Safety pilot "flight time"

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).

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 ;-)

"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.)"

No, it does not say that the safety pilot can log PIC, it
says that in order to log PIC, any pilot not holding a CFI
[or an ATP in airline service], must be mani[pulating the
controls.
(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 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
|
|
| ? 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.
| |
| |
| |
|
|

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

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

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.)
|
|

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
|
|
|

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?

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.

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