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

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

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

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

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.

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

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

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

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

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;