


In your second question you ask "[h]ow shall two Private Pilots
log their flight time when one pilot is under the hood for
simulated instrument time and the other pilot acts as safety
pilot?" The answer is the pilot who is under the hood may log
PIC time for that flight time in which he is the sole manipulator
of the controls of the aircraft, provided he is rated for that
aircraft. The appropriately rated safety pilot may concurrently
log as second in command (SIC) that time during which he is
acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight
that the safety pilot will be the PIC responsible for the
operation and safety of the aircraft during the flight. If this
is done, then the safety pilot may log all the flight time as PIC
time in accordance with FAR 1.1 and the pilot under the hood may
log, concurrently, all of the flight time during which he is the
sole manipulator of the controls as PIC time in accordance with
FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
interpretation concerning the logging of flight time under
simulated instrument flight conditions. We hope that this
interpretation will be of further assistance to you.

In your third question you ask "during instrument training, how shall a VFR Private Pilot log the following flight time: Pilot-In-Command time, Simulated Instrument time, and Actual Instrument
time, when that pilot is...A)...under the hood? B)...in actual
instrument conditions? C)...under the hood in actual instrument
conditions?" The answer is the VFR private pilot may log all of
the flight time you described as PIC flight time under FAR
61.51(c)(2)(i) if he was the sole manipulator of the controls of
an aircraft for which he is rated. Under FAR 61.51(c)(4) the
pilot may log as instrument flight time only that time during
which he operates the aircraft solely by reference to
instruments, under actual or simulated instrument flight
conditions. Please note that the FARs do not distinguish between
"actual" and "simulated" instrument flight time. Enclosed is a
prior FAA interpretation concerning the logging of instrument
flight time. We hope this interpretation will further assist
you.

Finally you ask "[d]oes FAR 61.57 affect how the VFR Private
Pilot shall log Pilot-In-Command time during instrument training,
either before or after meeting the 6/6/6 requirement, and if so,
how?" FAR 61.57 does not affect how a pilot logs PIC time during
instrument training; FAR 61.51(c)(2) and
(4) govern logging of instrument flight time. FAR 61.57(e)
provides currency requirements for acting as PIC under instrument
flight rules (IFR) or in weather conditions less than the
minimums for visual flight rules (VFR). Enclosed




3


please find a prior FAA interpretation on instrument flight time
and FAR 61.57(e). We hope this interpretation will further
assist you.

We hope this satisfactorily answers your questions.

Sincerely,



Donald P. Byrne
Assistant Chief Counsel Regulations Division

 

[Hacker15e]

Also, don't forget (since this is "Jetcareers") --

The airlines don't want to see "sole manipulator" PIC time at the interview...they want to see "authorized to be the PIC" time.

heh heh

 

[ctab5060X]

These interpretations are getting a workout today.

Question time...

According to this "interpretation" you can log PIC (sole manipulator) while conducting IFR training in less than VFR conditions...not the smartest thing in the world, but...61.51 says that you can only do this for an aircraft for which you are rated or have privileges. I would think that "is rated or have privileges" would mean that you would need an instrument rating in order to log "sole manipulator" PIC per 61.51 in this scenario.

Based on this interpretation of logging PIC in IFR conditions (less than VFR) while not instrument rated leads to the thought that one can log PIC in a multi engine aircraft without a multi rating, no?

Curious as they are both dealing with ratings (i.e. checkride required) needed to act as PIC...

 

[sopdan]

How 'bout this one....

I have 63 hours of PIC (legit PIC by ANY standard) in a tailwheel aircraft, but no tailwheel endorsement. How is that possible?

I'm just wondering how long it'll take for somebody here to figure it out...

(and I'm leaving on a 4-day trip tomorrow, so forgive me if I'm not back on here for a little while)

 

[Berkut]

I would think that "is rated or have privileges" would mean that you would need an instrument rating in order to log "sole manipulator" PIC per 61.51 in this scenario.

The "interpretation" does not agree with your assessment.

Based on this interpretation of logging PIC in IFR conditions (less than VFR) while not instrument rated leads to the thought that one can log PIC in a multi engine aircraft without a multi rating, no?

No, because you are not sole manipulator of the controls of an aircraft for which you are rated.

Curious as they are both dealing with ratings (i.e. checkride required) needed to act as PIC...

Remember, we're not talking about acting as pic, only logging. If you are flying along in an "airplane, single engine land" it does not change into something other than an "airplane, single engine land" just because it enters a cloud.

 

[Berkut]

I have 63 hours of PIC (legit PIC by ANY standard) in a tailwheel aircraft, but no tailwheel endorsement. How is that possible?

I would imagine you either:
A) flew that time before an endorsement was required, or
B) have a type rating in a tailwheel aircraft, in which case we're all jealous.

 

[Nihon_Ni]

I would imagine you either:
A) flew that time before an endorsement was required, or
B) have a type rating in a tailwheel aircraft, in which case we're all jealous.

or
C) It's not really legit PIC time and you're hoping the FAA never finds out you've been flying an airplane you're not supposed to, unless you have a different definition of the word "unless."


(i) Additional training required for operating tailwheel airplanes. (1) Except as provided in paragraph (i)(2) of this section, no person may act as pilot in command of a tailwheel airplane unless that person has received and logged flight training from an authorized instructor in a tailwheel airplane and received an endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane.