On 02/10/06 09:35, Gary Drescher wrote:
"Mark Hansen" wrote in message
...
On 02/10/06 08:54, Gary Drescher wrote:
In the IMC scenario, there is no safety pilot, and there is only one
required crew member (the PIC). Under those circumstances, merely acting
as PIC does not entitle the pilot to log PIC time (acting as PIC is not
one of the three conditions listed in 61.51e1 as the *only* conditions
that allow PIC time to be logged).

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

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

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

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

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

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

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

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

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

Okay ... I'm ready ;-)


Thanks again - this is a great discussion!

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

--Gary




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