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Thread: Interesting Logging PIC situation.

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    Default Interesting Logging PIC situation.

    This has come up a couple times over the past year.... The logging of PIC time... more recently during a SEA PLANE rating.

    In this last case a friend was obtaining his rating and I had signed him off for solo operations while flying a seaplane.
    A CFI can do that under 61.31D , so a pilot can act as PIC (solo) when they do not yet hold the appropriate category and class rating yet...
    Since many folks need PIC time for either insurance or employment reasons, we hoped he could log a bunch of PIC time while we continued training. He was sole manipulator of the controls and I just talked him along.....
    BUT...However..and guess what... We could not do that....

    According to the regs, and I have read all through them again, he could indeed log PIC if he was solo, and even during his check-ride. (Which is weird since he is not really rating yet either) But since he was not yet rated in Single Engine SEA Class, he could not log PIC time while under dual instruction.

    Many folks make the mistake of thinking that a Sea Plane rating is an add-on type rating... It is not... It is a new class under the Airplane category.

    Now some folks will say, wait a minute here I logged PIC time while under the hood while training for my IFR rating and that was while I was receiving dual instruction. Yes and you can do that legally since you were already a pilot with a Single engine land (or sea) category (airplane) and class (land or sea) rating. The Instrument part of it does not come into play. Neither does a tail-wheel endorsement or lack there-of... Plus you could log PIC time while working on your commercial since you were already rated in Aircraft either land or sea.


    But logging PIC (unless you are solo and signed off), while flying an aircraft class and category for which you are not yet rated is a no-no...
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  2. #2

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    Interesting... My multi-engine instructor gave me a "solo" endorsment after first couple flights and logged the following flights as both PIC and dual time. Was he wrong? Does FAA have a Letter of Interpretaion (LOI) on this subject? Does anyone here have a different opinion than Floatpilot?

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    From The FAA site
    http://www.faa.gov/about/office_org/...AND%20TIME.pdf

    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, flight training device, or aviation training device, as appropriate.
    (v) The name of a safety pilot, if required by §91.109 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, flight training device, or aviation 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, flight training device, or aviation training device.
    (iv) Use of night vision goggles in an aircraft in flight, in a flight simulator, or in 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, commercial, or airline transport pilot may log pilot in command flight time for flights-
    (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
    (ii) When the pilot is the sole occupant in the aircraft;
    (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

    (iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—
    (A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;
    (B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—
    ( 1 ) Preflight preparation;
    ( 2 ) Preflight procedures;
    ( 3 ) Takeoff and departure;
    ( 4 ) In-flight maneuvers;
    ( 5 ) Instrument procedures;
    ( 6 ) Landings and approaches to landings;
    ( 7 ) Normal and abnormal procedures;
    ( 8 ) Emergency procedures; and
    ( 9 ) Postflight procedures;

    (C) The supervising pilot in command holds—
    ( 1 ) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or
    ( 2 ) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and
    (D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.
    (2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.
    (3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.
    (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 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 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 person can use time in a flight simulator, flight training device, or aviation training device for acquiring instrument aeronautical experience for a pilot certificate, rating, or instrument recency experience, provided an authorized instructor is present to observe that time and signs the person's logbook or training record to verify the time and the content of the training session.
    (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.
    (j) Aircraft requirements for logging flight time. For a person to log flight time, the time must be acquired in an aircraft that is identified as an aircraft under §61.5(b), and is—
    (1) An aircraft of U.S. registry with either a standard or special airworthiness certificate;
    (2) An aircraft of foreign registry with an airworthiness certificate that is approved by the aviation authority of a foreign country that is a Member State to the Convention on International Civil Aviation Organization;
    (3) A military aircraft under the direct operational control of the U.S. Armed Forces; or
    (4) A public aircraft under the direct operational control of a Federal, State, county, or municipal law enforcement agency, if the flight time was acquired by the pilot while engaged on an official law enforcement flight for a Federal, State, County, or Municipal law enforcement agency.
    (k) Logging night vision goggle time. (1) A person may log night vision goggle time only for the time the person uses night vision goggles as the primary visual reference of the surface and operates:
    (i) An aircraft during a night vision goggle operation; or
    (ii) A flight simulator or flight training device with the lighting system adjusted to represent the period beginning 1 hour after sunset and ending 1 hour before sunrise.
    (2) An authorized instructor may log night vision goggle time when that person conducts training using night vision goggles as the primary visual reference of the surface and operates:
    (i) An aircraft during a night goggle operation; or
    (ii) A flight simulator or flight training device with the lighting system adjusted to represent the period beginning 1 hour after sunset and ending 1 hour before sunrise.
    (3) To log night vision goggle time to meet the recent night vision goggle experience requirements under §61.57(f), a person must log the information required under §61.51(b).
    [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; Amdt. 61–124, 74 FR 42549, Aug. 21, 2009; Amdt. 61–128, 76 FR 54105, Aug. 31, 2011]
    Floatplane,Tailwheel and Firearms Instructor- Dragonfly Aero
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  4. #4

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    If they are competent why not just go take the check ride and be done with the drama?

    Alot of instructors and pilots like to spin the drama but at the end of the day flying a plane is not rocket science. Every time I ask about a rating or some other such thing its like a "well now sonny this is for grown ups"

    Just easier to do the training and get the rating so you dont have to have these conversations. Also as a side note insurance is a joke, its nearly impossible to get and when you can get it it costs a fortune, they try to dictate what you can and cant do, etc etc. In aviation its just easier to not involve them or banks. Get a pre-buy and a title search and call it a day. I cant even get avemco to give me liability. I am not going to let insurance companies or banks dicate to me like im a child.

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    Thread Squawk "7500"
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    Quote Originally Posted by rppearso View Post
    If they are competent why not just go take the check ride and be done with the drama?

    Alot of instructors and pilots like to spin the drama but at the end of the day flying a plane is not rocket science. Every time I ask about a rating or some other such thing its like a "well now sonny this is for grown ups"

    Just easier to do the training and get the rating so you dont have to have these conversations. Also as a side note insurance is a joke, its nearly impossible to get and when you can get it it costs a fortune, they try to dictate what you can and cant do, etc etc. In aviation its just easier to not involve them or banks. Get a pre-buy and a title search and call it a day. I cant even get avemco to give me liability. I am not going to let insurance companies or banks dicate to me like im a child.
    You're right. rrpearso, flying isn't rocket science. But it is the basis of rocket science. Without it, you wouldn't havea rocket - - - you'd have just another big fireccracker. The reason real pilots treat you as a youngster is because of your surprising, and sometimes nonsensical, questions. As far as ratings are concerned, you'll find find all you really need to know about them in the FARs. I'm sure you can read, but I'm not sure why you're so very reluctant to use that skill. How did you manage to get a license without some knowledge of the provisions os Parts 61 and 91?

    As for Avenco, they no doubt discovered that you're not going to be a very responsible pilot in the first place. I know you've said that you intend to self-insure the hull of that Pitts. I hope you can handle the liability out of pocket, too. You're surely gonna need it !!!



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    Quote Originally Posted by Float Pilot View Post
    Thread Squawk "7500"
    AMEN, brother !!!

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    Most people in alaska dont carry insurnace because its too expensive or unavalible, thats common knowlage. I have no choice but to self insure or dont fly, but then whats the point of getting a licnece or working a job or living for that matter. Yes I can read, I did very well on my writen and check ride.

    I would love to get insurance but its not easy to get and even if you can get it its cost prohibitive, it is what it is, for thoes of you with a gillion hours and fly utility class planes and have your 3000$ a year insurance thats good for you but thoes options are not avalible to me so it is what it is. Even when I get 30-50 hrs in a pitts with an instructor my total time will still not be above 250 hrs so it will be a long time before I have insurance.

    I am going to keep checking on liability and hopefully I can get it before its time to buy but im not going to let it ground me.

    Also the design of air craft might be rocket science but flying them certianly is not.

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    Quote Originally Posted by rppearso View Post
    Most people in alaska dont carry insurnace because its too expensive or unavalible, thats common knowlage. I have no choice but to self insure or dont fly, but then whats the point of getting a licnece or working a job or living for that matter. Yes I can read, I did very well on my writen and check ride.

    I would love to get insurance but its not easy to get and even if you can get it its cost prohibitive, it is what it is, for thoes of you with a gillion hours and fly utility class planes and have your 3000$ a year insurance thats good for you but thoes options are not avalible to me so it is what it is. Even when I get 30-50 hrs in a pitts with an instructor my total time will still not be above 250 hrs so it will be a long time before I have insurance.

    I am going to keep checking on liability and hopefully I can get it before its time to buy but im not going to let it ground me.

    Also the design of air craft might be rocket science but flying them certianly is not.
    Just curious, did you graduate from college and then lose your spelling/grammer skills? Hopefully, your 'net persona is not a true reflection of you, but I have my fears.........

    Anyway, wonder where you get your information from....that "Most people in alaska don't carry insurnace...." I would think that everyone who has their plane financed would have hull insurance, most likely required to have it. How much are you going to set aside in a account for your "self insure" or are you going to just "say you did and don't"?

    Some people like to drive new fast cars but when they find out the cost of insurance to play they tone down their choices to something they can insure and afford. Some drive new fast sports cars while they are single and then when they marry and have kids, they realize that its not practical or affordable. They call that reality.

  10. #10

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    I dont like some peoples perception of reality, I hang out with people who work to make dreams reality.

  11. #11

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    Roger that. Let's stick to the original topic...
    Thanks for the clarification, Floatpilot. It's hard to argue with the cut and dry regs... I asked couple DPEs and they confirmed what you were saying. I guess I'll have to edit my logbook a bit.
    Quote Originally Posted by Float Pilot View Post
    Thread Squawk "7500"

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    I agree that most private pilots up here don't have insurance.

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    I agree that most private pilots up here don't have insurance.
    Yes and the number to Peninsula septic Pumping is 262-5969. And it too has nothing to do with the topic at hand.
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    Here is one that just happened and is relevant;

    Pilot A, a high time ATP comes to Alaska to get some Alaskan PIC time in his log books while riding dual with Pilot B, a good looking and daring Float Plane Instructor.

    But just when Pilot A arrives in Alaska, the FAA somehow looses his recent 1st class medical info and he is high and dry without a current medical.

    So he is already rated in class and category and he will be dual with Pilot B. So we know he can legally log dual time.... But can he log PIC as well without a current medical?????
    Floatplane,Tailwheel and Firearms Instructor- Dragonfly Aero
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  15. #15

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    I don't quite understand what you mean by "FAA somehow loses his medical info...". He should have the medical certificate and FAA should have a record of that. You/he can search the FAA database and find his medical cert. info along with his pilot certificates and ratings here: https://amsrvs.registry.faa.gov/airmeninquiry/

    But even if a pilot does not have a current medical and to quote your own post re: reg. 61.51:
    (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
    (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;


    He seems to falls into the above category. You can act as PIC while he can log time as PIC as a sole manipulator of the controls. As long as he is rated in the category and class, i.e. ASES in your case.


    Quote Originally Posted by Float Pilot View Post
    But just when Pilot A arrives in Alaska, the FAA somehow looses his recent 1st class medical info and he is high and dry without a current medical.

    So he is already rated in class and category and he will be dual with Pilot B. So we know he can legally log dual time.... But can he log PIC as well without a current medical?????

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    It is a bizarre story. He had or has some sort of medical issue which requires the FAA to review his medical status.
    So he usually sends in all his paperwork and gets their blessing. But this year they lost it.... So he is in the process of sending them copies and having his doctor write them a letter. Which is a pain for him since he is now up here and not down in the lower 48 where all his records are located...
    While not something a young healthy athlete like you would run across, I am seeing more and more oddball medical hang-ups with some of my older clients. Although this airline pilot is younger than I am...

    Anyway, I agree that the regs sure look like they agree with you..
    However, playing devil's advocate, since his medical is not current, he can not EXERCISE the privileges of PIC. He could not rent a plane, fly solo and so on... But your point about it being dual anyway, ( Under supervision) would also seem to hold some water.
    Hopefully we will be able to fix his paperwork issue. But it is an interesting question.

    Additionally....... in my plane he can claim it as a Light Sport Aircraft which requires no medical....and his is not denied, just lost..
    Yeah Piper Cub !!!

    Over the years I have done several BFRs for guys who are out of medical. No matter the PIC issue, at least they could legally fly once they finally managed to do whatever the FAA wanted them to do.
    In some cases I knew a few of those guys would probably never get their medicals back. So I did as many BFRs with them as they wanted so they could get in some flying time while they were still on this side of the ground. I hope somebody does that for me one day...
    Floatplane,Tailwheel and Firearms Instructor- Dragonfly Aero
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    Was responding to sig220 not trying to hijack your thread

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    It wasn't you who was trying to break-in the thread's cockpit door.

    By the way, the above medical situation with the FAA is resolved. They faxed a new med cert here....
    Floatplane,Tailwheel and Firearms Instructor- Dragonfly Aero
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    Another logging PIC question came up the other night while talking with one of my fellow CFI's up in Anchorage. Who is a very skilled pilot / CFI at the Elmendorf Flying Club by the way...

    You take a guy out flying, (I spent 40 hours in a plane with one guy last week) but he is already rated in class and category. Can I as a CFI log instruction time and dual PIC...????
    Well not really unless I am doing active instruction. And that guy "Don from Gig Harbor" did not need any instruction. I was just a high paid tour guide who was ready to jump on the controls. Plus I navigated and made suggestions on how to improve his float-flying skills. So my insurance company would probably say it was dual instruction ,,,but the FAA would probably not...

    Now I had another guy for 4.5 hours this week...who was also rated as a float pilot,,, (one of the 4 hour rating mills )
    BUT ..all he could do was take-off.... And not very well... They did not show him much in the desert about float flying...
    So even though he was rated, he needed constant instruction so we would both make it home. Thus I logged 4 hours of PIC as a CFI doing instruction. And he received PIC time and dual time.


    Now another question came up,,,,,

    What about when two rated pilots go off flying together.. And lets say both are CFI's ,,,,, can they both log PIC...
    Nope.....except...

    If one is under the hood, then yes they can.... since that activity requires a safety pilot.
    If one CFI or pilot is instructing the other pilot in some new nav gear, cockpit instruments, CAP Stan-Eval or particular TYPE aircraft yes they can...

    But if they are just out goat spotting.... NO.......

    BUT... you can make an agreement with the other pilot while out goat watching.... or in the case of the CIVIL AIR PATROL while out searching....
    The pilot next to the shore or mountain ridge looks (scans) while the outboard plot flies the plane. This keeps the outboard pilot's brain and eyes on flying....

    Every time you swap directions on a mountain slope or down a coast line. You exchange the controls. This keeps the flight safe and lets the pilot pilots split the flight time for PIC logging. It also allows for a much longer search or hunting recon flight since it reduces crew fatigue.
    Floatplane,Tailwheel and Firearms Instructor- Dragonfly Aero
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