Logging PIC time as student instrument pilot in IMC

I recently realized that I should not have included any "actual"
(IMC) time recorded in my logbook as PIC time while I was an
instrument student.


Why not? If you were actual, then it was PIC.

how about adding a "corrective" (new) entry?

That's what I do. Just make +/- entries to total with explanation.

"Marty Ross" wrote in message
t...
I recently realized that I should not have included any "actual" (IMC)
time
recorded in my logbook as PIC time while I was an instrument student.

Why not? You weren't PIC, but you can still log PIC time as the rated sole
manipulator (unless your CFII was flying the plane for you).

Any suggestions for correcting this error? Rather than making messy
corrections and recalculating page totals, how about adding a "corrective"
(new) entry?

More generally, are there any accepted conventions for retroactively
correcting logbook errors?

I use an Excel spreadsheet as my logbook, so corrections are seamless.

--Gary

On Thu, 24 Jul 2003 17:32:38 GMT, "Marty Ross"
wrote:

I recently realized that I should not have included any "actual" (IMC) time
recorded in my logbook as PIC time while I was an instrument student.

What makes you think that?

To log PIC time:

61.51(e) Logging pilot-in-command flight time. (1) A 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;

Were you not 'rated' in the aircraft?

To log instrument time:

61.51(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.

Neither paragraph says anything about needing to have an instrument rating;
or even about being qualified to ACT as PIC in the aircraft.

You do have to be rated. In other words, if you are a private pilot with a
Single-Engine Land rating, you cannot log PIC time in a Multi-Engine
aircraft (or a balloon, glider, etc).

Just remember: the rules for LOGGING PIC bear no relationship to the rules
for ACTING as PIC.



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

In article ,
Greg Esres wrote:

Why not? If you were actual, then it was PIC.

If he was actual is irrelevant. If he was sole manipulator, it was PIC.

--
Paul Baechler

Wow, what a mincing (slicing/dicing) of words this post has triggered!

I appreciate all of your attempts to second (and even third) guess what was
the original intend of my post in order to help!

Indeed, it was my understanding that I could not log PIC time for IMC I had
flown (yes - albeit as "sole manipulator") while with my instrument
instructor. This is because on my last few flights he corrected his entry
in my logbook, reducing the PIC time by exactly the amount he wrote in the
"Actual" column. When I asked him about this, I believe he said something
like: "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).

I understood this situation to be similar to the situation another person
asked recently on a related forum: "can a student pilot that flies with me
[a PPL] log time?", and the consensus here was: "no, he can't because he's
not yet rated to fly [in the current situation; namely, with a passenger,
even though he was sole manipulator]". Using that logic, it seemed to make
sense to me.

However, as someone pointed out, my post really was more about correcting
logbook errors. The fact that I may not have the error I think I have was
secondary. And, about that, I think I will insert a "adjustment" line into
my logbook that corrects for any errors I may find (no one seemed to think
that was a "bad" idea). I don't like the idea of using white-out and
recalculating page balances, it seems too messy and could introduce new
errors that would be even harder to correct later.

Regards,

-- Marty

"Marty Ross" wrote in message
t...
I recently realized that I should not have included any "actual" (IMC)
time
recorded in my logbook as PIC time while I was an instrument student.

Any suggestions for correcting this error? Rather than making messy
corrections and recalculating page totals, how about adding a "corrective"
(new) entry?

More generally, are there any accepted conventions for retroactively
correcting logbook errors?

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)

"Marty Ross" wrote in message rthlink.net...
Indeed, it was my understanding that I could not log PIC time for IMC I had
flown (yes - albeit as "sole manipulator") while with my instrument
instructor. This is because on my last few flights he corrected his entry
in my logbook, reducing the PIC time by exactly the amount he wrote in the
"Actual" column. When I asked him about this, I believe he said something
like: "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).

It is my belief that your flight instructor is incorrect
and that his opinion disagrees with several opinions from the
FAA Counsel's Office.

FWIW, this is how my actual time is logged: as PIC. My husband,
or my CFI, who acted as PIC, also logged PIC time.

I understood this situation to be similar to the situation another person
asked recently on a related forum: "can a student pilot that flies with me
[a PPL] log time?", and the consensus here was: "no, he can't because he's
not yet rated to fly [in the current situation; namely, with a passenger,
even though he was sole manipulator]". Using that logic, it seemed to make
sense to me.

I don't follow how your logic makes sense of this. There is a specific
regulation which covers logging PIC time. It states several
restrictions, including that the pilot must be rated. It says
nothing about the conditions of flight. If you're rated, and you
meet another criterion (such as "sole manipulator of the controls")
you can log PIC. Different situation than the student pilot analogy.

There is another regulation which covers who can *act* as PIC
under IFR, but it says nothing about logging the time.

Now, I will admit that to the uninitiated, this distinction between
*acting* as PIC vs *logging* PIC seems a bit bizarre. However,
to this I reply with DH's words: "these are Federal Regulations.
You're expecting them to make sense. That's your mistake. That's
where you're going wrong."

However, as someone pointed out, my post really was more about correcting
logbook errors.

FWIW:
I correct logbook entry errors the same way I correct my laboratory
notebook at work. Whiteout is verboten. I cross out the errant numbers
with a single ink line, initial and date above the line. I either
write in the correct number next to it, or write something like "see
entry XXX dated xx-xx-xxxx for correction".

HTH,
Sydney

"Snowbird" wrote in message
om...

FWIW, this is how my actual time is logged: as PIC. My husband,
or my CFI, who acted as PIC, also logged PIC time.

Well, I've often wondered about that one. From everyone's second-favorite
FAR:

A ... pilot may log pilot-in-command time only for that flight time during
which that person (is sole manip, sole occupant, or) ...is acting as pilot
in command of an aircraft on which more than one pilot is required under ...
the regulations under which the flight is conducted.

The regs have to *require* more than one pilot. Usually an ASEL flown under
IFR does not require more than one pilot by regulation. So it would seem not
to count.

However, if you are saying "given that this is a flight under IFR where the
controls are manipulated by a non-IR pilot, then the regulations do require
two pilots: the PF and the PNF/PIC", then they can log it.

-- David Brooks

David Brooks wrote:
"Snowbird" wrote in message
om...
FWIW, this is how my actual time is logged: as PIC. My husband,
or my CFI, who acted as PIC, also logged PIC time.

Well, I've often wondered about that one. From everyone's second-favorite
FAR:
A ... pilot may log pilot-in-command time only for that flight time during
which that person (is sole manip, sole occupant, or) ...is acting as pilot
in command of an aircraft on which more than one pilot is required under ...
the regulations under which the flight is conducted.

Correct.

The regs have to *require* more than one pilot. Usually an ASEL flown under
IFR does not require more than one pilot by regulation. So it would seem not
to count.

However, if you are saying "given that this is a flight under IFR where the
controls are manipulated by a non-IR pilot, then the regulations do require
two pilots: the PF and the PNF/PIC", then they can log it.

Yes, exactly. That appears to be the General Counsel interpretation --
Andrew Sarangan had a General Counsel letter on his website relevant to
the topic. Ron Rosenfeld referred to one. I have an email
correspondence with John Lynch of a few years back where he initially
disagreed, then consulted the GC office and came back concurring.

That's why we felt it was appropriate to log it as we did (why we
chose to log it that way is a seperate issue)

Cheers,
Sydney

On Tue, 29 Jul 2003 02:03:40 GMT, Sydney Hoeltzli
wrote:

Yes, exactly. That appears to be the General Counsel interpretation --
Andrew Sarangan had a General Counsel letter on his website relevant to
the topic. Ron Rosenfeld referred to one.

Actually, the CC opinions I referred allowed the *PF* to log PIC time.
They did not allow the PNF (acting PIC) to log PIC time. Although if the
acting PIC were either a CFI(I) giving instruction, or a safety pilot in
simulated instrument conditions, then the regulations would allow the PNF
to log PIC time.

At one time, there was information in the Part 61 FAQ's suggesting that the
PNF acting PIC could also log PIC time when the PF was not instrument
rated/current/confident. However, I just looked at that source again and
cannot locate that information in the revision dated 12/19/2000.

There was a letter from Alan Pinkston (in the FAA CC office) also
suggesting the PNF might be able to log PIC time during IMC, however, the
wording is "When the person in the right seat is acting as safety pilot as
a result of 91.109 for avoidance of traffic, or in the case of instrument
meteorological conditions since that person provides safety for the flight,
(***as well as legal rating requirements***) both persons may log pilot in
command time. "

(Emphasis mine). This implies that if the PNF is required for legal rating
requirements (or under 91.109) then PNF could log PIC time.




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