Logging Right Seat Time [Archive]

Jose

May 21st 05, 03:55 PM

> I'm a Captain in all the planes but move to the right seat often. When
> I'm in the right seat what can I log?

IMHO, If you are the Pilot In Command, you log PIC time, no matter what
(physical) seat you sit in. (Some planes don't even have a left seat!).
If you are =metaphorically= "sitting in the right seat" (i.e. you are
just along for the ride while somebody else takes responsibility for the
flight) then you don't log anything, no matter what physical seat you
occupy.

That is, you can log anything you want, but you can't use that
particular time towards ratings and currency.

My strict reading of 61.51(e) says that if you are not the "sole
manipulator", then even if you =are= the PIC, then so long as anybody
else is handling the controls, you can't log PIC time, but if you hand
over the controls to the autopilot and take a nap, you can log it
yourself. However, I would maintain that if somebody else is handling
the controls for you, under your direction, then you are merely using an
organic autopilot.

I don't see the essential difference between the two, especially with
the sophistication of some modern autopilots. The FAA may disagree, I'd
like to hear their reasoning (and the reasoning of anyone else who
disagrees)

Jose
--
I used to make money in the stock market, now I make money in the basement.
for Email, make the obvious change in the address.

Mike Rapoport

May 21st 05, 04:32 PM

CloudyIFR

May 21st 05, 05:07 PM

I realize I have a job and am getting paid, that's first and foremost,
but it seems that I should be able to log something as I'm doing the
same thing as I would when I fly SIC in the Learjet, but with the
Learjet I get to legally log SIC, whereas in say a Cessna 421 I don't.

Doesn't make sense to me.

Must be something that I can log?

Curtis

Paul Lynch

May 21st 05, 06:22 PM

You need to provide more information. What kind of airplane? What is the
seat configuration (# pax)? IFR or VFR operations? What does your company
operations specification require?

Here is the bottom line... If your OPSPEC or the AFM or Part 135 requires a
second pilot you can log SIC. You can only log approaches, landings, and
instrument time where you have your hands on the controls. IF, AND ONLY IF,
one of the above requires a SIC, and you are the designated Captain, you can
log PIC no matter what seat you are in or if you touch the controls. As
above, to log approaches, landings or instrument time you must be operating
the controls.

The reference is contained in Part 135 and 61.

One additional question... Who does your 135 training and checkrides? The
appear to be lacking.

"CloudyIFR" > wrote in message
oups.com...
> I'm a Part 135 pilot and we're starting to get a lot of missions that
> are two pilot crews. These are in airplanes that don't require a SIC
> as the AutoPilots work, we're not flying over 8 hours and it's not
> required by the Type certificate.
>
> I'm a Captain in all the planes but move to the right seat often. When
> I'm in the right seat what can I log? From my reading of the FAR's I
> can only log Total Time. Is that correct? I can't log PIC as I'm not
> the PIC nor sole manipulator of the controls. Can I log landings,
> Instrument, X/C, etc..?
>
> If you have a reference I'd appreciate it.
>
> Thanks for the help.
>
> Curt
>

Howard Nelson

May 21st 05, 11:13 PM

Mike Rapoport

May 21st 05, 11:22 PM

"CloudyIFR" > wrote in message
oups.com...
>I realize I have a job and am getting paid, that's first and foremost,
> but it seems that I should be able to log something as I'm doing the
> same thing as I would when I fly SIC in the Learjet, but with the
> Learjet I get to legally log SIC, whereas in say a Cessna 421 I don't.
>
>
> Doesn't make sense to me.
>
> Must be something that I can log?
>
> Curtis
>

I don't see the problem. A 421 is a single pilot airplane, so the (one)
pilot that is flying can log the time. A Learjet is a two pilot airplane so
the two pilots flying it can log time. It makes as much sense for three
pilots to log time in the Lear as two in the 421.

Mike
MU-2

Ron Natalie

May 22nd 05, 01:54 AM

Jose wrote:
>> I'm a Captain in all the planes but move to the right seat often. When
>> I'm in the right seat what can I log?
>
>
> IMHO, If you are the Pilot In Command, you log PIC time, no matter what
> (physical) seat you sit in.

Where you sit is not important. However, the rules don't say "LOG PIC
TIME WHEN YOU ARE PIC." In order to do that there are additional
qualifications. The most commonly used one is that the regulations
(lets say Part 135) require more than one pilot.

> My strict reading of 61.51(e) says that if you are not the "sole
> manipulator", then even if you =are= the PIC, then so long as anybody
> else is handling the controls, you can't log PIC time,Y

You better read 61.51 again. There are three more clauses than the
one you're reading.

Jose

May 22nd 05, 02:32 AM

>> My strict reading of 61.51(e) says that if you are not the "sole manipulator", then even if you =are= the PIC, then so long as anybody else is handling the controls, you can't log PIC time,Y
>
> You better read 61.51 again. There are three more clauses than the
> one you're reading.

I didn't think they were relevant to the discussion.

Rec, private, or comm pilot may log PIC if...
sole manipulator (& rated) ... or sole occupant ... or (not except for
rec pilots) =is= PIC when two pilots are required.

The other clauses pertain to ATPs, authorized instructors, and student
pilots. So I was focusing on the first set.

We were discussing a situation where only one pilot is required, and
there is another occupant of the aircraft. In this case, I believe that
as I wrote above, a strict reading says that even if you =are= the
actual Pilot In Command (perhaps by dint of being the only pilot aboard,
perhaps by another dint), then if anybody else is handling the controls,
you can't log PIC time. However, if an FAA approved robot is handling
the controls, then you can.

Handling the robot (turning on the autopilot) apparantly counts as
handling a control. You can program the FMS to do the takeoff, cruise,
and landing, take a nap, and set an alarm for when your wheels touch the
ground again, and log the whole thing as PIC. You can do this with a
non-FAA approved robot too, if you are flying an experimental class
aircraft. (At least I think that's true - how much does the FAA get
involved in certification of instrumentation and such for
experimentals?) It's unclear as to whether you can let a monkey operate
the controls and still log it as PIC (which may be a problem for those
that employ the cat-dog-duck method of IFR flight), but if you let a
human act as your autopilot, a strict reading of the rules says nix on
the logbook.

So, you (a regular private pilot) go up in a 172 with a friend who is
not a pilot, you let him take the controls while you very carefully
supervise her, and you can't log the time PIC. The next day you fly a
Cirrus by programming the CID (Cirrus Autoflight Device) and pushing the
GO button, essentially become a passenger while the glass cockpit does
the work, and all that time goes in your book as PIC.

Doesn't make sense to me. This is why I mention the organic autopilot.

Jose
--
I used to make money in the stock market, now I make money in the basement.
for Email, make the obvious change in the address.

Mike Rapoport

May 22nd 05, 03:07 AM

"Jose" > wrote in message
m...
>>> My strict reading of 61.51(e) says that if you are not the "sole
>>> manipulator", then even if you =are= the PIC, then so long as anybody
>>> else is handling the controls, you can't log PIC time,Y
>>
>> You better read 61.51 again. There are three more clauses than the
>> one you're reading.
>
> I didn't think they were relevant to the discussion.
>
> Rec, private, or comm pilot may log PIC if...
> sole manipulator (& rated) ... or sole occupant ... or (not except for rec
> pilots) =is= PIC when two pilots are required.
>
> The other clauses pertain to ATPs, authorized instructors, and student
> pilots. So I was focusing on the first set.
>
> We were discussing a situation where only one pilot is required, and there
> is another occupant of the aircraft. In this case, I believe that as I
> wrote above, a strict reading says that even if you =are= the actual Pilot
> In Command (perhaps by dint of being the only pilot aboard, perhaps by
> another dint), then if anybody else is handling the controls, you can't
> log PIC time. However, if an FAA approved robot is handling the controls,
> then you can.
>
> Handling the robot (turning on the autopilot) apparantly counts as
> handling a control. You can program the FMS to do the takeoff, cruise,
> and landing, take a nap, and set an alarm for when your wheels touch the
> ground again, and log the whole thing as PIC. You can do this with a
> non-FAA approved robot too, if you are flying an experimental class
> aircraft. (At least I think that's true - how much does the FAA get
> involved in certification of instrumentation and such for experimentals?)
> It's unclear as to whether you can let a monkey operate the controls and
> still log it as PIC (which may be a problem for those that employ the
> cat-dog-duck method of IFR flight), but if you let a human act as your
> autopilot, a strict reading of the rules says nix on the logbook.
>
> So, you (a regular private pilot) go up in a 172 with a friend who is not
> a pilot, you let him take the controls while you very carefully supervise
> her, and you can't log the time PIC. The next day you fly a Cirrus by
> programming the CID (Cirrus Autoflight Device) and pushing the GO button,
> essentially become a passenger while the glass cockpit does the work, and
> all that time goes in your book as PIC.
>
> Doesn't make sense to me. This is why I mention the organic autopilot.
>
> Jose
> --
> I used to make money in the stock market, now I make money in the
> basement.
> for Email, make the obvious change in the address.

I think that it is simpler. You can log pilot time when the FAA requires
you to be in the airplane performing as pilot. If you are not required (ie
you are one of 4 pilots in a 172) you can't log the time.

If you go through the specific rules this seems to hold true. Every time
that there is an instance where two pilots can log time, it is becasue two
pilots are required by regulation.

Mike
MU-2

Gary Drescher

May 22nd 05, 03:28 AM

"Jose" > wrote in message
m...
> So, you (a regular private pilot) go up in a 172 with a friend who is not
> a pilot, you let him take the controls while you very carefully supervise
> her, and you can't log the time PIC.

That's correct, at least according to the wording of the FARs (61.51e).
Whether it's what the FAA really intended is anyone's guess.

> Handling the robot (turning on the autopilot) apparantly counts as
> handling a control.

Yup. Whereas a passenger does not count as a control. That distinction per
se (between what is and isn't a control) is reasonable, though the
corresponding distinction between the time you can and can't log is less
reasonable, as you point out.

--Gary

Matt Barrow

May 22nd 05, 05:02 AM

"Ron Natalie" > wrote in message
...
> Jose wrote:
> >> I'm a Captain in all the planes but move to the right seat often. When
> >> I'm in the right seat what can I log?
> >
> >
> > IMHO, If you are the Pilot In Command, you log PIC time, no matter what
> > (physical) seat you sit in.
>
> Where you sit is not important. However, the rules don't say "LOG PIC
> TIME WHEN YOU ARE PIC." In order to do that there are additional
> qualifications. The most commonly used one is that the regulations
> (lets say Part 135) require more than one pilot.
>
> > My strict reading of 61.51(e) says that if you are not the "sole
> > manipulator", then even if you =are= the PIC, then so long as anybody
> > else is handling the controls, you can't log PIC time,Y
>
> You better read 61.51 again. There are three more clauses than the
> one you're reading.

Though it refers to currency, you might check 61.58 for some insights as
well.

Jose

May 22nd 05, 05:11 AM

>> Handling the robot (turning on the autopilot) apparantly counts as
>> handling a control.
>
>
> Yup. Whereas a passenger does not count as a control. That distinction per
> se (between what is and isn't a control) is reasonable

Why?

This is a serious question, especially considering the capabilities of
some robots, and the lack of capability of some organic autopilots.

Jose
--
I used to make money in the stock market, now I make money in the basement.
for Email, make the obvious change in the address.

Ron Garret

May 22nd 05, 05:42 AM

In article >,
Jose > wrote:

> So, you (a regular private pilot) go up in a 172 with a friend who is
> not a pilot, you let him take the controls while you very carefully
> supervise her, and you can't log the time PIC.

That's right. Not only that, but you've probably broken FAR 91.13 by
letting a person without a valid pilot certificate fly the plane. (A
little discretion goes a long way in such situations.)

> The next day you fly a
> Cirrus by programming the CID (Cirrus Autoflight Device) and pushing the
> GO button, essentially become a passenger while the glass cockpit does
> the work, and all that time goes in your book as PIC.

That's right, because you're still responsible if the CID goes belly-up.
That (and FAR 91.13) is why you can't just take a nap even when the
autopilot is on.

rg

Doug

May 22nd 05, 07:24 AM

You ask, "When I'm in the right seat what can I log"

There is not enough information to answer your question. Being "in the
right seat is irrelevant. If you are still the Pilot in Command then
you log PIC by virtue of being Pilot in Command. If the person in the
left seat is Pilot in Command, and logging PIC, then the situation may
be different. Let us assume that is the case. Is he loggin PIC by
virtue of manipulating the controls or by virtue of being in charge of
the airplane? (acting as PIC). If he he is logging by virtue of
manipulating the controls, then you could log PIC by virtue of being in
charge....but.....the operation of the plane doesn't require two crew
members. So this is iffy, very iffy. You are both logging PIC, and the
plane doesn't require two pilots. HOONNKK! You can't do it.
I don't even think you can log it as Total Time.

Think of it this way, if you log it as PIC and at your airline
interview you get asked, "why did you log these flights as PIC?". What
are you going to say?

The only way I see you could log it as PIC is if you are giving him
instruction, or he is under the hood. Not sure if your company ops
would permit that.

Gary Drescher

May 22nd 05, 12:46 PM

"Jose" > wrote in message
m...
>>> Handling the robot (turning on the autopilot) apparantly counts as
>>> handling a control.
>>
>>
>> Yup. Whereas a passenger does not count as a control. That distinction
>> per se (between what is and isn't a control) is reasonable
>
> Why?
>
> This is a serious question, especially considering the capabilities of
> some robots, and the lack of capability of some organic autopilots.

The distinction is reasonable because the ordinary meaning of 'control' is
that it refers to an inanimate or non-sentient device, not to a person. As
sophisticated as some autopilots are, they are not yet sentient. You're
right that *for purposes of logging PIC time*, that distinction doesn't
matter (though for many *other* purposes it certainly matters!). So the line
drawn by 61.51e doesn't make much sense, but that's different from the
distinction between control and non-control not making sense. The FAA should
just rephrase 61.51e(ii) to say "sole rated occupant" rather than "sole
occupant".

--Gary

Gary Drescher

May 22nd 05, 01:00 PM

"Ron Garret" > wrote in message
...
> In article >,
> Jose > wrote:
>
>> So, you (a regular private pilot) go up in a 172 with a friend who is
>> not a pilot, you let him take the controls while you very carefully
>> supervise her, and you can't log the time PIC.
>
> That's right. Not only that, but you've probably broken FAR 91.13 by
> letting a person without a valid pilot certificate fly the plane.

No you haven't. There is nothing inherently careless and reckless about
letting a non-pilot passenger manipulate the controls. It's a routine and
accepted practice. Have you ever read of an FAA opinion criticizing the
practice, or an enforcement action taken for that reason?

--Gary

Jose

May 22nd 05, 01:57 PM

>> So, you (a regular private pilot) go up in a 172 with a friend who is
>> not a pilot, you let him take the controls while you very carefully
>> supervise her, and you can't log the time PIC.
>
>
> That's right. Not only that, but you've probably broken FAR 91.13 by
> letting a person without a valid pilot certificate fly the plane.

You break 91.13 at the FAA's discretion. But I see nothing careless or
reckless unless I take a nap.

>> The next day you fly a
>> Cirrus by programming the CID (Cirrus Autoflight Device) and pushing the
>> GO button, essentially become a passenger while the glass cockpit does
>> the work, and all that time goes in your book as PIC.
>
>
> That's right, because you're still responsible if the CID goes belly-up.

You're still responsible if the organic autopilot goes awry too.

Jose
--
I used to make money in the stock market, now I make money in the basement.
for Email, make the obvious change in the address.

CloudyIFR

May 22nd 05, 03:38 PM

Please read this thread carefully, it answers the original question.

http://www.risingup.com/forums/archive/index.php/t-378.html

Newps

May 22nd 05, 06:18 PM

Jose wrote:
>>> Handling the robot (turning on the autopilot) apparantly counts as
>>> handling a control.
>>
>>
>>
>> Yup. Whereas a passenger does not count as a control. That distinction
>> per se (between what is and isn't a control) is reasonable
>
>
> Why?
>
> This is a serious question, especially considering the capabilities of
> some robots, and the lack of capability of some organic autopilots.

It's a distinction without a difference. Nobody with more than three
brain cells left who goes flying for an hour and lets their 10 year old
kid fly for 30 minutes of that hour only logs 30 minutes as PIC.

Gary Drescher

May 22nd 05, 06:26 PM

"Newps" > wrote in message
...
> Nobody with more than three brain cells left who goes flying for an hour
> and lets their 10 year old kid fly for 30 minutes of that hour only logs
> 30 minutes as PIC.

Why? Even if you're convinced that the FAA didn't mean what it said when it
wrote 61.51e (which is quite possible), what would be the harm in playing it
safe and logging no more time than the FARs actually say you can log?

--Gary

Ron Garret

May 22nd 05, 08:34 PM

In article >,
Jose > wrote:

> >> So, you (a regular private pilot) go up in a 172 with a friend who is
> >> not a pilot, you let him take the controls while you very carefully
> >> supervise her, and you can't log the time PIC.
> >
> >
> > That's right. Not only that, but you've probably broken FAR 91.13 by
> > letting a person without a valid pilot certificate fly the plane.
>
> You break 91.13 at the FAA's discretion. But I see nothing careless or
> reckless unless I take a nap.

As you yourself observed, what you see doesn't matter. It's what the
FAA sees that counts.

> >> The next day you fly a
> >> Cirrus by programming the CID (Cirrus Autoflight Device) and pushing the
> >> GO button, essentially become a passenger while the glass cockpit does
> >> the work, and all that time goes in your book as PIC.
> >
> >
> > That's right, because you're still responsible if the CID goes belly-up.
>
> You're still responsible if the organic autopilot goes awry too.

Yes, but to legally take on that responsibility "on the record" requires
an instructor's certificate.

I think this structuring of the rules is deliberate and not just an
oversight. It would have been easy enough to say that a pilot can log
PIC any time he is acting as PIC, but they apparently went to a lot of
effort not to say that. I think this was a deliberate attempt to
arrange things in such a way that turning over the controls to Aunt
Tillie is not explicitly banned, but that if you choose to do so and
anything goes wrong as a result (even in retrospect) they can nail your
ass to the wall.

There are actually other circumstances under which someone acting as PIC
can't log the time. For example, if an unlicensed passenger in a plane
where the pilot is incapacitated takes over and lands the plane then
that passenger is PIC operating (presumably) under the authority of
91.3(b). But he still can't log the time.

rg

Ron Garret

May 22nd 05, 08:47 PM

In article >,
"Gary Drescher" > wrote:

> "Ron Garret" > wrote in message
> ...
> > In article >,
> > Jose > wrote:
> >
> >> So, you (a regular private pilot) go up in a 172 with a friend who is
> >> not a pilot, you let him take the controls while you very carefully
> >> supervise her, and you can't log the time PIC.
> >
> > That's right. Not only that, but you've probably broken FAR 91.13 by
> > letting a person without a valid pilot certificate fly the plane.
>
> No you haven't. There is nothing inherently careless and reckless about
> letting a non-pilot passenger manipulate the controls. It's a routine and
> accepted practice. Have you ever read of an FAA opinion criticizing the
> practice, or an enforcement action taken for that reason?

I said "probably", but perhaps I should have said "possibly". I know
it's an accepted practice, and I don't know of any FAA action against
it, but I haven't read all the case law. It wouldn't surprise me a bit
if the FAA used 91.13 in a situation where something bad happened as a
result of someone letting a passenger fly.

In any case, the bottom line here is that yes, not all the time you
spend being PIC or acting as PIC is loggable as PIC time.

rg

Gary Drescher

May 22nd 05, 09:08 PM

"Ron Garret" > wrote in message
...
> I think this structuring of the rules is deliberate and not just an
> oversight. It would have been easy enough to say that a pilot can log
> PIC any time he is acting as PIC, but they apparently went to a lot of
> effort not to say that.

In a flight that doesn't require multiple pilots, the FAA does not want two
pilots to log PIC time simultaneously (one as the actual PIC, the other as
the rated sole manipulator). I'd guess that's why they don't just say that
time *as* PIC is *loggable* as PIC time. They probably just didn't think of
the non-pilot-manipulator case when they wrote the regulation.

> I think this was a deliberate attempt to
> arrange things in such a way that turning over the controls to Aunt
> Tillie is not explicitly banned, but that if you choose to do so and
> anything goes wrong as a result (even in retrospect) they can nail your
> ass to the wall.

It's be just as easy for them to nail you if the time were loggable.

--Gary

Ron Garret

May 22nd 05, 10:10 PM

In article >,
"Gary Drescher" > wrote:

> "Ron Garret" > wrote in message
> ...
> > I think this structuring of the rules is deliberate and not just an
> > oversight. It would have been easy enough to say that a pilot can log
> > PIC any time he is acting as PIC, but they apparently went to a lot of
> > effort not to say that.
>
> In a flight that doesn't require multiple pilots, the FAA does not want two
> pilots to log PIC time simultaneously (one as the actual PIC, the other as
> the rated sole manipulator). I'd guess that's why they don't just say that
> time *as* PIC is *loggable* as PIC time. They probably just didn't think of
> the non-pilot-manipulator case when they wrote the regulation.
>
> > I think this was a deliberate attempt to
> > arrange things in such a way that turning over the controls to Aunt
> > Tillie is not explicitly banned, but that if you choose to do so and
> > anything goes wrong as a result (even in retrospect) they can nail your
> > ass to the wall.
>
> It's be just as easy for them to nail you if the time were loggable.

Yeah, you're probably right. I concede the point.

rg

Jose

May 22nd 05, 11:04 PM

Ron Garret wrote...
> It wouldn't surprise me a bit
> if the FAA used 91.13 in a situation where something bad happened as a
> result of someone letting a passenger fly.

The "something bad" would not be as a result of letting a passenger fly,
it would be as a result of insufficient cockpit management. Same as a
runaway trim or autopilot malfunction.

and also responded to
>>You're still responsible if the organic autopilot goes awry too.

with
>
> Yes, but to legally take on that responsibility "on the record" requires
> an instructor's certificate.

My understanding is that what the instructor certificate allows is for
the student to count the instruction towards the required flight time.
It has nothing to do with "taking on the responsibility".

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

Jose

May 22nd 05, 11:05 PM

> Nobody with more than three brain cells left who goes flying for an hour and lets their 10 year old kid fly for 30 minutes of that hour only logs 30 minutes as PIC.

Well that leaves me out. I have three functioning brain cells, of which
only two operate at the same time.

How many rat cells is the new organic autopilot made from?

Jose
--
The price of freedom is... well... freedom.
for Email, make the obvious change in the address.

Ron Natalie

May 22nd 05, 11:55 PM

Jose wrote:

>
> This is a serious question, especially considering the capabilities of
> some robots, and the lack of capability of some organic autopilots.
>
This is where I usually make some crack about the sole manipulator of
the pilot in command.

[email protected]

May 23rd 05, 08:24 PM

Huh?

"T o d d P a t t i s t" > wrote in message
...
> Ron Garret > wrote:
>
> >> So, you (a regular private pilot) go up in a 172 with a friend who is
> >> not a pilot, you let him take the controls while you very carefully
> >> supervise her, and you can't log the time PIC.
> >
> >That's right.
>
> It's not right. It's perfectly legal to log all the time as
> PIC, and that's what most pilots do.
>
>
> "It is possible to fly without motors, but not without knowledge and
skill."
> Wilbur Wright

OtisWinslow

May 23rd 05, 09:55 PM

Talk the pilot flying into doing it under the hood with you as safety
pilot AND PIC while he/she's under there. You log it as PIC and
they log it as sole manipulator. Plus they get the Instrument time.
Man .. is life great or what.

"CloudyIFR" > wrote in message
oups.com...
> I'm a Part 135 pilot and we're starting to get a lot of missions that
> are two pilot crews. These are in airplanes that don't require a SIC
> as the AutoPilots work, we're not flying over 8 hours and it's not
> required by the Type certificate.
>
> I'm a Captain in all the planes but move to the right seat often. When
> I'm in the right seat what can I log? From my reading of the FAR's I
> can only log Total Time. Is that correct? I can't log PIC as I'm not
> the PIC nor sole manipulator of the controls. Can I log landings,
> Instrument, X/C, etc..?
>
> If you have a reference I'd appreciate it.
>
> Thanks for the help.
>
> Curt
>

Barry

May 24th 05, 01:04 AM

"T o d d P a t t i s t" > wrote:

> I have seen a written interpretation by the Chief Counsel
> stating that the only pilot on board can log PIC time when
> allowing other non-pilots to manipulate the controls. The
> reasoning given was that the only pilot on board was the
> PIC, followed by some handwaving and references to
> definitions in the FARs.

I've never heard of this, and don't see it in my copy of Jeppesen's "FARs
Explained". Do you have the reference?

Ron Garret

May 24th 05, 01:49 AM

In article >,
T o d d P a t t i s t > wrote:

> I posted the answer in this thread. It's because the Chief
> Counsel's Office of the FAA has issued a written
> interpretation saying it's OK. The reasoning is suspect,
> but since it's an answer I want, and since the Chief
> Counsel's opinion is right until it's overturned, I'll
> follow it.

Could you please post a reference so the rest of us can do likewise?

rg

Gary Drescher

May 24th 05, 03:43 PM

"T o d d P a t t i s t" > wrote in message
...
> I looked through my electronic files, but I haven't found it
> yet. I would have posted it if I had. The Chief Counsel's
> Office has a searchable database of interpretations, but
> only the FAA is allowed to use it. We had a retired FAA
> official here who snarfed a copy and he posted the interp
> about 2 years ago. Otherwise we wouldn't know about it,
> unless the original paper letter recipient posted it.

I have no reason to doubt the existence of that letter, but I've long since
decided that I refuse to consider myself bound by "interpretations" that
actually blatantly contradict the FARs, and that are unavailable except as
Internet rumors. If I ever have to defend that stance in court, so be it.
(In this case, of course, the unpublished "interpretation" is actually more
*lenient* than what the FARs actually say.)

--Gary

Bob Moore

May 24th 05, 06:09 PM

T o d d P a t t i s t wrote
> You won't find it in Jeppesen. It's not an FAR. It's an
> official interpretation of the FARs, and is binding on the
> FAA.

Here's one interpretation

June 22, 1977

Mr. Thomas Beane

Dear Mr. Beane:

This letter is in response to your recent letters to the FAA Flight
Standards Service and to the Chief Counsel inquiring about the logging
of pilot-in-command (PIC) time by an airman whenever he is not the
sole manipulator of the controls.

Section 1.1 of the Federal Aviation Regulations defines Pilot in
Command as:

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and
safety of the flight; (2) Has been designated as pilot in command
before or during the flight; and (3) Holds the appropriate category,
class, and type rating, if appropriate, for the conduct of the flight.

Section 61.51(c)(2) of the Federal Aviation Regulations provides, in
pertinent part:

(2) Pilot-in-Command flight time.

(I) A private or commercial pilot may log as pilot in command 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 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

..

A pilot may log PIC time in accordance with Section 61.51(c)(2)(I)
when he is not actually "flying the airplane", if the airplane is one
on which more than one pilot is required under its type certificate or
under the regulations under which the flight is conducted and he is
acting as PIC. Also, a pilot, rated in category and class (e.g.
airplane single-engine) could, as the pilot who "Has final authority
and responsibility for the operation and safety of the flight" log PIC
time if another pilot, not appropriately rated, was actually
manipulating the controls of the aircraft.

It should be noted that more than one pilot may log PIC time for the
same flight time. For example, one pilot receiving instruction may
log PIC time in accordance with paragraph (c)(2)(I) for the time he is
designated PIC, and another pilot may log PIC time in accordance with
(c)(2)(iii) for the same time during which he is actually giving
flight instruction.

We hope that we have satisfactorily responded to your inquiry on the
proper logging of PIC time.

Sincerely,

ORIGINAL SIGNED BY EDWARD P. FABERMAN

for NEIL R. EISNER Acting Assistant Chief Counsel Regulations &
Enforcement Division Office of the Chief Counsel
-

Bob Moore

May 24th 05, 06:20 PM

T o d d P a t t i s t wrote
> I looked through my electronic files, but I haven't found it
> yet. I would have posted it if I had. The Chief Counsel's
> Office has a searchable database of interpretations, but
> only the FAA is allowed to use it. We had a retired FAA
> official here who snarfed a copy and he posted the interp
> about 2 years ago. Otherwise we wouldn't know about it,
> unless the original paper letter recipient posted it.

I typed the following into the "Google Groups" search engine:
"Chief Counsel logging pilot time" and came up with about 250
hits. I really think that all of our "logging" questions have
been thoroughly answered in the past.

Bob Moore

Guillermo

May 24th 05, 08:50 PM

"CloudyIFR" > wrote in message
oups.com...
> I'm a Part 135 pilot and we're starting to get a lot of missions that
> are two pilot crews. These are in airplanes that don't require a SIC
> as the AutoPilots work, we're not flying over 8 hours and it's not
> required by the Type certificate.
>
> I'm a Captain in all the planes but move to the right seat often. When
> I'm in the right seat what can I log? From my reading of the FAR's I
> can only log Total Time. Is that correct? I can't log PIC as I'm not
> the PIC nor sole manipulator of the controls. Can I log landings,
> Instrument, X/C, etc..?

Maybe this doesn't apply exactly to your case, but I wanted to set up
another related discussion.
I was very confused, but then I figured out that the trick is realizing that
acting an PIC and logging PIC time is completely different (as weird as it
sounds).

Case 1: I am PIC, manipulator of controls and I log PIC time (the usual
case)
Case 2: A friend who is rated in an airplane, but is not current, takes over
the controls. He cannot be the PIC because he is not current, but he logs
PIC time because he is sole manipulator and he's rated for the airplane. I
am legally the PIC, but I'm not logging PIC time.
Case 3: I am safety pilot. I log PIC because I am required pilot (PIC) by
the regulation by which the flight is conducted. The manipulator of the
controls logs PIC because he is manipulating the controls.

Now, another question: Is there any regulation that requires that the
manipulator of the controls has to be rated in the aircraft and current? I
mean, is it illegal (if I'm not an instructor) to let a non-rated friend fly
the airplane. I've never found anything that says that is illegal. As long
as you are safe and you don't break the recklessness rules.

Does all this sound right?

guillermo

Barry

May 24th 05, 08:56 PM

>>I've never heard of this, and don't see it in my copy of Jeppesen's
>>"FARs Explained". Do you have the reference?
>
> You won't find it in Jeppesen. It's not an FAR. It's an
> official interpretation of the FARs, and is binding on the
> FAA.

The Jepp "FARs Explained" book combines the text of the FARs with explanations
by aviation attorneys and excerpts from relevant decisions by the FAA Chief
Counsel and NTSB. I've found it a useful book to have. It has several pages
on logging issues, but I found nothing on this scenario of logging PIC time
while allowing a non-pilot to manipulate the controls.

Barry

David Rind

May 25th 05, 12:39 AM

T o d d P a t t i s t wrote:
> Ron Garret > wrote:
>
>
>>>the Chief
>>>Counsel's Office of the FAA has issued a written
>>>interpretation saying it's OK. The reasoning is suspect,
>>>but since it's an answer I want, and since the Chief
>>>Counsel's opinion is right until it's overturned, I'll
>>>follow it.
>>
>>Could you please post a reference so the rest of us can do likewise?
>
>
> I understand why you want the reference, but I don't have
> it. I did spend 20 minutes looking in my saved
> interpretations and old messages, and the closest I found
> was a message I sent in rec.aviation.ifr responding to a
> message from Ron Natalie on 27 Sep 2002 which was after I
> had seen the interpretation. It was likely posted in
> rec.aviation.ifr or .pilot or .student, and it must have
> been before that date. There should be someone here who
> recalls that period and saved a copy of the interpretation.
> I suspect a computer crash prior to 2002 wiped out my copy.
> If it helps anyone, here's the message I sent in 2002:

From a Feb 5 2002 post by Rick Cremer:

> Rick Cremer Feb 5 2002, 6:31 pm show options
>
> Newsgroups: rec.aviation.student
> From: "Rick Cremer" > - Find messages by this author
> Date: Tue, 5 Feb 2002 18:30:46 -0500
> Local: Tues,Feb 5 2002 6:30 pm
> Subject: Re: PP-ASEL logging PIC when flying with student
> Reply to Author | Forward | Print | Individual Message | Show original | Report Abuse
>
>
>
>>>I thought you had an interp on this point already? <<
>
>
> I do. And I had to dig deep for it. it's an oldie and I don't know if would
> stand up to the test of time with all the regulatory changes we've had since
> 1977 but I think it would. Here 'tis
>
> Best
>
>
> ------------------------------*------------------------------*-----------------
> ------------------------------*---------------
> June 22, 1977
>
>
> Mr. Thomas Beane
>
>
> Dear Mr. Beane:
>
>
> This letter is in response to your recent letters to the FAA Flight Standards
> Service and to the Chief Counsel inquiring about the logging of
> pilot-in-command (PIC) time by an airman whenever he is not the sole
> manipulator of the controls.
>
>
> Section 1.1 of the Federal Aviation Regulations defines Pilot in Command as:
>
>
> Pilot in command means the person who:
>
>
> (1) Has final authority and responsibility for the operation and safety of
> the flight;
> (2) Has been designated as pilot in command before or during the flight; and
> (3) Holds the appropriate category, class, and type rating, if appropriate,
> for the conduct of the flight.
>
>
> Section 61.51(c)(2) of the Federal Aviation Regulations provides, in
> pertinent part:
>
>
> (2) Pilot-in-Command flight time.
>
>
> (i) A private or commercial pilot may log as pilot in command 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 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.
>
>
> A pilot may log PIC time in accordance with Section 61.51(c)(2)(i) when he is
> not actually "flying the airplane", if the airplane is one on which more than
> one pilot is required under its type certificate or under the regulations
> under which the flight is conducted and he is acting as PIC. Also, a pilot,
> rated in category and class (e.g. airplane single-engine) could, as the pilot
> who "Has final authority and responsibility for the operation and safety of
> the flight" log PIC time if another pilot, not appropriately rated, was
> actually manipulating the controls of the aircraft.
>
>
> It should be noted that more than one pilot may log PIC time for the same
> flight time. For example, one pilot receiving instruction may log PIC time
> in accordance with paragraph (c)(2)(i) for the time he is designated PIC, and
> another pilot may log PIC time in accordance with (c)(2)(iii) for the same
> time during which he is actually giving flight instruction.
>
>
> We hope that we have satisfactorily responded to your inquiry on the proper
> logging of PIC time.
>
>
> Sincerely,
>
>
> ORIGINAL SIGNED BY EDWARD P. FABERMAN
>
>
> for NEIL R. EISNER Acting Assistant Chief Counsel Regulations & Enforcement
> Division Office of the Chief Counsel
>
>

--
David Rind

Howard Nelson

May 25th 05, 01:18 AM

"Guillermo" > wrote in message
...
> "CloudyIFR" > wrote in message
> oups.com...
> > I'm a Part 135 pilot and we're starting to get a lot of missions that
> > are two pilot crews. These are in airplanes that don't require a SIC
> > as the AutoPilots work, we're not flying over 8 hours and it's not
> > required by the Type certificate.
> >
> > I'm a Captain in all the planes but move to the right seat often. When
> > I'm in the right seat what can I log? From my reading of the FAR's I
> > can only log Total Time. Is that correct? I can't log PIC as I'm not
> > the PIC nor sole manipulator of the controls. Can I log landings,
> > Instrument, X/C, etc..?
>
> Maybe this doesn't apply exactly to your case, but I wanted to set up
> another related discussion.
> I was very confused, but then I figured out that the trick is realizing
that
> acting an PIC and logging PIC time is completely different (as weird as it
> sounds).
>
> Case 1: I am PIC, manipulator of controls and I log PIC time (the usual
> case)
> Case 2: A friend who is rated in an airplane, but is not current, takes
over
> the controls. He cannot be the PIC because he is not current, but he logs
> PIC time because he is sole manipulator and he's rated for the airplane. I
> am legally the PIC, but I'm not logging PIC time.
> Case 3: I am safety pilot. I log PIC because I am required pilot (PIC) by
> the regulation by which the flight is conducted. The manipulator of the
> controls logs PIC because he is manipulating the controls.
>
> Now, another question: Is there any regulation that requires that the
> manipulator of the controls has to be rated in the aircraft and current? I
> mean, is it illegal (if I'm not an instructor) to let a non-rated friend
fly
> the airplane. I've never found anything that says that is illegal. As long
> as you are safe and you don't break the recklessness rules.
>
> Does all this sound right?

In number 3 you and the other pilot need to decide who is PIC. I log "safety
pilot" time in my book but not PIC. If an enforcement action is brought
against the flight the PIC is responsible. My partner and I usually have the
person under the hood as PIC.

Howard

> guillermo
>
>

Jay Beckman

May 25th 05, 01:35 AM

"Howard Nelson" > wrote in message
.. .
>
>
> In number 3 you and the other pilot need to decide who is PIC. I log
> "safety
> pilot" time in my book but not PIC. If an enforcement action is brought
> against the flight the PIC is responsible. My partner and I usually have
> the
> person under the hood as PIC.
>
> Howard

As a strictly VFR pilot at this point, I'm just curious about this:

When I hear other planes asking various valley ATC facilities to (don't
really know the right term...) "allow" them to practice approaches to
airports around the Phoenix area, the words "radar services not available,
maintain VFR" are often the last words out of the controllers mouth.

Given that the PIC is ultimately responsible for the safety of the flight,
how (if the person under the hood is the PIC) does this flight legally
maintain Visual Flight Rules when the PIC does not have any Visual?

TIA,

Jay Beckman
PP-ASEL
Chandler, AZ