PDA

View Full Version : Re: Logging PIC time as student instrument pilot in IMC


Greg Esres
July 24th 03, 07:05 PM
<<I recently realized that I should not have included any "actual"
(IMC) time recorded in my logbook as PIC time while I was an
instrument student.
>>

Why not? If you were actual, then it was PIC.

<<how about adding a "corrective" (new) entry?>>

That's what I do. Just make +/- entries to total with explanation.

Gary L. Drescher
July 24th 03, 08:07 PM
"Marty Ross" > wrote in message
t...
> I recently realized that I should not have included any "actual" (IMC)
time
> recorded in my logbook as PIC time while I was an instrument student.

Why not? You weren't PIC, but you can still log PIC time as the rated sole
manipulator (unless your CFII was flying the plane for you).

> Any suggestions for correcting this error? Rather than making messy
> corrections and recalculating page totals, how about adding a "corrective"
> (new) entry?
>
> More generally, are there any accepted conventions for retroactively
> correcting logbook errors?

I use an Excel spreadsheet as my logbook, so corrections are seamless. :)

--Gary

Greg Esres
July 24th 03, 08:14 PM
<<If it was actual, then someone else had better have been PIC.>>

The question was concerning logging, not acting.

Ron Natalie
July 24th 03, 08:25 PM
"Greg Esres" > wrote in message ...
> <<If it was actual, then someone else had better have been PIC.>>
>
> The question was concerning logging, not acting.
>
I know that (and said so in the second sentence which you decided
to omit). What I was trying to address was your comment:
If you were actual, then it was PIC.

Which makes no sense. What is the "it" in the second clause.
Insturment time has nothing to do with PIC time.

Ron Rosenfeld
July 24th 03, 08:34 PM
On Thu, 24 Jul 2003 17:32:38 GMT, "Marty Ross" >
wrote:

>I recently realized that I should not have included any "actual" (IMC) time
>recorded in my logbook as PIC time while I was an instrument student.

What makes you think that?

To log PIC time:

61.51(e) Logging pilot-in-command flight time. (1) A 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;

Were you not 'rated' in the aircraft?

To log instrument time:

61.51(g) Logging instrument flight time. (1) A person may log instrument
time only for that flight time when the person operates the aircraft solely
by reference to instruments under actual or simulated instrument flight
conditions.

Neither paragraph says anything about needing to have an instrument rating;
or even about being qualified to ACT as PIC in the aircraft.

You do have to be rated. In other words, if you are a private pilot with a
Single-Engine Land rating, you cannot log PIC time in a Multi-Engine
aircraft (or a balloon, glider, etc).

Just remember: the rules for LOGGING PIC bear no relationship to the rules
for ACTING as PIC.



Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Paul Baechler
July 24th 03, 09:45 PM
In article >,
Greg Esres > wrote:

>Why not? If you were actual, then it was PIC.

If he was actual is irrelevant. If he was sole manipulator, it was PIC.

--
Paul Baechler

Marty Ross
July 26th 03, 09:02 AM
Wow, what a mincing (slicing/dicing) of words this post has triggered!

I appreciate all of your attempts to second (and even third) guess what was
the original intend of my post in order to help!

Indeed, it was my understanding that I could not log PIC time for IMC I had
flown (yes - albeit as "sole manipulator") while with my instrument
instructor. This is because on my last few flights he corrected his entry
in my logbook, reducing the PIC time by exactly the amount he wrote in the
"Actual" column. When I asked him about this, I believe he said something
like: "since you're not currently rated to act as PIC in actual IFR
conditions, you can't log it as PIC time [even though you're sole
manipulator of the controls]" (content in brackets my interpretation of his
meaning).

I understood this situation to be similar to the situation another person
asked recently on a related forum: "can a student pilot that flies with me
[a PPL] log time?", and the consensus here was: "no, he can't because he's
not yet rated to fly ". Using that logic, it seemed to make
sense to me.

However, as someone pointed out, my post really was more about correcting
logbook errors. The fact that I may not have the error I think I have was
secondary. And, about that, I think I will insert a "adjustment" line into
my logbook that corrects for any errors I may find (no one seemed to think
that was a "bad" idea). I don't like the idea of using white-out and
recalculating page balances, it seems too messy and could introduce new
errors that would be even harder to correct later.

Regards,

-- Marty

"Marty Ross" > wrote in message
t...[i]
> I recently realized that I should not have included any "actual" (IMC)
time
> recorded in my logbook as PIC time while I was an instrument student.
>
> Any suggestions for correcting this error? Rather than making messy
> corrections and recalculating page totals, how about adding a "corrective"
> (new) entry?
>
> More generally, are there any accepted conventions for retroactively
> correcting logbook errors?
>
>
>
>

Ron Rosenfeld
July 26th 03, 12:14 PM
On Sat, 26 Jul 2003 08:02:19 GMT, "Marty Ross" >
wrote:

>since you're not currently rated to act as PIC in actual IFR
>conditions, you can't log it as PIC time [even though you're sole
>manipulator of the controls]" (content in brackets my interpretation of his
>meaning).

He is incorrect. His understanding of the term "rated" is not in accord
with the FAA Chief Counsel.

From a CC opinion (6/3/1999):

"14 CFR section 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 section 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
section 61.5 and are placed on the pilot certificate.

Therefore, based on the scenario given to Mr. Lynch, 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 is 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 section 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
section 61.31."

Also note this earlier CC opinion regarding your exact situation:

"In your third question you ask "[d]uring 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."


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

David Brooks
July 28th 03, 06:53 PM
"Todd Pattist" > wrote in message
...

> >However, as someone pointed out, my post really was more about correcting
> >logbook errors.
>
> You got more interest in the first part (your incorrect
> assumption) since that has a right/wrong answer and makes a
> difference. How you make entries in the logbook is merely a
> preference with no real importance to anyone except neatniks
> :-)
>
> >The fact that I may not have the error I think I have was
> >secondary.
>
> To you, perhaps, but many who post here are more interested
> in answering questions that seem to be important to them
> than questions that are merely important to you :-)

Another possible line of inquiry might be:

Has anyone had any grief from a DE or FAA rep about the way they made
corrections in their logbook? What was it that made the examiner unhappy?

(to the people in r.a.p and not r.a.i, welcome to the thread)

-- David Brooks

Snowbird
July 28th 03, 10:37 PM
"Marty Ross" > wrote in message k.net>...
> Indeed, it was my understanding that I could not log PIC time for IMC I had
> flown (yes - albeit as "sole manipulator") while with my instrument
> instructor. This is because on my last few flights he corrected his entry
> in my logbook, reducing the PIC time by exactly the amount he wrote in the
> "Actual" column. When I asked him about this, I believe he said something
> like: "since you're not currently rated to act as PIC in actual IFR
> conditions, you can't log it as PIC time [even though you're sole
> manipulator of the controls]" (content in brackets my interpretation of his
> meaning).

It is my belief that your flight instructor is incorrect
and that his opinion disagrees with several opinions from the
FAA Counsel's Office.

FWIW, this is how my actual time is logged: as PIC. My husband,
or my CFI, who acted as PIC, also logged PIC time.

> I understood this situation to be similar to the situation another person
> asked recently on a related forum: "can a student pilot that flies with me
> [a PPL] log time?", and the consensus here was: "no, he can't because he's
> not yet rated to fly [in the current situation; namely, with a passenger,
> even though he was sole manipulator]". Using that logic, it seemed to make
> sense to me.

I don't follow how your logic makes sense of this. There is a specific
regulation which covers logging PIC time. It states several
restrictions, including that the pilot must be rated. It says
nothing about the conditions of flight. If you're rated, and you
meet another criterion (such as "sole manipulator of the controls")
you can log PIC. Different situation than the student pilot analogy.

There is another regulation which covers who can *act* as PIC
under IFR, but it says nothing about logging the time.

Now, I will admit that to the uninitiated, this distinction between
*acting* as PIC vs *logging* PIC seems a bit bizarre. However,
to this I reply with DH's words: "these are Federal Regulations.
You're expecting them to make sense. That's your mistake. That's
where you're going wrong."

> However, as someone pointed out, my post really was more about correcting
> logbook errors.

FWIW:
I correct logbook entry errors the same way I correct my laboratory
notebook at work. Whiteout is verboten. I cross out the errant numbers
with a single ink line, initial and date above the line. I either
write in the correct number next to it, or write something like "see
entry XXX dated xx-xx-xxxx for correction".

HTH,
Sydney

David Brooks
July 28th 03, 11:48 PM
"Snowbird" > wrote in message
om...

> FWIW, this is how my actual time is logged: as PIC. My husband,
> or my CFI, who acted as PIC, also logged PIC time.

Well, I've often wondered about that one. From everyone's second-favorite
FAR:

A ... pilot may log pilot-in-command time only for that flight time during
which that person (is sole manip, sole occupant, or) ...is acting as pilot
in command of an aircraft on which more than one pilot is required under ...
the regulations under which the flight is conducted.

The regs have to *require* more than one pilot. Usually an ASEL flown under
IFR does not require more than one pilot by regulation. So it would seem not
to count.

However, if you are saying "given that this is a flight under IFR where the
controls are manipulated by a non-IR pilot, then the regulations do require
two pilots: the PF and the PNF/PIC", then they can log it.

-- David Brooks

Sydney Hoeltzli
July 29th 03, 03:03 AM
David Brooks wrote:
> "Snowbird" > wrote in message
> om...
>>FWIW, this is how my actual time is logged: as PIC. My husband,
>>or my CFI, who acted as PIC, also logged PIC time.

> Well, I've often wondered about that one. From everyone's second-favorite
> FAR:
> A ... pilot may log pilot-in-command time only for that flight time during
> which that person (is sole manip, sole occupant, or) ...is acting as pilot
> in command of an aircraft on which more than one pilot is required under ...
> the regulations under which the flight is conducted.

Correct.

> The regs have to *require* more than one pilot. Usually an ASEL flown under
> IFR does not require more than one pilot by regulation. So it would seem not
> to count.

> However, if you are saying "given that this is a flight under IFR where the
> controls are manipulated by a non-IR pilot, then the regulations do require
> two pilots: the PF and the PNF/PIC", then they can log it.

Yes, exactly. That appears to be the General Counsel interpretation --
Andrew Sarangan had a General Counsel letter on his website relevant to
the topic. Ron Rosenfeld referred to one. I have an email
correspondence with John Lynch of a few years back where he initially
disagreed, then consulted the GC office and came back concurring.

That's why we felt it was appropriate to log it as we did (why we
chose to log it that way is a seperate issue)

Cheers,
Sydney

Ron Rosenfeld
July 29th 03, 03:07 AM
On Mon, 28 Jul 2003 15:48:03 -0700, "David Brooks" >
wrote:

>However, if you are saying "given that this is a flight under IFR where the
>controls are manipulated by a non-IR pilot, then the regulations do require
>two pilots: the PF and the PNF/PIC", then they can log it.

If I understand you correctly, I believe this statement of yours is wrong.
Given a light SEL a/c, what regulation requires *two* pilots under the
circumstances you put forth?

I'm not aware of any such regulation.

The fact that the person manipulating the controls is not legal to act as
PIC under IFR does not lead to a regulatory requirement to have two pilots
in the aircraft. The only pilot that is *required* is the one who is
acting as PIC. The PF is not *required* by the regulations.

So in the instance where the acting PIC/PNF is not a CFI(I) giving
instruction, the PNF cannot log PIC time.

An instance where the non-CFI PNF may log PIC time because of a regulatory
requirement for two pilots would be when the PNF is acting as a safety
pilot in simulated instrument conditions. Under that circumstance, two
pilots are required by the regulations (91.109) and both may log PIC time.




Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Robert M. Gary
July 29th 03, 05:16 AM
No instrument rating is required to log actual. In fact, there are
times when you can log actual in VMC (dark moonless night over water
is the FAA example).
Of course, you cannot, cannot serve as PIC in IMC or anytime while on
an IFR clearance but I assume your CFII took care of that.



"Marty Ross" > wrote in message >...
> I recently realized that I should not have included any "actual" (IMC) time
> recorded in my logbook as PIC time while I was an instrument student.
>
> Any suggestions for correcting this error? Rather than making messy
> corrections and recalculating page totals, how about adding a "corrective"
> (new) entry?
>
> More generally, are there any accepted conventions for retroactively
> correcting logbook errors?

Barry
July 29th 03, 12:25 PM
A lot of these situations are covered in the FAA's Part 61 Frequently Asked
Questions:

http://www.faa.gov/avr/afs/afs800/docs/pt61FAQ.doc

This is a big file (about 2.2MB).

Barry

Ron Rosenfeld
July 29th 03, 01:17 PM
On Tue, 29 Jul 2003 02:03:40 GMT, Sydney Hoeltzli >
wrote:

>Yes, exactly. That appears to be the General Counsel interpretation --
>Andrew Sarangan had a General Counsel letter on his website relevant to
>the topic. Ron Rosenfeld referred to one.

Actually, the CC opinions I referred allowed the *PF* to log PIC time.
They did not allow the PNF (acting PIC) to log PIC time. Although if the
acting PIC were either a CFI(I) giving instruction, or a safety pilot in
simulated instrument conditions, then the regulations would allow the PNF
to log PIC time.

At one time, there was information in the Part 61 FAQ's suggesting that the
PNF acting PIC could also log PIC time when the PF was not instrument
rated/current/confident. However, I just looked at that source again and
cannot locate that information in the revision dated 12/19/2000.

There was a letter from Alan Pinkston (in the FAA CC office) also
suggesting the PNF might be able to log PIC time during IMC, however, the
wording is "When the person in the right seat is acting as safety pilot as
a result of 91.109 for avoidance of traffic, or in the case of instrument
meteorological conditions since that person provides safety for the flight,
(***as well as legal rating requirements***) both persons may log pilot in
command time. "

(Emphasis mine). This implies that if the PNF is required for legal rating
requirements (or under 91.109) then PNF could log PIC time.




Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Robert M. Gary
July 31st 03, 08:46 PM
Sydney Hoeltzli > wrote in message >...

> Correct.
>
> > The regs have to *require* more than one pilot. Usually an ASEL flown under
> > IFR does not require more than one pilot by regulation. So it would seem not
> > to count.
>
> > However, if you are saying "given that this is a flight under IFR where the
> > controls are manipulated by a non-IR pilot, then the regulations do require
> > two pilots: the PF and the PNF/PIC", then they can log it.
>
> Yes, exactly. That appears to be the General Counsel interpretation --
> Andrew Sarangan had a General Counsel letter on his website relevant to
> the topic. Ron Rosenfeld referred to one. I have an email
> correspondence with John Lynch of a few years back where he initially
> disagreed, then consulted the GC office and came back concurring.
>
> That's why we felt it was appropriate to log it as we did (why we
> chose to log it that way is a seperate issue)


But the flying pilot must be under a hood in order for the non-flying
(acting as PIC ) pilot to log PIC too. Actual instrument doesn't cut
it because there is no FAR requiring multiple crew for part 91 IFR,
there is one for wearing a hood.

Ron Rosenfeld
July 31st 03, 11:14 PM
On Thu, 31 Jul 2003 13:17:19 -0700, "David Brooks" >
wrote:

> If it is "a flight under IFR in
>which the controls are, in fact, for at least some of the time, manipulated
>by a pilot who is not IR or not current" then two pilots are required

What regulation requires two pilots under this circumstance?


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

David Brooks
August 1st 03, 02:14 AM
"Ron Rosenfeld" > wrote in message
...
> On Thu, 31 Jul 2003 13:17:19 -0700, "David Brooks"
>
> wrote:
>
> > If it is "a flight under IFR in
> >which the controls are, in fact, for at least some of the time,
manipulated
> >by a pilot who is not IR or not current" then two pilots are required
>
> What regulation requires two pilots under this circumstance?

61.3(e)(1) for the "not IR" option. As I said, I am manufacturing an
artificially rigid definition of the flight to try to figure out if there is
any rationale for logging PIC. Almost a reduction ad absurdum.

-- David Brooks

Ron Rosenfeld
August 1st 03, 04:15 AM
On Thu, 31 Jul 2003 18:14:00 -0700, "David Brooks" >
wrote:

>"Ron Rosenfeld" > wrote in message
...
>> On Thu, 31 Jul 2003 13:17:19 -0700, "David Brooks"
>
>> wrote:
>>
>> > If it is "a flight under IFR in
>> >which the controls are, in fact, for at least some of the time,
>manipulated
>> >by a pilot who is not IR or not current" then two pilots are required
>>
>> What regulation requires two pilots under this circumstance?
>
>61.3(e)(1) for the "not IR" option. As I said, I am manufacturing an
>artificially rigid definition of the flight to try to figure out if there is
>any rationale for logging PIC. Almost a reduction ad absurdum.
>
>-- David Brooks
>

I don't see 61.3 (e) (1) requiring two pilots in the case where a non-rated
person (or pilot) happens to be manipulating the controls.

The only pilot that is *required* is the one who is acting as PIC.

================
61.3 e) Instrument rating. No person may act as pilot in command of a civil
aircraft under IFR or in weather conditions less than the minimums
prescribed for VFR flight unless that person holds:
(1) The appropriate aircraft category, class, type (if required), and
instrument rating on that person's pilot certificate for any airplane,
helicopter, or powered-lift being flown;
==================


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Teacherjh
August 1st 03, 05:08 AM
>>
I don't see 61.3 (e) (1) requiring two pilots in the case where a non-rated
person (or pilot) happens to be manipulating the controls.

The only pilot that is *required* is the one who is acting as PIC.
<<

Well, there's no such requirment for a hood either - the only required pilot is
the PIC. As long as the PIC can see out, you can have a trained hamster under
the hood manipulating the controls.

Jose

(for Email, make the obvious changes in my address)

Ron Rosenfeld
August 1st 03, 02:04 PM
On 01 Aug 2003 04:08:54 GMT, (Teacherjh) wrote:

>Well, there's no such requirment for a hood either - the only required pilot is
>the PIC. As long as the PIC can see out, you can have a trained hamster under
>the hood manipulating the controls.

I think what you are saying is that there is no requirement for a second
pilot if the person flying is wearing a hood.

If that is what you are saying, I would disagree. 91.109(b) is pretty
clear in requiring a second pilot if the person flying is wearing a hood:

===============
(b) No person may operate a civil aircraft in simulated instrument flight
unless--
(1) The other control seat is occupied by a safety pilot who possesses at
least a private pilot certificate with category and class ratings
appropriate to the aircraft being flown.
==============

In addition, numerous FAA Chief Council legal opinions have upheld this
interpretation.

Now so far as the trained hamster wearing a hood, the regulation does say
"person" and I would not consider a trained hamster to be a "person" :-))


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Teacherjh
August 1st 03, 04:42 PM
>>
I think what you are saying is that there is no requirement for a second
pilot if the person flying is wearing a hood.
<<

No, that's not what I'm saying. What I'm saying is that there's no requirement
to even use a hood unless the "purpose of the flight" is to fly under the hood.
Absent that, the only required pilot is the one not wearing the hood. The one
wearing the hood is superfluous (except that the purpose of the flight is to
give the hooded pilot the chance to fly).

Well, if the thread is really that thin, then it ought to apply in actual too.
If the "purpose of the flight" is to have the non-IR pilot fly in the clouds,
then another pilot is required. But the flight itself could be conducted
without the non-IR pilot, just like the above flight could be conducted without
the hooded pilot.

The only difference I see is the lack of a 91.109(q) which would say:
(q) No person may operate a civil aircraft in actual instrument flight
unless--
[...] or
(2) The other control seat is occupied by a safety pilot who possesses at
least a private pilot certificate and instrument rating with category and
class ratings appropriate to the aircraft being flown.

Is this what it hangs on?

Jose

(for Email, make the obvious changes in my address)

Ron Rosenfeld
August 2nd 03, 04:44 AM
On 01 Aug 2003 15:42:55 GMT, (Teacherjh) wrote:

>>>
>I think what you are saying is that there is no requirement for a second
>pilot if the person flying is wearing a hood.
><<
>
>No, that's not what I'm saying. What I'm saying is that there's no requirement
>to even use a hood unless the "purpose of the flight" is to fly under the hood.
> Absent that, the only required pilot is the one not wearing the hood. The one
>wearing the hood is superfluous (except that the purpose of the flight is to
>give the hooded pilot the chance to fly).

We agree!

>
>Well, if the thread is really that thin, then it ought to apply in actual too.
>If the "purpose of the flight" is to have the non-IR pilot fly in the clouds,
>then another pilot is required. But the flight itself could be conducted
>without the non-IR pilot, just like the above flight could be conducted without
>the hooded pilot.

I don't think that 91.109 speaks to the "purpose of the flight". I think
it rather speaks to safety implications.

>
>The only difference I see is the lack of a 91.109(q) which would say:
>(q) No person may operate a civil aircraft in actual instrument flight
>unless--
>[...] or
>(2) The other control seat is occupied by a safety pilot who possesses at
>least a private pilot certificate and instrument rating with category and
>class ratings appropriate to the aircraft being flown.
>
>Is this what it hangs on?
>

It doesn't apply in actual because the function of a safety pilot is to
enable the pilot flying (PF) under the hood to avoid conflicting traffic.
So if you can't see out the window, the safety pilot is superfluous.

The "second pilot" requirement allows the safety pilot to log PIC time, if
he is the actual PIC. If there is no second pilot requirement, then only
the PF can log PIC time (even thought the PF is not the PIC).

In general, a PNF/PIC (non-CFI) cannot log PIC time (in small GA a/c).
This is an exception to that general rule.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Mike Weller
August 2nd 03, 05:20 PM
On 1 Aug 2003 15:48:15 -0700, (Alex) wrote:

>I had an FAA Safety Inspector once scold me for having poor
>handwriting. He said that the way I kept my log book spoke volumes of
>the way I flew (this was before we flew together).
>
>Next he refused to pass me on the oral portion of the test until I
>took my log book and converted all the ditto marks to actual
>make/models and identifiers. So I sat in the corner and crossed out
>the three years I owned an airplane and wrote in the same make/model
>and ident on every line.
>
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class.
I will not chew gum in class. I will not chew gum in class...

Mike Weller

Google