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#31
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Multi time building Q
On Dec 11, 6:17 am, "F. Baum" wrote:
The dishonest applicants (The ones who got sent home) would maintain that you could have 2 or more people logging PIC for the same flight. As would I because the FAA has said you can over and over again. As a CFII I would never hire a CFI who did not understand that both the CFI and the rated student *SHOULD* be logging PIC at the same time. If you do not log your rated student's flights as PIC when you fly with them you are doing them a disservice and are not understanding the rules. My guess it that you misunderstood what the local FSDO wrote. I would suggest you post it here. If it really does say what you are saying I'll take it to the FAA and have them reverse it. -Robert, CFII |
#32
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Multi time building Q
On Dec 11, 10:49 am, "Robert M. Gary" wrote:
I never said otherwise. However, to understand this discussion you must mentally separate logging PIC from servings as PIC, the two are the not same. The well understood method of both pilots logging PIC (that the Chief Council approves of is).. Guy #1 flys the plane. He logs PIC because he is the sole manipulator of the controls (very, very clear in 61.51(e)(1)(i). This pilot is under the hood. Guy #2 serves as safety pilot and PIC. He logs PIC under 61.51(e)(1) (iii) and doesn't touch the controls. Both log PIC. This is the method the FAA suggests for both pilots to log PIC. OK Rob, here is what I got from the FAA. Ill use quotation marks where my FSDO budy is talking although it is not entirely verbatim. "This question has come up alot with an entire cottage industry of multi engine time building schools trying to exploit a percieved loophole in the regs. The operation of a light twin does not require two crewmembers so unless one pilot who is rated and current is recieving instruction, only one pilot can log PIC. If the PIC uses a view limiting device he must have a rated safety pilot. This pilot can log time as a safety pilot for the time that the PIC is under the hood. It is concevable that he could log SIC time because the operation reqires two pilots". Robert ask yourself this, if this situation doesnt work at an airline (Where the situation is much more clearly defined), why would it work for GA ? I think this is along the lines of your 50 hours of multi rule. Please note that logging PIC is regulatated by 61.51(e). -Robert, CFII |
#33
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Multi time building Q
On Dec 11, 10:53 am, "Robert M. Gary" wrote:
On Dec 11, 6:17 am, "F. Baum" wrote: As a CFII I would never hire a CFI who did not understand that both the CFI and the rated student *SHOULD* be logging PIC at the same time. If you do not log your rated student's flights as PIC when you fly with them you are doing them a disservice and are not understanding the rules. This is not what is being disputed. Furthermore, the airlines frown on this practice too. I havent filled out an app in awhile but I recall the last ones I did fill out ask for time that I was "soley resposible for the operation of the aircraft" . Maybe the feds could clear things up a bit with verbage similar to this. My guess it that you misunderstood what the local FSDO wrote. I would suggest you post it here. If it really does say what you are saying I'll take it to the FAA and have them reverse it. That was a long time ago and I never had a copy of it. I doubt the FAA would suport the logging of PIC by anyone other than the PIC. -Robert, CFII |
#34
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Multi time building Q
Does that mean if Fred (rated pilot) goes flying with me and we both
watch for traffic and he follows the GPS on a nav chart, I cannot log PIC because I was not 'soley' responsible for the operation of the aircraft? denny - inquiring mind, and all that |
#35
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Multi time building Q
Denny wrote:
Does that mean if Fred (rated pilot) goes flying with me and we both watch for traffic and he follows the GPS on a nav chart, I cannot log PIC because I was not 'soley' responsible for the operation of the aircraft? denny - inquiring mind, and all that No it means that he can't. |
#36
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Multi time building Q
On Dec 12, 6:11 am, Bob Moore wrote:
F. Baum wrote OK Rob, here is what I got from the FAA. Ill use quotation marks where my FSDO budy is talking although it is not entirely verbatim. I have C/P a letter from an FAA Chief Counsel concerning the logging of pilot time by more than one pilot. It is verbatim. :-) Bob Moore ATP ASMEL, Flight Instructor-Instrument PanAm (retired) 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 Robert, thanks for the post. Something to remember is that this letter is 15 years old and the FAA has revised the definitions of logable flight time several times since 1992. Also, as it pertains to these multi engine timebuilding mills, there is still a big grey area . This is why it comes up alot during a pilots interview. I have seen it come up at major airline interviews (I have been ask this) so it is a good idea to be truthfull as to ones capacity during a flight. Happy Holidays, FB |
#37
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Multi time building Q
On Dec 12, 5:48 am, Denny wrote:
Does that mean if Fred (rated pilot) goes flying with me and we both watch for traffic and he follows the GPS on a nav chart, I cannot log PIC because I was not 'soley' responsible for the operation of the aircraft? Hows Fred doin . In this scenario the aircraft type certificate would have to require two pilots, and then one of you would have to log SIC. Helping with the flying chores and looking for traffic is still a great idea. FB |
#38
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Multi time building Q
On Dec 12, 6:54 am, "F. Baum" wrote:
On Dec 12, 6:11 am, Bob Moore wrote: F. Baum wrote OK Rob, here is what I got from the FAA. Ill use quotation marks where my FSDO budy is talking although it is not entirely verbatim. I have C/P a letter from an FAA Chief Counsel concerning the logging of pilot time by more than one pilot. It is verbatim. :-) Bob Moore ATP ASMEL, Flight Instructor-Instrument PanAm (retired) 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 Robert, thanks for the post. Something to remember is that this letter is 15 years old and the FAA has revised the definitions of logable flight time several times since 1992. Also, as it pertains to these multi engine timebuilding mills, there is still a big grey area . This is why it comes up alot during a pilots interview. I have seen it come up at major airline interviews (I have been ask this) so it is a good idea to be truthfull as to ones capacity during a flight. Happy Holidays, I agree. If the applicant were trying to tell you that two pilots were both serving as PIC at the same time then something is very wrong. However, the FAA does allow for both pilots to log PIC at the same time (you don't have to serve as PIC to log PIC per 61.51(e)). I can only speculate as to the FDSO letter however I could easily see that the FSDO may have decided that if one pilot were logging the PIC time as an authorized instructor that the FSDO may have determined that in their operation the MEIs were not really providing instruction but just sitting back and logging PIC. If this were my operation I would require whoever is acting as the MEI at the time to provide a lesson plan and an evaluation afterwards to ensure the MEIs understood that they must provide instruction. -Robert |
#39
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Multi time building Q
On Dec 11, 8:04 pm, "F. Baum" wrote:
On Dec 11, 10:53 am, "Robert M. Gary" wrote: On Dec 11, 6:17 am, "F. Baum" wrote: As a CFII I would never hire a CFI who did not understand that both the CFI and the rated student *SHOULD* be logging PIC at the same time. If you do not log your rated student's flights as PIC when you fly with them you are doing them a disservice and are not understanding the rules. This is not what is being disputed. Furthermore, the airlines frown on this practice too. I havent filled out an app in awhile but I recall the last ones I did fill out ask for time that I was "soley resposible for the operation of the aircraft" . Maybe the feds could clear things up a bit with verbage similar to this. That's probably true. The airlines may ask for the time you served as PIC, the number of times you went to the bathroom, or the number of stewardess you've impregnated. However, 61.51(e) provides for the "logging of PIC" and is very specific as to when you can and cannot log PIC and it is not the same as serving as PIC. The airlines are clearly asking for something different than the FAA is and I can understand why. My guess it that you misunderstood what the local FSDO wrote. I would suggest you post it here. If it really does say what you are saying I'll take it to the FAA and have them reverse it. That was a long time ago and I never had a copy of it. I doubt the FAA would suport the logging of PIC by anyone other than the PIC. FAR 61.51(e) explicitly says you can. Cheers, -Robert |
#40
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Multi time building Q
On Dec 12, 4:48 am, Denny wrote:
Does that mean if Fred (rated pilot) goes flying with me and we both watch for traffic and he follows the GPS on a nav chart, I cannot log PIC because I was not 'soley' responsible for the operation of the aircraft? In fact if you let your 4 year old grand daughter try her hands at the controls during a cross country flight (legal under part 91) then no one an log PIC. Most pilots log PIC as "sole manipulator".... 61.51(e)(1)(i) (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; |
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