On Sat, 26 Jul 2003 08:02:19 GMT, "Marty Ross"
wrote:

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

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

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

"14 CFR section 61.51(e) governs the logging of pilot-in-command time.
This section provides, in pertinent part, that a private pilot may log
pilot-in-command time for that flight time during which that person is the
sole manipulator of the controls of an AIRCRAFT FOR WHICH THE PILOT IS
RATED. (Emphasis added)

The term "rated," as used under 14 CFR section 61.51(e), refers to the
pilot holding the appropriate aircraft ratings (category, class, and type,
if a type rating is required). These ratings are listed under 14 CFR
section 61.5 and are placed on the pilot certificate.

Therefore, based on the scenario given to Mr. Lynch, a private pilot may
log pilot-in-command time, in a complex or high performance airplane, for
those portions of the flight when he or she is the sole manipulator of the
controls because the aircraft is being operated is single-engine land and
the private pilot holds a single-engine land rating. Note, while the
private pilot may log this time as pilot-in-command time in accordance with
14 CFR section 61.51(e), he or she may not act as the pilot in command
unless he or she has the appropriate endorsement as required under 14 CFR
section 61.31."

Also note this earlier CC opinion regarding your exact situation:

"In your third question you ask "[d]uring instrument training, how
shall a VFR Private Pilot log the following flight time:
Pilot-In-Command time, Simulated Instrument time, and Actual
Instrument time, when that pilot is ...
A) ... under the hood?
B) ...in actual instrument conditions?
C) ... under the hood in actual instrument conditions?"
The answer is the VFR private pilot may log all of the flight time
you described as PIC flight time under FAR 61.51(c)(2)(i)
if he was the sole manipulator of the controls of an aircraft for
which he is rated."


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