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#51
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A couple of questions about IPC
On 02/10/06 15:20, Gary Drescher wrote:
"Mark Hansen" wrote in message ... On 02/10/06 14:48, Gary Drescher wrote: "Mark Hansen" wrote in message ... Yes, I see that, and that certainly seems to be the consensus of everyone offering help here. So, I will conform ;-) No need to change your view just because you're in the minority. I just have a different interpretation of 61.51 (e) (1) (iii), because in my opinion, the pilot not flying is required under the FARs due to the fact that the pilot flying isn't current for IMC. Yup, you're right about that. I don't see how that could be disputed. The question is why you'd think that the regs require the *other* pilot to be there. Remember, 61.51e1iii only applies if the regs require there to be *more than one pilot* for the particular flight. I'm not asserting that the pilot flying (PF) is required by regs to be there. Ok, good. No disagreement so far. I think the regs entitle the PF to log PIC as per 61.51 (e)(1)(i). No disagreement there either. Where I'm getting lost is that if the pilot-not-flying (PNF) must act as PIC (because someone must act as PIC, and the PF cannot due to IMC currency), why his time cannot be logged as PIC. I think the answer is that acting as PIC doesn't mean you can also log PIC. Right. More specifically, 61.51e1iii says you can log PIC time *only* under three specified conditions (and *being* PIC is *not* one of those conditions). But ... 61.51 (e)(1)(iii) seems to tell me that because the PNF is required to be there, he can log his time as PIC. No, that's not what 61.51e1iii says. How do you interpret it that way? Let me state 61.51 (e)(1)(iii) in a way that I think makes my point: "is acting as pilot in command of an aircraft on which more than one pilot is required by the regulations under which the flight is conducted." Yes, that's what 61.51e1iii says. But how does that make your point? Because 61.51 (e) is about logging pilot-in-command flight time. It seems to me the PNF can log the time as PIC because he fits under 61.51 (e)(1)(iii). But ... I think what you're saying is that only one crew member is required because if the PNF was alone, the flight would be legal (assuming he started flying). Yes. The PIC is the only required pilot in the IMC/IFR scenario. I guess I was getting hung up on the premise that the PF not being IMC current caused the 2nd crew member to be required. You're right that the second pilot is required. But the first one isn't! Yeah ... I was presuming that the PNF could log the time because he was required, and the PF could log the time because he was sole manipulator. Do you see why I presumed the 2nd crew member was required? Yes, and I agree with you on that. But 61.51e1iii only applies if the first pilot is *also* required. That is, 61.51e1iii only applies if *more than one* pilot is required for the flight. Okay, I can't argue with that. Thanks again. --Gary -- Mark Hansen, PP-ASEL, Instrument Airplane Cal Aggie Flying Farmers Sacramento, CA |
#52
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A couple of questions about IPC
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. Yes. But the pilot flying is not required. OTOH, in VFR, the pilot flying (under the hood) =is= required, because the whole point of the flight is to train =that= pilot. A reasonable argument can be made that if the purpose of the IFR flight is also to train the pilot flying, then the pilot flying =would= also be a required crewmember, but this has not been addressd by chief counsel to my knowledge. Yes, the rules don't make sense. Yes, a different interpretation makes as much sense as this one. That's the way it is. Jose -- Money: what you need when you run out of brains. for Email, make the obvious change in the address. |
#53
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A couple of questions about IPC
"Jose" wrote in message
... 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. Yes. But the pilot flying is not required. OTOH, in VFR, the pilot flying (under the hood) =is= required, because the whole point of the flight is to train =that= pilot. A reasonable argument can be made that if the purpose of the IFR flight is also to train the pilot flying, then the pilot flying =would= also be a required crewmember, but this has not been addressd by chief counsel to my knowledge. I think the FAA's rationale for allowing the PIC safety pilot (along with the sole manipulator) to log PIC time under 61.51e1iii is that in order to fly according to 91.109b, you need to have the two pilots mentioned by that section; otherwise, you're flying according to some other regulation instead. In contrast, there's no regulation that mentions both pilots in the IMC/IFR training scenario. I agree that's a weak argument for letting the safety pilot log PIC time; but at rate, it's stronger than any argument that can be made for letting the IR-rated PIC log PIC time in the IMC/IFR scenario. --Gary |
#54
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A couple of questions about IPC
Not at all. Why do you say that? Being a required pilot does not entitle you
to log PIC time; I'm using "required crew member" in the more standard sense, referring to 61.51(e).iii "more than one pilot required". The term is also used with reference to medicals being necessary (i.e. the safety pilot must have a medical). -Robert |
#55
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A couple of questions about IPC
"Robert M. Gary" wrote in message
oups.com... Not at all. Why do you say that? Being a required pilot does not entitle you to log PIC time; I'm using "required crew member" in the more standard sense, referring to 61.51(e).iii "more than one pilot required". That's not a different sense of "required pilot". It's the same sense but a different *number*. The instrument-rated PIC in the IFR scenario *is* a required pilot in the sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC time, because the flight in question does not require *more than one* pilot (because the other pilot, the non-instrument-rated sole manipulator, is *not* a required pilot for the flight). --Gary |
#56
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A couple of questions about IPC
On 02/17/06 11:52, Gary Drescher wrote:
"Robert M. Gary" wrote in message oups.com... Not at all. Why do you say that? Being a required pilot does not entitle you to log PIC time; I'm using "required crew member" in the more standard sense, referring to 61.51(e).iii "more than one pilot required". That's not a different sense of "required pilot". It's the same sense but a different *number*. The instrument-rated PIC in the IFR scenario *is* a required pilot in the sense of 61.51e1iii. But 61.51e1iii still does not entitle her to log PIC time, because the flight in question does not require *more than one* pilot (because the other pilot, the non-instrument-rated sole manipulator, is *not* a required pilot for the flight). --Gary I wasn't going to jump back in here, but ... I just don't buy this, and I would really like to see something from the FAA on the subject. Something more than just your interpretations of the FAR the way it's currently written. This flight is for regaining currency on the part of the pilot flying. Without the pilot flying, there is no purpose for the flight. For this flight, the pilot flying is required - as you must have a pilot flying. With that, the pilot flying cannot act as PIC because his currency has lapsed, so the pilot not flying is also required. That is how I interpret 61.51 (e) (1) (iii). -- Mark Hansen, PP-ASEL, Instrument Airplane Cal Aggie Flying Farmers Sacramento, CA |
#57
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A couple of questions about IPC
"Mark Hansen" wrote in message
... This flight is for regaining currency on the part of the pilot flying. Without the pilot flying, there is no purpose for the flight. For this flight, the pilot flying is required - as you must have a pilot flying. You're right that the sole-manipulator pilot is required for the purpose of that flight. And since the instrument-rated PIC is required too (to be legal for IFR), you're right that that does add up to more than one pilot required for the purpose of the flight. Nonetheless, there is not more than one pilot required *by the regulations under which the flight is conducted* (as opposed to being required by the purpose of the flight). And requirement *by the regulations under which the flight is conducted* is the criterion set forth by 61.51e1iii. If instead the criterion were just that more than one pilot is required *for the purpose of the flight*, then the criterion that more than one pilot is required could be met on *any* flight--because if the purpose of a particular flight is to allow the sole-manipulator and the acting-PIC both to log PIC time simultaneously (therefore at half the cost to each), then of course both pilots are indeed required *for that purpose*! But then the multiple-pilots-required criterion would be meaningless. Therefore, the multiple-pilots-required criterion couldn't reasonably be interpreted to mean that the multiple pilots are merely required *for the flight's purpose*. (And again, the regulation explicitly says that multiple pilots must be required *by the regulations under which the flight is conducted*.) I would really like to see something from the FAA on the subject. That's certainly appropriate. I'm only addressing what the FARs can reasonably be intepreted to mean, which is something we can analyze on our own. But how the FAA actually interprets the FARs is a separate question that requires additional evidence to answer. --Gary |
#58
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A couple of questions about IPC
On 02/18/06 09:48, Gary Drescher wrote:
"Mark Hansen" wrote in message ... This flight is for regaining currency on the part of the pilot flying. Without the pilot flying, there is no purpose for the flight. For this flight, the pilot flying is required - as you must have a pilot flying. You're right that the sole-manipulator pilot is required for the purpose of that flight. And since the instrument-rated PIC is required too (to be legal for IFR), you're right that that does add up to more than one pilot required for the purpose of the flight. Nonetheless, there is not more than one pilot required *by the regulations under which the flight is conducted* (as opposed to being required by the purpose of the flight). And requirement *by the regulations under which the flight is conducted* is the criterion set forth by 61.51e1iii. I think that more than one pilot is required, by regulation. As per the currency regulation (I don't have the number handy) the pilot flying cannot fly in IMC without a second qualified and current pilot acting as PIC. Therefore, the regulations require that for this flight, the second pilot is required. If instead the criterion were just that more than one pilot is required *for the purpose of the flight*, then the criterion that more than one pilot is required could be met on *any* flight--because if the purpose of a particular flight is to allow the sole-manipulator and the acting-PIC both to log PIC time simultaneously (therefore at half the cost to each), then of course both pilots are indeed required *for that purpose*! But then the multiple-pilots-required criterion would be meaningless. Therefore, the multiple-pilots-required criterion couldn't reasonably be interpreted to mean that the multiple pilots are merely required *for the flight's purpose*. (And again, the regulation explicitly says that multiple pilots must be required *by the regulations under which the flight is conducted*.) I would really like to see something from the FAA on the subject. That's certainly appropriate. I'm only addressing what the FARs can reasonably be intepreted to mean, which is something we can analyze on our own. But how the FAA actually interprets the FARs is a separate question that requires additional evidence to answer. I agree. --Gary -- Mark Hansen, PP-ASEL, Instrument Airplane Cal Aggie Flying Farmers Sacramento, CA |
#59
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A couple of questions about IPC
"Mark Hansen" wrote in message
... On 02/18/06 09:48, Gary Drescher wrote: "Mark Hansen" wrote in message ... This flight is for regaining currency on the part of the pilot flying. Without the pilot flying, there is no purpose for the flight. For this flight, the pilot flying is required - as you must have a pilot flying. You're right that the sole-manipulator pilot is required for the purpose of that flight. And since the instrument-rated PIC is required too (to be legal for IFR), you're right that that does add up to more than one pilot required for the purpose of the flight. Nonetheless, there is not more than one pilot required *by the regulations under which the flight is conducted* (as opposed to being required by the purpose of the flight). And requirement *by the regulations under which the flight is conducted* is the criterion set forth by 61.51e1iii. I think that more than one pilot is required, by regulation. As per the currency regulation (I don't have the number handy) the pilot flying cannot fly in IMC without a second qualified and current pilot acting as PIC. Therefore, the regulations require that for this flight, the second pilot is required. Yes, but we're back to the same point again: the *regulations* do require the second pilot but don't require the first pilot! (Therefore, the regulations don't require more than one pilot.) The *purpose of the flight* requires the first pilot too, but 61.51e1iii only refers to who's required by the *regulations of the flight*, not who's required by the *purpose of the flight*. (Otherwise, as I noted earlier, you could *always* say that two pilots are required as long as the "purpose of the flight" is to have both logging PIC simultaneously!) --Gary |
#60
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A couple of questions about IPC
The FAA will say that the pilot needing to get his IFR
currency can do it in VMC and does not need IMC with a current IFR pilot, if they go out on a VMC day, the IFR pilot is just a safety pilot. -- James H. Macklin ATP,CFI,A&P -- The people think the Constitution protects their rights; But government sees it as an obstacle to be overcome. some support http://www.usdoj.gov/olc/secondamendment2.htm See http://www.fija.org/ more about your rights and duties. "Mark Hansen" wrote in message ... | On 02/18/06 09:48, Gary Drescher wrote: | "Mark Hansen" wrote in message | ... | This flight is for regaining currency on the part of the pilot flying. | Without the pilot flying, there is no purpose for the flight. For this | flight, the pilot flying is required - as you must have a pilot flying. | | You're right that the sole-manipulator pilot is required for the purpose of | that flight. And since the instrument-rated PIC is required too (to be legal | for IFR), you're right that that does add up to more than one pilot required | for the purpose of the flight. | | Nonetheless, there is not more than one pilot required *by the regulations | under which the flight is conducted* (as opposed to being required by the | purpose of the flight). And requirement *by the regulations under which the | flight is conducted* is the criterion set forth by 61.51e1iii. | | I think that more than one pilot is required, by regulation. As per the | currency regulation (I don't have the number handy) the pilot flying | cannot fly in IMC without a second qualified and current pilot acting | as PIC. Therefore, the regulations require that for this flight, the | second pilot is required. | | | | If instead the criterion were just that more than one pilot is required *for | the purpose of the flight*, then the criterion that more than one pilot is | required could be met on *any* flight--because if the purpose of a | particular flight is to allow the sole-manipulator and the acting-PIC both | to log PIC time simultaneously (therefore at half the cost to each), then of | course both pilots are indeed required *for that purpose*! But then the | multiple-pilots-required criterion would be meaningless. Therefore, the | multiple-pilots-required criterion couldn't reasonably be interpreted to | mean that the multiple pilots are merely required *for the flight's | purpose*. (And again, the regulation explicitly says that multiple pilots | must be required *by the regulations under which the flight is conducted*.) | | I would really like to see something from the FAA on the subject. | | That's certainly appropriate. I'm only addressing what the FARs can | reasonably be intepreted to mean, which is something we can analyze on our | own. But how the FAA actually interprets the FARs is a separate question | that requires additional evidence to answer. | | I agree. | | | --Gary | | | | | -- | Mark Hansen, PP-ASEL, Instrument Airplane | Cal Aggie Flying Farmers | Sacramento, CA |
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