A couple of questions about IPC

[Paul Tomblin]

I've only done one approach in the last 6 months. I've let my currency
lapse, so as I read the regs I now have to do an IPC, right? What does an
IPC consist of? Just 6 approaches and a hold, or is there more to it?
Can it be fewer than 6 approaches?

--
Paul Tomblin > http://xcski.com/blogs/pt/
"You're one of those condescending Unix computer users!"
"Here's a nickel, kid. Get yourself a better computer" - Dilbert.

[Dave Butler]

Paul Tomblin wrote:
> I've only done one approach in the last 6 months. I've let my currency
> lapse, so as I read the regs I now have to do an IPC, right? What does an
> IPC consist of? Just 6 approaches and a hold, or is there more to it?
> Can it be fewer than 6 approaches?

[from memory] don't you have another 6 months after your currency lapses in
which you can regain your currency by flying with a safety pilot? ...not that an
IPC is a bad idea.

Dave

[three-eight-hotel]

You have 6 months after your currency lapses to become current, without
having to do an IPC... You are not legal to fly IFR, but you may take
a safety pilot up with you and become current again. If you miss the 6
month window to become current, you will have to perform an IPC.

I'm sure if I stated that incorrectly or unclearly, someone will jump
in to correct me... ;-)

Best Regards,
Todd

[Robert Chambers]

The IPC can consist of whatever you want to make yourself current. 6
approaches, tracking VOR's and holding, which you can do with a safety
pilot. However since you have the CFII in the plane with you, it could
be something else you'd like to work on such as timed turns or partial
panel, along with a couple of approaches and a hold or so.

The CFII is going to assess whether you are safe and competant to fly
IFR and signs the log book to that effect. I do an IPC with my CFI
whenever I haven't flown in the gauges for a while and want to make sure
that I haven't picked up any bad habits.

Technically you don't need to do the IPC until 1 year after you lose IFR
currency but you don't have to do just the minimum required to get by.

Robert

Paul Tomblin wrote:
> I've only done one approach in the last 6 months. I've let my currency
> lapse, so as I read the regs I now have to do an IPC, right? What does an
> IPC consist of? Just 6 approaches and a hold, or is there more to it?
> Can it be fewer than 6 approaches?
>

[Mark Hansen]

On 02/09/06 07:07, Robert Chambers wrote:
> The IPC can consist of whatever you want to make yourself current. 6
> approaches, tracking VOR's and holding, which you can do with a safety
> pilot. However since you have the CFII in the plane with you, it could
> be something else you'd like to work on such as timed turns or partial
> panel, along with a couple of approaches and a hold or so.
>
> The CFII is going to assess whether you are safe and competant to fly
> IFR and signs the log book to that effect. I do an IPC with my CFI
> whenever I haven't flown in the gauges for a while and want to make sure
> that I haven't picked up any bad habits.
>
> Technically you don't need to do the IPC until 1 year after you lose IFR
> currency but you don't have to do just the minimum required to get by.

Actually, the IPC is required 6 months after you lose currency.


>
> Robert
>
> Paul Tomblin wrote:
>> I've only done one approach in the last 6 months. I've let my currency
>> lapse, so as I read the regs I now have to do an IPC, right? What does an
>> IPC consist of? Just 6 approaches and a hold, or is there more to it?
>> Can it be fewer than 6 approaches?
>>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[paul kgyy]

You only have to satisfy the CFII that you can do the job. I take
these routinely because a couple of hours with an instructor are always
beneficial and not that expensive in AMUs.

Typically, it will be similar to an IFR lesson - do 3 different types
of approach, practice a steep turn, find a radial, do a hold, recover
from unusual attitude, and back to the barn for a signing ceremony.

[Gary Drescher]

"three-eight-hotel" > wrote in message
oups.com...
> You have 6 months after your currency lapses to become current, without
> having to do an IPC... You are not legal to fly IFR, but you may take
> a safety pilot up with you and become current again. If you miss the 6
> month window to become current, you will have to perform an IPC.
>
> I'm sure if I stated that incorrectly or unclearly, someone will jump
> in to correct me... ;-)

No error, but one addition may be useful: another alternative is to fly IFR
and do the approaches in IMC, but with another pilot (who's IFR-current)
acting as PIC.

--Gary

[Robert M. Gary]

> The IPC can consist of whatever you want to make yourself current.

The IPC tasks are very strictly defined by the instrument PTS task
table.

-Robert

[Robert M. Gary]

I still consider an IPC every 6 months with a CFII to be important to
me. In my opinion, if you are the type of instrument pilot who just
pops through a hole every once-in-a-while doing hood work with a friend
is probably ok. However, if you regularly fly actual IMC you probably
want to do an IPC every 6 months (or at least every other one at 12
months).

-Robert, CFI

[Mark Hansen]

On 02/09/06 07:45, Gary Drescher wrote:
> "three-eight-hotel" > wrote in message
> oups.com...
>> You have 6 months after your currency lapses to become current, without
>> having to do an IPC... You are not legal to fly IFR, but you may take
>> a safety pilot up with you and become current again. If you miss the 6
>> month window to become current, you will have to perform an IPC.
>>
>> I'm sure if I stated that incorrectly or unclearly, someone will jump
>> in to correct me... ;-)
>
> No error, but one addition may be useful: another alternative is to fly IFR
> and do the approaches in IMC, but with another pilot (who's IFR-current)
> acting as PIC.
>
> --Gary
>
>

Wait a tick ;-) Are you saying that if you're beyond the 6-month
currency, that you can fly in actual IMC and all you need is an IR-
current safety pilot - not a CFII?

Can you show the FAR or chief counsel opinion which shows this?
This would be yet another place where my instructor taught me incorrect
information ;-(

--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Roy Smith]

Paul Tomblin > wrote:
> I've only done one approach in the last 6 months. I've let my
> currency lapse, so as I read the regs I now have to do an IPC,
> right?

No. If you're less than 6 months out of currency, you can go get
yourself current again by flying 6 approachs and a hold with a safety
pilot. If you let things go beyond 6 months (from the date you ran
out of IFR currency), *then* you need to do an IPC. You can elect to
do an IPC anyway.

> What does an IPC consist of? Just 6 approaches and a hold, or is
> there more to it? Can it be fewer than 6 approaches?

The IFR PTS lays out the details. To a reasonable approximation, it's
a repeat of your instrument checkride. In practice, what I want to
see is that you can fly a partial-panel ILS, a full-procedure GPS
approach, a hold, and still remember how to navigate without a GPS
(i.e. a VOR or LOC approach flown with just the nav radios).

[Mitty]

On 2/9/2006 10:52 AM, Mark Hansen wrote the following:
>
> Wait a tick ;-) Are you saying that if you're beyond the 6-month
> currency, that you can fly in actual IMC and all you need is an IR-
> current safety pilot - not a CFII?
>

Sure. The IFR-current pilot would be PIC and could legally let a
monkey handle the controls if he chose to, so why not an IA rated pilot?

[Mark Hansen]

On 02/09/06 09:02, Mitty wrote:
>
> On 2/9/2006 10:52 AM, Mark Hansen wrote the following:
>>
>> Wait a tick ;-) Are you saying that if you're beyond the 6-month
>> currency, that you can fly in actual IMC and all you need is an IR-
>> current safety pilot - not a CFII?
>>
>
> Sure. The IFR-current pilot would be PIC and could legally let a
> monkey handle the controls if he chose to, so why not an IA rated pilot?

Yes, but I didn't think this 'monkey' was allowed to use the time toward
IR currency.


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Jim Macklin]

The IPC now is listed as a procedure in the PTS for the
instrument rating, it is no longer just a "pick your own"
flight.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Robert Chambers" > wrote in
message
om...
| The IPC can consist of whatever you want to make yourself
current. 6
| approaches, tracking VOR's and holding, which you can do
with a safety
| pilot. However since you have the CFII in the plane with
you, it could
| be something else you'd like to work on such as timed
turns or partial
| panel, along with a couple of approaches and a hold or so.
|
| The CFII is going to assess whether you are safe and
competant to fly
| IFR and signs the log book to that effect. I do an IPC
with my CFI
| whenever I haven't flown in the gauges for a while and
want to make sure
| that I haven't picked up any bad habits.
|
| Technically you don't need to do the IPC until 1 year
after you lose IFR
| currency but you don't have to do just the minimum
required to get by.
|
| Robert
|
| Paul Tomblin wrote:
| > I've only done one approach in the last 6 months. I've
let my currency
| > lapse, so as I read the regs I now have to do an IPC,
right? What does an
| > IPC consist of? Just 6 approaches and a hold, or is
there more to it?
| > Can it be fewer than 6 approaches?
| >

[Ron Rosenfeld]

On Thu, 09 Feb 2006 09:23:33 -0800, Mark Hansen >
wrote:

>On 02/09/06 09:02, Mitty wrote:
>>
>> On 2/9/2006 10:52 AM, Mark Hansen wrote the following:
>>>
>>> Wait a tick ;-) Are you saying that if you're beyond the 6-month
>>> currency, that you can fly in actual IMC and all you need is an IR-
>>> current safety pilot - not a CFII?
>>>
>>
>> Sure. The IFR-current pilot would be PIC and could legally let a
>> monkey handle the controls if he chose to, so why not an IA rated pilot?
>
>Yes, but I didn't think this 'monkey' was allowed to use the time toward
>IR currency.

If you review 61.57 regarding instrument currency, you will see that the
requirements are for logging flight under actual or simulated instrument
conditions.

The requirements for logging are merely that you be sole manipulator of the
controls.

So yes, the non-current pilot can manipulate the controls and log PIC in
IMC, while the IR pilot acts as PIC, but cannot log PIC while in IMC.


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

[Robert Chambers]

I meant to say you don't have to do 6 approaches, holds and VOR tracking
which is the requirement for currency. You do have to fly to standards
with the CFI or he/she would be remiss in signing off the IPC.

Robert M. Gary wrote:
>>The IPC can consist of whatever you want to make yourself current.
>
>
> The IPC tasks are very strictly defined by the instrument PTS task
> table.
>
> -Robert
>

[Robert Chambers]

Mark Hansen wrote:

>
>
> Actually, the IPC is required 6 months after you lose currency.
>

Duh, how about a year AFTER the last thing you did that kept you current
either though the (6 apps, hold, vor track) or the last IPC you did.

I mean a year after your "lack of currency" clock started ticking which
of course is 6 months before your considered no longer current to fly IFR.

[Mark Hansen]

On 02/09/06 11:07, Ron Rosenfeld wrote:
> On Thu, 09 Feb 2006 09:23:33 -0800, Mark Hansen >
> wrote:
>
>>On 02/09/06 09:02, Mitty wrote:
>>>
>>> On 2/9/2006 10:52 AM, Mark Hansen wrote the following:
>>>>
>>>> Wait a tick ;-) Are you saying that if you're beyond the 6-month
>>>> currency, that you can fly in actual IMC and all you need is an IR-
>>>> current safety pilot - not a CFII?
>>>>
>>>
>>> Sure. The IFR-current pilot would be PIC and could legally let a
>>> monkey handle the controls if he chose to, so why not an IA rated pilot?
>>
>>Yes, but I didn't think this 'monkey' was allowed to use the time toward
>>IR currency.
>
> If you review 61.57 regarding instrument currency, you will see that the
> requirements are for logging flight under actual or simulated instrument
> conditions.
>
> The requirements for logging are merely that you be sole manipulator of the
> controls.
>
> So yes, the non-current pilot can manipulate the controls and log PIC in
> IMC, while the IR pilot acts as PIC, but cannot log PIC while in IMC.

Yes, I see that. I think I just had the wrong impression based on something
my instructor told me - and didn't question.

I won't bother with the details, as I'm convinced now that he was
wrong.

Thanks!

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


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Robert M. Gary]

> I meant to say you don't have to do 6 approaches, holds and VOR tracking

That's true. In fact an IPC can often take less time than doing the 6
in 6 with a safety pilot. In fact, the entire instrument PTS is very
thin compared to the other PTSs. The items on the instrument PTS are
not numerous, just challenging.

-Robert, CFI

[three-eight-hotel]

More of an FYI than a response to any particular post, but doing a
quick google on +ipc +pts, took me to some CFI's home page, with a nice
little layout of the IPC

Here's the link, if anyone is interested...

http://www.geocities.com/cfidarren/fr-ipc.htm

Best Regards,
Todd

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> On 02/09/06 07:45, Gary Drescher wrote:
>> "three-eight-hotel" > wrote in message
>> oups.com...
>>> You have 6 months after your currency lapses to become current, without
>>> having to do an IPC... You are not legal to fly IFR, but you may take
>>> a safety pilot up with you and become current again. If you miss the 6
>>> month window to become current, you will have to perform an IPC.
>>>
>>> I'm sure if I stated that incorrectly or unclearly, someone will jump
>>> in to correct me... ;-)
>>
>> No error, but one addition may be useful: another alternative is to fly
>> IFR and do the approaches in IMC, but with another pilot (who's
>> IFR-current) acting as PIC.
>>
>> --Gary
>
> Wait a tick ;-) Are you saying that if you're beyond the 6-month
> currency, that you can fly in actual IMC and all you need is an IR-
> current safety pilot - not a CFII?

In this case, the IR-current pilot isn't functioning as "safety pilot".
That's the term for a traffic-spotting pilot in VMC when the pilot doing the
flying is wearing a hood. In my scenario, there's no hood and no safety
pilot--just another pilot acting as PIC.

--Gary

[Gary Drescher]

"Ron Rosenfeld" > wrote in message
...
> On Thu, 09 Feb 2006 09:23:33 -0800, Mark Hansen >
> wrote:
>>Yes, but I didn't think this 'monkey' was allowed to use the time toward
>>IR currency.
>
> If you review 61.57 regarding instrument currency, you will see that the
> requirements are for logging flight under actual or simulated instrument
> conditions.
>
> The requirements for logging are merely that you be sole manipulator of
> the
> controls.
>
> So yes, the non-current pilot can manipulate the controls and log PIC in
> IMC, while the IR pilot acts as PIC, but cannot log PIC while in IMC.

Yup. Or alternatively, the PIC can log PIC time, and the non-current pilot
can log the approaches, but not log PIC time. (The PIC's ability to log PIC
time--as long as the sole manipulator doesn't also do so--isn't actually in
the FARs, but has been affirmed in the FAA's legal "interpretations".)

--Gary

[Mark Hansen]

On 02/10/06 05:31, Gary Drescher wrote:
> "Ron Rosenfeld" > wrote in message
> ...
>> On Thu, 09 Feb 2006 09:23:33 -0800, Mark Hansen >
>> wrote:
>>>Yes, but I didn't think this 'monkey' was allowed to use the time toward
>>>IR currency.
>>
>> If you review 61.57 regarding instrument currency, you will see that the
>> requirements are for logging flight under actual or simulated instrument
>> conditions.
>>
>> The requirements for logging are merely that you be sole manipulator of
>> the
>> controls.
>>
>> So yes, the non-current pilot can manipulate the controls and log PIC in
>> IMC, while the IR pilot acts as PIC, but cannot log PIC while in IMC.
>
> Yup. Or alternatively, the PIC can log PIC time, and the non-current pilot
> can log the approaches, but not log PIC time. (The PIC's ability to log PIC
> time--as long as the sole manipulator doesn't also do so--isn't actually in
> the FARs, but has been affirmed in the FAA's legal "interpretations".)
>
> --Gary
>
>


Perhaps I'm still a little confused here. If I get a safety pilot who
agrees to act as pilot in command of the flight, that pilot will be
able to log the time as PIC.

If I am sole manipulator of the controls, then I can log the time as
PIC as per FAR 61.51(e)(i)

In this case, we would both be logging PIC, although for different
reasons.

Is this wrong?

When flying in VMC and using a view limiting device, the safety pilot
is considered a required crew member, and as such can decide to act
as PIC or SIC. However, I would think this is not the case when flying
in IMC, as the safety pilot must be PIC (because the pilot flying is
not IMC current).

Is this wrong?

If this is covered by one of the Chief Counsel written opinions, can
you please provide a reference to it? I have a hard time finding them.

Thanks,

--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Mark Hansen]

On 02/10/06 05:20, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> On 02/09/06 07:45, Gary Drescher wrote:
>>> "three-eight-hotel" > wrote in message
>>> oups.com...
>>>> You have 6 months after your currency lapses to become current, without
>>>> having to do an IPC... You are not legal to fly IFR, but you may take
>>>> a safety pilot up with you and become current again. If you miss the 6
>>>> month window to become current, you will have to perform an IPC.
>>>>
>>>> I'm sure if I stated that incorrectly or unclearly, someone will jump
>>>> in to correct me... ;-)
>>>
>>> No error, but one addition may be useful: another alternative is to fly
>>> IFR and do the approaches in IMC, but with another pilot (who's
>>> IFR-current) acting as PIC.
>>>
>>> --Gary
>>
>> Wait a tick ;-) Are you saying that if you're beyond the 6-month
>> currency, that you can fly in actual IMC and all you need is an IR-
>> current safety pilot - not a CFII?
>
> In this case, the IR-current pilot isn't functioning as "safety pilot".
> That's the term for a traffic-spotting pilot in VMC when the pilot doing the
> flying is wearing a hood. In my scenario, there's no hood and no safety
> pilot--just another pilot acting as PIC.

Yes. My confusion was that my instructor told me that when the IR pilot
was not IMC current, and wanted to perform the actions to regain currency
in actual IMC (not simulated) that the person in the right seat had to
be a CFII.

However, after the discussions in the other parts of this thread and more
looking through the FARs, I see no evidence for this and now believe that
my instructor was wrong. Perhaps what he meant to say was "A CFII would
be more experienced in that situation, and so it would be safer, etc.".

.... it wouldn't be the first time I was given an opinion by the CFII
which was represented a fact/rule.

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[three-eight-hotel]

This same topic came up in a post a few months back, where there seemed
to be a lot of gray area around "logging" PIC time. I don't recall
ever seeing a clear response as to what the definitive regs around
logging PIC are supposed to mean. I am as interested as you, and I'm
sure as are others, as to when we can legally log PIC time (in the
stated circumstances), both as a safety pilot, and as the sole
manipulators fo the controls.

Best Regards,
Todd

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> When flying in VMC and using a view limiting device, the safety pilot
> is considered a required crew member, and as such can decide to act
> as PIC or SIC.

Correct. And because the flight is construed to require multiple crew
members, the safety pilot (if acting as PIC) can log PIC time (in addition
to the sole manipulator doing so), according to 61.51e1iii.

> However, I would think this is not the case when flying
> in IMC, as the safety pilot must be PIC (because the pilot flying is
> not IMC current).

In the IMC scenario, there is no safety pilot, and there is only one
required crew member (the PIC). Under those circumstances, merely acting as
PIC does not entitle the pilot to log PIC time (acting as PIC is not one of
the three conditions listed in 61.51e1 as the *only* conditions that allow
PIC time to be logged).

Nonetheless, the FAA has reportedly said that a pilot acting as PIC (even
when just one crewmember is required) can log PIC time if the sole
manipulator does not or cannot.

> If this is covered by one of the Chief Counsel written opinions, can
> you please provide a reference to it?

That's certainly a reasonable question, but they're not readily available as
far as I know; they circulate mainly as Usenet chain mail. So my own policy
when a purported Chief Counsel opinion flatly contradicts the FARs is just
to follow the FARs.

--Gary

[Mark Hansen]

On 02/10/06 08:54, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> When flying in VMC and using a view limiting device, the safety pilot
>> is considered a required crew member, and as such can decide to act
>> as PIC or SIC.
>
> Correct. And because the flight is construed to require multiple crew
> members, the safety pilot (if acting as PIC) can log PIC time (in addition
> to the sole manipulator doing so), according to 61.51e1iii.
>
>> However, I would think this is not the case when flying
>> in IMC, as the safety pilot must be PIC (because the pilot flying is
>> not IMC current).
>
> In the IMC scenario, there is no safety pilot, and there is only one
> required crew member (the PIC). Under those circumstances, merely acting as
> PIC does not entitle the pilot to log PIC time (acting as PIC is not one of
> the three conditions listed in 61.51e1 as the *only* conditions that allow
> PIC time to be logged).
>
> Nonetheless, the FAA has reportedly said that a pilot acting as PIC (even
> when just one crewmember is required) can log PIC time if the sole
> manipulator does not or cannot.

Thank you, Gary. This is certainly very clear, although it is not what
I previously understood. I wonder if the Chief Counsel simply hasn't been
asked this specific case:

- IMC conditions
- Pilot flying is not IMC current
- Pilot flying is sole manipulator of the controls, and thus logs PIC
- Pilot not flying is acting PIC (required because the pilot flying is
not IMC current) and so logs PIC

Perhaps what is confusing me is that I thought that any pilot "acting"
as PIC was entitled to log the time as PIC. Your statement to the contrary,
above, is the first time I've ever heard that.

Thanks again - this is a great discussion!

>
>> If this is covered by one of the Chief Counsel written opinions, can
>> you please provide a reference to it?
>
> That's certainly a reasonable question, but they're not readily available as
> far as I know; they circulate mainly as Usenet chain mail. So my own policy
> when a purported Chief Counsel opinion flatly contradicts the FARs is just
> to follow the FARs.
>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> On 02/10/06 08:54, Gary Drescher wrote:
>> In the IMC scenario, there is no safety pilot, and there is only one
>> required crew member (the PIC). Under those circumstances, merely acting
>> as PIC does not entitle the pilot to log PIC time (acting as PIC is not
>> one of the three conditions listed in 61.51e1 as the *only* conditions
>> that allow PIC time to be logged).
>>
>> Nonetheless, the FAA has reportedly said that a pilot acting as PIC (even
>> when just one crewmember is required) can log PIC time if the sole
>> manipulator does not or cannot.
>
> Thank you, Gary. This is certainly very clear, although it is not what
> I previously understood. I wonder if the Chief Counsel simply hasn't been
> asked this specific case:
>
> - IMC conditions
> - Pilot flying is not IMC current
> - Pilot flying is sole manipulator of the controls, and thus logs PIC
> - Pilot not flying is acting PIC (required because the pilot flying is
> not IMC current) and so logs PIC

I'd guess that the Chief Counsel hasn't addressed that particular
combination of circumstances. But even flying VFR with no instrument
practice, you can have a pilot acting as PIC and another pilot acting as
sole manipulator (who may or may not be qualified to be PIC for that
flight). There's nothing special about being in IMC or being IFR that bears
on the PIC-logging questions for such a flight, so there's no need for the
FAA to separately address those specific circumstances.

> Perhaps what is confusing me is that I thought that any pilot "acting"
> as PIC was entitled to log the time as PIC.

Nope, 61.51e1 clearly states the contrary (even though it's partially
contradicted by the FAA's "interpretations").

> Thanks again - this is a great discussion!

You're welcome! Perhaps if enough pilots keep raising this question, the FAA
will eventually fix either the FARs or the Chief Counsel opinions. :)

--Gary

[three-eight-hotel]

I think I'm clear now, but wanted to clarify a point from the last post

>> - Pilot not flying is acting PIC (required because the pilot flying is
>> not IMC current) and so logs PIC

Was meant to be posted as a question to the Chief Counsel and not as a
statement of understanding, right?

Acting PIC (not flying) may NOT log PIC, based on what I'm hearing and
reading in other searches... From the following link
(http://www.propilot.com/doc/logging2.html) I snipped a section
regarding this specific situation...

<========= Begin Snip ==========>
A non-instrument-rated private pilot (but rated in the aircraft
category and class) flies with another private pilot who is instrument
rated, on an IFR flight plan in IMC conditions. The non-IFR pilot
manipulates the flight controls for the entire flight. The IFR pilot
acts as PIC, and is required to be the PIC since he/she is the only
pilot appropriately rated to act as PIC under IFR, but logs no flight
time. Why?
The instrument-rated pilot did not manipulate the flight controls and
is not acting as PIC of an aircraft requiring more than one pilot.

The non-IFR pilot may log PIC time for the entire flight since he/she
was the sole manipulator of the flight controlsof an aircraft for whih
he/she is rated. See legal opinion # 5 for details.

This legal opinion is written to answer a question involving a CFII as
the PIC, but the opinion later states "The other pilot must be the PIC,
....", and does not impose a requirement to hold an instructor
certificate.

Also, see legal opinion # 6 , under "TAB AERO Question # 2" which
further clarifies the fact that a non-rated pilot can manipulate the
controls under IFR.

This represents no change from the old rules.
<========= End Snip ==========>

Best Regards,
Todd

[Mark Hansen]

On 02/10/06 09:35, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> On 02/10/06 08:54, Gary Drescher wrote:
>>> In the IMC scenario, there is no safety pilot, and there is only one
>>> required crew member (the PIC). Under those circumstances, merely acting
>>> as PIC does not entitle the pilot to log PIC time (acting as PIC is not
>>> one of the three conditions listed in 61.51e1 as the *only* conditions
>>> that allow PIC time to be logged).
>>>
>>> Nonetheless, the FAA has reportedly said that a pilot acting as PIC (even
>>> when just one crewmember is required) can log PIC time if the sole
>>> manipulator does not or cannot.
>>
>> Thank you, Gary. This is certainly very clear, although it is not what
>> I previously understood. I wonder if the Chief Counsel simply hasn't been
>> asked this specific case:
>>
>> - IMC conditions
>> - Pilot flying is not IMC current
>> - Pilot flying is sole manipulator of the controls, and thus logs PIC
>> - Pilot not flying is acting PIC (required because the pilot flying is
>> not IMC current) and so logs PIC
>
> I'd guess that the Chief Counsel hasn't addressed that particular
> combination of circumstances. But even flying VFR with no instrument
> practice, you can have a pilot acting as PIC and another pilot acting as
> sole manipulator (who may or may not be qualified to be PIC for that
> flight). There's nothing special about being in IMC or being IFR that bears
> on the PIC-logging questions for such a flight, so there's no need for the
> FAA to separately address those specific circumstances.
>
>> Perhaps what is confusing me is that I thought that any pilot "acting"
>> as PIC was entitled to log the time as PIC.
>
> Nope, 61.51e1 clearly states the contrary (even though it's partially
> contradicted by the FAA's "interpretations").

61.51(e)(iii) (what I think you meant above) states:

"Except for a recreational pilot, is acting as pilot in command of an
aircraft on which more than one pilot is required under the type
certification of the aircraft or the regulations under which the flight
is conducted."

It would be possible for someone to interpret "... the regulations under
which the flight is conducted" to indicate that because the pilot flying
cannot legally fly in IMC, due to currency, that the pilot not flying is
required.

Okay ... I'm ready ;-)

>
>> Thanks again - this is a great discussion!
>
> You're welcome! Perhaps if enough pilots keep raising this question, the FAA
> will eventually fix either the FARs or the Chief Counsel opinions. :)
>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Mark Hansen]

On 02/10/06 09:47, three-eight-hotel wrote:
> I think I'm clear now, but wanted to clarify a point from the last post
>
>>> - Pilot not flying is acting PIC (required because the pilot flying is
>>> not IMC current) and so logs PIC
>
> Was meant to be posted as a question to the Chief Counsel and not as a
> statement of understanding, right?

Yes, this is the question I'm trying to get clear on myself.

>
> Acting PIC (not flying) may NOT log PIC, based on what I'm hearing and
> reading in other searches... From the following link
> (http://www.propilot.com/doc/logging2.html) I snipped a section
> regarding this specific situation...
>
> <========= Begin Snip ==========>
> A non-instrument-rated private pilot (but rated in the aircraft
> category and class) flies with another private pilot who is instrument
> rated, on an IFR flight plan in IMC conditions. The non-IFR pilot
> manipulates the flight controls for the entire flight. The IFR pilot
> acts as PIC, and is required to be the PIC since he/she is the only
> pilot appropriately rated to act as PIC under IFR, but logs no flight
> time. Why?
> The instrument-rated pilot did not manipulate the flight controls and
> is not acting as PIC of an aircraft requiring more than one pilot.
>
> The non-IFR pilot may log PIC time for the entire flight since he/she
> was the sole manipulator of the flight controlsof an aircraft for whih
> he/she is rated. See legal opinion # 5 for details.
>
> This legal opinion is written to answer a question involving a CFII as
> the PIC, but the opinion later states "The other pilot must be the PIC,
> ...", and does not impose a requirement to hold an instructor
> certificate.
>
> Also, see legal opinion # 6 , under "TAB AERO Question # 2" which
> further clarifies the fact that a non-rated pilot can manipulate the
> controls under IFR.

How do you find opinion #5 and #6? When I go to the FAA web site,
I can search by keyword, and the results don't provide the opinion
number.

Thanks for digging this up, Todd. I've saved it off, and will read
the complete article when I get a few minutes.

>
> This represents no change from the old rules.
> <========= End Snip ==========>
>
> Best Regards,
> Todd
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
>> Nope, 61.51e1 clearly states the contrary (even though it's partially
>> contradicted by the FAA's "interpretations").
>
> 61.51(e)(iii) (what I think you meant above)

Close--61.51e1iii is one of the three clauses of 61.51e1. :)

> states:
>
> "Except for a recreational pilot, is acting as pilot in command of an
> aircraft on which more than one pilot is required under the type
> certification of the aircraft or the regulations under which the flight
> is conducted."
>
> It would be possible for someone to interpret "... the regulations under
> which the flight is conducted" to indicate that because the pilot flying
> cannot legally fly in IMC, due to currency, that the pilot not flying is
> required.

That's correct. The PIC (the pilot not flying) is indeed required. It's the
other pilot (the sole manipulator) who's not required in that scenario.

Now, you might reasonably ask why the hooded pilot flying with a safety
pilot is considered a required pilot. And the FAA's answer is apparently
that the specific regulations that pertain to flying with a safety pilot do
mention two distinct pilots, so you need two pilots to conduct a flight
*under those regulations* (otherwise, you'd be flying under different
regulations instead). Whatever the merits of that interpretation may be, it
doesn't carry over to the IMC/IFR scenario, since there is no particular
regulation that speaks of two distinct pilots in that scenario.

--Gary

[three-eight-hotel]

>> How do you find opinion #5 and #6? When I go to the FAA web site,
>> I can search by keyword, and the results don't provide the opinion
>> number.

You can search for IMC, and it takes you right to the topic we are
discussing... Here are the links, to save you time. (I haven't read
them yet)

http://www.propilot.com/doc/legal5.html
http://www.propilot.com/doc/legal6.html

Best Regards,
Todd

[Mark Hansen]

On 02/10/06 10:09, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>>> Nope, 61.51e1 clearly states the contrary (even though it's partially
>>> contradicted by the FAA's "interpretations").
>>
>> 61.51(e)(iii) (what I think you meant above)
>
> Close--61.51e1iii is one of the three clauses of 61.51e1. :)

I'm reading from a form of the online regs that shows this as
61.51 (e) (iii) ... not 61.51 (e) (1) (iii).


>
>> states:
>>
>> "Except for a recreational pilot, is acting as pilot in command of an
>> aircraft on which more than one pilot is required under the type
>> certification of the aircraft or the regulations under which the flight
>> is conducted."
>>
>> It would be possible for someone to interpret "... the regulations under
>> which the flight is conducted" to indicate that because the pilot flying
>> cannot legally fly in IMC, due to currency, that the pilot not flying is
>> required.
>
> That's correct. The PIC (the pilot not flying) is indeed required. It's the
> other pilot (the sole manipulator) who's not required in that scenario.

Right, so the pilot not flying is required, so he can log PIC.
The pilot flying is sole manipulator, so he can log PIC.

See where I'm coming from?

>
> Now, you might reasonably ask why the hooded pilot flying with a safety
> pilot is considered a required pilot. And the FAA's answer is apparently
> that the specific regulations that pertain to flying with a safety pilot do
> mention two distinct pilots, so you need two pilots to conduct a flight
> *under those regulations* (otherwise, you'd be flying under different
> regulations instead). Whatever the merits of that interpretation may be, it
> doesn't carry over to the IMC/IFR scenario, since there is no particular
> regulation that speaks of two distinct pilots in that scenario.

Except for the one I stated above... ;-)

Given that you're flying in IMC conditions, the pilot in command is
required to be IMC current. Because the pilot-flying is not, the
IMC-current pilot-not-flying is required, and must act as pilot in
command (and, I think, should be allowed to log PIC).

However, the non-IMC-current pilot-flying is sole manipulator of the
controls, and thus is entitled to log PIC according to 61.51 (e) (i).

The stuff posted by Todd seems to indicate that the Chief Counsel
did offer an opinion on this specific case, and states that the
pilot-not-flying would not be entitled to log PIC even when acting
as Pilot in Command if the pilot-flying is logging PIC as a result of
61.51 (e) (i). That just doesn't seem fair to me, and I would sure
like to see those Chief Counsel opinions (#5 and #6).

I hope I'm not coming across as argumentative. I'm really enjoying
the discussion ;-)

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> On 02/10/06 10:09, Gary Drescher wrote:
>> Close--61.51e1iii is one of the three clauses of 61.51e1. :)
>
> I'm reading from a form of the online regs that shows this as
> 61.51 (e) (iii) ... not 61.51 (e) (1) (iii).

No, if you look closely, you'll see there's a '1' between the 'e' and the
'iii', although it's obscured by the confusing formatting. (But there's
always an Arabic numeral between the letter and the Roman numeral.)
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?&c=ecfr&tpl=/ecfrbrowse/Title14/14tab_02.tpl

>> That's correct. The PIC (the pilot not flying) is indeed required. It's
>> the other pilot (the sole manipulator) who's not required in that
>> scenario.
>
> Right, so the pilot not flying is required, so he can log PIC.

No. Being a required pilot is not one of the three specific conditions that
allow you to log PIC time.

> Given that you're flying in IMC conditions, the pilot in command is
> required to be IMC current. Because the pilot-flying is not, the
> IMC-current pilot-not-flying is required, and must act as pilot in
> command

So far, so good.

> (and, I think, should be allowed to log PIC).

No, that's the part that's wrong. Neither being a required pilot nor being
PIC allows you to log PIC time (unless multiple crew members are required).
According to 61.51e1, the three specified conditions are the *only*
conditions that allow you to log PIC time.

What the FAA calls "logging PIC time" is simply a misnomer, since it has
little to do with the concept of PIC. The terminology is needlessly
confusing. The FAA should just call it something else, such as "logging
primary-pilot time".

> I hope I'm not coming across as argumentative. I'm really enjoying
> the discussion ;-)

Not argumentative at all--at least, not in a bad way. :) Informative
discussions are always fun.

--Gary

[Gary Drescher]

"three-eight-hotel" > wrote in message
oups.com...
>>> How do you find opinion #5 and #6? When I go to the FAA web site,
>>> I can search by keyword, and the results don't provide the opinion
>>> number.
>
> You can search for IMC, and it takes you right to the topic we are
> discussing... Here are the links, to save you time. (I haven't read
> them yet)
>
> http://www.propilot.com/doc/legal5.html
> http://www.propilot.com/doc/legal6.html

I think what Mark was seeking is an official source of those opinions on the
FAA's own web site; otherwise, it's just Internet chain mail. But
unfortunately, the FAA doesn't publish the opinions, as far as I know.

--Gary

[Mark Hansen]

On 02/10/06 10:59, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> On 02/10/06 10:09, Gary Drescher wrote:
>>> Close--61.51e1iii is one of the three clauses of 61.51e1. :)
>>
>> I'm reading from a form of the online regs that shows this as
>> 61.51 (e) (iii) ... not 61.51 (e) (1) (iii).
>
> No, if you look closely, you'll see there's a '1' between the 'e' and the
> 'iii', although it's obscured by the confusing formatting. (But there's
> always an Arabic numeral between the letter and the Roman numeral.)
> http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?&c=ecfr&tpl=/ecfrbrowse/Title14/14tab_02.tpl

Oh, I see. Here's how it looks in the view I'm looking at:

(e) Logging pilot-in-command flight time. (1) A sport, recreational,
private...

The (1) is on the same line as the (e) ;-\

>
>>> That's correct. The PIC (the pilot not flying) is indeed required. It's
>>> the other pilot (the sole manipulator) who's not required in that
>>> scenario.
>>
>> Right, so the pilot not flying is required, so he can log PIC.
>
> No. Being a required pilot is not one of the three specific conditions that
> allow you to log PIC time.

I'm interpreting it differently (and, I guess, incorrectly)...

>
>> Given that you're flying in IMC conditions, the pilot in command is
>> required to be IMC current. Because the pilot-flying is not, the
>> IMC-current pilot-not-flying is required, and must act as pilot in
>> command
>
> So far, so good.
>
>> (and, I think, should be allowed to log PIC).
>
> No, that's the part that's wrong. Neither being a required pilot nor being
> PIC allows you to log PIC time (unless multiple crew members are required).
> According to 61.51e1, the three specified conditions are the *only*
> conditions that allow you to log PIC time.

And I think you're saying that 61.51(e)(1)(iii) is referring to aircraft
which require multiple crew members, and not the case we're discussing
here. The way I (incorrectly) interpreted it, it could apply to our case
as well - but I hear you saying that it does not ... and I believe you,
even if I don't agree with it ;-)

By the way, if the pilot-not-flying was an active CFI, they *would*
be able to log PIC in this case, due to 61.51(e)(3), right? Even if
the pilot-flying was logging PIC due to 61.51(e)(1)(i).

>
> What the FAA calls "logging PIC time" is simply a misnomer, since it has
> little to do with the concept of PIC. The terminology is needlessly
> confusing. The FAA should just call it something else, such as "logging
> primary-pilot time".

I realize the difference between acting and logging PIC - in fact, it
is that different that I *thought* made it possible for both pilots
in this situation to log PIC.

>
>> I hope I'm not coming across as argumentative. I'm really enjoying
>> the discussion ;-)
>
> Not argumentative at all--at least, not in a bad way. :) Informative
> discussions are always fun.

Thanks. I definitely learned something new today!

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Mark Hansen]

On 02/10/06 10:27, three-eight-hotel wrote:
>>> How do you find opinion #5 and #6? When I go to the FAA web site,
>>> I can search by keyword, and the results don't provide the opinion
>>> number.
>
> You can search for IMC, and it takes you right to the topic we are
> discussing... Here are the links, to save you time. (I haven't read
> them yet)
>
> http://www.propilot.com/doc/legal5.html
> http://www.propilot.com/doc/legal6.html

Great, Thanks. In fact, in looking at these, they don't seem to specifically
say that the pilot acting as pilot in command cannot log the flight time as
PIC during the time that the pilot flying is sole manipulator of the
controls. They clearly say that the instrument-rated pilot is required to
act as pilot in command. Here is an excerpt:

> An instrument student who holds at least a private pilot certificate
> and who is rated for the aircraft flown may log as pilot in command flight
> time under Section 61.51 (c)(2)(i), the time spent as sole manipulator of
> the controls regardless of the meteorological conditions of the flight.
> In situations where actual IFR meteorological conditions exist, as in the
> case presented in the above example, the safety pilot or flight instructor,
> as the case may be, must be pilot in command, as that term is defined under
> 1.1 of the FAR.
>

However, I think the issue that's been confusing me, is that I was under the
impression that if you acted as pilot in command, that gave you the right
to log PIC. ... but I guess not.


>
> Best Regards,
> Todd
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> And I think you're saying that 61.51(e)(1)(iii) is referring to aircraft
> which require multiple crew members,

Yes, at least for a particular flight. FAR 61.51e1iii refers explicitly to
"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". The regulations that pertain to the IMC/IFR scenario do not
require the plane to have "more than one pilot" for that flight.

--Gary

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> By the way, if the pilot-not-flying was an active CFI, they *would*
> be able to log PIC in this case, due to 61.51(e)(3), right? Even if
> the pilot-flying was logging PIC due to 61.51(e)(1)(i).

Yup, the rules are different for a CFI giving instruction.

--Gary

[Robert M. Gary]

> - IMC conditions
> - Pilot flying is not IMC current
> - Pilot flying is sole manipulator of the controls, and thus logs PIC
> - Pilot not flying is acting PIC (required because the pilot flying
is
> not IMC current) and so logs PIC

There is no provision for the pilot acting as PIC to log PIC in this
case. Only the flying pilot would be able to log PIC. The only way you
can log PIC is per 61.51(e). In this case the guy serving as PIC does
not meet the requirements of a "required crew member" since the
aircraft is legal to fly IFR with just one pilot (the fact that that
pilot isn't qualified doesn't change that).

-Robert

[Mark Hansen]

On 02/10/06 14:10, Robert M. Gary wrote:
>> - IMC conditions
>> - Pilot flying is not IMC current
>> - Pilot flying is sole manipulator of the controls, and thus logs PIC
> > - Pilot not flying is acting PIC (required because the pilot flying
> is
>> not IMC current) and so logs PIC
>
> There is no provision for the pilot acting as PIC to log PIC in this
> case. Only the flying pilot would be able to log PIC. The only way you
> can log PIC is per 61.51(e). In this case the guy serving as PIC does
> not meet the requirements of a "required crew member" since the
> aircraft is legal to fly IFR with just one pilot (the fact that that
> pilot isn't qualified doesn't change that).
>
> -Robert
>

Yes, I see that, and that certainly seems to be the consensus of everyone
offering help here. So, I will conform ;-)

I just have a different interpretation of 61.51 (e) (1) (iii), because
in my opinion, the pilot not flying is required under the FARs due to
the fact that the pilot flying isn't current for IMC.

I've tried pretty hard to make my case and no ones buying it, so I'll
concede that my interpretation is incorrect.

It was a lot of fun discussing it in any event ;-)

--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Robert M. Gary" > wrote in message
oups.com...
>> - IMC conditions
>> - Pilot flying is not IMC current
>> - Pilot flying is sole manipulator of the controls, and thus logs PIC
> > - Pilot not flying is acting PIC (required because the pilot flying
> is
>> not IMC current) and so logs PIC
>
> There is no provision for the pilot acting as PIC to log PIC in this
> case. Only the flying pilot would be able to log PIC. The only way you
> can log PIC is per 61.51(e). In this case the guy serving as PIC does
> not meet the requirements of a "required crew member" since the
> aircraft is legal to fly IFR with just one pilot (the fact that that
> pilot isn't qualified doesn't change that).

Actually, the pilot serving as PIC *is* a "required pilot" under the
regulations that apply to the flight; and being required *by those
regulations* is what 61.51e1iii talks about. It's the *other* pilot (the
sole manipulator) who isn't required under the regulations that apply to the
flight in question.

--Gary

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> Yes, I see that, and that certainly seems to be the consensus of everyone
> offering help here. So, I will conform ;-)

No need to change your view just because you're in the minority.

> I just have a different interpretation of 61.51 (e) (1) (iii), because
> in my opinion, the pilot not flying is required under the FARs due to
> the fact that the pilot flying isn't current for IMC.

Yup, you're right about that. I don't see how that could be disputed.

The question is why you'd think that the regs require the *other* pilot to
be there. Remember, 61.51e1iii only applies if the regs require there to be
*more than one pilot* for the particular flight.

> I've tried pretty hard to make my case and no ones buying it, so I'll
> concede that my interpretation is incorrect.

The fact that the handful of people who happened to chime in here disagree
with you is no reason to concede error! On the other hand, the *reasons*
we've put forth may well be grounds for you to do so. :)

--Gary

[Mark Hansen]

On 02/10/06 14:43, Gary Drescher wrote:
> "Robert M. Gary" > wrote in message
> oups.com...
>>> - IMC conditions
>>> - Pilot flying is not IMC current
>>> - Pilot flying is sole manipulator of the controls, and thus logs PIC
>> > - Pilot not flying is acting PIC (required because the pilot flying
>> is
>>> not IMC current) and so logs PIC
>>
>> There is no provision for the pilot acting as PIC to log PIC in this
>> case. Only the flying pilot would be able to log PIC. The only way you
>> can log PIC is per 61.51(e). In this case the guy serving as PIC does
>> not meet the requirements of a "required crew member" since the
>> aircraft is legal to fly IFR with just one pilot (the fact that that
>> pilot isn't qualified doesn't change that).
>
> Actually, the pilot serving as PIC *is* a "required pilot" under the
> regulations that apply to the flight; and being required *by those
> regulations* is what 61.51e1iii talks about. It's the *other* pilot (the
> sole manipulator) who isn't required under the regulations that apply to the
> flight in question.

But I guess the pilot not flying (in this case), although a required
crew member as per 61.51 (e)(1)(iii), cannot log his time as PIC *if*
the pilot flying logs his time as PIC as per 61.51 (e)(1)(i).

Is that right?



>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Robert M. Gary]

> Actually, the pilot serving as PIC *is* a "required pilot" under the regulations that apply to the flight;

If that were true with regard to 61.51(e) then this pilot would be able
to log PIC. However, I cannot see how you can say he meets that
requirement...

61.51(e)...
(iii) Except for a recreational pilot, is acting as pilot in command of
an^M
aircraft on which more than one pilot is required under the type^M
certification of the aircraft or the regulations under which the flight
is^M
conducted.^M

How can you say this operation requires multiple crew members??
-Robert

[Robert M. Gary]

> I just have a different interpretation of 61.51 (e) (1) (iii), because
> in my opinion, the pilot not flying is required under the FARs due to
> the fact that the pilot flying isn't current for IMC.

Don't back down just because you're being bullied. :) However, the
question not, "is this pilot required" but "does this operation require
MORE THAN ONE pilot"

61.51(e)...
(iii) Except for a recreational pilot, is acting as pilot in command of
an^M
aircraft on which more than one pilot is required under the type^M
certification of the aircraft or the regulations under which the flight
is^M
conducted.^M

[Mark Hansen]

On 02/10/06 14:48, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> Yes, I see that, and that certainly seems to be the consensus of everyone
>> offering help here. So, I will conform ;-)
>
> No need to change your view just because you're in the minority.
>
>> I just have a different interpretation of 61.51 (e) (1) (iii), because
>> in my opinion, the pilot not flying is required under the FARs due to
>> the fact that the pilot flying isn't current for IMC.
>
> Yup, you're right about that. I don't see how that could be disputed.
>
> The question is why you'd think that the regs require the *other* pilot to
> be there. Remember, 61.51e1iii only applies if the regs require there to be
> *more than one pilot* for the particular flight.

I'm not asserting that the pilot flying (PF) is required by regs to be there.

I think the regs entitle the PF to log PIC as per 61.51 (e)(1)(i).

Where I'm getting lost is that if the pilot-not-flying (PNF) must act as
PIC (because someone must act as PIC, and the PF cannot due to IMC currency),
why his time cannot be logged as PIC.

I think the answer is that acting as PIC doesn't mean you can also log PIC.

But ... 61.51 (e)(1)(iii) seems to tell me that because the PNF is required
to be there, he can log his time as PIC.

Let me state 61.51 (e)(1)(iii) in a way that I think makes my point:

"is acting as pilot in command of an aircraft on which more than one pilot
is required by the regulations under which the flight is conducted."

But ... I think what you're saying is that only one crew member is required
because if the PNF was alone, the flight would be legal (assuming he started
flying). I guess I was getting hung up on the premise that the PF not being
IMC current caused the 2nd crew member to be required.

Do you see why I presumed the 2nd crew member was required?



>
>> I've tried pretty hard to make my case and no ones buying it, so I'll
>> concede that my interpretation is incorrect.
>
> The fact that the handful of people who happened to chime in here disagree
> with you is no reason to concede error! On the other hand, the *reasons*
> we've put forth may well be grounds for you to do so. :)

And I know you're going to a lot of effort here, and I really appreciate
it.

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> On 02/10/06 14:48, Gary Drescher wrote:
>> "Mark Hansen" > wrote in message
>> ...
>>> Yes, I see that, and that certainly seems to be the consensus of
>>> everyone
>>> offering help here. So, I will conform ;-)
>>
>> No need to change your view just because you're in the minority.
>>
>>> I just have a different interpretation of 61.51 (e) (1) (iii), because
>>> in my opinion, the pilot not flying is required under the FARs due to
>>> the fact that the pilot flying isn't current for IMC.
>>
>> Yup, you're right about that. I don't see how that could be disputed.
>>
>> The question is why you'd think that the regs require the *other* pilot
>> to be there. Remember, 61.51e1iii only applies if the regs require there
>> to be *more than one pilot* for the particular flight.
>
> I'm not asserting that the pilot flying (PF) is required by regs to be
> there.

Ok, good. No disagreement so far.

> I think the regs entitle the PF to log PIC as per 61.51 (e)(1)(i).

No disagreement there either.

> Where I'm getting lost is that if the pilot-not-flying (PNF) must act as
> PIC (because someone must act as PIC, and the PF cannot due to IMC
> currency),
> why his time cannot be logged as PIC.
>
> I think the answer is that acting as PIC doesn't mean you can also log
> PIC.

Right. More specifically, 61.51e1iii says you can log PIC time *only* under
three specified conditions (and *being* PIC is *not* one of those
conditions).

> But ... 61.51 (e)(1)(iii) seems to tell me that because the PNF is
> required
> to be there, he can log his time as PIC.

No, that's not what 61.51e1iii says. How do you interpret it that way?

> Let me state 61.51 (e)(1)(iii) in a way that I think makes my point:
>
> "is acting as pilot in command of an aircraft on which more than one
> pilot
> is required by the regulations under which the flight is conducted."

Yes, that's what 61.51e1iii says. But how does that make your point?

> But ... I think what you're saying is that only one crew member is
> required
> because if the PNF was alone, the flight would be legal (assuming he
> started
> flying).

Yes. The PIC is the only required pilot in the IMC/IFR scenario.

> I guess I was getting hung up on the premise that the PF not being
> IMC current caused the 2nd crew member to be required.

You're right that the second pilot is required. But the first one isn't! :)

> Do you see why I presumed the 2nd crew member was required?

Yes, and I agree with you on that. But 61.51e1iii only applies if the first
pilot is *also* required. That is, 61.51e1iii only applies if *more than
one* pilot is required for the flight.

--Gary

[Gary Drescher]

"Robert M. Gary" > wrote in message
oups.com...
>> Actually, the pilot serving as PIC *is* a "required pilot" under the
>> regulations that apply to the flight;
>
> If that were true with regard to 61.51(e) then this pilot would be able
> to log PIC.

Not at all. Why do you say that? Being a required pilot does not entitle you
to log PIC time; that's not one of the three specified conditions in
61.51e1.

> However, I cannot see how you can say he meets that
> requirement...
>
> 61.51(e)...
> (iii) Except for a recreational pilot, is acting as pilot in command of
> an^M
> aircraft on which more than one pilot is required under the type^M
> certification of the aircraft or the regulations under which the flight
> is^M
> conducted.^M
>
> How can you say this operation requires multiple crew members??

I *didn't* say that. In fact, I repeatedly said the opposite.

--Gary

[Mark Hansen]

On 02/10/06 15:20, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> On 02/10/06 14:48, Gary Drescher wrote:
>>> "Mark Hansen" > wrote in message
>>> ...
>>>> Yes, I see that, and that certainly seems to be the consensus of
>>>> everyone
>>>> offering help here. So, I will conform ;-)
>>>
>>> No need to change your view just because you're in the minority.
>>>
>>>> I just have a different interpretation of 61.51 (e) (1) (iii), because
>>>> in my opinion, the pilot not flying is required under the FARs due to
>>>> the fact that the pilot flying isn't current for IMC.
>>>
>>> Yup, you're right about that. I don't see how that could be disputed.
>>>
>>> The question is why you'd think that the regs require the *other* pilot
>>> to be there. Remember, 61.51e1iii only applies if the regs require there
>>> to be *more than one pilot* for the particular flight.
>>
>> I'm not asserting that the pilot flying (PF) is required by regs to be
>> there.
>
> Ok, good. No disagreement so far.
>
>> I think the regs entitle the PF to log PIC as per 61.51 (e)(1)(i).
>
> No disagreement there either.
>
>> Where I'm getting lost is that if the pilot-not-flying (PNF) must act as
>> PIC (because someone must act as PIC, and the PF cannot due to IMC
>> currency),
>> why his time cannot be logged as PIC.
>>
>> I think the answer is that acting as PIC doesn't mean you can also log
>> PIC.
>
> Right. More specifically, 61.51e1iii says you can log PIC time *only* under
> three specified conditions (and *being* PIC is *not* one of those
> conditions).
>
>> But ... 61.51 (e)(1)(iii) seems to tell me that because the PNF is
>> required
>> to be there, he can log his time as PIC.
>
> No, that's not what 61.51e1iii says. How do you interpret it that way?
>
>> Let me state 61.51 (e)(1)(iii) in a way that I think makes my point:
>>
>> "is acting as pilot in command of an aircraft on which more than one
>> pilot
>> is required by the regulations under which the flight is conducted."
>
> Yes, that's what 61.51e1iii says. But how does that make your point?

Because 61.51 (e) is about logging pilot-in-command flight time.

It seems to me the PNF can log the time as PIC because he fits under
61.51 (e)(1)(iii).

>
>> But ... I think what you're saying is that only one crew member is
>> required
>> because if the PNF was alone, the flight would be legal (assuming he
>> started
>> flying).
>
> Yes. The PIC is the only required pilot in the IMC/IFR scenario.
>
>> I guess I was getting hung up on the premise that the PF not being
>> IMC current caused the 2nd crew member to be required.
>
> You're right that the second pilot is required. But the first one isn't! :)


Yeah ... I was presuming that the PNF could log the time because he was
required, and the PF could log the time because he was sole manipulator.


>
>> Do you see why I presumed the 2nd crew member was required?
>
> Yes, and I agree with you on that. But 61.51e1iii only applies if the first
> pilot is *also* required. That is, 61.51e1iii only applies if *more than
> one* pilot is required for the flight.

Okay, I can't argue with that.

Thanks again.

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Jose]

> It would be possible for someone to interpret "... the regulations under
> which the flight is conducted" to indicate that because the pilot flying
> cannot legally fly in IMC, due to currency, that the pilot not flying is
> required.

Yes. But the pilot flying is not required.

OTOH, in VFR, the pilot flying (under the hood) =is= required, because
the whole point of the flight is to train =that= pilot. A reasonable
argument can be made that if the purpose of the IFR flight is also to
train the pilot flying, then the pilot flying =would= also be a required
crewmember, but this has not been addressd by chief counsel to my knowledge.

Yes, the rules don't make sense.

Yes, a different interpretation makes as much sense as this one.

That's the way it is.

Jose
--
Money: what you need when you run out of brains.
for Email, make the obvious change in the address.

[Gary Drescher]

"Jose" > wrote in message
...
>> It would be possible for someone to interpret "... the regulations under
>> which the flight is conducted" to indicate that because the pilot flying
>> cannot legally fly in IMC, due to currency, that the pilot not flying is
>> required.
>
> Yes. But the pilot flying is not required.
>
> OTOH, in VFR, the pilot flying (under the hood) =is= required, because the
> whole point of the flight is to train =that= pilot. A reasonable argument
> can be made that if the purpose of the IFR flight is also to train the
> pilot flying, then the pilot flying =would= also be a required crewmember,
> but this has not been addressd by chief counsel to my knowledge.

I think the FAA's rationale for allowing the PIC safety pilot (along with
the sole manipulator) to log PIC time under 61.51e1iii is that in order to
fly according to 91.109b, you need to have the two pilots mentioned by that
section; otherwise, you're flying according to some other regulation
instead. In contrast, there's no regulation that mentions both pilots in the
IMC/IFR training scenario. I agree that's a weak argument for letting the
safety pilot log PIC time; but at rate, it's stronger than any argument that
can be made for letting the IR-rated PIC log PIC time in the IMC/IFR
scenario.

--Gary

[Robert M. Gary]

> Not at all. Why do you say that? Being a required pilot does not entitle you
> to log PIC time;

I'm using "required crew member" in the more standard sense, referring
to 61.51(e).iii "more than one pilot required". The term is also used
with reference to medicals being necessary (i.e. the safety pilot must
have a medical).

-Robert

[Gary Drescher]

"Robert M. Gary" > wrote in message
oups.com...
>> Not at all. Why do you say that? Being a required pilot does not entitle
>> you
>> to log PIC time;
>
> I'm using "required crew member" in the more standard sense, referring
> to 61.51(e).iii "more than one pilot required".

That's not a different sense of "required pilot". It's the same sense but a
different *number*.

The instrument-rated PIC in the IFR scenario *is* a required pilot in the
sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC
time, because the flight in question does not require *more than one* pilot
(because the other pilot, the non-instrument-rated sole manipulator, is
*not* a required pilot for the flight).

--Gary

[Mark Hansen]

On 02/17/06 11:52, Gary Drescher wrote:
> "Robert M. Gary" > wrote in message
> oups.com...
>>> Not at all. Why do you say that? Being a required pilot does not entitle
>>> you
>>> to log PIC time;
>>
>> I'm using "required crew member" in the more standard sense, referring
>> to 61.51(e).iii "more than one pilot required".
>
> That's not a different sense of "required pilot". It's the same sense but a
> different *number*.
>
> The instrument-rated PIC in the IFR scenario *is* a required pilot in the
> sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC
> time, because the flight in question does not require *more than one* pilot
> (because the other pilot, the non-instrument-rated sole manipulator, is
> *not* a required pilot for the flight).
>
> --Gary
>
>

I wasn't going to jump back in here, but ... I just don't buy this, and I
would really like to see something from the FAA on the subject. Something
more than just your interpretations of the FAR the way it's currently
written.

This flight is for regaining currency on the part of the pilot flying.
Without the pilot flying, there is no purpose for the flight. For this
flight, the pilot flying is required - as you must have a pilot flying.

With that, the pilot flying cannot act as PIC because his currency has
lapsed, so the pilot not flying is also required.

That is how I interpret 61.51 (e) (1) (iii).

--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> This flight is for regaining currency on the part of the pilot flying.
> Without the pilot flying, there is no purpose for the flight. For this
> flight, the pilot flying is required - as you must have a pilot flying.

You're right that the sole-manipulator pilot is required for the purpose of
that flight. And since the instrument-rated PIC is required too (to be legal
for IFR), you're right that that does add up to more than one pilot required
for the purpose of the flight.

Nonetheless, there is not more than one pilot required *by the regulations
under which the flight is conducted* (as opposed to being required by the
purpose of the flight). And requirement *by the regulations under which the
flight is conducted* is the criterion set forth by 61.51e1iii.

If instead the criterion were just that more than one pilot is required *for
the purpose of the flight*, then the criterion that more than one pilot is
required could be met on *any* flight--because if the purpose of a
particular flight is to allow the sole-manipulator and the acting-PIC both
to log PIC time simultaneously (therefore at half the cost to each), then of
course both pilots are indeed required *for that purpose*! But then the
multiple-pilots-required criterion would be meaningless. Therefore, the
multiple-pilots-required criterion couldn't reasonably be interpreted to
mean that the multiple pilots are merely required *for the flight's
purpose*. (And again, the regulation explicitly says that multiple pilots
must be required *by the regulations under which the flight is conducted*.)

> I would really like to see something from the FAA on the subject.

That's certainly appropriate. I'm only addressing what the FARs can
reasonably be intepreted to mean, which is something we can analyze on our
own. But how the FAA actually interprets the FARs is a separate question
that requires additional evidence to answer.

--Gary

[Mark Hansen]

On 02/18/06 09:48, Gary Drescher wrote:
> "Mark Hansen" > wrote in message
> ...
>> This flight is for regaining currency on the part of the pilot flying.
>> Without the pilot flying, there is no purpose for the flight. For this
>> flight, the pilot flying is required - as you must have a pilot flying.
>
> You're right that the sole-manipulator pilot is required for the purpose of
> that flight. And since the instrument-rated PIC is required too (to be legal
> for IFR), you're right that that does add up to more than one pilot required
> for the purpose of the flight.
>
> Nonetheless, there is not more than one pilot required *by the regulations
> under which the flight is conducted* (as opposed to being required by the
> purpose of the flight). And requirement *by the regulations under which the
> flight is conducted* is the criterion set forth by 61.51e1iii.

I think that more than one pilot is required, by regulation. As per the
currency regulation (I don't have the number handy) the pilot flying
cannot fly in IMC without a second qualified and current pilot acting
as PIC. Therefore, the regulations require that for this flight, the
second pilot is required.


>
> If instead the criterion were just that more than one pilot is required *for
> the purpose of the flight*, then the criterion that more than one pilot is
> required could be met on *any* flight--because if the purpose of a
> particular flight is to allow the sole-manipulator and the acting-PIC both
> to log PIC time simultaneously (therefore at half the cost to each), then of
> course both pilots are indeed required *for that purpose*! But then the
> multiple-pilots-required criterion would be meaningless. Therefore, the
> multiple-pilots-required criterion couldn't reasonably be interpreted to
> mean that the multiple pilots are merely required *for the flight's
> purpose*. (And again, the regulation explicitly says that multiple pilots
> must be required *by the regulations under which the flight is conducted*.)
>
>> I would really like to see something from the FAA on the subject.
>
> That's certainly appropriate. I'm only addressing what the FARs can
> reasonably be intepreted to mean, which is something we can analyze on our
> own. But how the FAA actually interprets the FARs is a separate question
> that requires additional evidence to answer.

I agree.

>
> --Gary
>
>


--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

[Gary Drescher]

"Mark Hansen" > wrote in message
...
> On 02/18/06 09:48, Gary Drescher wrote:
>> "Mark Hansen" > wrote in message
>> ...
>>> This flight is for regaining currency on the part of the pilot flying.
>>> Without the pilot flying, there is no purpose for the flight. For this
>>> flight, the pilot flying is required - as you must have a pilot flying.
>>
>> You're right that the sole-manipulator pilot is required for the purpose
>> of that flight. And since the instrument-rated PIC is required too (to be
>> legal for IFR), you're right that that does add up to more than one pilot
>> required for the purpose of the flight.
>>
>> Nonetheless, there is not more than one pilot required *by the
>> regulations under which the flight is conducted* (as opposed to being
>> required by the purpose of the flight). And requirement *by the
>> regulations under which the flight is conducted* is the criterion set
>> forth by 61.51e1iii.
>
> I think that more than one pilot is required, by regulation. As per the
> currency regulation (I don't have the number handy) the pilot flying
> cannot fly in IMC without a second qualified and current pilot acting
> as PIC. Therefore, the regulations require that for this flight, the
> second pilot is required.

Yes, but we're back to the same point again: the *regulations* do require
the second pilot but don't require the first pilot! (Therefore, the
regulations don't require more than one pilot.) The *purpose of the flight*
requires the first pilot too, but 61.51e1iii only refers to who's required
by the *regulations of the flight*, not who's required by the *purpose of
the flight*. (Otherwise, as I noted earlier, you could *always* say that two
pilots are required as long as the "purpose of the flight" is to have both
logging PIC simultaneously!)

--Gary

[Jim Macklin]

The FAA will say that the pilot needing to get his IFR
currency can do it in VMC and does not need IMC with a
current IFR pilot, if they go out on a VMC day, the IFR
pilot is just a safety pilot.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Mark Hansen" > wrote in message
...
| On 02/18/06 09:48, Gary Drescher wrote:
| > "Mark Hansen" > wrote in message
| > ...
| >> This flight is for regaining currency on the part of
the pilot flying.
| >> Without the pilot flying, there is no purpose for the
flight. For this
| >> flight, the pilot flying is required - as you must have
a pilot flying.
| >
| > You're right that the sole-manipulator pilot is required
for the purpose of
| > that flight. And since the instrument-rated PIC is
required too (to be legal
| > for IFR), you're right that that does add up to more
than one pilot required
| > for the purpose of the flight.
| >
| > Nonetheless, there is not more than one pilot required
*by the regulations
| > under which the flight is conducted* (as opposed to
being required by the
| > purpose of the flight). And requirement *by the
regulations under which the
| > flight is conducted* is the criterion set forth by
61.51e1iii.
|
| I think that more than one pilot is required, by
regulation. As per the
| currency regulation (I don't have the number handy) the
pilot flying
| cannot fly in IMC without a second qualified and current
pilot acting
| as PIC. Therefore, the regulations require that for this
flight, the
| second pilot is required.
|
|
| >
| > If instead the criterion were just that more than one
pilot is required *for
| > the purpose of the flight*, then the criterion that more
than one pilot is
| > required could be met on *any* flight--because if the
purpose of a
| > particular flight is to allow the sole-manipulator and
the acting-PIC both
| > to log PIC time simultaneously (therefore at half the
cost to each), then of
| > course both pilots are indeed required *for that
purpose*! But then the
| > multiple-pilots-required criterion would be meaningless.
Therefore, the
| > multiple-pilots-required criterion couldn't reasonably
be interpreted to
| > mean that the multiple pilots are merely required *for
the flight's
| > purpose*. (And again, the regulation explicitly says
that multiple pilots
| > must be required *by the regulations under which the
flight is conducted*.)
| >
| >> I would really like to see something from the FAA on
the subject.
| >
| > That's certainly appropriate. I'm only addressing what
the FARs can
| > reasonably be intepreted to mean, which is something we
can analyze on our
| > own. But how the FAA actually interprets the FARs is a
separate question
| > that requires additional evidence to answer.
|
| I agree.
|
| >
| > --Gary
| >
| >
|
|
| --
| Mark Hansen, PP-ASEL, Instrument Airplane
| Cal Aggie Flying Farmers
| Sacramento, CA

[Gary Drescher]

"Jim Macklin" > wrote in message
news:r%LJf.95587$4l5.41646@dukeread05...
> The FAA will say that the pilot needing to get his IFR
> currency can do it in VMC and does not need IMC with a
> current IFR pilot, if they go out on a VMC day, the IFR
> pilot is just a safety pilot.

Sure, no one disagrees with any of that. But we were discussing the rules
for PIC logging in the scenario where the nonrated (or noncurrent)
sole-manipulator is flying IFR in IMC with a rated and current PIC.

--Gary

[Robert M. Gary]

> The instrument-rated PIC in the IFR scenario *is* a required pilot in the
> sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC
> time, because the flight in question does not require *more than one* pilot
> (because the other pilot, the non-instrument-rated sole manipulator, is
> *not* a required pilot for the flight).

No, I'm sorry. There is nothing in the certification of her aircraft or
the regulation she is flying under that require her to be there (i.e. a
"required pilot") per 61.51(e)iii. This is a well understood FAR, if
not well written. I suggest you call AOPA. They have an entire handout
they can mail to you to explain the subject.


-Robert

[Gary Drescher]

"Robert M. Gary" > wrote in message
oups.com...
>> The instrument-rated PIC in the IFR scenario *is* a required pilot in the
>> sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC
>> time, because the flight in question does not require *more than one*
>> pilot
>> (because the other pilot, the non-instrument-rated sole manipulator, is
>> *not* a required pilot for the flight).
>
> No, I'm sorry. There is nothing in the certification of her aircraft or
> the regulation she is flying under that require her to be there (i.e. a
> "required pilot") per 61.51(e)iii.

Of course there is. The regulation that requires her to be there is 61.57c,
which sets forth the currency requirements for flying IFR or in IMC. If the
instrument-current PIC is not present, the flight is not legal, since the
flight is IFR and the other pilot (the sole manipulator) is not
instrument-current. Therefore, the instrument-current PIC is required by the
regs (specifically, by 61.57c), but the sole-manipulator pilot is not a
required pilot according to the regs for that flight.

--Gary

[Jim Macklin]

Whether current or not, the pilot flying logs PIC when sole
manipulator. The current pilot, who is required to be PIC
because of a current status of IFR, in IMC is not allowed to
log anything unless they are a CFI. An ATP under Part 121
or 135 [for operations that require an ATP] may log PIC when
they are instructing or observing, or during normal flight
operations.
But the desire to log as much PIC as possible is not a
justification for doing so. What you log and what the FAA
will accept [after the accident] or the insurance company,
may be enough to get your ticket pulled or insurance
cancelled.
Yes, the non-current IFR pilot must have a safety pilot when
getting current in the six month grace period and an IPC is
required after 12 months have expired from the date of the
first flight used to last meet the IFR currency
requirements. In other words, count backwards until you have
the day of the required flights all being meet, then count
forward 6 months. If you are within 6 months file and fly
and log what you do. If more than 6 months have passed you
need a safety pilot, who will log SIC since they are
required and will not be sole manipulator, they are just
EYES and for emergencies. If you can get an IFR rated and
current pilot to let you fly, unless they are a CFI they are
just a passenger even though their IFR currency and name
will be the basis for the IFR flight being legal.

The plain CFI-A can log PIC under these conditions, but a
CFI-IA can conduct the IPC and log as PIC.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.



"Gary Drescher" > wrote in message
...
| "Jim Macklin" > wrote
in message
| news:r%LJf.95587$4l5.41646@dukeread05...
| > The FAA will say that the pilot needing to get his IFR
| > currency can do it in VMC and does not need IMC with a
| > current IFR pilot, if they go out on a VMC day, the IFR
| > pilot is just a safety pilot.
|
| Sure, no one disagrees with any of that. But we were
discussing the rules
| for PIC logging in the scenario where the nonrated (or
noncurrent)
| sole-manipulator is flying IFR in IMC with a rated and
current PIC.
|
| --Gary
|
|

[Jim Macklin]

But the non-current pilot IS NOT required to fly in IMC to
get current, so the flight only requires one pilot per
aircraft certification. The current IFR pilot is required
on the flight plan in IMC but is not flying, nor a CFI so
they cannot log the time, they are just legally responsible
as PIC, but they cannot log it.

There conditions when no pilot will be allowed to log any
pilot time for a flight, and there are times when more than
one pilot will log PIC, but the FAA may ask anytime for you
to explain the facts on a flight. If you have a flight that
doesn't meet the requirements, that flight won't be allowed
to count towards currency or flight test requirements, if
there are many such flights, you may have a real problem.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Gary Drescher" > wrote in message
. ..
| "Robert M. Gary" > wrote in message
|
oups.com...
| >> The instrument-rated PIC in the IFR scenario *is* a
required pilot in the
| >> sense of 61.51e1iii. But 61.51e1iii still does not
entitle her to log PIC
| >> time, because the flight in question does not require
*more than one*
| >> pilot
| >> (because the other pilot, the non-instrument-rated sole
manipulator, is
| >> *not* a required pilot for the flight).
| >
| > No, I'm sorry. There is nothing in the certification of
her aircraft or
| > the regulation she is flying under that require her to
be there (i.e. a
| > "required pilot") per 61.51(e)iii.
|
| Of course there is. The regulation that requires her to be
there is 61.57c,
| which sets forth the currency requirements for flying IFR
or in IMC. If the
| instrument-current PIC is not present, the flight is not
legal, since the
| flight is IFR and the other pilot (the sole manipulator)
is not
| instrument-current. Therefore, the instrument-current PIC
is required by the
| regs (specifically, by 61.57c), but the sole-manipulator
pilot is not a
| required pilot according to the regs for that flight.
|
| --Gary
|
|

[Gary Drescher]

"Jim Macklin" > wrote in message
news:_TMJf.95592$4l5.35130@dukeread05...
> Whether current or not, the pilot flying logs PIC when sole
> manipulator. The current pilot, who is required to be PIC
> because of a current status of IFR, in IMC is not allowed to
> log anything unless they are a CFI.

Right, that's what I've been saying all along.

> Yes, the non-current IFR pilot must have a safety pilot when
> getting current in the six month grace period

Or else must fly in IMC with an instrument-current PIC (the PIC is not a
safety pilot in that scenario).

--Gary

[Gary Drescher]

"Jim Macklin" > wrote in message
news:F%MJf.95595$4l5.29658@dukeread05...
> But the non-current pilot IS NOT required to fly in IMC to
> get current, so the flight only requires one pilot per
> aircraft certification. The current IFR pilot is required
> on the flight plan in IMC but is not flying, nor a CFI so
> they cannot log the time, they are just legally responsible
> as PIC, but they cannot log it.

Right, that's exactly what I've been saying throughout this thread.

--Gary

[Jim Macklin]

We agree on this, now if everybody else will just accept our
position on the subject.


--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.


"Gary Drescher" > wrote in message
...
| "Jim Macklin" > wrote
in message
| news:_TMJf.95592$4l5.35130@dukeread05...
| > Whether current or not, the pilot flying logs PIC when
sole
| > manipulator. The current pilot, who is required to be
PIC
| > because of a current status of IFR, in IMC is not
allowed to
| > log anything unless they are a CFI.
|
| Right, that's what I've been saying all along.
|
| > Yes, the non-current IFR pilot must have a safety pilot
when
| > getting current in the six month grace period
|
| Or else must fly in IMC with an instrument-current PIC
(the PIC is not a
| safety pilot in that scenario).
|
| --Gary
|
|

[Jim Macklin]

When I would go over to the local FSDO for my 6 month 135
checks and annual chief flight instructor checks, the old
hands at the FSDO would send me to the new guys. When I was
asked about some rule or procedure, I'd do my Jack Webb
impression.
Q When does the flight require oxygen? A. "FAR (I'd quote
the rule and paragraph number) says" and the inspector would
interrupt to ask a different question. After about 15
minutes of them asking questions and me starting with the
FAR paragraph number they'd call it a day. Then they
government renumbered part 91 and that made it necessary for
me to either memorize the rules again or actually give
answers.


"Gary Drescher" > wrote in message
...
| "Jim Macklin" > wrote
in message
| news:F%MJf.95595$4l5.29658@dukeread05...
| > But the non-current pilot IS NOT required to fly in IMC
to
| > get current, so the flight only requires one pilot per
| > aircraft certification. The current IFR pilot is
required
| > on the flight plan in IMC but is not flying, nor a CFI
so
| > they cannot log the time, they are just legally
responsible
| > as PIC, but they cannot log it.
|
| Right, that's exactly what I've been saying throughout
this thread.
|
| --Gary
|
|

[Gary Drescher]

"Jim Macklin" > wrote in message
news:vENJf.95896$4l5.91480@dukeread05...
> When I would go over to the local FSDO for my 6 month 135
> checks and annual chief flight instructor checks, the old
> hands at the FSDO would send me to the new guys. When I was
> asked about some rule or procedure, I'd do my Jack Webb
> impression.
> Q When does the flight require oxygen? A. "FAR (I'd quote
> the rule and paragraph number) says" and the inspector would
> interrupt to ask a different question. After about 15
> minutes of them asking questions and me starting with the
> FAR paragraph number they'd call it a day. Then they
> government renumbered part 91 and that made it necessary for
> me to either memorize the rules again or actually give
> answers.

Or just bring a handheld PC and search in real time for the relevant FAR. :)

--Gary

[Jim Macklin]

When I was a student pilot, 1967, the idea of the hand held
computer was only on StarTrek, Bill Gates was still broke
and I was having to learn the regs. I was a fan of Dragnet
and Sgt. Joe Friday. Whenever he would make an arrest he
would say something like, "You're under arrest for violation
of 187 PC" instead of murder.

So just made a game out of the regs in order to memorize
them. Did just fine until they renumbered them, which is
much better since they are grouped rather than scattered.
But it was fun to make the feds squirm when they didn't know
the number until they were flipping the book looking for a
question to ask. Sometimes they would even call me to ask
what a regulation meant.

But if I was learning to fly today, I'd certainly have a big
screen PDA with a GPS and a flash card with all the FARS and
charts.

--
James H. Macklin
ATP,CFI,A&P

--
The people think the Constitution protects their rights;
But government sees it as an obstacle to be overcome.
some support
http://www.usdoj.gov/olc/secondamendment2.htm
See http://www.fija.org/ more about your rights and duties.



"Gary Drescher" > wrote in message
. ..
| "Jim Macklin" > wrote
in message
| news:vENJf.95896$4l5.91480@dukeread05...
| > When I would go over to the local FSDO for my 6 month
135
| > checks and annual chief flight instructor checks, the
old
| > hands at the FSDO would send me to the new guys. When I
was
| > asked about some rule or procedure, I'd do my Jack Webb
| > impression.
| > Q When does the flight require oxygen? A. "FAR (I'd
quote
| > the rule and paragraph number) says" and the inspector
would
| > interrupt to ask a different question. After about 15
| > minutes of them asking questions and me starting with
the
| > FAR paragraph number they'd call it a day. Then they
| > government renumbered part 91 and that made it necessary
for
| > me to either memorize the rules again or actually give
| > answers.
|
| Or just bring a handheld PC and search in real time for
the relevant FAR. :)
|
| --Gary
|
|