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Loging PIC?

Question:

Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong.

Please provide a citation of the FARs which permits you to log PIC time when acting as PIC except where required by regs or type certificate. The instructor reference in 61.51 has nothing to do with acting as PIC or not — it has to do with instructing. — Reece R. Pollack CP-ASMEL-IA — N1707H Piper Arrow III (based KGAI)

Response:

Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong.

I hate to argue with "the man", but what regulatory or legal opinion is this based on.  It is contrary to both how 61.51 reads and the letters we have from the FAA Legal Counsel.

Response:

Acting as PIC is never good enough in itself to log PIC time. Wrong.

Actually, Ron is quite right. There is no regulation that says that the person acting as PIC may log PIC. Here’s one scenario. You and another pilot get together for a trip. You are the more experienced and the two of you agree that you will be in command of the flight. (This is actually a good idea — in case of an emergency, there’s not doubt who has the right to take over). You ARE PIC, and if there’s a problem with the flight (and assuming, of course, that the prior agreement is disclosed to the FAA), YOU will be held responsible. But if your friend flies the whole flight, ONLY she will be able to log PIC. Another, very wield, scenario: You and a friend who is a student pilot go flying together. You let her fly the whole flight — takeoff, landing, the works. You ARE clearly PIC. NO ONE get to log PIC!     (o)/       Denver, Colorado     o O o       www.midlifeflight.com       replace "spamaway" with "mlf" for email

Response:

I logged 9 hours of actual before I got the rating. My instructor believed in real-world experience where possible, so we looked for weather with some reduced vis, but not unflyable (no convective stuff or ice forecast). His opinion (mine too) was that it’s a bad idea to pass instrument candidates who have never been inside a cloud. David Fielding – Hide quoted text — Show quoted text – When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? Francisco Murillo N55260

Response:

Aditionaly, if you’re doing some JFK flying without a IFR flight plan (let’s say 5 miles visibility, over a lake, ocean or anywhere you don’t have a reliable horizon, and you have to fly the gauges), you can log actual instrument time without being in legal IMC. I’m not sugesting it’s smart doing that, but that doing it is not illegal and you can log it without problems, I would just be sure to keep notes on the logbook so you can explain what’s going on. Marcelo – Hide quoted text — Show quoted text – When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? You’re new instructor is crocked.  You can log actual time anytime you fly the aircraft solely by reference to the instruments in actual instrument conditions.  Margy had a couple of hours of actual prior to getting her private. You can log PIC time as a private pilot whenever you are the sole manipulator of the controls of an aircraft for which you are rated.  It makes no difference if you were actually the pilot in command or not. What this poor soul is confused over is that you could not legally be PIC under IFR (really actual has nothing to do with it except it implies you had better have been operating under IFR) and thus your instructor had to have been the pilot in command.  However this is unrelated to the logging issue.

Response:

Exception…most airlines only will consider PIC as defined by Part 1. Paul – Hide quoted text — Show quoted text -You cannot ACT as PIC in an a/c under IMC until you have the instrument rating, but you certainly can LOG PIC time per 61.51.

Response:

Francisco, You should ask the chief instructor what FAR he was based that makes an exception, as if the logbook has a column for actual IMC, and you were in actual IMC, it’s only obvious you can and must log that time as actual instrument conditions (isn’t that what IMC means). Instrument conditions means conditions where you have to fly by reference to your instruments. There might be technically 10+ miles visibility, clear skyes, but due to lack of a useable horizon, you have to use your instruments. You don’t need to me IFR rated to fly on such conditions. Let’s say, crossing lake michigan, with 20 miles visibility. Let’s say flying a long range capable plane over open waters in VFR while without any useable horizon. Now somebody from the FAA could possibily come out and say: If you can’t see anything, then you where not VFR, hence you need an IFR rating, which doesn’t seem to be correct. Francisco, it’s all a matter of how this guy’s interpreting the FARs. I believe he’s wrong. I heard many pilots say this doesn’t make sense, and that you could log actual IMC time. I would log it myself, and defend with the question I gave you. Marcelo Pacheco – Hide quoted text — Show quoted text – When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? Francisco Murillo N55260

Response:

Maybe all this is why there’s a big move up north (Canada) to have the designations PF (Pilot Flying) and PNF (Pilot Not Flying) in addition to PIC, SIC, and Dual logging requirements. It’s gonna be messy.

– Hide quoted text — Show quoted text – Acting as PIC is never good enough in itself to log PIC time. Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong. I hate to argue with "the man", but what regulatory or legal opinion is this based on.  It is contrary to both how 61.51 reads and the letters we have from the FAA Legal Counsel. Here is my interpretation of what was written.  I think if you all go back and read this again carefully, you will see you are all agreeing. First: 61.51(e)(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. This says that for atp operationss, the atp ACTING as pic can log pic. So, the last part of the statement that said   _or in the case of ATP ops_   is true. Now look at 61.51(e)(1) – A recreational, private, or commercial pilot may log pilot-in-command time only that flight time during which that person — (ii) 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 certificate of the aircraft or the regulation under which the flight is conducted. This says that if the reg or type cert. requires more than on pilot, the pilot ACTING as PIC can log PIC. In both cases, ATP ops, and multipilot operation (required by regs or type certificate) will allow a pilot to log PIC just because they are ACTING PIC. So, let’s look at that statement again: Acting as PIC is never good enough in itself to log PIC time. You all have said this is true.  The reg for acting PIC and logging PIC are different Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) This seems true too according to 61.51(e)(1)(ii) as showm above. or in the case of ATP ops.<< This seems true according to 61.51(e)(2) So it seems to me that the statement really is true. Maurice Givens CFI-AI, IGI, AGI

Response:

Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong. I hate to argue with "the man", but what regulatory or legal opinion is this based on.  It is contrary to both how 61.51 reads and the letters we have from the FAA Legal Counsel.

Actually, the letters from the FAA is one of the reasons that Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate)

is accepted.  This is what allows the safety pilot to log PIC if the safety pilot is ACTING as PIC. This is  _acting as PIC in a multipilot operation required by regs or type certificate_

Response:

Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong. I hate to argue with "the man", but what regulatory or legal opinion is this based on.  It is contrary to both how 61.51 reads and the letters we have from the FAA Legal Counsel.

Here is my interpretation of what was written.  I think if you all go back and read this again carefully, you will see you are all agreeing. First: 61.51(e)(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. This says that for atp operationss, the atp ACTING as pic can log pic. So, the last part of the statement that said   _or in the case of ATP ops_   is true. Now look at 61.51(e)(1) – A recreational, private, or commercial pilot may log pilot-in-command time only that flight time during which that person — (ii) 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 certificate of the aircraft or the regulation under which the flight is conducted. This says that if the reg or type cert. requires more than on pilot, the pilot ACTING as PIC can log PIC. In both cases, ATP ops, and multipilot operation (required by regs or type certificate) will allow a pilot to log PIC just because they are ACTING PIC. So, let’s look at that statement again: Acting as PIC is never good enough in itself to log PIC time.  

You all have said this is true.  The reg for acting PIC and logging PIC are different Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate)

This seems true too according to 61.51(e)(1)(ii) as showm above. or in the case of ATP ops.<<

This seems true according to 61.51(e)(2) So it seems to me that the statement really is true. Maurice Givens CFI-AI, IGI, AGI

Response:

I don’t know what you mean by logging "actual" PIC. If you are rated in the a/c, (category, class and if required, type), then you can log PIC whenever you are sole manipulator of the controls. Including in IMC even if you do not have an instrument rating. You cannot ACT as PIC in an a/c under IMC until you have the instrument rating, but you certainly can LOG PIC time per 61.51. –ron

– Hide quoted text — Show quoted text – When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? Francisco Murillo N55260

Response:

Acting as PIC is never good enough in itself to log PIC time.  Acting

as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops.<< Wrong. The instructor can log PIC time because 61.51(e)(3) says:

Right. — Best Regards Rick Cremer

– Hide quoted text — Show quoted text – One who is manipulating the controls and the one who is responsible for the safety of the flight (the acting PIC). Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops. The instructor can log PIC time because 61.51(e)(3) says:    An authorized instructor may log as pilot-in-command time all flight time    while acting as an authorized instructor. He need not be acting as PIC.

Response:

So how does this breakout? My CFII logged as PIC when we were in actual, I logged as PIC in hood and VFR. Is this the what you are suggesting?

It breaks out like this… (For your scenario only) Your CFII logs time as instruction given as well as PIC. You log as PIC any time you’ve spent as sole manipulator of the controls, while appropriately certificated and rated, regardless of flight environment. …just like the regs say. Safe flights, John John Williams http://users.ev1.net/~jwwda50

Response:

One who is manipulating the controls and the one who is responsible for the safety of the flight (the acting PIC).

Acting as PIC is never good enough in itself to log PIC time.  Acting as PIC only is considered if it is a multipilot operation (required by regs or type certificate) or in the case of ATP ops. The instructor can log PIC time because 61.51(e)(3) says:    An authorized instructor may log as pilot-in-command time all flight time    while acting as an authorized instructor. He need not be acting as PIC.

Response:

BOTH the pilot manipulating the controls on and aircraft for which the pilot is rated *AND* the CFI may log PIC time (simultaneously). In other words two pilots can be logging PIC time at the same time. One who is manipulating the controls and the one who is responsible for the safety of the flight (the acting PIC). That scenario can happen in a couple of ways. The CFI teaching a rated pilot is one. A person acting as a safety pilot under FAR 91 is another. This subject has been clarified by the FAA many times in writing and is in the Part 61 FAQs on their web site. The FAA will tell you that there is a difference between Logging PIC time and Acting as PIC and that each can be done at the same time on the same flight. — Best Regards Rick Cremer FAA Safety Inspector (Operations and Airworthiness) ATP DC-9/MD-80 CFI Grd. Inst. Acft. Disp. A&P Mech. Air Traffic Controller

– Hide quoted text — Show quoted text – So how does this breakout? My CFII logged as PIC when we were in actual, I logged as PIC in hood and VFR. Is this the what you are suggesting? One can log as pic because he IS the "responsible person" (I/A/W ..Part 1), and/or …log as pic that time while sole manipulator of controls in an aircraft in which he/she is appropriately certificated/rated/typed (I/A/W …Part 61). Sorry, this is wrong.  "Responsible person" has nothing to do with logging.  61.51 specifically tells you what you can log as PIC.   Which for private pilots boils down to: 1.  Sole manipulator of the controls of an aircraft     for which you are rated. 2.  Pilot in command of an operation requiring more than             one pilot by the type certification of the aircraft             or the regulations under which the flight is conducted. The rules do not say "LOG PIC WHEN YOU ARE PIC."  If the FAA wanted to say that, it would be easy enough to do, however it is clear that the FAA pretty much wants: 1.  You to be actually flying the aircraft. or 2.  In a command roll in a multipilot operation. While the intent of the second clearly had aircraft that require multiple pilots or commercial operations that require two crewmembers (part 121 or 135), the FAA has admitted that the way the regulation is worded also applies to 91.109 requiring safety pilots for simulated instrument flight. Please do not confuse being the pilot in command which is a very serious duty with specific requirements and responsibilities with the criteria for writing entries in your log book.

Response:

Gak, before the jokes start: or      2.  In a command roll in a multipilot operation.

should read "role" not "roll" -Ron (frequently in uncommanded rolls).

Response:

So how does this breakout? My CFII logged as PIC when we were in actual, I logged as PIC in hood and VFR. Is this the what you are suggesting?

Note I said "Private Pilot" in my discussions.  If you read farther down in 61.51, you can see that CFI’s can log PIC while instructing (whether they are or not and whether they are touching the controls or not) and they can log instrument time when instructing in actual. You can log PIC time when you are the sole manipulator.  Doesn’t matter what else is going on.  If you flew this entire flight, you may log it as PIC. You log simulated instrument time for the time that you were flying under the hood and actual for the time while in actual. Your instructor should endorse your book for instruction received for this time as well. On your instructors case, he logs instruction given and PIC for the entire flight.  He can log instrument time (actual) for the time you were in actual. NONE OF THIS HAS ONE THING TO DO WITH WHO WAS ACTUALLY PILOT IN COMMAND.  If you were operating under IFR, then it would be required that your instructor (the one with the instrument rating) be pilot in command for this flight.  He had better meet the requirements (currency, etc…) required by the regulations as pilot in command. -Ron

Response:

So how does this breakout? My CFII logged as PIC when we were in actual, I logged as PIC in hood and VFR. Is this the what you are suggesting?

– Hide quoted text — Show quoted text – One can log as pic because he IS the "responsible person" (I/A/W ..Part 1), and/or …log as pic that time while sole manipulator of controls in an aircraft in which he/she is appropriately certificated/rated/typed (I/A/W …Part 61). Sorry, this is wrong.  "Responsible person" has nothing to do with logging.  61.51 specifically tells you what you can log as PIC.   Which for private pilots boils down to: 1.  Sole manipulator of the controls of an aircraft     for which you are rated. 2.  Pilot in command of an operation requiring more than             one pilot by the type certification of the aircraft             or the regulations under which the flight is conducted. The rules do not say "LOG PIC WHEN YOU ARE PIC."  If the FAA wanted to say that, it would be easy enough to do, however it is clear that the FAA pretty much wants: 1.  You to be actually flying the aircraft. or 2.  In a command roll in a multipilot operation. While the intent of the second clearly had aircraft that require multiple pilots or commercial operations that require two crewmembers (part 121 or 135), the FAA has admitted that the way the regulation is worded also applies to 91.109 requiring safety pilots for simulated instrument flight. Please do not confuse being the pilot in command which is a very serious duty with specific requirements and responsibilities with the criteria for writing entries in your log book.

Response:

One can log as pic because he IS the "responsible person" (I/A/W ..Part 1), and/or …log as pic that time while sole manipulator of controls in an aircraft in which he/she is appropriately certificated/rated/typed (I/A/W …Part 61).

Sorry, this is wrong.  "Responsible person" has nothing to do with logging.  61.51 specifically tells you what you can log as PIC.   Which for private pilots boils down to:         1.  Sole manipulator of the controls of an aircraft             for which you are rated.         2.  Pilot in command of an operation requiring more than             one pilot by the type certification of the aircraft             or the regulations under which the flight is conducted. The rules do not say "LOG PIC WHEN YOU ARE PIC."  If the FAA wanted to say that, it would be easy enough to do, however it is clear that the FAA pretty much wants:         1.  You to be actually flying the aircraft. or      2.  In a command roll in a multipilot operation. While the intent of the second clearly had aircraft that require multiple pilots or commercial operations that require two crewmembers (part 121 or 135), the FAA has admitted that the way the regulation is worded also applies to 91.109 requiring safety pilots for simulated instrument flight. Please do not confuse being the pilot in command which is a very serious duty with specific requirements and responsibilities with the criteria for writing entries in your log book.

Response:

how should I log it?<<

The chief instructor is incorrect. You should log the time as PIC (since you were sole manipulator of the controls) and log it as actual instrument time (or simulated as appropriate). Your CFI should log it as instruction given and PIC since he too was PIC (especially during the actual part). — Best Regards Rick Cremer FAA

– Hide quoted text — Show quoted text – When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? Francisco Murillo N55260

Response:

The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? The chief instructor of your new school needs to do some refresher work on the difference between acting as PIC and logging PIC. Sounds like the way you have things logged is perfectly correct.

I’m in total agreement. Ref:  14 CFR Part 1, Definition of PIC          14 CFR Part 61, "Logging of Pilot time" One can log as pic because he IS the "responsible person" (I/A/W ..Part 1), and/or …log as pic that time while sole manipulator of controls in an aircraft in which he/she is appropriately certificated/rated/typed (I/A/W …Part 61). John Williams http://users.ev1.net/~jwwda50

Response:

When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it?

You’re new instructor is crocked.  You can log actual time anytime you fly the aircraft solely by reference to the instruments in actual instrument conditions.  Margy had a couple of hours of actual prior to getting her private. You can log PIC time as a private pilot whenever you are the sole manipulator of the controls of an aircraft for which you are rated.  It makes no difference if you were actually the pilot in command or not. What this poor soul is confused over is that you could not legally be PIC under IFR (really actual has nothing to do with it except it implies you had better have been operating under IFR) and thus your instructor had to have been the pilot in command.  However this is unrelated to the logging issue.

Response:

When my previous CFII when to work for an airline, I had the chief instructor in my new school checking my logbooks.  He was interested in a IFR cross contry to Orlando, where we encounter some actual IMC conditions. My previous instructor had logged that as "actual" and the rest of that trip as "simulated".  The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it? Francisco Murillo N55260

Response:

The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct?

The chief instructor of your new school needs to do some refresher work on the difference between acting as PIC and logging PIC. Sounds like the way you have things logged is perfectly correct.

Response:

The chief instructuor of my new school indicated that I could not log "actual" PIC since I was not yet instrument rated. Is this correct? If it is, how should I log it?

If you flew in actual, you flew in actual…how on earth is he trying to tell you that you can’t log it as actual? You should log it as actual for the time that was actual,  simulated for the part that is simulated, and PIC for all of it. BDWood

Response:

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