Alas there are FAA chief counsel opinions for other regs that read crap into them that is not in the literal text.
A safety pilot acting as PIC is a pilot acting as PIC in an operation that requires more than one pilot. Really? So a pilot without a current medical can't fly under the hood with a private pilot as PIC because he's a required crewmember who must meet medical requirements? And you certainly can't put your 14 year old niece under the hood to practice what he learned on MSFS because she's not a pilot at all?I have never seen an FAA counsel definition on 61.51 that didn't affirm the regulations mean exactly what they say.
This is a bone to the student adding a new category/class rating (see the student pilot rule below) where they technically couldn't log the time as PIC only SOLO before.
...
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.
This one also changed. A student pilot was previously never allowed to log PIC even when they were PIC (which they indeed are when soloing). They only could log SOLO time.
I've submitted a letter to the FAA interps department on this question. We will see...
What do you believe this is going to cause?
Alas there are FAA chief counsel opinions for other regs that read crap into them that is not in the literal text.
Tired of the thread yet bumps it with a rant.. Well played, Denver, well played.
Not sure why any "old timers" would care about this. Does anyone need the extra +-20 hours that they logged as "solo" only to also be "PIC"?This stuff above makes a mess of us old-timer's logbooks that have it logged the old way when these rules change. ****es me off. I'm not going to go back and change this crap in mine, since it was logged the legal way back when it happened, but I've had at least one instructor look at it and say, "that could have been logged differently", and I have to explain that back THEN, it could not.
Not sure why any "old timers" would care about this. Does anyone need the extra +-20 hours that they logged as "solo" only to also be "PIC"?
Really? How long ago did that rule change? Presumably anyone who was affected would have logged enough PIC hours since then that the extra 20 hours is just background noise.Maybe - depends on what they'd be needing PIC time for. Insurance, whatever. Different places and businesses use the numbers for things the FAA never cared about, but they do affect people. Even if it's minor.
That's a nifty flow chart, however the question at hand has little almost nothing to do with "can I log PIC.."
It's more about "can one guy be acting PIC while another guy manipulates the controls for a portion of the flight."
Really? How long ago did that rule change? Presumably anyone who was affected would have logged enough PIC hours since then that the extra 20 hours is just background noise.
Speaking for me . . .
NO!!!
That's what it turned into. No one has refuted or really bothered with the original question. Just how to log it.
I am tempted to use R&W's favorite smiley...Now. How about the year it changed?
Really? In all these posts someone must have tossed out the simple "Yes" that answers the original question.That's what it turned into. No one has refuted or really bothered with the original question.
I am tempted to use R&W's favorite smiley...
If this was the year after it happened the person wouldn't be an "old timer" and would have corrected their logbook if they decided it was necessary.
Really? In all these posts someone must have tossed out the simple "Yes" that answers the original question.
Edit: Waitaminit. I did! Back in post #5. I'm sure there had to be others.
Speaking of changing the subject, you went from complaining that "old timers" would need to make corrections to, "What if it was last year?" If it was last year, people who needed the time would probably make the correction in their logbook without complaint. In fact they would probably be happy that the change in regs gave them the opportunity.But you've done a nice job trying to change the subject I brought up, which was that changing the rule served no purpose other than bureaucratic masturbation, AFAICT. Like I said, I should be used to it, but I'm not. Ha.
Why couldn't they log pic?This misses the currency question. Let's say I am PIC I could in theory allow someone to fly the plane from take off to landing who is a great pilot (Bob Hoover for the sake of argument) but not current to carry passengers due to no landings in the last 90 days . They could not legally log PIC because that would in theory make me the passenger and they can't carry passengers. Although nothing about the flight as described is technically illegal.
Except it is totally wrong. Currency has nothing to do with logging of the time. It only applies to acting as PIC. Two totally different things.This misses the currency question. Let's say I am PIC I could in theory allow someone to fly the plane from take off to landing who is a great pilot (Bob Hoover for the sake of argument) but not current to carry passengers due to no landings in the last 90 days . They could not legally log PIC because that would in theory make me the passenger and they can't carry passengers. Although nothing about the flight as described is technically illegal.
What currency question? How does logging make you a passenger in theory?This misses the currency question. Let's say I am PIC I could in theory allow someone to fly the plane from take off to landing who is a great pilot (Bob Hoover for the sake of argument) but not current to carry passengers due to no landings in the last 90 days . They could not legally log PIC because that would in theory make me the passenger and they can't carry passengers. Although nothing about the flight as described is technically illegal.
What currency question? How does logging make you a passenger in theory?
Acting PIC acts. Manipulating pilot logs. Two different things, and in this case, two different people. You don't have to be the acting PIC to be logging. And, logging does not make you the acting PIC.
Speaking of changing the subject, you went from complaining that "old timers" would need to make corrections to, "What if it was last year?" If it was last year, people who needed the time would probably make the correction in their logbook without complaint.
Correct however you can not act as PIC and carry passengers if you are not current so in the case I stated Bob Hoover could not act as PIC. I suppose he could log it as sole manipulator but not as PIC. The question then becomes do those landings count for currency? The two CFIs I talked to today said no.
Agree with CFIs Greg and BUF. FWIW, I have a bunch of letters after my name with a CFI (EIEIO), and a handful of type ratings, but none of that means diddly. If you're right, you're right. When you're not, you're wrong.Acting... Logging... Not the same thing...
I'm a CFI, I say yes.
My FSDO says yes.
A CFI I spoke with today says no, she also said a CFI needs to be night current in order to give instruction at night, which has already been shown to be incorrect.
And as an example, nearly everyone logs PIC during an initial complex checkout, even though it is not legal to act as PIC prior to the endorsement. If you aren't sole manipulator during a checkout, someone is doing it wrong.And Yea Bob Hoover could IN FACT log it as PIC. YOU DO NOT HAVE TO BE LEGAL TO ACT AS PIC TO LOG PIC.
I am cornfused. So I hope that this is the case.
Scenario
Pilot 1: TW endorsed not current with landings to carry passengers. Therefor can not be PIC with a passenger on board.
Pilot 2: Mr. Very Experienced pilot. PIC agreed upon by both parties
Pilot 1 is sole manipulator for the entire flight from start to finish including 3 full stop landings. So you are saying pilot 1 can log the time but not fill in the PIC box and is now passenger current?
Is there an FAA written opinion on this to refer to or is this just parsing the rules(which I am fine with by the way)?
Seems like you got most of it, other than a comma here and there.So if I am understanding this Pilot 1 can LOG the PIC time because they are the sole manipulator and rated in the Aircraft. Pilot 2 can not log the time because although they are acting as PIC in this case for the flight someone who is rated is acting as sole manipulator. Clear as mud.
Actually, it is not the fact that someone who is rated is the sole manipulator that the acting pic cannot log it. It is because he has no basis in 61.51 for doing so.Seems like you got most of it, other than a comma here and there.
That's the thing. There's not an interpretation, only ones for how it works with a CFI. Latest one I can find is in 2006 regarding whether a CFI or student becomes a "passenger". And some other ancillary ones.Pilot 1 logs it as pic and becomes current. This is straight up sole manipulator. Probably an interpretation on it somewhere.
But if someone goes and asks, it's probably a 50/50 chance of coming back something so stupid and convoluted that only a lawyer could nod and agree with it. And it'll be all screwed up. That's been a pattern for a long time.
Seems to me that back in the day, people were told that they could count their old "solo" time as PIC. But I didn't care about it one way or another. Can you provide some documentation saying that people are unable to correct their logbooks in this manner, or simply count it as PIC when filling in any appropriate form?You keep saying they could make a correction. They could NOT, since it was legal to log it that way when they made the initial entry and they can't change it to the new way, just because they want to.