A challenging "How do I / Can I log this flight time?"

[mattg]

EDIT: My question has been answered. The answer is NO. Thank you mjburian for actually referencing regulations. There's special circumstances that apply to type-rating required aircraft regarding training, but only under 121 or 135 operations. And that specific part was the purpose for this question.


I've lucked my way into getting to fly left seat (either really) in a Super King Air, B350. It's over 12,500 so a type rating is required.

I'm PPL/ASEL/IR. The pilot I'm flying with is an ATP / CPL / AMEL and CFI (not double I, not MEI) and obviously typed in the aircraft. The aircraft is operated under Part 91.

I'm reading 61.51 and I think the time can be logged, and I'm less sure about logging PIC. I'm asking for your clarification on both logging the time, and logging PIC.

I believe these are the regs that apply.

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-
(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided -
(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.


Thoughts?

 

[RyanB]

Nope, it can’t be logged toward anything. You are not rated for the aircraft class (no AMEL or Type) and the PIC is not an MEI. Logging SIC wouldn’t be applicable to you either.

 

[mattg]

That was my initial take on it as well until I reviewed 61.51.

Because the aircraft requires a type rating, and the other pilot is an ATP / CFI, I believe c(2) and d apply.

 

[mjburian]

You skipped (A) and (B) under 61.51(e)(iv):

(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;​

 

[mattg]

Isn't it A or B or C (with the referenced AND at the end of C2).

Perhaps I need a lesson on reading the regs.

 

[mjburian]

At the end of 61.51(e)(iv), the wording basically says "you can log it, provided the following criteria are met" and then lists those 4 criteria under A-D.

C has two criteria that are "or"... so either C1 or C2 will suffice for that item. But the "and" at the end of C2 is the continuation of "you can log PIC as long as A, B, C and D are met"

 

[benyflyguy]

I think here’s where common sense prevails. Is there anything in your history that makes you think PIC king air is justified??

 

[mattg]

I think here’s where common sense prevails. Is there anything in your history that makes you think PIC king air is justified??

No, of course not. I don't care so much about the PIC as I do just being able to log the time. It's valuable and expensive experience.

The goal of my aviation "career" at this time is part time CFI and charter pilot since I have a good career already. I was hoping to be able to reference this experience towards that goal.

 

[RyanB]

That was my initial take on it as well until I reviewed 61.51.

Because the aircraft requires a type rating, and the other pilot is an ATP / CFI, I believe c(2) and d apply.

As I’ve stated already...the supervising pilot does not possess an MEI which is needed for a King Air. You have to interpret the reg based upon the aircraft you’re flying. A standard CFI rating doesn’t cut it.

So because of this, you cannot log the time toward anything.

 

[mattg]

At the end of 61.51(e)(iv), the wording basically says "you can log it, provided the following criteria are met" and then lists those 4 criteria under A-D.

C has two criteria that are "or"... so either C1 or C2 will suffice for that item. But the "and" at the end of C2 is the continuation of "you can log PIC as long as A, B, C and D are met"

Thank you for that. Makes sense.

 

[bradg33]

You can't log it.

Look, I get that you want to log some twin turbine time. I've been there, I know how hard that experience is to come by and how valuable it can be. But, when you have to resort to finding "creative" ways to log time you can pretty well bet that it's not legitimate time. And even if you can convince yourself that there's a regulatory basis for logging the time (which usually involves a real strained reading of the rules), employers are going to look down on you for logging time that isn't really legitimate.

 

[mattg]

As I’ve stated already...the supervising pilot does not possess an MEI which is needed for a King Air. You have to interpret the reg based upon the aircraft you’re flying. A standard CFI rating doesn’t cut it.

So because of this, you cannot log the time toward anything.

I've been told, and my reason for this post is to verify that, since it's a typed aircraft and the supervising pilot is an ATP the time is loggable.

 

[mattg]

You can't log it.

Look, I get that you want to log some twin turbine time. I've been there, I know how hard that experience is to come by and how valuable it can be. But, when you have to resort to finding "creative" ways to log time you can pretty well bet that it's not legitimate time. And even if you can convince yourself that there's a regulatory basis for logging the time (which usually involves a real strained reading of the rules), employers are going to look down on you for logging time that isn't really legitimate.

The reason for this post is to make sure it's legitimate. I'm perfectly happy with not logging it. Thanks

 

[RyanB]

I've been told, and my reason for this post is to verify that, since it's a typed aircraft and the supervising pilot is an ATP the time is loggable.

And three of us have answered the question. Our response? NO! You cannot log it. Period.

If we all could log flight time in high performance aircraft without having to earn the required ratings, believe me, we would.

End of thread. Game over.

 

[benyflyguy]

And three of us have answered the question. Our response? NO! You cannot log it. Period.

If it was legal, we all would take advantage of this loophole by not having to earn the required ratings in order to log flight time in high performance aircraft.

End of thread. Game over.

36 posts later...

 

[mattg]

Holy hell.

This is why I stopped coming to this site.

Ryanb, your posts never once referenced the regulations. I suppose I should have worded my question a little differently to read "What regs allow or disallow logging of this flight time? and if loggable, in what way may I log it?"

I had thought all along that I could not log this time. I have been told differently, which is what I was trying to verify.

Through googling, not here, I finally found verbiage that verifies what I was thinking all along.

http://www.askacfi.com/8432/logging-hours-in-a-jet.htm

from the above link, in a response FROM THE FAA.
Since the flight is not part of an FAA air carrier training program approved
under part 121 or part 135, that fact is’ dispositive of whether the ATP, who does not have a CFI, may give flight instruction,
While section 61.167(b)(2) authorizes an ATP to give instruction when the ATP does not
hold a CFI, the ATP would have to comply with both §61.167(b)(2) and §61.3(d)(3)(ii).
According to §61.3(d)(3)(ii), the instruction must be “… conducted in accordance with an
approved air carrier training program approved under part 121 or part 135 …. ” In your
questions, the ATP is not a CFI and the flight is not part of an FAA approved air carrier
training program approved under part 121 or part 135. As a result, the ATP may not instruct the commercial pilot. Since the ATP is not authorized to provide dual instruction, the flight time may not be counted as instructional time.”

Done. There's why I can't log it. Thanks.

 

[Salty]

POA commandment IV: thou shalt not ask for clarification, nor shalt thou continue asking questions until thine understanding is complete. Thou shalt immediately take the first response as gospel and repeat it in every similar thread that is posted forevermore. Verse 2. If thy neighbor continues to ask questions after an answer is bestowed upon them, thou shalt reply with the utmost condescension possible.

Amen.

 

[mscard88]

As I’ve stated already...the supervising pilot does not possess an MEI which is needed for a King Air.
.

MEI needed? How about a ME rating and Type Rating in a KA?

 

[RyanB]

MEI needed? How about a ME rating and Type Rating in a KA?

It’s implied that you need both a ME and B350 Type. The MEI was referring to the rating that would also be required by the supervising pilot in order to log the time as noted in part (d) of the reg.