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Backcountry Pilot • Logging PIC, AOPA Senarios

Logging PIC, AOPA Senarios

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Logging PIC, AOPA Senarios

Maybe someone here can help me. Here are three scenarios that I just don't understand how these can be logged as PIC. Take number 1 for instance, if you don't have a high performance endorsement or current flight review and its agreed that pilot B is acting as PIC, then pilot B logs the flight, correct? Here's the article.


Time Logging Scenarios

Scenario 1
Two Pilots
Pilot A wants to accompany Pilot B on a cross-country flight in a single-engine, high-performance aircraft. Pilot A is rated for the airplane but does not have a current medical, high-performance endorsement, or current flight review. Pilot A will be practicing simulated instrument flying, wearing a view-limited device, and will be sole manipulator of the controls during the en route portion of the flight. Pilot B meets all the requirements to be PIC and has agreed to be PIC and safety pilot during the flight.

Under these circumstances, Pilot A may log PIC time and simulated instrument time; Pilot B may log PIC time but not instrument time, because he/she is not operating the aircraft by reference to instruments (FAR 61.51).

Scenario 2

Pilot A wishes to fly with Pilot B on a cross-country flight in a single-engine, high-performance aircraft. Pilot A is rated for the aircraft but is not instrument rated or endorsed to fly high-performance aircraft and does not have a current medical certificate or flight review. Pilot A will be flying by reference to instruments during actual instrument conditions. Pilot B is legal to act as PIC and has agreed to be the PIC. Under these circumstances, Pilot A may log PIC and actual instrument time (although Pilot A should be prepared to explain to an FAA inspector why PIC time was logged while in actual instrument conditions, when he/she was not instrument rated). Pilot B cannot log PIC as he/she is not the sole manipulator of the flight controls and cannot log instrument time because he/she was not flying the aircraft by reference to instruments (Far 61.51).

Scenario 3

"Foggles"Pilot A wishes to fly with Pilot B for the purpose of practicing instrument flying in a high-performance aircraft. Pilot A may legally act as PIC and has agreed to act as PIC. Pilot A will be wearing a view-limiting device and will be flying by reference to instruments. Pilot B is rated in the aircraft and has a current medical certificate but is not instrument rated, endorsed to fly high-performance airplanes, or have a current flight review. Pilot B has agreed to be the safety pilot for the flight.

Pilot A may log PIC and simulated instrument time. Pilot B may log second-in-command (SIC) time. Pilot A is assuming PIC responsibilities and may log PIC. Pilot B is a crewmember where more than one pilot is required and may log SIC (FAR 61.51). Again, because Pilot B is a required crewmember, he/she will need a current medical certificate (FAR 61.3).

Flight instructors may log any flight time as PIC whenever they are providing flight instruction, whether or not they are acting as PIC (FAR 61.51). This mainly applies to FAR Part 91 operations! An instructor may not give flight instruction during a FAR 135 or 121 operation unless he/she is a designated flight instructor as stated in the carrier's approved operations manual.

Another popular question that arises in discussion is whether or not a student pilot may log PIC time. As per FAR 61.51 (e)(4), a student pilot may log PIC when they are the sole occupant of the aircraft and have a current solo flight endorsement. This is a part of the August 4, 1997, Part 61 rewrite and is a change from past regulations.

What happens when a student pilot is taking a checkride for his/her private, recreational, or sport pilot certificate, or a pilot is upgrading to a higher rating or privilege? By FAR 61.47, the examiner is not PIC. The student pilot or pilot at this time is now considered a flight test applicant and may log the flight evaluation as PIC, whether or not he/she passes.

A special note to "time builders": Although the FAA provides several means to log PIC time, PIC time represents flying or instructional experience and sound decision making ability. Commercial employers might not be impressed with hundreds of hours logged as PIC where the pilot was not actually flying.

This document has been prepared from various reference to FARs and letters of interpretation from the FAA.


http://www.aopa.org/Pilot-Resources/Lea ... -Scenarios
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Re: Logging PIC, AOPA Senarios

This may answer part of it:

This letter responds to your request for a legal interpretation of 14 C.F.R. § 61.129 dated
October 10, 20 13. You asked several questions concerning crediting required flight time
under § 61.129(a)(4)! by performing the duties of pilot in command (PIC) in a single engine
airplane with an authorized instructor on board instead of performing this required flight
time as solo flight time.
Your first question is whether a certificated flight instructor (CFI) may log PIC time for a
flight conducted to meet the flight time requirements of § 61. 129(a)(4). Section 61.51(e)
prescribes the requirements for logging PIC time. Specifically, § 61.51(e)(3) states: "A
certificated flight instructor may log pilot in command flight time for all flight time while
serving as the authorized instructor in an operation if the instructor is rated to act as pilot in
command of that aircraft." Provided the instructor is rated to act as PIC of the aircraft, the
instructor can log PIC time for the entire flight because the instructor is serving as an
authorized instructor under § 61.129( a)(4) for that flight.
X0.!:ITsecond question concerns how the pilot performing the duties of PIC with an
- -
authorized instructor may log flight time. Because this flight time is a substitute for solo
flight time, the pilot is not receiving instruction and therefore cannot log this time as dual
instruction received. The pilot can log the time to meet the requirements of § 61. 129(a)(4)
and log total flight time. Section 61.51 (e) prescribes the requirements for logging PIC time.
The pilot could log PIC time under § 61.51(e)(l)(i) if the pilot has a private pilot certificate
with the appropriate ratings for the aircraft. Otherwise, the pilot cannot log PIC time. None
of the other § 61.51(e) logging provisions are applicable to your scenario. However,
§ 61. 129(a)(4) permits crediting of the time toward the 100 hours of PIC time required for
the commercial pilot certificate under § 61.129(a)(2). The logbook entry should accurately
reflect the provision under which the flight time is logged.
Your final question is whether the CFI must act as PIC for this type of flight. If either the
instructor or the pilot performing the duties of PIC has the appropriate category, class, and
type (if applicable) ratings for the aircraft and is otherwise authorized to act as PIC, either
can act as PIC. Otherwise, the CFI must have the appropriate ratings for the aircraft, be
authorized to act as PIC, and act as PIC. See Legal Interpretation to Jason E. Herman (May
21,2009).
This response was prepared by Robert Hawks, an Attorney in the International Law,
Legislation, and Regulations Division of the Office of Chief Counsel, and coordinated with
the General Aviation and Commercial Division of Flight Standards Service. We hope this
response has been helpful to you. If you have additional questions regarding this matter,
please contact us at your convenience at (202) 267-3073.
Mark W. Bury
Assistant Chief Counsel for
International Law, Legislation and Regulations (AGC-200)
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Re: Logging PIC, AOPA Senarios

Legal niceties aside, I don't understand how more than one pilot can log PIC time. An instructor giving dual instruction to a licensed pilot, maybe.
Secondly, there were numerous references made about pilots not having a high-performance endorsement yet being "rated for the (high performance) aircraft". Seems like an oxymoron.
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Re: Logging PIC, AOPA Senarios

hotrod180 wrote:Legal niceties aside, I don't understand how more than one pilot can log PIC time. An instructor giving dual instruction to a licensed pilot, maybe.
Secondly, there were numerous references made about pilots not having a high-performance endorsement yet being "rated for the (high performance) aircraft". Seems like an oxymoron.


High performance is not a "rating". It's simply an endorsement.

MTV
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Re: Logging PIC, AOPA Senarios

There is a very clear difference between acting as pic and being the pic during the flight. Acting as pic requires that you are the sole manipulator of the controls in an aircraft in which you are rated i.e. single engine land, multi engine land.... Being pic for the flight is the person who is rated in the aircraft and is the responsible party for the safe operation of that flight. So if a pilot is manipulating the controls of an aircraft in which they are rated then they may log the time as pic. However the safety pilot is required because it is there responsibility for the safe outcome of the flight i.e. see and avoid during flight in vmc.
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Re: Logging PIC, AOPA Senarios

So you can legally log and act as PIC in a high performance aircraft without a high performance endorsement? What about tail wheel endorsement or complex? Or how about the scenario where the pilot didn't have a current flight review? That wouldn't be legal to log would it? It seems the article is poorly written and kinda pointless.
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Re: Logging PIC, AOPA Senarios

mtv wrote:
hotrod180 wrote:Legal niceties aside, I don't understand how more than one pilot can log PIC time. An instructor giving dual instruction to a licensed pilot, maybe.
Secondly, there were numerous references made about pilots not having a high-performance endorsement yet being "rated for the (high performance) aircraft". Seems like an oxymoron.

High performance is not a "rating". It's simply an endorsement.
MTV


Perhaps I misspoke. I was wondering how someone can be "rated for the aircraft", if it is a high-performance aircraft and they do not have a high-performance endorsement.
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Re: Logging PIC, AOPA Senarios

hotrod180 wrote:
mtv wrote:
hotrod180 wrote:Legal niceties aside, I don't understand how more than one pilot can log PIC time. An instructor giving dual instruction to a licensed pilot, maybe.
Secondly, there were numerous references made about pilots not having a high-performance endorsement yet being "rated for the (high performance) aircraft". Seems like an oxymoron.

High performance is not a "rating". It's simply an endorsement.
MTV


Perhaps I misspoke. I was wondering how someone can be "rated for the aircraft", if it is a high-performance aircraft and they do not have a high-performance endorsement.

I have always thought it was just a matter of paperwork. I'm rated in a complex, high performance airplane, and took my commercial ASEL checkride in a complex airplane. I have neither a complex or a high performance endorsement. I have always assumed it was taken care of with my aircraft qual.

Do I need to find a cfi buddy to endorse my logbook?
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Re: Logging PIC, AOPA Senarios

hotrod180 wrote:
mtv wrote:
hotrod180 wrote:Legal niceties aside, I don't understand how more than one pilot can log PIC time. An instructor giving dual instruction to a licensed pilot, maybe.
Secondly, there were numerous references made about pilots not having a high-performance endorsement yet being "rated for the (high performance) aircraft". Seems like an oxymoron.

High performance is not a "rating". It's simply an endorsement.
MTV


Perhaps I misspoke. I was wondering how someone can be "rated for the aircraft", if it is a high-performance aircraft and they do not have a high-performance endorsement.


From 61.5 of the FARs, these are "Certificates":

(a) The following certificates are issued under this part to an applicant who satisfactorily accomplishes the training and certification requirements for the certificate sought:

(1) Pilot certificates—

(i) Student pilot.

(ii) Sport pilot.

(iii) Recreational pilot.

(iv) Private pilot.

(v) Commercial pilot.

(vi) Airline transport pilot.

(2) Flight instructor certificates.

(3) Ground instructor certificates.

And, THESE are "Ratings" as defined in the regulations....:

(b) The following ratings are placed on a pilot certificate (other than student pilot) when an applicant satisfactorily accomplishes the training and certification requirements for the rating sought:

(1) Aircraft category ratings—

(i) Airplane.

(ii) Rotorcraft.

(iii) Glider.

(iv) Lighter-than-air.

(v) Powered-lift.

(vi) Powered parachute.

(vii) Weight-shift-control aircraft.

(2) Airplane class ratings—

(i) Single-engine land.

(ii) Multiengine land.

(iii) Single-engine sea.

(iv) Multiengine sea.

(3) Rotorcraft class ratings—

(i) Helicopter.

(ii) Gyroplane.

(4) Lighter-than-air class ratings—

(i) Airship.

(ii) Balloon.

(5) Weight-shift-control aircraft class ratings—

(i) Weight-shift-control aircraft land.

(ii) Weight-shift-control aircraft sea.

(6) Powered parachute class ratings—

(i) Powered parachute land.

(ii) Powered parachute sea.

(7) Aircraft type ratings—

(i) Large aircraft other than lighter-than-air.

(ii) Turbojet-powered airplanes.

(iii) Other aircraft type ratings specified by the Administrator through the aircraft type certification procedures.

(iv) Second-in-command pilot type rating for aircraft that is certificated for operations with a minimum crew of at least two pilots.

(8) Instrument ratings (on private and commercial pilot certificates only)—
"
(i) Instrument—Airplane.

(ii) Instrument—Helicopter.

(iii) Instrument—Powered-lift.

Note that tailwheel, high performance and complex are not listed as "Ratings" here. They are "endorsements" which are required to operate these aircraft when "serving" as PIC.

The term "rated for" is very loosely applied, and generally, it is used to describe the category and class of aircraft you're licensed to operate: "Airplane, Single Engine Land", "Rotorcraft, Helicopter", etc. You may also possess "ratings", as in "Instrument-Airplane". And, all these will appear on your certificate.....

But, again, the three "endorsements" are just that: logbook endorsements. They don't appear on your certificate anywhere.

MTV
Last edited by mtv on Sat Feb 20, 2016 10:59 am, edited 1 time in total.
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Re: Logging PIC, AOPA Senarios

CamTom12 wrote:I have always thought it was just a matter of paperwork. I'm rated in a complex, high performance airplane, and took my commercial ASEL checkride in a complex airplane. I have neither a complex or a high performance endorsement. I have always assumed it was taken care of with my aircraft qual.

Do I need to find a cfi buddy to endorse my logbook?


Short answer is yes.

Here is the regulation from 61.31:

(e) Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane, unless the person has—

(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a flight simulator or flight training device that is representative of a complex 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 complex airplane.

(2) The training and endorsement required by paragraph (e)(1) of this section is not required if the person has logged flight time as pilot in command of a complex airplane, or in a flight simulator or flight training device that is representative of a complex airplane prior to August 4, 1997.

(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.

(2) The training and endorsement required by paragraph (f)(1) of this section is not required if the person has logged flight time as pilot in command of a high-performance airplane, or in a flight simulator or flight training device that is representative of a high-performance airplane prior to August 4, 1997.

Note that both of these (and the tailwheel qualification) specifically require a logbook endorsement to the effect that you've been found qualified. I'm surprised your DPE didn't catch that. The fact that you've logged time in such airplanes does not fulfill the requirements.

So, yes, I'd get a CFI to endorse your logbook.

MTV
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Re: Logging PIC, AOPA Senarios

Most of these questions can be answered by just reading the regs, and understanding that logging PIC and being PIC are two different things. It's easy to imagine a situation in which the actual PIC cannot log any PIC time (private or commercial pilot only, not a CFI, didn't touch the controls, current medical and flight review), but the sole manipulator of the controls, although certificated for that category and class of airplane, flies the airplane start to finish yet has no current medical or flight review, and no endorsements that apply to that airplane, but can log the entire flight as PIC.

To add to the confusion, another "gotcha" is that a safety pilot must have a current medical and be certificated for that category and class of airplane, but is not required to have a current flight review so long as the hooded pilot has both.

And still more confusion: a CFI is not required to have a current medical or flight review to provide instruction, so long as the "student" is already certificated for that category and class of airplane and is current with both his medical and flight review, and both can log the entire flight as PIC.

Interesting, huh?

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Re: Logging PIC, AOPA Senarios

CamTom12 wrote:I have always thought it was just a matter of paperwork. I'm rated in a complex, high performance airplane, and took my commercial ASEL checkride in a complex airplane. I have neither a complex or a high performance endorsement. I have always assumed it was taken care of with my aircraft qual.

Do I need to find a cfi buddy to endorse my logbook?



From talking to my FSDO guys and local FAA examiner, as long as you can provide a copy of your Air Force Form 8 or Navy NATOPS sheet showing you were checked out in a certain kind of aircraft, it's just as good. I assume you've been checked out in a T-6 or some other primary trainer, and this will suffice
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Re: Logging PIC, AOPA Senarios

Cary wrote:Most of these questions can be answered by just reading the regs, and understanding that logging PIC and being PIC are two different things. It's easy to imagine a situation in which the actual PIC cannot log any PIC time (private or commercial pilot only, not a CFI, didn't touch the controls, current medical and flight review), but the sole manipulator of the controls, although certificated for that category and class of airplane, flies the airplane start to finish yet has no current medical or flight review, and no endorsements that apply to that airplane, but can log the entire flight as PIC.

To add to the confusion, another "gotcha" is that a safety pilot must have a current medical and be certificated for that category and class of airplane, but is not required to have a current flight review so long as the hooded pilot has both.

And still more confusion: a CFI is not required to have a current medical or flight review to provide instruction, so long as the "student" is already certificated for that category and class of airplane and is current with both his medical and flight review, and both can log the entire flight as PIC.

Interesting, huh?

Cary


Cary is right. What's more important, though is that you need to be VERY careful in logging PIC. As Cary says, there's a difference between serving as PIC and ACTING as PIC.

Many years ago, when I completed my commercial certificate, the FAA had some heartburn with some of the PIC that I reported in my 8710 application for the the certificate. The Examiner (who was an FSDO Inspector) and I spent a couple of months writing letters to prove that what was reported was in fact legal, and met the letter of the regs. Eventually, we got it settled, but in the meantime, there was a great deal of angst.

My advice is simple: While there are lots of cases where you MIGHT be able to log PIC time, unless it's really clear and easy to document....don't.

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Re: Logging PIC, AOPA Senarios

Timberwolf wrote:From talking to my FSDO guys and local FAA examiner, as long as you can provide a copy of your Air Force Form 8 or Navy NATOPS sheet showing you were checked out in a certain kind of aircraft, it's just as good. I assume you've been checked out in a T-6 or some other primary trainer, and this will suffice


C-12 here. My DPE saw my C-12 course records, that's probably why he didn't care about any endorsements. I'll get some endorsements signed in my book. Thanks, guys!
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