Safety pilot "flight time" [Archive]

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kevmor

January 22nd 07, 03:22 AM

When logging safety pilot time, what do you put under the "duration of
flight" column? For example, say I'm flying with a friend who is
wearing a hood. We decided I'll be responsible for the flight before
hand. I can log PIC for the time the other person had the hood on, and
under the "total flight time" column, put the same as the PIC/when he
was wearing the hood?

Someone told me once if the person wore the hood most of the flight,
you could log the "flight time" for the entire flight, because you were
a required crew member. But once he takes it off though, you aren't
required...so I'm thinking it's the same as the PIC time.

Jim Macklin

January 22nd 07, 01:22 PM

Second in command time, only a CFI can log PIC when they are
not actually sole manipulator of the controls.

Be honest, you are only required while the hood is on.

"kevmor" > wrote in message
ups.com...
| When logging safety pilot time, what do you put under the
"duration of
| flight" column? For example, say I'm flying with a friend
who is
| wearing a hood. We decided I'll be responsible for the
flight before
| hand. I can log PIC for the time the other person had the
hood on, and
| under the "total flight time" column, put the same as the
PIC/when he
| was wearing the hood?
|
| Someone told me once if the person wore the hood most of
the flight,
| you could log the "flight time" for the entire flight,
because you were
| a required crew member. But once he takes it off though,
you aren't
| required...so I'm thinking it's the same as the PIC time.
|

Dave Butler

January 22nd 07, 02:20 PM

Jim Macklin wrote:
> Second in command time, only a CFI can log PIC when they are
> not actually sole manipulator of the controls.
>
> Be honest, you are only required while the hood is on.

You can log PIC, instructor or not, any time you are either acting as
PIC, or the sole manipulator of the controls.

Anyway, it's your logbook, you can write anything you want to in it.
It's only when you want to use your logbook as evidence of experience
for a job or rating application that it matters.

Personally, I don't log time I spend as a safety pilot, but you
certainly may, either as

[PIC if you are acting as PIC], or as

[SIC if you're not PIC but a required crewmember since the PIC is using
a view restricting device].

Mark Hansen

January 22nd 07, 03:25 PM

On 01/22/07 05:22, Jim Macklin wrote:
> Second in command time, only a CFI can log PIC when they are
> not actually sole manipulator of the controls.

What? Can you please show the regulation that stipulates this?
I've never seen it.

>
> Be honest, you are only required while the hood is on.

That depends on the agreement made by the pilots ahead of time. If
they both agree that the safety pilot shall be PIC, then he can log
it that way - for the entire flight. Of course, to do this, the safety
pilot must be qualified to be PIC (if he doesn't have a complex endorsement,
he can't be PIC in a complex airplane for example).

However, if the pilot flying is PIC, the safety pilot is required only
while the pilot flying has a view limiting device on, and should log
SIC only for that time.

>
>
>
> "kevmor" > wrote in message
> ups.com...
> | When logging safety pilot time, what do you put under the
> "duration of
> | flight" column? For example, say I'm flying with a friend
> who is
> | wearing a hood. We decided I'll be responsible for the
> flight before
> | hand. I can log PIC for the time the other person had the
> hood on, and
> | under the "total flight time" column, put the same as the
> PIC/when he
> | was wearing the hood?
> |
> | Someone told me once if the person wore the hood most of
> the flight,
> | you could log the "flight time" for the entire flight,
> because you were
> | a required crew member. But once he takes it off though,
> you aren't
> | required...so I'm thinking it's the same as the PIC time.
> |
>
>

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

Ron Natalie

January 22nd 07, 04:44 PM

Jim Macklin wrote:
> Second in command time, only a CFI can log PIC when they are
> not actually sole manipulator of the controls.

>
You need to go back and read the rules again. There are
certainly several cases where you can log PIC when not
the sole manipulator of the controls. The safety pilot
who is acting as PIC is one of them.

Ron Natalie

January 22nd 07, 04:47 PM

Dave Butler wrote:
> Jim Macklin wrote:
>> Second in command time, only a CFI can log PIC when they are not
>> actually sole manipulator of the controls.
>>
>> Be honest, you are only required while the hood is on.
>
> You can log PIC, instructor or not, any time you are either acting as
> PIC, or the sole manipulator of the controls.
Incorrect.

61.56 is pretty clear. The instructor doesn't need to act as PIC
to log PIC, just to give instruction.

An ATP can log PIC when acting as PIC.

A private or better pilot can log PIC time when acting as PIC
in an operation requiring more than one pilot under the aircraft
certification or under the rules under which the flight was conducted.

Now the latter was probably done with Part 135/121 operations in
mind, but the FAA has affirmed that simulated instrument flight
IS indeed a more-than-one-pilot-required operation.

Dave Butler

January 22nd 07, 05:00 PM

Ron Natalie wrote:
> Dave Butler wrote:

>> You can log PIC, instructor or not, any time you are either acting as
>> PIC, or the sole manipulator of the controls.

> Incorrect.

Hmm, Ron, you are usually precise in your statements, but, assuming you
meant 61.51 below, I don't see anything that contradicts my statement.

>
> 61.56 is pretty clear. The instructor doesn't need to act as PIC
> to log PIC, just to give instruction.

Did you mean 61.51?

>
> An ATP can log PIC when acting as PIC.
>
> A private or better pilot can log PIC time when acting as PIC
> in an operation requiring more than one pilot under the aircraft
> certification or under the rules under which the flight was conducted.
>
> Now the latter was probably done with Part 135/121 operations in
> mind, but the FAA has affirmed that simulated instrument flight
> IS indeed a more-than-one-pilot-required operation.

Mark Hansen

January 22nd 07, 05:28 PM

On 01/22/07 09:46, pgbnh wrote:
> I think part of what you said was in error:
>
>
> Of course, to do this, the safety
>> pilot must be qualified to be PIC (if he doesn't have a complex
>> endorsement,
>> he can't be PIC in a complex airplane for example).
>
> I think the regs say that the SP must be rated in Category and Class. I
> believe that if I am rated in a SEL airplane, I can fly SP in a complex SEL
> airplane.

That's true to act as Safety Pilot. I was talking about acting as PIC.
To be PIC you must also have all the required endorsements, etc.

> "Mark Hansen" > wrote in message
> ...
>> On 01/22/07 05:22, Jim Macklin wrote:
>>> Second in command time, only a CFI can log PIC when they are
>>> not actually sole manipulator of the controls.
>>
>> What? Can you please show the regulation that stipulates this?
>> I've never seen it.
>>
>>>
>>> Be honest, you are only required while the hood is on.
>>
>> That depends on the agreement made by the pilots ahead of time. If
>> they both agree that the safety pilot shall be PIC, then he can log
>> it that way - for the entire flight. Of course, to do this, the safety
>> pilot must be qualified to be PIC (if he doesn't have a complex
>> endorsement,
>> he can't be PIC in a complex airplane for example).
>>
>> However, if the pilot flying is PIC, the safety pilot is required only
>> while the pilot flying has a view limiting device on, and should log
>> SIC only for that time.
>>
>>
>>>
>>>
>>>
>>> "kevmor" > wrote in message
>>> ups.com...
>>> | When logging safety pilot time, what do you put under the
>>> "duration of
>>> | flight" column? For example, say I'm flying with a friend
>>> who is
>>> | wearing a hood. We decided I'll be responsible for the
>>> flight before
>>> | hand. I can log PIC for the time the other person had the
>>> hood on, and
>>> | under the "total flight time" column, put the same as the
>>> PIC/when he
>>> | was wearing the hood?
>>> |
>>> | Someone told me once if the person wore the hood most of
>>> the flight,
>>> | you could log the "flight time" for the entire flight,
>>> because you were
>>> | a required crew member. But once he takes it off though,
>>> you aren't
>>> | required...so I'm thinking it's the same as the PIC time.
>>> |
>>>
>>>
>>
>>
>>
>> --
>> Mark Hansen, PP-ASEL, Instrument Airplane
>> Cal Aggie Flying Farmers
>> Sacramento, CA
>
>

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

Ron Natalie

January 22nd 07, 05:38 PM

Dave Butler wrote:
> Ron Natalie wrote:
>> Dave Butler wrote:
>
>>> You can log PIC, instructor or not, any time you are either acting as
>>> PIC, or the sole manipulator of the controls.
>
>> Incorrect.
>
> Hmm, Ron, you are usually precise in your statements, but, assuming you
> meant 61.51 below, I don't see anything that contradicts my statement.

Where in 61.51 does it say anybody (instructor or not) can log PIC
because they are acting as PIC? There are two specific instances
(ATP and multipilot operation). Otherwise you have to meet one of
the other requirements.

pgbnh[_1_]

January 22nd 07, 05:46 PM

I think part of what you said was in error:

Of course, to do this, the safety
> pilot must be qualified to be PIC (if he doesn't have a complex
> endorsement,
> he can't be PIC in a complex airplane for example).

I think the regs say that the SP must be rated in Category and Class. I
believe that if I am rated in a SEL airplane, I can fly SP in a complex SEL
airplane.
"Mark Hansen" > wrote in message
...
> On 01/22/07 05:22, Jim Macklin wrote:
>> Second in command time, only a CFI can log PIC when they are
>> not actually sole manipulator of the controls.
>
> What? Can you please show the regulation that stipulates this?
> I've never seen it.
>
>>
>> Be honest, you are only required while the hood is on.
>
> That depends on the agreement made by the pilots ahead of time. If
> they both agree that the safety pilot shall be PIC, then he can log
> it that way - for the entire flight. Of course, to do this, the safety
> pilot must be qualified to be PIC (if he doesn't have a complex
> endorsement,
> he can't be PIC in a complex airplane for example).
>
> However, if the pilot flying is PIC, the safety pilot is required only
> while the pilot flying has a view limiting device on, and should log
> SIC only for that time.
>
>
>>
>>
>>
>> "kevmor" > wrote in message
>> ups.com...
>> | When logging safety pilot time, what do you put under the
>> "duration of
>> | flight" column? For example, say I'm flying with a friend
>> who is
>> | wearing a hood. We decided I'll be responsible for the
>> flight before
>> | hand. I can log PIC for the time the other person had the
>> hood on, and
>> | under the "total flight time" column, put the same as the
>> PIC/when he
>> | was wearing the hood?
>> |
>> | Someone told me once if the person wore the hood most of
>> the flight,
>> | you could log the "flight time" for the entire flight,
>> because you were
>> | a required crew member. But once he takes it off though,
>> you aren't
>> | required...so I'm thinking it's the same as the PIC time.
>> |
>>
>>
>
>
>
> --
> Mark Hansen, PP-ASEL, Instrument Airplane
> Cal Aggie Flying Farmers
> Sacramento, CA

Dave Butler

January 22nd 07, 06:13 PM

Ron Natalie wrote:
> Dave Butler wrote:
>> Ron Natalie wrote:
>>> Dave Butler wrote:
>>
>>>> You can log PIC, instructor or not, any time you are either
>>>> acting as PIC, or the sole manipulator of the controls.
>>
>>> Incorrect.
>>
>> Hmm, Ron, you are usually precise in your statements, but, assuming
>> you meant 61.51 below, I don't see anything that contradicts my
>> statement.
>
> Where in 61.51 does it say anybody (instructor or not) can log PIC
> because they are acting as PIC? There are two specific instances
> (ATP and multipilot operation). Otherwise you have to meet one of
> the other requirements.

[(1) A sport, recreational, private, or commercial pilot may log
pilot-in-command time only for that flight time during which that
person-- ...

(iii) Except for a recreational pilot,
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.

I assumed we were talking about safety pilot for a pilot who is wearing
a view-restricting device, so the flight falls under the "more than one
pilot required" clause.

Jim Macklin

January 22nd 07, 07:15 PM

A safety pilot just looks out the window and can only log
SIC, they are a required crewmember/observer, but rarely
actually even touch the controls, almost never sole
manipulator.

"Dave Butler" > wrote in message
...
| Jim Macklin wrote:
| > Second in command time, only a CFI can log PIC when they
are
| > not actually sole manipulator of the controls.
| >
| > Be honest, you are only required while the hood is on.
|
| You can log PIC, instructor or not, any time you are
either acting as
| PIC, or the sole manipulator of the controls.
|
| Anyway, it's your logbook, you can write anything you want
to in it.
| It's only when you want to use your logbook as evidence of
experience
| for a job or rating application that it matters.
|
| Personally, I don't log time I spend as a safety pilot,
but you
| certainly may, either as
|
| [PIC if you are acting as PIC], or as
|
| [SIC if you're not PIC but a required crewmember since the
PIC is using
| a view restricting device].

Jim Macklin

January 22nd 07, 07:20 PM

ATP not operating under FAR 135 or 121 actually can log PIC
the same as any commercial pilot, the must be flying. But
under 121, an ATP assigned as Captain [PIC] can log PIC
while sleeping in the crew bunk room.

Also, ATPs without a CFI can only instruct under 135 or 121
in operations called for in those parts.

"Ron Natalie" > wrote in message
...
| Dave Butler wrote:
| > Ron Natalie wrote:
| >> Dave Butler wrote:
| >
| >>> You can log PIC, instructor or not, any time you are
either acting as
| >>> PIC, or the sole manipulator of the controls.
| >
| >> Incorrect.
| >
| > Hmm, Ron, you are usually precise in your statements,
but, assuming you
| > meant 61.51 below, I don't see anything that contradicts
my statement.
|
| Where in 61.51 does it say anybody (instructor or not) can
log PIC
| because they are acting as PIC? There are two specific
instances
| (ATP and multipilot operation). Otherwise you have to
meet one of
| the other requirements.

Ron Natalie

January 22nd 07, 07:20 PM

Dave Butler wrote:
> Ron Natalie wrote:
>> Dave Butler wrote:
>>> Ron Natalie wrote:
>>>> Dave Butler wrote:
>>>
>>>>> You can log PIC, instructor or not, any time you are either acting
>>>>> as PIC, or the sole manipulator of the controls.
>>>
>>>> Incorrect.
>>>
>>> Hmm, Ron, you are usually precise in your statements, but, assuming
>>> you meant 61.51 below, I don't see anything that contradicts my
>>> statement.
>>
>> Where in 61.51 does it say anybody (instructor or not) can log PIC
>> because they are acting as PIC? There are two specific instances
>> (ATP and multipilot operation). Otherwise you have to meet one of the
>> other requirements.
>
> [(1) A sport, recreational, private, or commercial pilot may log
> pilot-in-command time only for that flight time during which that
> person-- ...
>
> (iii) Except for a recreational pilot,
> 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.
>
> I assumed we were talking about safety pilot for a pilot who is wearing
> a view-restricting device, so the flight falls under the "more than one
> pilot required" clause.
>
>
Your quote said "Any time you are either acting as PIC ..."

Jim Macklin

January 22nd 07, 07:24 PM

You can agree all you want, but to log PIC you must be the
sole manipulator of the controls unless you also hold a
valid CFI.

61.51
(c) Logging of pilot time. The pilot time described in this
section may be used to:

(1) Apply for a certificate or rating issued under this part
or a privilege authorized under this part; or

(2) Satisfy the recent flight experience requirements of
this part.

(d) Logging of solo flight time. Except for a student pilot
performing the duties of pilot in command of an airship
requiring more than one pilot flight crewmember, a pilot may
log as solo flight time only that flight time when the pilot
is the sole occupant of the aircraft.

(e) Logging pilot-in-command flight time. (1) A sport,
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 or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) 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.

(2) An airline transport pilot may log as pilot-in-command
time all of the flight time while acting as pilot-in-command
of an operation requiring an airline transport pilot
certificate.

(3) An authorized instructor may log as pilot-in-command
time all flight time while acting as an authorized
instructor.

(4) A student pilot may log pilot-in-command time only when
the student pilot-

(i) Is the sole occupant of the aircraft or is performing
the duties of pilot of command

"Mark Hansen" > wrote in message
...
| On 01/22/07 05:22, Jim Macklin wrote:
| > Second in command time, only a CFI can log PIC when they
are
| > not actually sole manipulator of the controls.
|
| What? Can you please show the regulation that stipulates
this?
| I've never seen it.
|
| >
| > Be honest, you are only required while the hood is on.
|
| That depends on the agreement made by the pilots ahead of
time. If
| they both agree that the safety pilot shall be PIC, then
he can log
| it that way - for the entire flight. Of course, to do
this, the safety
| pilot must be qualified to be PIC (if he doesn't have a
complex endorsement,
| he can't be PIC in a complex airplane for example).
|
| However, if the pilot flying is PIC, the safety pilot is
required only
| while the pilot flying has a view limiting device on, and
should log
| SIC only for that time.
|
|
| >
| >
| >
| > "kevmor" > wrote in message
| >
ups.com...
| > | When logging safety pilot time, what do you put under
the
| > "duration of
| > | flight" column? For example, say I'm flying with a
friend
| > who is
| > | wearing a hood. We decided I'll be responsible for
the
| > flight before
| > | hand. I can log PIC for the time the other person had
the
| > hood on, and
| > | under the "total flight time" column, put the same as
the
| > PIC/when he
| > | was wearing the hood?
| > |
| > | Someone told me once if the person wore the hood most
of
| > the flight,
| > | you could log the "flight time" for the entire flight,
| > because you were
| > | a required crew member. But once he takes it off
though,
| > you aren't
| > | required...so I'm thinking it's the same as the PIC
time.
| > |
| >
| >
|
|
|
| --
| Mark Hansen, PP-ASEL, Instrument Airplane
| Cal Aggie Flying Farmers
| Sacramento, CA

Jim Macklin

January 22nd 07, 07:25 PM

BS

"Ron Natalie" > wrote in message
m...
| Jim Macklin wrote:
| > Second in command time, only a CFI can log PIC when they
are
| > not actually sole manipulator of the controls.
|
| >
| You need to go back and read the rules again. There are
| certainly several cases where you can log PIC when not
| the sole manipulator of the controls. The safety pilot
| who is acting as PIC is one of them.

Mark Hansen

January 22nd 07, 07:49 PM

On 01/22/07 11:24, Jim Macklin wrote:
> You can agree all you want, but to log PIC you must be the
> sole manipulator of the controls unless you also hold a
> valid CFI.

Not according to the regs you just copied. See below:

For this purpose we're talking about the non-flying pilot
performing safety pilot duties for the flying pilot. If both
pilots agree that the non-flying pilot will be the PIC...

>
>
> 61.51
> (c) Logging of pilot time. The pilot time described in this
> section may be used to:
>
> (1) Apply for a certificate or rating issued under this part
> or a privilege authorized under this part; or
>
> (2) Satisfy the recent flight experience requirements of
> this part.
>
> (d) Logging of solo flight time. Except for a student pilot
> performing the duties of pilot in command of an airship
> requiring more than one pilot flight crewmember, a pilot may
> log as solo flight time only that flight time when the pilot
> is the sole occupant of the aircraft.
>
> (e) Logging pilot-in-command flight time. (1) A sport,
> 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 or has privileges;

The non-flying pilot is not sole manipulator of the controls, so
he can't log PIC as a result of this section.

>
> (ii) Is the sole occupant of the aircraft; or

The non-flying pilot is not the sole occupant either...

>
> (iii) 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.

He is acting as PIC of an aircraft on which more than one pilot
is required by the regulations under which the flight is conducted
(the pilot flying is using a view limiting device, which now
requires the second pilot).

Note that I'm not suggesting the pilot not flying can log PIC for
the entire flight; only that portion which meets the above regs.

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

Ron Natalie

January 22nd 07, 07:51 PM

Jim Macklin wrote:

>
> (iii) 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.
>

Jim, the FAA has repeatedly stated that 14 CFR 91.109(b)
is considered to be one of those caes which more than one pilot
is required under the REGULATIONS UNDER WHICH THE FLIGHT IS
CONDUCTED.

Ron Natalie

January 22nd 07, 07:54 PM

Jim Macklin wrote:
> BS
>
>
>
Well there's a reasoned and intelligent comment backed up with facts.
61.51(2)(iii), 61.52(3), and 61.51(4) all provide for logging PIC
when acting as PIC. In this case 61.51(2)(iii) applies as the flight
is conducted under 61.109(2) which requires a second pilot.

Jim Macklin

January 22nd 07, 08:17 PM

You can agree who will be PIC all you want. That decision
will be important in court during a trial for insurance
coverage, etc. But for logging the time, unless you are the
sole manipulator, a CFI or an ATP in airline operations, you
can't log PIC unless you are flying. If all you are is a
safety pilot, you can't be PIC for the purpose of logging
the time. You can be pic for the purpose of deciding
whether Joe or Fred is legally required to pay from their
estate for the damages.

FAR 1.1
Pilot in command means the person who:

(1) Has final authority and responsibility for the operation
and safety of the flight;

(2) Has been designated as pilot in command before or during
the flight; and

(3) Holds the appropriate category, class, and type rating,
if appropriate, for the conduct of the flight.

"Mark Hansen" > wrote in message
...
| On 01/22/07 11:24, Jim Macklin wrote:
| > You can agree all you want, but to log PIC you must be
the
| > sole manipulator of the controls unless you also hold a
| > valid CFI.
|
| Not according to the regs you just copied. See below:
|
| For this purpose we're talking about the non-flying pilot
| performing safety pilot duties for the flying pilot. If
both
| pilots agree that the non-flying pilot will be the PIC...
|
| >
| >
| > 61.51
| > (c) Logging of pilot time. The pilot time described in
this
| > section may be used to:
| >
| > (1) Apply for a certificate or rating issued under this
part
| > or a privilege authorized under this part; or
| >
| > (2) Satisfy the recent flight experience requirements of
| > this part.
| >
| > (d) Logging of solo flight time. Except for a student
pilot
| > performing the duties of pilot in command of an airship
| > requiring more than one pilot flight crewmember, a pilot
may
| > log as solo flight time only that flight time when the
pilot
| > is the sole occupant of the aircraft.
| >
| > (e) Logging pilot-in-command flight time. (1) A sport,
| > 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 or has privileges;
|
| The non-flying pilot is not sole manipulator of the
controls, so
| he can't log PIC as a result of this section.
|
| >
| > (ii) Is the sole occupant of the aircraft; or
|
| The non-flying pilot is not the sole occupant either...
|
| >
| > (iii) 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.
|
| He is acting as PIC of an aircraft on which more than one
pilot
| is required by the regulations under which the flight is
conducted
| (the pilot flying is using a view limiting device, which
now
| requires the second pilot).
|
| Note that I'm not suggesting the pilot not flying can log
PIC for
| the entire flight; only that portion which meets the above
regs.
|
| --
| Mark Hansen, PP-ASEL, Instrument Airplane
| Cal Aggie Flying Farmers
| Sacramento, CA

Jim Macklin

January 22nd 07, 08:24 PM

Sure, one to look and one is flying. The one flying can LOG
PIC, the one looking can log SIC unless they are a CFI, in
which case they can log PIC w/o actually touching the
controls.

FAR 1.1
Pilot in command means the person who:

(1) Has final authority and responsibility for the operation
and safety of the flight;

(2) Has been designated as pilot in command before or during
the flight; and

(3) Holds the appropriate category, class, and type rating,
if appropriate, for the conduct of the flight.

has nothing to do with logging the time. It is quite
possible that nobody can log PIC on a flight, but every
flight will have somebody who will meet the FAR 1.1
responsibility for the flight.

Agree who is PIC, the decision maker (1), was assigned to be
PIC by the flight dispatcher (2) and do that in writing if
you don't want your widow to be homeless. But the FAA
LOGGING rules are different from the idea that you can
decide to allow the non-flying pilot to log PIC time.

"Ron Natalie" > wrote in message
m...
| Jim Macklin wrote:
|
| >
| > (iii) 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.
| >
|
| Jim, the FAA has repeatedly stated that 14 CFR 91.109(b)
| is considered to be one of those caes which more than one
pilot
| is required under the REGULATIONS UNDER WHICH THE FLIGHT
IS
| CONDUCTED.

Jim Macklin

January 22nd 07, 08:33 PM

You ignored my reasoned statements, so I said your statement
was BS. I stand by that.

All the rules you cite require that to LOG PIC you must be
the pilot flying. Yes, you are looking, you are a safety
pilot. You are required to be there because the single
pilot can't see outside. But unless the guy under the hood
is just sitting there while YOU do the flying, YOU can't LOG
PIC unless you hold a CFI or the flight is an airline
training flight and you're the assigned PIC.

Just because a second pilot is required by 91.109 does not
make that pilot time logable as PIC unless they are the sole
manipulator.
It is very possible that neither pilot can log PIC, but the
FAA will insist that at least one of them will be held
responsible as PIC even if they can't log it.

A safety pilot who is not a CFI should log that time as SIC
because that is what it is. Required crew member not
manipulating the controls.

"Ron Natalie" > wrote in message
m...
| Jim Macklin wrote:
| > BS
| >
| >
| >
| Well there's a reasoned and intelligent comment backed up
with facts.
| 61.51(2)(iii), 61.52(3), and 61.51(4) all provide for
logging PIC
| when acting as PIC. In this case 61.51(2)(iii) applies as
the flight
| is conducted under 61.109(2) which requires a second
pilot.

Mark Hansen

January 22nd 07, 08:41 PM

On 01/22/07 12:17, Jim Macklin wrote:
> You can agree who will be PIC all you want. That decision
> will be important in court during a trial for insurance
> coverage, etc. But for logging the time, unless you are the
> sole manipulator, a CFI or an ATP in airline operations, you
> can't log PIC unless you are flying. If all you are is a
> safety pilot, you can't be PIC for the purpose of logging
> the time. You can be pic for the purpose of deciding
> whether Joe or Fred is legally required to pay from their
> estate for the damages.

Unless you have an FAA legal counsel ruling to the contrary,
the FARs simply don't support your opinion.

>
> FAR 1.1
> Pilot in command means the person who:
>
> (1) Has final authority and responsibility for the operation
> and safety of the flight;
>
> (2) Has been designated as pilot in command before or during
> the flight; and
>
> (3) Holds the appropriate category, class, and type rating,
> if appropriate, for the conduct of the flight.

As for the definition of PIC: In the situation I mentioned before,
the pilot not flying meets all three of the definitions for Pilot
in Command you have listed above.

Mark Hansen

January 22nd 07, 08:45 PM

On 01/22/07 12:33, Jim Macklin wrote:
> You ignored my reasoned statements, so I said your statement
> was BS. I stand by that.
>
> All the rules you cite require that to LOG PIC you must be
> the pilot flying.

Okay, that's a compelling argument. Can you please state which
FAR it is that states that to log PIC you must be the pilot flying?

I can't find it.

> Yes, you are looking, you are a safety
> pilot. You are required to be there because the single
> pilot can't see outside. But unless the guy under the hood
> is just sitting there while YOU do the flying, YOU can't LOG
> PIC unless you hold a CFI or the flight is an airline
> training flight and you're the assigned PIC.
>
> Just because a second pilot is required by 91.109 does not
> make that pilot time logable as PIC unless they are the sole
> manipulator.

Again, I think the FARs disagree with you.

> It is very possible that neither pilot can log PIC, but the
> FAA will insist that at least one of them will be held
> responsible as PIC even if they can't log it.
>
> A safety pilot who is not a CFI should log that time as SIC
> because that is what it is. Required crew member not
> manipulating the controls.
>
>
>
> "Ron Natalie" > wrote in message
> m...
> | Jim Macklin wrote:
> | > BS
> | >
> | >
> | >
> | Well there's a reasoned and intelligent comment backed up
> with facts.
> | 61.51(2)(iii), 61.52(3), and 61.51(4) all provide for
> logging PIC
> | when acting as PIC. In this case 61.51(2)(iii) applies as
> the flight
> | is conducted under 61.109(2) which requires a second
> pilot.
>
>

Jim Macklin

January 22nd 07, 08:49 PM

FAR 1.1 does not and is not controlling for the PURPOSE of
logging flight time. Logging time is required only to show
compliance with some regulation for some certificate or
privilege. To that end, 61.51 is controlling. 61.51
requires manipulation of the controls to LOG PIC.

Perhaps you should either cite the legal counsel's letter or
re-read it.

"Mark Hansen" > wrote in message
...
| On 01/22/07 12:17, Jim Macklin wrote:
| > You can agree who will be PIC all you want. That
decision
| > will be important in court during a trial for insurance
| > coverage, etc. But for logging the time, unless you are
the
| > sole manipulator, a CFI or an ATP in airline operations,
you
| > can't log PIC unless you are flying. If all you are is
a
| > safety pilot, you can't be PIC for the purpose of
logging
| > the time. You can be pic for the purpose of deciding
| > whether Joe or Fred is legally required to pay from
their
| > estate for the damages.
|
|
| Unless you have an FAA legal counsel ruling to the
contrary,
| the FARs simply don't support your opinion.
|
|
| >
| > FAR 1.1
| > Pilot in command means the person who:
| >
| > (1) Has final authority and responsibility for the
operation
| > and safety of the flight;
| >
| > (2) Has been designated as pilot in command before or
during
| > the flight; and
| >
| > (3) Holds the appropriate category, class, and type
rating,
| > if appropriate, for the conduct of the flight.
|
| As for the definition of PIC: In the situation I mentioned
before,
| the pilot not flying meets all three of the definitions
for Pilot
| in Command you have listed above.
|

Jim Macklin

January 22nd 07, 09:01 PM

You cite the rule, that by the two exceptions the FAA lists
for logging time as PIC when not manipulating the controls,
allow logging that time as PIC just because two bozos agree
to both log PIC time beforehand.

It is legal to log the time under the requirement of 91.109
but 91`.109 does not state whether that loggable time is PIC
or SIC.

Title 14: Aeronautics and Space
PART 61-CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND
GROUND INSTRUCTORS
Subpart A-General

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§ 61.51 Pilot logbooks.
(a) Training time and aeronautical experience. Each person
must document and record the following time in a manner
acceptable to the Administrator:

(1) Training and aeronautical experience used to meet the
requirements for a certificate, rating, or flight review of
this part.

(2) The aeronautical experience required for meeting the
recent flight experience requirements of this part.

(b) Logbook entries. For the purposes of meeting the
requirements of paragraph (a) of this section, each person
must enter the following information for each flight or
lesson logged:

(1) General-

(i) Date.

(ii) Total flight time or lesson time.

(iii) Location where the aircraft departed and arrived, or
for lessons in a flight simulator or flight training device,
the location where the lesson occurred.

(iv) Type and identification of aircraft, flight simulator,
or flight training device, as appropriate.

(v) The name of a safety pilot, if required by §91.109(b) of
this chapter.

(2) Type of pilot experience or training-

(i) Solo.

(ii) Pilot in command.

(iii) Second in command.

(iv) Flight and ground training received from an authorized
instructor.

(v) Training received in a flight simulator or flight
training device from an authorized instructor.

(3) Conditions of flight-

(i) Day or night.

(ii) Actual instrument.

(iii) Simulated instrument conditions in flight, a flight
simulator, or a flight training device.

(c) Logging of pilot time. The pilot time described in this
section may be used to:

(1) Apply for a certificate or rating issued under this part
or a privilege authorized under this part; or

(2) Satisfy the recent flight experience requirements of
this part.

(d) Logging of solo flight time. Except for a student pilot
performing the duties of pilot in command of an airship
requiring more than one pilot flight crewmember, a pilot may
log as solo flight time only that flight time when the pilot
is the sole occupant of the aircraft.

(e) Logging pilot-in-command flight time. (1) A sport,
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 or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) 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.

(2) An airline transport pilot may log as pilot-in-command
time all of the flight time while acting as pilot-in-command
of an operation requiring an airline transport pilot
certificate.

(3) An authorized instructor may log as pilot-in-command
time all flight time while acting as an authorized
instructor.

(4) A student pilot may log pilot-in-command time only when
the student pilot-

(i) Is the sole occupant of the aircraft or is performing
the duties of pilot of command of an airship requiring more
than one pilot flight crewmember;

(ii) Has a current solo flight endorsement as required under
§61.87 of this part; and

(iii) Is undergoing training for a pilot certificate or
rating.

(f) Logging second-in-command flight time. A person may log
second-in-command time only for that flight time during
which that person:

(1) Is qualified in accordance with the second-in-command
requirements of §61.55 of this part, and occupies a
crewmember station in an aircraft that requires more than
one pilot by the aircraft's type certificate; or

(2) Holds the appropriate category, class, and instrument
rating (if an instrument rating is required for the flight)
for the aircraft being flown, and more than one pilot is
required under the type certification of the aircraft or the
regulations under which the flight is being conducted.

(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.

(2) An authorized instructor may log instrument time when
conducting instrument flight instruction in actual
instrument flight conditions.

(3) For the purposes of logging instrument time to meet the
recent instrument experience requirements of §61.57(c) of
this part, the following information must be recorded in the
person's logbook-

(i) The location and type of each instrument approach
accomplished; and

(ii) The name of the safety pilot, if required.

(4) A flight simulator or approved flight training device
may be used by a person to log instrument time, provided an
authorized instructor is present during the simulated
flight.

(h) Logging training time. (1) A person may log training
time when that person receives training from an authorized
instructor in an aircraft, flight simulator, or flight
training device.

(2) The training time must be logged in a logbook and must:

(i) Be endorsed in a legible manner by the authorized
instructor; and

(ii) Include a description of the training given, the length
of the training lesson, and the authorized instructor's
signature, certificate number, and certificate expiration
date.

(i) Presentation of required documents. (1) Persons must
present their pilot certificate, medical certificate,
logbook, or any other record required by this part for
inspection upon a reasonable request by-

(i) The Administrator;

(ii) An authorized representative from the National
Transportation Safety Board; or

(iii) Any Federal, State, or local law enforcement officer.

(2) A student pilot must carry the following items in the
aircraft on all solo cross-country flights as evidence of
the required authorized instructor clearances and
endorsements-

(i) Pilot logbook;

(ii) Student pilot certificate; and

(iii) Any other record required by this section.

(3) A sport pilot must carry his or her logbook or other
evidence of required authorized instructor endorsements on
all flights.

(4) A recreational pilot must carry his or her logbook with
the required authorized instructor endorsements on all solo
flights-

(i) That exceed 50 nautical miles from the airport at which
training was received;

(ii) Within airspace that requires communication with air
traffic control;

(iii) Conducted between sunset and sunrise; or

(iv) In an aircraft for which the pilot does not hold an
appropriate category or class rating.

(5) A flight instructor with a sport pilot rating must carry
his or her logbook or other evidence of required authorized
instructor endorsements on all flights when providing flight
training.

[Doc. No. 25910, 62 FR 16298, Apr. 4, 1997; Amdt. 61-103, 62
FR 40897, July 30, 1997; Amdt. 61-104, 63 FR 20286, Apr. 23,
1998; Amdt. 61-110, 69 FR 44865, July 27, 2004]

Browse Previous | Browse Next

§ 91.109 Flight instruction; Simulated instrument flight
and certain flight tests.
(a) No person may operate a civil aircraft (except a manned
free balloon) that is being used for flight instruction
unless that aircraft has fully functioning dual controls.
However, instrument flight instruction may be given in a
single-engine airplane equipped with a single, functioning
throwover control wheel in place of fixed, dual controls of
the elevator and ailerons when-

(1) The instructor has determined that the flight can be
conducted safely; and

(2) The person manipulating the controls has at least a
private pilot certificate with appropriate category and
class ratings.

(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.

(2) The safety pilot has adequate vision forward and to each
side of the aircraft, or a competent observer in the
aircraft adequately supplements the vision of the safety
pilot; and

(3) Except in the case of lighter-than-air aircraft, that
aircraft is equipped with fully functioning dual controls.
However, simulated instrument flight may be conducted in a
single-engine airplane, equipped with a single, functioning,
throwover control wheel, in place of fixed, dual controls of
the elevator and ailerons, when-

(i) The safety pilot has determined that the flight can be
conducted safely; and

(ii) The person manipulating the controls has at least a
private pilot certificate with appropriate category and
class ratings.

(c) No person may operate a civil aircraft that is being
used for a flight test for an airline transport pilot
certificate or a class or type rating on that certificate,
or for a part 121 proficiency flight test, unless the pilot
seated at the controls, other than the pilot being checked,
is fully qualified to act as pilot in command of the
aircraft.

FAR 1.1 (does not refer to logging time0

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation
and safety of the flight;

(2) Has been designated as pilot in command before or during
the flight; and

(3) Holds the appropriate category, class, and type rating,
if appropriate, for the conduct of the flight

Second in command means a pilot who is designated to be
second in command of an aircraft during flight time.

"Mark Hansen" > wrote in message
...
| On 01/22/07 12:33, Jim Macklin wrote:
| > You ignored my reasoned statements, so I said your
statement
| > was BS. I stand by that.
| >
| > All the rules you cite require that to LOG PIC you must
be
| > the pilot flying.
|
| Okay, that's a compelling argument. Can you please state
which
| FAR it is that states that to log PIC you must be the
pilot flying?
|
| I can't find it.
|
|
|
| > Yes, you are looking, you are a
safety
| > pilot. You are required to be there because the single
| > pilot can't see outside. But unless the guy under the
hood
| > is just sitting there while YOU do the flying, YOU can't
LOG
| > PIC unless you hold a CFI or the flight is an airline
| > training flight and you're the assigned PIC.
| >
| > Just because a second pilot is required by 91.109 does
not
| > make that pilot time logable as PIC unless they are the
sole
| > manipulator.
|
| Again, I think the FARs disagree with you.
|
| > It is very possible that neither pilot can log PIC, but
the
| > FAA will insist that at least one of them will be held
| > responsible as PIC even if they can't log it.
| >
| > A safety pilot who is not a CFI should log that time as
SIC
| > because that is what it is. Required crew member not
| > manipulating the controls.
| >
| >
| >
| > "Ron Natalie" > wrote in message
| > m...
| > | Jim Macklin wrote:
| > | > BS
| > | >
| > | >
| > | >
| > | Well there's a reasoned and intelligent comment backed
up
| > with facts.
| > | 61.51(2)(iii), 61.52(3), and 61.51(4) all provide for
| > logging PIC
| > | when acting as PIC. In this case 61.51(2)(iii)
applies as
| > the flight
| > | is conducted under 61.109(2) which requires a second
| > pilot.
| >
| >
|

Bob Moore

January 22nd 07, 09:12 PM

Jim Macklin wrote
> A safety pilot who is not a CFI should log that time as SIC
> because that is what it is. Required crew member not
> manipulating the controls.

Bull****!!!

I'll post the entire opinion if you need it.

Bob Moore

Here is the Chief Counsel decision on the matter:

---
October 30, l992

Mr. David M. Reid

Dear Mr. Reid:

Clip...Clip....Clip

Therefore, while it is not possible for two pilots to act as PIC
simultaneously, it is possible for two pilots to log PIC flight
time simultaneously. PIC flight time may be logged by both the
PIC responsible for the operation and safety of the aircraft
during flight time in accordance with FAR 1.1, and by the pilot
who acts as the sole manipulator of the controls of the aircraft
for which the pilot is rated under FAR 61.51. Enclosed please
find two prior FAA interpretations concerning logging of PIC
time. We hope that these will be of further assistance to you.

In your second question you ask "[h]ow shall two Private Pilots
log their flight time when one pilot is under the hood for
simulated instrument time and the other pilot acts as safety
pilot?" The answer is the pilot who is under the hood may log
PIC time for that flight time in which he is the sole manipulator
of the controls of the aircraft, provided he is rated for that
aircraft. The appropriately rated safety pilot may concurrently
log as second in command (SIC) that time during which he is
acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight
that the safety pilot will be the PIC responsible for the
operation and safety of the aircraft during the flight. If this
is done, then the safety pilot may log all the flight time as PIC
time in accordance with FAR 1.1 and the pilot under the hood may
log, concurrently, all of the flight time during which he is the
sole manipulator of the controls as PIC time in accordance with
FAR 61.51(c)(2)(i).

Mark Hansen

January 22nd 07, 09:54 PM

On 01/22/07 12:49, Jim Macklin wrote:
> FAR 1.1 does not and is not controlling for the PURPOSE of
> logging flight time. Logging time is required only to show
> compliance with some regulation for some certificate or
> privilege. To that end, 61.51 is controlling. 61.51
> requires manipulation of the controls to LOG PIC.
>
> Perhaps you should either cite the legal counsel's letter or
> re-read it.

Actually, I've read 61.51. Can you please state where it says
that the PIC must be manipulating the controls?

I've already shown you where it says he doesn't. It's your turn ;-)

Mark Hansen

January 22nd 07, 10:03 PM

On 01/22/07 13:01, Jim Macklin wrote:
> You cite the rule, that by the two exceptions the FAA lists
> for logging time as PIC when not manipulating the controls,
> allow logging that time as PIC just because two bozos agree
> to both log PIC time beforehand.

We're weren't talking about bozos. We were talking about Pilots.

>
> It is legal to log the time under the requirement of 91.109
> but 91`.109 does not state whether that loggable time is PIC
> or SIC.

That's right - it doesn't. However, 61.51 says that it can be
logged as PIC (under the conditions mentioned earlier).

Once again, you've simply copied the existing FARs without noting
the specific FAR which supports your point.

Are you able to cite the specific FAR are aren't you?

As I've said before, 61.51 (e) (1) (iii) says that the pilot not
flying can log PIC during the time the pilot flying is under the
hood so long as both pilots agree that the pilot flying is acting
as PIC and the pilot not flying meets the other requirements (certs,
ratings, etc.)

>
> Title 14: Aeronautics and Space
> PART 61-CERTIFICATION: PILOTS, FLIGHT INSTRUCTORS, AND
> GROUND INSTRUCTORS
> Subpart A-General
>
> Browse Previous | Browse Next
>
>
> ï¿½ 61.51 Pilot logbooks.
> (a) Training time and aeronautical experience. Each person
> must document and record the following time in a manner
> acceptable to the Administrator:
>
> (1) Training and aeronautical experience used to meet the
> requirements for a certificate, rating, or flight review of
> this part.
>
> (2) The aeronautical experience required for meeting the
> recent flight experience requirements of this part.
>
> (b) Logbook entries. For the purposes of meeting the
> requirements of paragraph (a) of this section, each person
> must enter the following information for each flight or
> lesson logged:
>
> (1) General-
>
> (i) Date.
>
> (ii) Total flight time or lesson time.
>
> (iii) Location where the aircraft departed and arrived, or
> for lessons in a flight simulator or flight training device,
> the location where the lesson occurred.
>
> (iv) Type and identification of aircraft, flight simulator,
> or flight training device, as appropriate.
>
> (v) The name of a safety pilot, if required by ï¿½91.109(b) of
> this chapter.
>
> (2) Type of pilot experience or training-
>
> (i) Solo.
>
> (ii) Pilot in command.
>
> (iii) Second in command.
>
> (iv) Flight and ground training received from an authorized
> instructor.
>
> (v) Training received in a flight simulator or flight
> training device from an authorized instructor.
>
> (3) Conditions of flight-
>
> (i) Day or night.
>
> (ii) Actual instrument.
>
> (iii) Simulated instrument conditions in flight, a flight
> simulator, or a flight training device.
>
> (c) Logging of pilot time. The pilot time described in this
> section may be used to:
>
> (1) Apply for a certificate or rating issued under this part
> or a privilege authorized under this part; or
>
> (2) Satisfy the recent flight experience requirements of
> this part.
>
> (d) Logging of solo flight time. Except for a student pilot
> performing the duties of pilot in command of an airship
> requiring more than one pilot flight crewmember, a pilot may
> log as solo flight time only that flight time when the pilot
> is the sole occupant of the aircraft.
>
> (e) Logging pilot-in-command flight time. (1) A sport,
> 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 or has privileges;
>
> (ii) Is the sole occupant of the aircraft; or
>
> (iii) 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.
>
> (2) An airline transport pilot may log as pilot-in-command
> time all of the flight time while acting as pilot-in-command
> of an operation requiring an airline transport pilot
> certificate.
>
> (3) An authorized instructor may log as pilot-in-command
> time all flight time while acting as an authorized
> instructor.
>
> (4) A student pilot may log pilot-in-command time only when
> the student pilot-
>
> (i) Is the sole occupant of the aircraft or is performing
> the duties of pilot of command of an airship requiring more
> than one pilot flight crewmember;
>
> (ii) Has a current solo flight endorsement as required under
> ï¿½61.87 of this part; and
>
> (iii) Is undergoing training for a pilot certificate or
> rating.
>
> (f) Logging second-in-command flight time. A person may log
> second-in-command time only for that flight time during
> which that person:
>
> (1) Is qualified in accordance with the second-in-command
> requirements of ï¿½61.55 of this part, and occupies a
> crewmember station in an aircraft that requires more than
> one pilot by the aircraft's type certificate; or
>
> (2) Holds the appropriate category, class, and instrument
> rating (if an instrument rating is required for the flight)
> for the aircraft being flown, and more than one pilot is
> required under the type certification of the aircraft or the
> regulations under which the flight is being conducted.
>
> (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.
>
> (2) An authorized instructor may log instrument time when
> conducting instrument flight instruction in actual
> instrument flight conditions.
>
> (3) For the purposes of logging instrument time to meet the
> recent instrument experience requirements of ï¿½61.57(c) of
> this part, the following information must be recorded in the
> person's logbook-
>
> (i) The location and type of each instrument approach
> accomplished; and
>
> (ii) The name of the safety pilot, if required.
>
> (4) A flight simulator or approved flight training device
> may be used by a person to log instrument time, provided an
> authorized instructor is present during the simulated
> flight.
>
> (h) Logging training time. (1) A person may log training
> time when that person receives training from an authorized
> instructor in an aircraft, flight simulator, or flight
> training device.
>
> (2) The training time must be logged in a logbook and must:
>
> (i) Be endorsed in a legible manner by the authorized
> instructor; and
>
> (ii) Include a description of the training given, the length
> of the training lesson, and the authorized instructor's
> signature, certificate number, and certificate expiration
> date.
>
> (i) Presentation of required documents. (1) Persons must
> present their pilot certificate, medical certificate,
> logbook, or any other record required by this part for
> inspection upon a reasonable request by-
>
> (i) The Administrator;
>
> (ii) An authorized representative from the National
> Transportation Safety Board; or
>
> (iii) Any Federal, State, or local law enforcement officer.
>
> (2) A student pilot must carry the following items in the
> aircraft on all solo cross-country flights as evidence of
> the required authorized instructor clearances and
> endorsements-
>
> (i) Pilot logbook;
>
> (ii) Student pilot certificate; and
>
> (iii) Any other record required by this section.
>
> (3) A sport pilot must carry his or her logbook or other
> evidence of required authorized instructor endorsements on
> all flights.
>
> (4) A recreational pilot must carry his or her logbook with
> the required authorized instructor endorsements on all solo
> flights-
>
> (i) That exceed 50 nautical miles from the airport at which
> training was received;
>
> (ii) Within airspace that requires communication with air
> traffic control;
>
> (iii) Conducted between sunset and sunrise; or
>
> (iv) In an aircraft for which the pilot does not hold an
> appropriate category or class rating.
>
> (5) A flight instructor with a sport pilot rating must carry
> his or her logbook or other evidence of required authorized
> instructor endorsements on all flights when providing flight
> training.
>
> [Doc. No. 25910, 62 FR 16298, Apr. 4, 1997; Amdt. 61-103, 62
> FR 40897, July 30, 1997; Amdt. 61-104, 63 FR 20286, Apr. 23,
> 1998; Amdt. 61-110, 69 FR 44865, July 27, 2004]
>
>
> Browse Previous | Browse Next
>
> ï¿½ 91.109 Flight instruction; Simulated instrument flight
> and certain flight tests.
> (a) No person may operate a civil aircraft (except a manned
> free balloon) that is being used for flight instruction
> unless that aircraft has fully functioning dual controls.
> However, instrument flight instruction may be given in a
> single-engine airplane equipped with a single, functioning
> throwover control wheel in place of fixed, dual controls of
> the elevator and ailerons when-
>
> (1) The instructor has determined that the flight can be
> conducted safely; and
>
> (2) The person manipulating the controls has at least a
> private pilot certificate with appropriate category and
> class ratings.
>
> (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.
>
> (2) The safety pilot has adequate vision forward and to each
> side of the aircraft, or a competent observer in the
> aircraft adequately supplements the vision of the safety
> pilot; and
>
> (3) Except in the case of lighter-than-air aircraft, that
> aircraft is equipped with fully functioning dual controls.
> However, simulated instrument flight may be conducted in a
> single-engine airplane, equipped with a single, functioning,
> throwover control wheel, in place of fixed, dual controls of
> the elevator and ailerons, when-
>
> (i) The safety pilot has determined that the flight can be
> conducted safely; and
>
> (ii) The person manipulating the controls has at least a
> private pilot certificate with appropriate category and
> class ratings.
>
> (c) No person may operate a civil aircraft that is being
> used for a flight test for an airline transport pilot
> certificate or a class or type rating on that certificate,
> or for a part 121 proficiency flight test, unless the pilot
> seated at the controls, other than the pilot being checked,
> is fully qualified to act as pilot in command of the
> aircraft.
>
>
>
> FAR 1.1 (does not refer to logging time0
>
> Pilot in command means the person who:
>
> (1) Has final authority and responsibility for the operation
> and safety of the flight;
>
> (2) Has been designated as pilot in command before or during
> the flight; and
>
> (3) Holds the appropriate category, class, and type rating,
> if appropriate, for the conduct of the flight
>
> Second in command means a pilot who is designated to be
> second in command of an aircraft during flight time.
>
>
>
>
> "Mark Hansen" > wrote in message
> ...
> | On 01/22/07 12:33, Jim Macklin wrote:
> | > You ignored my reasoned statements, so I said your
> statement
> | > was BS. I stand by that.
> | >
> | > All the rules you cite require that to LOG PIC you must
> be
> | > the pilot flying.
> |
> | Okay, that's a compelling argument. Can you please state
> which
> | FAR it is that states that to log PIC you must be the
> pilot flying?
> |
> | I can't find it.
> |
> |
> |
> | > Yes, you are looking, you are a
> safety
> | > pilot. You are required to be there because the single
> | > pilot can't see outside. But unless the guy under the
> hood
> | > is just sitting there while YOU do the flying, YOU can't
> LOG
> | > PIC unless you hold a CFI or the flight is an airline
> | > training flight and you're the assigned PIC.
> | >
> | > Just because a second pilot is required by 91.109 does
> not
> | > make that pilot time logable as PIC unless they are the
> sole
> | > manipulator.
> |
> | Again, I think the FARs disagree with you.
> |
> | > It is very possible that neither pilot can log PIC, but
> the
> | > FAA will insist that at least one of them will be held
> | > responsible as PIC even if they can't log it.
> | >
> | > A safety pilot who is not a CFI should log that time as
> SIC
> | > because that is what it is. Required crew member not
> | > manipulating the controls.
> | >
> | >
> | >
> | > "Ron Natalie" > wrote in message
> | > m...
> | > | Jim Macklin wrote:
> | > | > BS
> | > | >
> | > | >
> | > | >
> | > | Well there's a reasoned and intelligent comment backed
> up
> | > with facts.
> | > | 61.51(2)(iii), 61.52(3), and 61.51(4) all provide for
> | > logging PIC
> | > | when acting as PIC. In this case 61.51(2)(iii)
> applies as
> | > the flight
> | > | is conducted under 61.109(2) which requires a second
> | > pilot.
> | >
> | >
> |
>
>

Mark Hansen

January 22nd 07, 10:08 PM

On 01/22/07 14:03, Mark Hansen wrote:
> On 01/22/07 13:01, Jim Macklin wrote:
>> You cite the rule, that by the two exceptions the FAA lists
>> for logging time as PIC when not manipulating the controls,
>> allow logging that time as PIC just because two bozos agree
>> to both log PIC time beforehand.
>
> We're weren't talking about bozos. We were talking about Pilots.
>
>>
>> It is legal to log the time under the requirement of 91.109
>> but 91`.109 does not state whether that loggable time is PIC
>> or SIC.
>
> That's right - it doesn't. However, 61.51 says that it can be
> logged as PIC (under the conditions mentioned earlier).
>
>
> Once again, you've simply copied the existing FARs without noting
> the specific FAR which supports your point.
>
> Are you able to cite the specific FAR are aren't you?
>
> As I've said before, 61.51 (e) (1) (iii) says that the pilot not
> flying can log PIC during the time the pilot flying is under the
> hood so long as both pilots agree that the pilot flying is acting
^^^^^^^^^^^^

Oops, this should have been pilot not flying, of course.

> as PIC and the pilot not flying meets the other requirements (certs,
> ratings, etc.)
>
>>

Jim Macklin

January 22nd 07, 10:28 PM

Yes, please post the entire letter.

"Bob Moore" > wrote in message
46.128...
| Jim Macklin wrote
| > A safety pilot who is not a CFI should log that time as
SIC
| > because that is what it is. Required crew member not
| > manipulating the controls.
|
| Bull****!!!
|
| I'll post the entire opinion if you need it.
|
| Bob Moore
|
| Here is the Chief Counsel decision on the matter:
|
| ---
| October 30, l992
|
|
| Mr. David M. Reid
|
|
| Dear Mr. Reid:
|
| Clip...Clip....Clip
|
| Therefore, while it is not possible for two pilots to act
as PIC
| simultaneously, it is possible for two pilots to log PIC
flight
| time simultaneously. PIC flight time may be logged by
both the
| PIC responsible for the operation and safety of the
aircraft
| during flight time in accordance with FAR 1.1, and by the
pilot
| who acts as the sole manipulator of the controls of the
aircraft
| for which the pilot is rated under FAR 61.51. Enclosed
please
| find two prior FAA interpretations concerning logging of
PIC
| time. We hope that these will be of further assistance to
you.
|
| In your second question you ask "[h]ow shall two Private
Pilots
| log their flight time when one pilot is under the hood for
| simulated instrument time and the other pilot acts as
safety
| pilot?" The answer is the pilot who is under the hood may
log
| PIC time for that flight time in which he is the sole
manipulator
| of the controls of the aircraft, provided he is rated for
that
| aircraft. The appropriately rated safety pilot may
concurrently
| log as second in command (SIC) that time during which he
is
| acting as safety pilot.
|
| The two pilots may, however, agree prior to initiating the
flight
| that the safety pilot will be the PIC responsible for the
| operation and safety of the aircraft during the flight.
If this
| is done, then the safety pilot may log all the flight time
as PIC
| time in accordance with FAR 1.1 and the pilot under the
hood may
| log, concurrently, all of the flight time during which he
is the
| sole manipulator of the controls as PIC time in accordance
with
| FAR 61.51(c)(2)(i).

Jim Macklin

January 22nd 07, 10:34 PM

The PILOT IN COMMAND, responsible for the flight may not be
able to LOG the PIC TIME I.A.W. FAR 61.51 unless he meets
the total rule.

Manipulation of the controls is an essential part of the
logging of PIC time EXCEPT for the two exceptions given to
CFIs and to the extent of certain commercial operations
requiring an ATP, in those cases an ATP who has been
designated as PIC remains pilot in command up to the moment
of the completion of the flight, and the departure of the
passengers safely at the destination.

61.51
e) Logging pilot-in-command flight time. (1) A sport,
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 or has privileges;

"Mark Hansen" > wrote in message
...
| On 01/22/07 12:49, Jim Macklin wrote:
| > FAR 1.1 does not and is not controlling for the PURPOSE
of
| > logging flight time. Logging time is required only to
show
| > compliance with some regulation for some certificate or
| > privilege. To that end, 61.51 is controlling. 61.51
| > requires manipulation of the controls to LOG PIC.
| >
| > Perhaps you should either cite the legal counsel's
letter or
| > re-read it.
|
| Actually, I've read 61.51. Can you please state where it
says
| that the PIC must be manipulating the controls?
|
| I've already shown you where it says he doesn't. It's your
turn ;-)

Jim Macklin

January 22nd 07, 10:38 PM

Bob Moore

January 22nd 07, 10:43 PM

Jim Macklin wrote
> Yes, please post the entire letter.

How many times do we have to argue this issue?
Every year?

Here is the Chief Counsel decision on the matter:

---
October 30, l992

Mr. David M. Reid

Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the
logging of pilot-in-command (PIC) time under the Federal Aviation
Regulations (FAR).

In your letter you ask four questions. First, you ask whether
there are "any circumstances when, during a normal flight, two
Private Pilots may simultaneously act as (and therefore log the
time as) Pilot-In-Command?" The answer is two private pilots may
not simultaneously act as PIC but they may, under certain
circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC
time. PIC, as defined in FAR 1.1, means the pilot responsible
for the operation and safety of an aircraft during flight time.
FAR 61.51 deals with logging PIC flight time, and it provides
that a private or commercial pilot may log as PIC time only that
flight time during which he is the sole manipulator of the
controls of an aircraft for which he is rated, or when he is the
sole occupant of the aircraft, or when he acts as PIC 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 is important to note that FAR 61.51 only
regulates the recording of PIC time used to meet the requirements
toward a higher certificate, higher rating, or for recent flight
experience.

Therefore, while it is not possible for two pilots to act as PIC
simultaneously, it is possible for two pilots to log PIC flight
time simultaneously. PIC flight time may be logged by both the
PIC responsible for the operation and safety of the aircraft
during flight time in accordance with FAR 1.1, and by the pilot
who acts as the sole manipulator of the controls of the aircraft
for which the pilot is rated under FAR 61.51. Enclosed please
find two prior FAA interpretations concerning logging of PIC
time. We hope that these will be of further assistance to you.

In your second question you ask "[h]ow shall two Private Pilots
log their flight time when one pilot is under the hood for
simulated instrument time and the other pilot acts as safety
pilot?" The answer is the pilot who is under the hood may log
PIC time for that flight time in which he is the sole manipulator
of the controls of the aircraft, provided he is rated for that
aircraft. The appropriately rated safety pilot may concurrently
log as second in command (SIC) that time during which he is
acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight
that the safety pilot will be the PIC responsible for the
operation and safety of the aircraft during the flight. If this
is done, then the safety pilot may log all the flight time as PIC
time in accordance with FAR 1.1 and the pilot under the hood may
log, concurrently, all of the flight time during which he is the
sole manipulator of the controls as PIC time in accordance with
FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
interpretation concerning the logging of flight time under
simulated instrument flight conditions. We hope that this
interpretation will be of further assistance to you.

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. Under FAR 61.51(c)(4) the
pilot may log as instrument flight time only that time during
which he operates the aircraft solely by reference to
instruments, under actual or simulated instrument flight
conditions. Please note that the FARs do not distinguish between
"actual" and "simulated" instrument flight time. Enclosed is a
prior FAA interpretation concerning the logging of instrument
flight time. We hope this interpretation will further assist
you.

Finally you ask "[d]oes FAR 61.57 affect how the VFR Private
Pilot shall log Pilot-In-Command time during instrument training,
either before or after meeting the 6/6/6 requirement, and if so,
how?" FAR 61.57 does not affect how a pilot logs PIC time during
instrument training; FAR 61.51(c)(2) and
(4) govern logging of instrument flight time. FAR 61.57(e)
provides currency requirements for acting as PIC under instrument
flight rules (IFR) or in weather conditions less than the
minimums for visual flight rules (VFR). Enclosed
please find a prior FAA interpretation on instrument flight time
and FAR 61.57(e). We hope this interpretation will further
assist you.

We hope this satisfactorily answers your questions.

Sincerely,

Donald P. Byrne
Assistant Chief Counsel
Regulations Division

Mark Hansen

January 22nd 07, 10:46 PM

On 01/22/07 14:34, Jim Macklin wrote:
> The PILOT IN COMMAND, responsible for the flight may not be
> able to LOG the PIC TIME I.A.W. FAR 61.51 unless he meets
> the total rule.

Are you suggesting that for a pilot to log PIC time, according
to 61.51 (e) (1), that the pilot must meet (i) (ii) and (iii)
- All Three?

I must assume then that you do not know what the word "or" means,
so I'm going to bow out of this discussion.

Best Regards,

>
> Manipulation of the controls is an essential part of the
> logging of PIC time EXCEPT for the two exceptions given to
> CFIs and to the extent of certain commercial operations
> requiring an ATP, in those cases an ATP who has been
> designated as PIC remains pilot in command up to the moment
> of the completion of the flight, and the departure of the
> passengers safely at the destination.
>
> 61.51
> e) Logging pilot-in-command flight time. (1) A sport,
> 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 or has privileges;
>
> "Mark Hansen" > wrote in message
> ...
> | On 01/22/07 12:49, Jim Macklin wrote:
> | > FAR 1.1 does not and is not controlling for the PURPOSE
> of
> | > logging flight time. Logging time is required only to
> show
> | > compliance with some regulation for some certificate or
> | > privilege. To that end, 61.51 is controlling. 61.51
> | > requires manipulation of the controls to LOG PIC.
> | >
> | > Perhaps you should either cite the legal counsel's
> letter or
> | > re-read it.
> |
> | Actually, I've read 61.51. Can you please state where it
> says
> | that the PIC must be manipulating the controls?
> |
> | I've already shown you where it says he doesn't. It's your
> turn ;-)
>
>

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

Jim Macklin

January 22nd 07, 10:46 PM

You may be pilot in command many times when you cannot log
that time. There are two kinds of pilot in command.

There is pilot experience pilot in command and there is who
the hell goes to jail pilot in command. One is pilot
experience and one is legal responsibility. They may be
the same person and they may be two or more different
people.

FAR 91.109 allows the safety pilot, as a required crew
member to log the time in accordance with 61.51, but 61.51
STILL requires that actual sole manipulations of the
controls is required to log any PIC time that will apply to
a rating, currency or other purpose.

Just because two pilots agree who will be RESPONSIBLE for
the flight, they cannot alter FAR 61.51 as to who can log
pilot experience PIC time.

If the FAA finds that you have logged time improperly, they
may disallow any or all the time in question. If ratings
have been issued, they can be revoked. If fraud is present
[not merely an innocent error] and flight operations have
been conducted, serious legal action may be taken by the
FAA.

"Mark Hansen" > wrote in message
...
| On 01/22/07 14:03, Mark Hansen wrote:
| > On 01/22/07 13:01, Jim Macklin wrote:
| >> You cite the rule, that by the two exceptions the FAA
lists
| >> for logging time as PIC when not manipulating the
controls,
| >> allow logging that time as PIC just because two bozos
agree
| >> to both log PIC time beforehand.
| >
| > We're weren't talking about bozos. We were talking about
Pilots.
| >
| >>
| >> It is legal to log the time under the requirement of
91.109
| >> but 91`.109 does not state whether that loggable time
is PIC
| >> or SIC.
| >
| > That's right - it doesn't. However, 61.51 says that it
can be
| > logged as PIC (under the conditions mentioned earlier).
| >
| >
| > Once again, you've simply copied the existing FARs
without noting
| > the specific FAR which supports your point.
| >
| > Are you able to cite the specific FAR are aren't you?
| >
| > As I've said before, 61.51 (e) (1) (iii) says that the
pilot not
| > flying can log PIC during the time the pilot flying is
under the
| > hood so long as both pilots agree that the pilot flying
is acting
| ^^^^^^^^^^^^
|
| Oops, this should have been pilot not flying, of course.
|
| > as PIC and the pilot not flying meets the other
requirements (certs,
| > ratings, etc.)
| >
| >>

Jim Macklin

January 22nd 07, 11:00 PM

Thank you for posting the letter. I agrees with my position
IMHO. The question is whether you note the time as 61.51 or
1.1 time.

I wonder what cases have gone through in the past 14 years
to further clarify the issue?

"Bob Moore" > wrote in message
46.128...
| Jim Macklin wrote
| > Yes, please post the entire letter.
|
| How many times do we have to argue this issue?
| Every year?
|
| Here is the Chief Counsel decision on the matter:
|
| ---
| October 30, l992
|
|
| Mr. David M. Reid
|
|
| Dear Mr. Reid:
|
| Thank you for your letter of June 12, 1992, concerning the
| logging of pilot-in-command (PIC) time under the Federal
Aviation
| Regulations (FAR).
|
| In your letter you ask four questions. First, you ask
whether
| there are "any circumstances when, during a normal flight,
two
| Private Pilots may simultaneously act as (and therefore
log the
| time as) Pilot-In-Command?" The answer is two private
pilots may
| not simultaneously act as PIC but they may, under certain
| circumstances, simultaneously log PIC time.
|
| There is a difference between serving as PIC and logging
PIC
| time. PIC, as defined in FAR 1.1, means the pilot
responsible
| for the operation and safety of an aircraft during flight
time.
| FAR 61.51 deals with logging PIC flight time, and it
provides
| that a private or commercial pilot may log as PIC time
only that
| flight time during which he is the sole manipulator of the
| controls of an aircraft for which he is rated, or when he
is the
| sole occupant of the aircraft, or when he acts as PIC 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 is important to note that FAR
61.51 only
| regulates the recording of PIC time used to meet the
requirements
| toward a higher certificate, higher rating, or for recent
flight
| experience.
|
| Therefore, while it is not possible for two pilots to act
as PIC
| simultaneously, it is possible for two pilots to log PIC
flight
| time simultaneously. PIC flight time may be logged by
both the
| PIC responsible for the operation and safety of the
aircraft
| during flight time in accordance with FAR 1.1, and by the
pilot
| who acts as the sole manipulator of the controls of the
aircraft
| for which the pilot is rated under FAR 61.51. Enclosed
please
| find two prior FAA interpretations concerning logging of
PIC
| time. We hope that these will be of further assistance to
you.
|
| In your second question you ask "[h]ow shall two Private
Pilots
| log their flight time when one pilot is under the hood for
| simulated instrument time and the other pilot acts as
safety
| pilot?" The answer is the pilot who is under the hood may
log
| PIC time for that flight time in which he is the sole
manipulator
| of the controls of the aircraft, provided he is rated for
that
| aircraft. The appropriately rated safety pilot may
concurrently
| log as second in command (SIC) that time during which he
is
| acting as safety pilot.
|
| The two pilots may, however, agree prior to initiating the
flight
| that the safety pilot will be the PIC responsible for the
| operation and safety of the aircraft during the flight.
If this
| is done, then the safety pilot may log all the flight time
as PIC
| time in accordance with FAR 1.1 and the pilot under the
hood may
| log, concurrently, all of the flight time during which he
is the
| sole manipulator of the controls as PIC time in accordance
with
| FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
| interpretation concerning the logging of flight time under
| simulated instrument flight conditions. We hope that this
| interpretation will be of further assistance to you.
|
| 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. Under FAR 61.51(c)(4)
the
| pilot may log as instrument flight time only that time
during
| which he operates the aircraft solely by reference to
| instruments, under actual or simulated instrument flight
| conditions. Please note that the FARs do not distinguish
between
| "actual" and "simulated" instrument flight time. Enclosed
is a
| prior FAA interpretation concerning the logging of
instrument
| flight time. We hope this interpretation will further
assist
| you.
|
| Finally you ask "[d]oes FAR 61.57 affect how the VFR
Private
| Pilot shall log Pilot-In-Command time during instrument
training,
| either before or after meeting the 6/6/6 requirement, and
if so,
| how?" FAR 61.57 does not affect how a pilot logs PIC time
during
| instrument training; FAR 61.51(c)(2) and
| (4) govern logging of instrument flight time. FAR
61.57(e)
| provides currency requirements for acting as PIC under
instrument
| flight rules (IFR) or in weather conditions less than the
| minimums for visual flight rules (VFR). Enclosed
| please find a prior FAA interpretation on instrument
flight time
| and FAR 61.57(e). We hope this interpretation will
further
| assist you.
|
| We hope this satisfactorily answers your questions.
|
| Sincerely,
|
| Donald P. Byrne
| Assistant Chief Counsel
| Regulations Division
|
|
|

kevmor

January 23rd 07, 01:02 AM

My question was actually what to put in the "flight duration" or "total
flight time" field of your logbook, if anything. For example, I have a
friend who wants to start his instrument rating. I want to fly with
him between his CFI lessons to let him practice and give tips. If I
can log "flight time" along with the "PIC" (when he's under the hood)
to get time towards a higher rating, that would be great. Should the
"flight time" be equal to the PIC (him under the hood)?

I think the FAA or AOPA should come out with a quick reference card for
this sort of thing! :)

Bob Moore wrote:
> Jim Macklin wrote
> > Yes, please post the entire letter.
>
> How many times do we have to argue this issue?
> Every year?
>

Newps

January 23rd 07, 01:07 AM

kevmor wrote:

> My question was actually what to put in the "flight duration" or "total
> flight time" field of your logbook, if anything. For example, I have a
> friend who wants to start his instrument rating. I want to fly with
> him between his CFI lessons to let him practice and give tips. If I
> can log "flight time" along with the "PIC" (when he's under the hood)
> to get time towards a higher rating, that would be great. Should the
> "flight time" be equal to the PIC (him under the hood)?

That's what nearly everybody does. Log what you fly and don't worry
about it.

Mark Hansen

January 23rd 07, 01:18 AM

On 01/22/07 17:02, kevmor wrote:
> My question was actually what to put in the "flight duration" or "total
> flight time" field of your logbook, if anything. For example, I have a
> friend who wants to start his instrument rating. I want to fly with
> him between his CFI lessons to let him practice and give tips. If I
> can log "flight time" along with the "PIC" (when he's under the hood)
> to get time towards a higher rating, that would be great. Should the
> "flight time" be equal to the PIC (him under the hood)?

If you agree before the flight that you will be PIC while he is under
the hood, then you can log it as PIC for the time that he is under
the hood. If he remains PIC for the flight, then you can log as SIC
the time that he is under the hood.

>
> I think the FAA or AOPA should come out with a quick reference card for
> this sort of thing! :)

Well, that's probably true of a lot of areas. Also, there's a lot of
differing opinions here. The FAA does, from time to time, write legal
opinions on subjects where the FARs are not very clear. Bob Moore
was kind enough to post the results of one which is appropriate to
this discussion.

>
> Bob Moore wrote:
>> Jim Macklin wrote
>> > Yes, please post the entire letter.
>>
>> How many times do we have to argue this issue?
>> Every year?
>>
>

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

kevmor

January 23rd 07, 02:24 AM

Thanks Mark, I think after reading pages and pages of this topic it's
starting to get clearer (especially the SIC/PIC difference). I can log
the time I put in the PIC or SIC column in the flight duration column,
right? So this could count towards the 250 hr. Commercial rating
requirement?

On Jan 22, 5:18 pm, Mark Hansen > wrote:
> On 01/22/07 17:02, kevmor wrote:
>
> > My question was actually what to put in the "flight duration" or "total
> > flight time" field of your logbook, if anything. For example, I have a
> > friend who wants to start his instrument rating. I want to fly with
> > him between his CFI lessons to let him practice and give tips. If I
> > can log "flight time" along with the "PIC" (when he's under the hood)
> > to get time towards a higher rating, that would be great. Should the
> > "flight time" be equal to the PIC (him under the hood)?If you agree before the flight that you will be PIC while he is under
> the hood, then you can log it as PIC for the time that he is under
> the hood. If he remains PIC for the flight, then you can log as SIC
> the time that he is under the hood.
>
>
>
> > I think the FAA or AOPA should come out with a quick reference card for
> > this sort of thing! :)Well, that's probably true of a lot of areas. Also, there's a lot of
> differing opinions here. The FAA does, from time to time, write legal
> opinions on subjects where the FARs are not very clear. Bob Moore
> was kind enough to post the results of one which is appropriate to
> this discussion.
>
>
>
> > Bob Moore wrote:
> >> Jim Macklin wrote
> >> > Yes, please post the entire letter.
>
> >> How many times do we have to argue this issue?
> >> Every year?--
> Mark Hansen, PP-ASEL, Instrument Airplane
> Cal Aggie Flying Farmers
> Sacramento, CA

Mark Hansen

January 23rd 07, 04:30 AM

On 01/22/07 18:24, kevmor wrote:
> Thanks Mark, I think after reading pages and pages of this topic it's
> starting to get clearer (especially the SIC/PIC difference). I can log
> the time I put in the PIC or SIC column in the flight duration column,
> right?

That's the way I understand it.

> So this could count towards the 250 hr. Commercial rating
> requirement?

You'd have to look at the Commercial rating requirements to see if
there are any restrictions mentioned there. Otherwise, yes.

I haven't looked at the commercial rating requirements in a while...

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

Ron Rosenfeld

January 23rd 07, 12:29 PM

On Mon, 22 Jan 2007 09:20:51 -0500, Dave Butler > wrote:

>You can log PIC, instructor or not, any time you are either acting as
>PIC, or the sole manipulator of the controls.

For Part 91 flights, the non-instructor must be PIC on a flight which
requires two flight crew members if he is not the sole manipulator.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld

January 23rd 07, 12:31 PM

On Mon, 22 Jan 2007 07:22:44 -0600, "Jim Macklin"
> wrote:

>Second in command time, only a CFI can log PIC when they are
>not actually sole manipulator of the controls.

Not true.

A non manipulating PIC may log PIC time if the flight requires two flight
crew members. And that is the case if the pilot flying is wearing a
view-limiting device (and the pilots have agreed in advance that the safety
pilot will act as PIC).
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld

January 23rd 07, 12:32 PM

On Mon, 22 Jan 2007 13:15:52 -0600, "Jim Macklin"
> wrote:

>A safety pilot just looks out the window and can only log
>SIC, they are a required crewmember/observer, but rarely
>actually even touch the controls, almost never sole
>manipulator.

If they are required, and acting as PIC, there is no requirement for them
to be the sole manipulator.

This is according to both FAA regulations and written interpretations from
the FAA lawyers.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld

January 23rd 07, 12:42 PM

On Mon, 22 Jan 2007 14:49:04 -0600, "Jim Macklin"
> wrote:

>FAR 1.1 does not and is not controlling for the PURPOSE of
>logging flight time. Logging time is required only to show
>compliance with some regulation for some certificate or
>privilege. To that end, 61.51 is controlling. 61.51
>requires manipulation of the controls to LOG PIC.
>
>Perhaps you should either cite the legal counsel's letter or
>re-read it.
>
>
>

Legal opinion citation:

June 22, 1977 to Mr. Thomas Beane

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

ORIGINAL SIGNED BY EDWARD P. FABERMAN

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

=============================

He actually notes three instance under which the non-manipulating pilot may
log PIC time:

1. More than one pilot required under type certificate.
2. More than one pilot required under regulations (e.g. safety pilot)
3. Pilot manipulating not appropriately rated.

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

Ron Rosenfeld

January 23rd 07, 12:56 PM

On 21 Jan 2007 19:22:35 -0800, "kevmor" > wrote:

>When logging safety pilot time, what do you put under the "duration of
>flight" column? For example, say I'm flying with a friend who is
>wearing a hood. We decided I'll be responsible for the flight before
>hand. I can log PIC for the time the other person had the hood on, and
>under the "total flight time" column, put the same as the PIC/when he
>was wearing the hood?
>
>Someone told me once if the person wore the hood most of the flight,
>you could log the "flight time" for the entire flight, because you were
>a required crew member. But once he takes it off though, you aren't
>required...so I'm thinking it's the same as the PIC time.

According to my interpretation of 61.51, you would log as "total flight
time" the time from when the a/c begins moving for the purpose of flight,
until the time when it stops moving.

---------------------------------------
14 CFR 1.1

Flight time means:

(1) Pilot time that commences when an aircraft moves under its own power
for the purpose of flight and ends when the aircraft comes to rest after
landing;

....
----------------------------------------
14 CFR 61.51

b) Logbook entries. For the purposes of meeting the requirements of
paragraph (a) of this section, each person must enter the following
information for each flight or lesson logged:

(ii) Total flight time or lesson time.

....

(2) Type of pilot experience or training—

(i) Solo.

(ii) Pilot in command.

(iii) Second in command.

....
------------------------------------------

In the scenario you cite, *IF* you meet all of the requirements to *ACT* as
PIC (currency, ratings, endorsements, etc), then, given your agreement with
the pilot flying, you may log PIC time for that part of the flight during
which the pilot flying is "under the hood". If you do not have the
appropriate endorsements, you may log that time as SIC time.

You may not log either PIC or SIC time during that period when the pilot
flying is NOT under the hood (assuming the pilot flying is qualified to act
as PIC).
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Dave Butler

January 23rd 07, 02:52 PM

Ron Rosenfeld wrote:
> On Mon, 22 Jan 2007 09:20:51 -0500, Dave Butler > wrote:
>
>> You can log PIC, instructor or not, any time you are either acting as
>> PIC, or the sole manipulator of the controls.
>
> For Part 91 flights, the non-instructor must be PIC on a flight which
> requires two flight crew members if he is not the sole manipulator.

That is correct. My statement was in the context of a question about
safety-piloting (a flight which requires two flight crew members) and in
the context of a reply to a specific posting that claimed you had to be
an instructor to log PIC if you weren't manipulating the controls. I
didn't spell out all the restrictions because I thought it was clear
from the context.

In the future I will respond to questions of this kind by just saying
"read 61.51". Actually that's still a pretty good answer. There's a lot
of misinformation in this thread that can be cleared up in a few seconds
spent reading 61.51.

Mark Hansen

January 23rd 07, 03:05 PM

On 01/23/07 04:56, Ron Rosenfeld wrote:
> On 21 Jan 2007 19:22:35 -0800, "kevmor" > wrote:
>
>>When logging safety pilot time, what do you put under the "duration of
>>flight" column? For example, say I'm flying with a friend who is
>>wearing a hood. We decided I'll be responsible for the flight before
>>hand. I can log PIC for the time the other person had the hood on, and
>>under the "total flight time" column, put the same as the PIC/when he
>>was wearing the hood?
>>
>>Someone told me once if the person wore the hood most of the flight,
>>you could log the "flight time" for the entire flight, because you were
>>a required crew member. But once he takes it off though, you aren't
>>required...so I'm thinking it's the same as the PIC time.
>
> According to my interpretation of 61.51, you would log as "total flight
> time" the time from when the a/c begins moving for the purpose of flight,
> until the time when it stops moving.
>
> ---------------------------------------
> 14 CFR 1.1
>
> Flight time means:
>
> (1) Pilot time that commences when an aircraft moves under its own power
> for the purpose of flight and ends when the aircraft comes to rest after
> landing;
>
> ...
> ----------------------------------------
> 14 CFR 61.51
>
> b) Logbook entries. For the purposes of meeting the requirements of
> paragraph (a) of this section, each person must enter the following
> information for each flight or lesson logged:
>
> (ii) Total flight time or lesson time.
>
> ...
>
> (2) Type of pilot experience or trainingï¿½
>
> (i) Solo.
>
> (ii) Pilot in command.
>
> (iii) Second in command.
>
> ...
> ------------------------------------------
>
> In the scenario you cite, *IF* you meet all of the requirements to *ACT* as
> PIC (currency, ratings, endorsements, etc), then, given your agreement with
> the pilot flying, you may log PIC time for that part of the flight during
> which the pilot flying is "under the hood". If you do not have the
> appropriate endorsements, you may log that time as SIC time.
>
> You may not log either PIC or SIC time during that period when the pilot
> flying is NOT under the hood (assuming the pilot flying is qualified to act
> as PIC).
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

But ... and I hadn't considered this until now... you would still log the
entire flight time as "total flight time" even though the amount of time
logged under PIC, SIC or both is less than the total.

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

kevmor

January 23rd 07, 08:50 PM

Hmm... but then doesn't that seem kind of far fetched if you decide
before takeoff the safety pilot will be PIC, then the other person
wears the hood for .3 hours, the safety pilot can log the entire
flight, maybe 5 hours, as towards their total time? I wonder if any
examiner would question logging that much time? I could say, "hey,
wear this for a few minutes", then we both log the total time.

On Jan 23, 7:05 am, Mark Hansen > wrote:
> On 01/23/07 04:56, Ron Rosenfeld wrote:
>
>
>
> > On 21 Jan 2007 19:22:35 -0800, "kevmor" > wrote:
>
> >>When logging safety pilot time, what do you put under the "duration of
> >>flight" column? For example, say I'm flying with a friend who is
> >>wearing a hood. We decided I'll be responsible for the flight before
> >>hand. I can log PIC for the time the other person had the hood on, and
> >>under the "total flight time" column, put the same as the PIC/when he
> >>was wearing the hood?
>
> >>Someone told me once if the person wore the hood most of the flight,
> >>you could log the "flight time" for the entire flight, because you were
> >>a required crew member. But once he takes it off though, you aren't
> >>required...so I'm thinking it's the same as the PIC time.
>
> > According to my interpretation of 61.51, you would log as "total flight
> > time" the time from when the a/c begins moving for the purpose of flight,
> > until the time when it stops moving.
>
> > ---------------------------------------
> > 14 CFR 1.1
>
> > Flight time means:
>
> > (1) Pilot time that commences when an aircraft moves under its own power
> > for the purpose of flight and ends when the aircraft comes to rest after
> > landing;
>
> > ...
> > ----------------------------------------
> > 14 CFR 61.51
>
> > b) Logbook entries. For the purposes of meeting the requirements of
> > paragraph (a) of this section, each person must enter the following
> > information for each flight or lesson logged:
>
> > (ii) Total flight time or lesson time.
>
> > ...
>
> > (2) Type of pilot experience or training?
>
> > (i) Solo.
>
> > (ii) Pilot in command.
>
> > (iii) Second in command.
>
> > ...
> > ------------------------------------------
>
> > In the scenario you cite, *IF* you meet all of the requirements to *ACT* as
> > PIC (currency, ratings, endorsements, etc), then, given your agreement with
> > the pilot flying, you may log PIC time for that part of the flight during
> > which the pilot flying is "under the hood". If you do not have the
> > appropriate endorsements, you may log that time as SIC time.
>
> > You may not log either PIC or SIC time during that period when the pilot
> > flying is NOT under the hood (assuming the pilot flying is qualified to act
> > as PIC).
> > Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)But ... and I hadn't considered this until now... you would still log the
> entire flight time as "total flight time" even though the amount of time
> logged under PIC, SIC or both is less than the total.
>
> --
> Mark Hansen, PP-ASEL, Instrument Airplane
> Cal Aggie Flying Farmers
> Sacramento, CA

Mark Hansen

January 23rd 07, 09:01 PM

On 01/23/07 12:50, kevmor wrote:
> Hmm... but then doesn't that seem kind of far fetched if you decide
> before takeoff the safety pilot will be PIC, then the other person
> wears the hood for .3 hours, the safety pilot can log the entire
> flight, maybe 5 hours, as towards their total time? I wonder if any
> examiner would question logging that much time? I could say, "hey,
> wear this for a few minutes", then we both log the total time.

Well, your concerns are what I used to think as well. However, the regs
talk about total flight time as that from when the airplane first moves
under its own power for the purpose of flight, etc.

I would say that if you're on the flight to be a passenger, then don't
log it. If you're on the flight to be a required member, then log it.

What do others have to say about this?

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

Dave Butler

January 23rd 07, 10:08 PM

Mark Hansen wrote:
> On 01/23/07 12:50, kevmor wrote:
>> Hmm... but then doesn't that seem kind of far fetched if you decide
>> before takeoff the safety pilot will be PIC, then the other person
>> wears the hood for .3 hours, the safety pilot can log the entire
>> flight, maybe 5 hours, as towards their total time? I wonder if any
>> examiner would question logging that much time? I could say, "hey,
>> wear this for a few minutes", then we both log the total time.
>
> Well, your concerns are what I used to think as well. However, the regs
> talk about total flight time as that from when the airplane first moves
> under its own power for the purpose of flight, etc.
>
> I would say that if you're on the flight to be a passenger, then don't
> log it. If you're on the flight to be a required member, then log it.
>
> What do others have to say about this

Just because the regulations are nonsensical, we don't have to be. I
don't take the trouble to log SIC time when acting as safety pilot, nor
do I act as PIC when acting as safety pilot. If I did, I'd log what
makes sense.

DGB

Mark Hansen

January 23rd 07, 10:20 PM

On 01/23/07 14:08, Dave Butler wrote:
> Mark Hansen wrote:
>> On 01/23/07 12:50, kevmor wrote:
>>> Hmm... but then doesn't that seem kind of far fetched if you decide
>>> before takeoff the safety pilot will be PIC, then the other person
>>> wears the hood for .3 hours, the safety pilot can log the entire
>>> flight, maybe 5 hours, as towards their total time? I wonder if any
>>> examiner would question logging that much time? I could say, "hey,
>>> wear this for a few minutes", then we both log the total time.
>>
>> Well, your concerns are what I used to think as well. However, the regs
>> talk about total flight time as that from when the airplane first moves
>> under its own power for the purpose of flight, etc.
>>
>> I would say that if you're on the flight to be a passenger, then don't
>> log it. If you're on the flight to be a required member, then log it.
>>
>> What do others have to say about this
>
> Just because the regulations are nonsensical, we don't have to be. I
> don't take the trouble to log SIC time when acting as safety pilot, nor
> do I act as PIC when acting as safety pilot. If I did, I'd log what
> makes sense.
>
> DGB

Well, when I'm acting as safety pilot and not PIC, I log SIC time. What
I wasn't doing was logging the entire time of the flight as the "Total
Flight Time" in my log entry.

In fact, for "Total Flight Time", I put the same value I used for the
SIC time (which was just the time the Pilot Flying had the foggles on).

However, I think that I should be logging the SIC time and Total Flight
Time as two separate, different values.

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

Mark Hansen

January 23rd 07, 10:25 PM

On 01/22/07 15:00, Jim Macklin wrote:
> Thank you for posting the letter. I agrees with my position
> IMHO.

Are you saying that you believe the letter posted by Bob supports
your position?

> The question is whether you note the time as 61.51 or
> 1.1 time.

What? You don't log 1.1 time. You either log your time as PIC or you don't.
1.1 describes the definition of PIC. 61.51 describes the requirements for
logging your time as PIC (among other things).

Oh my!

>
> I wonder what cases have gone through in the past 14 years
> to further clarify the issue?
>
>

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

Alan Gerber

January 23rd 07, 11:44 PM

Dave Butler > wrote:
> In the future I will respond to questions of this kind by just saying
> "read 61.51". Actually that's still a pretty good answer. There's a lot
> of misinformation in this thread that can be cleared up in a few seconds
> spent reading 61.51.

Or in a couple of minutes finding the *LAST* 6,437 threads with this
discussion.

.... Alan
--
Alan Gerber
PP-ASEL
gerber AT panix DOT com

Ron Rosenfeld

January 24th 07, 02:12 AM

On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen >
wrote:

>But ... and I hadn't considered this until now... you would still log the
>entire flight time as "total flight time" even though the amount of time
>logged under PIC, SIC or both is less than the total.

That's what I thought I had written.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld

January 24th 07, 02:14 AM

On 23 Jan 2007 12:50:00 -0800, "kevmor" > wrote:

>Hmm... but then doesn't that seem kind of far fetched if you decide
>before takeoff the safety pilot will be PIC, then the other person
>wears the hood for .3 hours, the safety pilot can log the entire
>flight, maybe 5 hours, as towards their total time? I wonder if any
>examiner would question logging that much time? I could say, "hey,
>wear this for a few minutes", then we both log the total time.

You may be logging the entire flight as total flight time. However, the
only time that "counts" for your commercial is that time that is logged as
PIC time. In your scenario, you would log total flight time as 5 hours;
but PIC time is 0.3 hours.

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

kevmor

January 24th 07, 09:27 PM

Ok, but it'll still count towards the 250 hours of "flight time", you
only need 100 of PIC.

61.129 - Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in
paragraph (i) of this section, a person who applies for a commercial
pilot certificate with an airplane category and single-engine class
rating must log at least 250 hours of flight time as a pilot that
consists of at least:
(1) 100 hours in powered aircraft, of which 50 hours must be in
airplanes.
(2) 100 hours of pilot-in-command flight time, which includes at least
--
....

On Jan 23, 6:14 pm, Ron Rosenfeld > wrote:
> On 23 Jan 2007 12:50:00 -0800, "kevmor" > wrote:
>
> >Hmm... but then doesn't that seem kind of far fetched if you decide
> >before takeoff the safety pilot will be PIC, then the other person
> >wears the hood for .3 hours, the safety pilot can log the entire
> >flight, maybe 5 hours, as towards their total time? I wonder if any
> >examiner would question logging that much time? I could say, "hey,
> >wear this for a few minutes", then we both log the total time.You may be logging the entire flight as total flight time. However, the
> only time that "counts" for your commercial is that time that is logged as
> PIC time. In your scenario, you would log total flight time as 5 hours;
> but PIC time is 0.3 hours.
>
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

bsalai

January 28th 07, 11:58 PM

Ron Rosenfeld wrote:
> On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen >
> wrote:
>
>> But ... and I hadn't considered this until now... you would still log the
>> entire flight time as "total flight time" even though the amount of time
>> logged under PIC, SIC or both is less than the total.
>
> That's what I thought I had written.
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Are you sure about logging the second in command time?

61.51 says:

....
(f) Logging second-in-command time. A person may log second-in-command
flight time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements
of Sec. 61.55 of this part, and occupies a crewmember station in an
aircraft that requires more than one pilot by the aircraft's type
certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an
instrument rating is required for the flight) for the aircraft being
flown, and more than one pilot is required under the type certification
of the aircraft or the regulations under which the flight is being
conducted.

In both cases, it seems to require that the time be in an aircraft that
requires more than one pilot by the aircraft's type certificate.

That isn't the case in any of the aircraft I fly as safety pilot, so,
I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
log it as something else?

Brad

Mark Hansen

January 29th 07, 12:10 AM

On 01/28/07 15:58, bsalai wrote:
> Ron Rosenfeld wrote:
>> On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen >
>> wrote:
>>
>>> But ... and I hadn't considered this until now... you would still log the
>>> entire flight time as "total flight time" even though the amount of time
>>> logged under PIC, SIC or both is less than the total.
>>
>> That's what I thought I had written.
>> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
>
> Are you sure about logging the second in command time?
>
> 61.51 says:
>
> ...
> (f) Logging second-in-command time. A person may log second-in-command
> flight time only for that flight time during which that person:
> (1) Is qualified in accordance with the second-in-command requirements
> of Sec. 61.55 of this part, and occupies a crewmember station in an
> aircraft that requires more than one pilot by the aircraft's type
> certificate; or
> (2) Holds the appropriate category, class, and instrument rating (if an
> instrument rating is required for the flight) for the aircraft being
> flown, and more than one pilot is required under the type certification
> of the aircraft or the regulations under which the flight is being
> conducted.
>
> In both cases, it seems to require that the time be in an aircraft that
> requires more than one pilot by the aircraft's type certificate.

No. In number 2 above, it says:

"... required under the type certificate of the aircraft *or* the
regulations under which the flight..."

When the pilot flying is wearing a view limiting device, the regulations
require that the safety pilot be present.

>
> That isn't the case in any of the aircraft I fly as safety pilot, so,
> I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
> log it as something else?
>
> Brad

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

Ron Rosenfeld

January 29th 07, 12:15 PM

On Sun, 28 Jan 2007 18:58:32 -0500, bsalai > wrote:

>Ron Rosenfeld wrote:
>> On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen >
>> wrote:
>>
>>> But ... and I hadn't considered this until now... you would still log the
>>> entire flight time as "total flight time" even though the amount of time
>>> logged under PIC, SIC or both is less than the total.
>>
>> That's what I thought I had written.
>> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
>
>Are you sure about logging the second in command time?

YES

>
>61.51 says:
>
>...
>(f) Logging second-in-command time. A person may log second-in-command
>flight time only for that flight time during which that person:
>(1) Is qualified in accordance with the second-in-command requirements
>of Sec. 61.55 of this part, and occupies a crewmember station in an
>aircraft that requires more than one pilot by the aircraft's type
>certificate; or
>(2) Holds the appropriate category, class, and instrument rating (if an
>instrument rating is required for the flight) for the aircraft being
>flown, and more than one pilot is required under the type certification
>of the aircraft or the regulations under which the flight is being
>conducted.
>
>In both cases, it seems to require that the time be in an aircraft that
>requires more than one pilot by the aircraft's type certificate.
>
>That isn't the case in any of the aircraft I fly as safety pilot, so,
>I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
>log it as something else?
>
>Brad

Reread 61.51(f)(2) carefully: "...more than one pilot is required under
the type certification of the aircraft ***or the regulations under which
the flight is being conducted***.

91.109(b)(1) is the regulation that *requires* a safety pilot when the
pilot flying is operating the aircraft in simulated instrument flight.

Hence "the regulations under which the flight is being conducted" requires
more than one pilot.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

bsalai

January 29th 07, 12:28 PM

Ron Rosenfeld wrote:
> On Sun, 28 Jan 2007 18:58:32 -0500, bsalai > wrote:
>
>> Ron Rosenfeld wrote:
>>> On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen >
>>> wrote:
>>>
>>>> But ... and I hadn't considered this until now... you would still log the
>>>> entire flight time as "total flight time" even though the amount of time
>>>> logged under PIC, SIC or both is less than the total.
>>> That's what I thought I had written.
>>> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
>> Are you sure about logging the second in command time?
>
> YES
>
>
>> 61.51 says:
>>
>> ...
>> (f) Logging second-in-command time. A person may log second-in-command
>> flight time only for that flight time during which that person:
>> (1) Is qualified in accordance with the second-in-command requirements
>> of Sec. 61.55 of this part, and occupies a crewmember station in an
>> aircraft that requires more than one pilot by the aircraft's type
>> certificate; or
>> (2) Holds the appropriate category, class, and instrument rating (if an
>> instrument rating is required for the flight) for the aircraft being
>> flown, and more than one pilot is required under the type certification
>> of the aircraft or the regulations under which the flight is being
>> conducted.
>>
>> In both cases, it seems to require that the time be in an aircraft that
>> requires more than one pilot by the aircraft's type certificate.
>>
>> That isn't the case in any of the aircraft I fly as safety pilot, so,
>> I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
>> log it as something else?
>>
>> Brad
>
> Reread 61.51(f)(2) carefully: "...more than one pilot is required under
> the type certification of the aircraft ***or the regulations under which
> the flight is being conducted***.
>
> 91.109(b)(1) is the regulation that *requires* a safety pilot when the
> pilot flying is operating the aircraft in simulated instrument flight.
>
> Hence "the regulations under which the flight is being conducted" requires
> more than one pilot.
> Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Absolutely, thanks.

Brad

Stan Prevost

January 29th 07, 03:48 PM

"Ron Rosenfeld" > wrote in message
...

> Legal opinion citation:
>
> June 22, 1977 to Mr. Thomas Beane
>
> ...
> Also, a pilot, rated in category and class (e.g.
> airplane single-engine) could, as the pilot who "Has final authority
> and responsibility for the operation and safety of the flight" log PIC
> time if another pilot, not appropriately rated, was actually
> manipulating the controls of the aircraft.
> ...
>
> =============================
>
> He actually notes three instance under which the non-manipulating pilot
> may
> log PIC time:
>
> 1. More than one pilot required under type certificate.
> 2. More than one pilot required under regulations (e.g. safety pilot)
> 3. Pilot manipulating not appropriately rated.
>
>

I wonder what regulation the lawyer bases #3 on.

He says "rated", meaning has the appropriate ratings on his pilot
certificate. I wonder if that is what he intended, or if he intended
"qualified", which to me would include endorsements, currency and medical.
Seems like the intent must have been if the pilot manipulating was not
qualified as PIC, then the one not manipulating but acting as PIC could log
PIC. But regardless, he said "rated", and we have to take it as written, if
we accept the opinion as valid.

Anyway, that opinion from the chief counsel's office is very interesting.

Ron Rosenfeld

January 29th 07, 08:58 PM

On Mon, 29 Jan 2007 09:48:17 -0600, "Stan Prevost" >
wrote:

>
>"Ron Rosenfeld" > wrote in message
...
>
>> Legal opinion citation:
>>
>> June 22, 1977 to Mr. Thomas Beane
>>
>> ...
>> Also, a pilot, rated in category and class (e.g.
>> airplane single-engine) could, as the pilot who "Has final authority
>> and responsibility for the operation and safety of the flight" log PIC
>> time if another pilot, not appropriately rated, was actually
>> manipulating the controls of the aircraft.
>> ...
>>
>> =============================
>>
>> He actually notes three instance under which the non-manipulating pilot
>> may
>> log PIC time:
>>
>> 1. More than one pilot required under type certificate.
>> 2. More than one pilot required under regulations (e.g. safety pilot)
>> 3. Pilot manipulating not appropriately rated.
>>
>>
>
>I wonder what regulation the lawyer bases #3 on.
>
>He says "rated", meaning has the appropriate ratings on his pilot
>certificate. I wonder if that is what he intended, or if he intended
>"qualified", which to me would include endorsements, currency and medical.
>Seems like the intent must have been if the pilot manipulating was not
>qualified as PIC, then the one not manipulating but acting as PIC could log
>PIC. But regardless, he said "rated", and we have to take it as written, if
>we accept the opinion as valid.
>
>Anyway, that opinion from the chief counsel's office is very interesting.
>

It's an old opinion (1977), and I've not seen that question addressed
recently. However, I don't have a problem accepting "rated" as
differentiated from "qualified to act as PIC".

I guess I would put that in the same category as being able to log PIC if a
"pilot" with "no" ratings (e.g. your kid sister) were manipulating the
controls.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Stan Prevost[_1_]

January 30th 07, 12:25 AM

"Ron Rosenfeld" > wrote in message
...
>
> It's an old opinion (1977), and I've not seen that question addressed
> recently.

I don't think the opinions die of old age unless the underlying regulations
change, and I would think it could be relied upon unless rescinded. I
haven't gone back to the old part 61 and compared.

> However, I don't have a problem accepting "rated" as
> differentiated from "qualified to act as PIC".
>

Nor do I. He said "rated", and as I said, we have to accept what he said.
I was just speculating that the actual intent might have been different.

> I guess I would put that in the same category as being able to log PIC if
> a
> "pilot" with "no" ratings (e.g. your kid sister) were manipulating the
> controls.

I agree, except that you are not allowed to log PIC during the time the kid
sister is manipulating the controls, except perhaps under this legal
opinion.

Dave Butler

January 30th 07, 01:43 PM

> I agree, except that you are not allowed to log PIC during the time the kid
> sister is manipulating the controls, except perhaps under this legal
> opinion.

I call baloney.

Stan Prevost[_1_]

January 30th 07, 02:25 PM

"Dave Butler" > wrote in message
...
>
>> I agree, except that you are not allowed to log PIC during the time the
>> kid sister is manipulating the controls, except perhaps under this legal
>> opinion.
>
> I call baloney.

You call what baloney?

Dave Butler

January 30th 07, 03:36 PM

Stan Prevost wrote:
> "Dave Butler" > wrote in message
> ...
>>> I agree, except that you are not allowed to log PIC during the time the
>>> kid sister is manipulating the controls, except perhaps under this legal
>>> opinion.
>> I call baloney.
>
> You call what baloney?

That one is not allowed to log PIC during the time the kid sister is
manipulating the controls.

Mark Hansen

January 30th 07, 03:54 PM

On 01/30/07 07:36, Dave Butler wrote:
> Stan Prevost wrote:
>> "Dave Butler" > wrote in message
>> ...
>>>> I agree, except that you are not allowed to log PIC during the time the
>>>> kid sister is manipulating the controls, except perhaps under this legal
>>>> opinion.
>>> I call baloney.
>>
>> You call what baloney?
>
> That one is not allowed to log PIC during the time the kid sister is
> manipulating the controls.

The regs are specific in this area, and I agree with Stan. Here they
are:

(e) Logging pilot-in-command flight time.
(1) A sport, 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 or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) 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.

When our Pilot is letting his kid sister operate the controls and fly the
airplane, which one of those three apply to the pilot? He's not the sole
manipulator of the controls, he's not the sole occupant, and the aircraft
does not require more than one pilot.

Now I would guess that every pilot in this situation is logging the time as
PIC, but the statement was that a strict interpretation of the regulations
do not allow it (except that now, the legal opinion provides a way, in that
it allows for an exception if the person operating the controls is not
"rated").

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

Stan Prevost[_1_]

January 30th 07, 03:58 PM

"Mark Hansen" > wrote in message >
> Now I would guess that every pilot in this situation is logging the time
> as
> PIC, but the statement was that a strict interpretation of the regulations
> do not allow it (except that now, the legal opinion provides a way, in
> that
> it allows for an exception if the person operating the controls is not
> "rated").
>
>

Maybe allows a way. The continued effectivity of the opinion would have to
be researched. As Dr. Rosenfeld said, it is old. Part 61 underwent a major
rewrite since that opinion, and the basis for the opinion may have changed.

Mark Hansen

January 30th 07, 04:13 PM

On 01/30/07 07:58, Stan Prevost wrote:
> "Mark Hansen" > wrote in message >
>> Now I would guess that every pilot in this situation is logging the time
>> as
>> PIC, but the statement was that a strict interpretation of the regulations
>> do not allow it (except that now, the legal opinion provides a way, in
>> that
>> it allows for an exception if the person operating the controls is not
>> "rated").
>>
>>
>
> Maybe allows a way. The continued effectivity of the opinion would have to
> be researched. As Dr. Rosenfeld said, it is old. Part 61 underwent a major
> rewrite since that opinion, and the basis for the opinion may have changed.
>

I wonder if when they go about re-writing a section of the FAR if they
don't consider the legal opinions that were written for the section over
the years. I would think they may not want to incorporate the opinion
into the FAR simply because the opinion, as written, is doing its job.

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

Dave Butler

January 30th 07, 07:03 PM

Mark Hansen wrote:

> The regs are specific in this area, and I agree with Stan. Here they
> are:

I withdraw my baloney. Thanks for the correction. DGB