Becoming current vis 61.57...

denverpilot said:
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.

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.
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If you say there isn't one, that is fine. I guess in the absence of an opinion otherwise, we just go with plain language of the reg. Sole manipulator.
 
whattauser said:
If you say there isn't one, that is fine. I guess in the absence of an opinion otherwise, we just go with plain language of the reg. Sole manipulator.
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Well no, that's one of the significant problems of this "law by letter" system, really. You shouldn't have to rely on me or anyone else saying, "There isn't one." They should be printed right in the damned rule book at the appropriate section, if these letters are really new law.

Imagine if the Internet didn't exist, and we were back to the days before the net. How the hell would anyone even know about these stupid letters?

I recall no service the FAA provided then, or see one now, that forwarded copies of this garbage.

They put things they wanted people to know in Advisory Circulars. And back then, mailed the important ones to our houses. And even that's a relatively new phenomena overall.

They really should just fix the damned wording of the actual regs, and shove it through the proper NPRM process, rather than rely on "go play hide and seek with letters from our lawyers on a website".

But that'd make too damned much sense, I suppose.
 
Everskyward said:
Seems to me that back in the day, people were told that they could count their old "solo" time as PIC.
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By what authority? Sounds like just someone's opinion and people did it. I've seen no documents that allowed it.

I did have a lengthy conversation with a DPE once about white out... Oh good lord was that a waste of an hour. Especially when I learned later that two other DPEs disagreed with his opinion about its use.

That was probably one of the first "lightbulb went on" moments for me when I realized most of this crap is propagated by people making it up. Finding out later that even two different FSDOs can't get organized enough to agree on something, sealed it for me.

I became a "show me on paper" kinda person after that.

So you're essentially asking for the same thing I'm asking for... You want proof it can't be done, I'm saying my proof is the regs said you couldn't log it that way back then.

At least I can show you the paper, so to speak. There's no paper saying "feel free to modify your historical logs when we change the logging rules" -- definitely never seen that.

We'd probably both benefit from the system being a whole lot more organized about this type of stuff than it actually is. All of us, really. But we've seen what happens when someone asks.

The Mangiamele letter, probably being the "poster child" for that. But there's others that overturned the very learned opinions of hundreds of CFIs and DPEs over the years.
 
Greg Bockelman said:
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.
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It's time to give up. As this thread demonstrates, some folks will simply not be willing to understand the distinction the FAA has made for decades and will continue to believe that logging PIC time has something to do with acting as PIC.
 
MAKG1 said:
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.

Heck, I logged PIC during my IFR cross country (why not?) but it sure as heck wasn't legal for me to act as PIC under IFR at the time.
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You are wrong. You can log PIC because you are authorized to fly the category and class of airplane. HP, tailwheel, etc does not matter in a lot of cases, especially during training. The same is true with the IFR issue. One can log actual instrument time even though they do not hold the rating if they are rated in category and class. Here is the Walker Interpretation from 2011 spelling it out. Sing HP is NOT a category, Class or Type, it also follows this logic.

Walker Interpretation (2011) PIC in IMC but not IA rated
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=8&cad=rja&uact=8&ved=0ahUKEwj-3YrP9cnMAhURy2MKHRl0A7YQFghRMAc&url=http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf&usg=AFQjCNE4qCPDD3JhKtlugvXEGhpMF9THcg&sig2=mgCak9fPHTS9FBRqjdF_zA

Herman Interpretation (2009) HP & Complex http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/herman - (2009) legal interpretation.pdf
 
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denverpilot said:
By what authority? Sounds like just someone's opinion and people did it. I've seen no documents that allowed it.

I did have a lengthy conversation with a DPE once about white out... Oh good lord was that a waste of an hour. Especially when I learned later that two other DPEs disagreed with his opinion about its use.

That was probably one of the first "lightbulb went on" moments for me when I realized most of this crap is propagated by people making it up. Finding out later that even two different FSDOs can't get organized enough to agree on something, sealed it for me.

I became a "show me on paper" kinda person after that.

So you're essentially asking for the same thing I'm asking for... You want proof it can't be done, I'm saying my proof is the regs said you couldn't log it that way back then.

At least I can show you the paper, so to speak. There's no paper saying "feel free to modify your historical logs when we change the logging rules" -- definitely never seen that.

We'd probably both benefit from the system being a whole lot more organized about this type of stuff than it actually is. All of us, really. But we've seen what happens when someone asks.

The Mangiamele letter, probably being the "poster child" for that. But there's others that overturned the very learned opinions of hundreds of CFIs and DPEs over the years.
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I'm one of those who generally thinks the regs are there to limit you, not to give you permission.
 
red4golf said:
You are wrong. You can log PIC because you are authorized to fly the category and class of airplane. HP, tailwheel, etc does not matter in a lot of cases, especially during training. The same is true with the IFR issue. One can log actual instrument time even though they do not hold the rating if they are rated in category and class. Here is the Walker Interpretation from 2011 spelling it out. Sing HP is NOT a category, Class or Type, it also follows this logic.

Walker Interpretation (2011) PIC in IMC but not IA rated
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=8&cad=rja&uact=8&ved=0ahUKEwj-3YrP9cnMAhURy2MKHRl0A7YQFghRMAc&url=http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf&usg=AFQjCNE4qCPDD3JhKtlugvXEGhpMF9THcg&sig2=mgCak9fPHTS9FBRqjdF_zA

Herman Interpretation (2009) HP & Complex http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/herman - (2009) legal interpretation.pdf
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How am I wrong? You and both of the interpretations you cite are saying the same thing I did.
 
I heard another doozie yesterday..

A CFI cannot give instruction to a friend...
 
fbdac824d5879c4cf67a75650753398a.jpg
 
MAKG1 said:
How am I wrong? You and both of the interpretations you cite are saying the same thing I did.
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You are saying that it can't be logged while the FAA says that it can.




Edit: I reread your post and I think I misread it last night. Are you saying that you can legally log it even if you can't legally act as the PIC?

I was on my 3rd rum and coke when I started reading so I might have missed things implied or coated in sarcasm.
Sent from my SM-N920P using Tapatalk
 
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red4golf said:
I did and edited the above post while you were typing your response. You just typed faster.

Sent from my SM-N920P using Tapatalk
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No biggie. To answer your question, yes it's perfectly legal to log PIC in any single engine land airplane (assuming an ASEL rating) for which you are sole manipulator, regardless of whether or not you can act as PIC.
 
Yup. I read the first post as saying that you logged it because everyone logs it, not because it was proper.

Sent from my SM-N920P using Tapatalk
 
red4golf said:
Yup. I read the first post as saying that you logged it because everyone logs it, not because it was proper.

Sent from my SM-N920P using Tapatalk
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I wouldn't do that.

If I needed extra PIC time, I'd fly cadet orientation rides and make it useful. Worth about 1 hour apiece, and the cadets seem to enjoy it.
 
red4golf said:
You are wrong. You can log PIC because you are authorized to fly the category and class of airplane. HP, tailwheel, etc does not matter in a lot of cases, especially during training. The same is true with the IFR issue. One can log actual instrument time even though they do not hold the rating if they are rated in category and class. Here is the Walker Interpretation from 2011 spelling it out. Sing HP is NOT a category, Class or Type, it also follows this logic.

Walker Interpretation (2011) PIC in IMC but not IA rated
https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=8&cad=rja&uact=8&ved=0ahUKEwj-3YrP9cnMAhURy2MKHRl0A7YQFghRMAc&url=http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf&usg=AFQjCNE4qCPDD3JhKtlugvXEGhpMF9THcg&sig2=mgCak9fPHTS9FBRqjdF_zA

Herman Interpretation (2009) HP & Complex http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/herman - (2009) legal interpretation.pdf
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i don't understand. Where is MAKG wrong? Unless I misunderstood completely (certainly possible) he gave them as examples of situations in which one may not act as PIC but may log it as PIC. Which they are. And which is exactly what those interpretations say.

Edit: ah, just saw the follow up. Rum and coke strikes again.
 
Everskyward said:
I'm one of those who generally thinks the regs are there to limit you, not to give you permission.
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What limits are there in logging regs? Logging regs are the opposite, they describe what you must log. Not keep you from writing an autobiography in the margins.

And back before the reg changed it said you must log that time as solo, and after the reg changed that you must log it as PIC. (Technically it really just tells you that you must log certain things, and the regs don't give a rat's ass what you log overall.)

But if there was once a reg that said "if you log it, this is how you may log it", and the rule changes, that doesn't give you any good reason you could stand before an ALJ and give, for changing the old log, or what you're calling a "correction". The original log is what it is, based on the regs at the time, and there's no correction to be made.
 
denverpilot said:
But if there was once a reg that said "if you log it, this is how you may log it", and the rule changes, that doesn't give you any good reason you could stand before an ALJ and give, for changing the old log, or what you're calling a "correction". The original log is what it is, based on the regs at the time, and there's no correction to be made.
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You're missing the fact that when the regs changed, you could count your previous solo time as PIC. It doesn't matter what was in your logbook, corrected or not. But I don't think anyone cares except you. Certainly not an ALJ.
 
Everskyward said:
You're missing the fact that when the regs changed, you could count your previous solo time as PIC. It doesn't matter what was in your logbook, corrected or not. But I don't think anyone cares except you. Certainly not an ALJ.
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I remember nothing that allowed that. Got the documentation that allowed it? You've claimed it, but I suspect it wasn't actually allowed. Where did you read that?

You still haven't addressed my initial point. That the change was useless bureaucrats wasting everyone's time. Nor my point that no safety or other goal was accomplished by it.
 
denverpilot said:
I remember nothing that allowed that. Got the documentation that allowed it? You've claimed it, but I suspect it wasn't actually allowed. Where did you read that?

You still haven't addressed my initial point. That the change was useless bureaucrats wasting everyone's time. Nor my point that no safety or other goal was accomplished by it.
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You claimed it wasn't allowed but provided no documentation.

I don't know what the point was other than to allow people to claim the 20+ hours (that was the solo requirement at the time) they flew solo as PIC, putting them closer to qualifying for other ratings. Isn't that a good thing?
 
Everskyward said:
You claimed it wasn't allowed but provided no documentation.

I don't know what the point was other than to allow people to claim the 20+ hours (that was the solo requirement at the time) they flew solo as PIC, putting them closer to qualifying for other ratings. Isn't that a good thing?
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I claimed the logging rules said one thing and then another. I claimed nothing about your assertion that a logbook could be essentially falsified later with a "correction", that's all you. I can back my assertion by simply copying the regs from before and after the change.

Why would allowing people to claim 20 more hours be "good"? Good enough to meddle with law?

This particular example is the perfect "just messing around to be messing around" example, and at least followed the NPRM process mandated by Congress.

Many of the instances where Chief Counsel letters have essentially changed the common interpretation of law are far worse bureaucratic silliness than this one.

But in general, logging law changes are mostly silly, considering that ironically, logging anything other than the minimum required items has no basis in anything other than tradition, mostly.

Which is why I don't much care about the specifics of what someone does with their book, it's theirs, but I do care about wasteful bureaucracy piddling around making silly changes for no reason. Which seems to happen with regularity in this biz.

It's expensive to make these types of silly changes. And it's really hard to justify paying for that. Nearly impossible actually.
 
denverpilot said:
Why would allowing people to claim 20 more hours be "good"? Good enough to meddle with law?
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If you were a new pilot interested in getting ratings quickly, you might think it was good. What difficulties did the change cause?

Regs have changed over the years and it seems like many changes have made things easier. There's the 20 hour solo which changed to 10. There's the 200 hours before getting an instrument rating that changed to 125. There's the provision to use more sim time for the instrument rating. There's the whole sport pilot certificate. Were these silly changes too?
 
Everskyward said:
If you were a new pilot interested in getting ratings quickly, you might think it was good. What difficulties did the change cause?

Regs have changed over the years and it seems like many changes have made things easier. There's the 20 hour solo which changed to 10. There's the 200 hours before getting an instrument rating that changed to 125. There's the provision to use more sim time for the instrument rating. There's the whole sport pilot certificate. Were these silly changes too?
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Some were. Sure. And those aren't the only changes over the years. Cherry picking stuff that may have had positive benefit isn't a completely valid way to assess all of them.

Those also aren't logging changes that are only logging changes. Those are requirements and standards changes. We're talking about logging changes and their usefulness in this example.

Which, you still haven't addressed.
 
denverpilot said:
Some were. Sure. And those aren't the only changes over the years. Cherry picking stuff that may have had positive benefit isn't a completely valid way to assess all of them.

Those also aren't logging changes that are only logging changes. Those are requirements and standards changes. We're talking about logging changes and their usefulness in this example.

Which, you still haven't addressed.
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I addressed them and showed you how they would be useful to some people. You just don't agree.
 
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denverpilot said:
By what authority? Sounds like just someone's opinion and people did it. I've seen no documents that allowed it.
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https://www.faa.gov/about/office_or...ogram/media/LOGGING PILOT-IN-COMMAND TIME.pdf

Now you have.

According to the FAA:
A student pilot can now log PIC. That's new, and since there is no restriction, your logbook can be updated so that all student solo time prior to August 4, 1997 may be logged as PIC.
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For some pilots who were licensed prior to August 1997, but didn't fly much after that, this could be a significant chunk of PIC time. You might not care. Others might.
 
BTW, updating, correcting, fixing, whatever-you-want-to-call-it, your paper logbook is as easy as entering on a single line "Student solo time counted as PIC time per 61.51(e)(4)" along with the total of your student solo time in the PIC column. Easy peasy, and up to date.
 
This makes my head spin. I just log PIC when I am actually PIC.

Apparently I have not logged the Airbus PIC that I am entitled to log. So be it. My conscious is clear.
 
Lindberg said:
https://www.faa.gov/about/office_or...ogram/media/LOGGING PILOT-IN-COMMAND TIME.pdf

Now you have.



For some pilots who were licensed prior to August 1997, but didn't fly much after that, this could be a significant chunk of PIC time. You might not care. Others might.
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That's the reg change. It says absolutely nothing about changing what was already logged.

But people did it anyway, I'm sure.

I asked for written proof that an already logged flight prior to the reg change could be "corrected", and this doesn't say that.
 
Everskyward said:
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.
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Same problem which you haven't addressed, why was the change necessary at all? Just Bearcats circle jerking. Feels good, no real purpose. Certainly no purpose based on the FAA charter of safety and efficiency of air travel.

The change to "what if it was yesterday" was hypothetical to prove the point, and was not the point being made, and you know that. You're not that dumb. You're just avoiding answering the question I raised about the real point, as hard as you can.

Let's try again...

Why change logging rules as it relates to what FAA is paid to accomplish?

Certainly their goal wasn't to "help out" pilots get 20 more hours of PIC? Why would they do that?

No pressure from any groups to give more PIC hours to anyone back then, that I'm aware of.

Just a bureaucrat somewhere, wasting everyone's time.
 
denverpilot said:
That's the reg change. It says absolutely nothing about changing what was already logged.

But people did it anyway, I'm sure.

I asked for written proof that an already logged flight prior to the reg change could be "corrected", and this doesn't say that.
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o_O I quoted the relevant part for you. Not sure which one of us is confused.

A student pilot can now log PIC. That's new, and since there is no restriction, your logbook can be updated so that all student solo time prior to August 4, 1997 may be logged as PIC.
Click to expand...

 
denverpilot said:
Ok. So it still doesn't address the uselessness of the change.
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Not sure which, if any, question I am answering. If any.

As I recall, the reg change wasn't huge. It was part of the big 1997 Part 61 revision and the addition of solo time to PIC was for some internal consistency. Maybe some beureaucrat just didn't like the idea of a flight in which no one could log PIC. One effect was to allow student solo time to be counted as PIC toward additional certificates and ratings. Which is the sole FAA purpose to logging anything - to show qualification and currency. How many, if any, applicants were affected in a way that made any difference? Beats me.

I don't think there is anything saying either one must or may not "correct" the entries. But I do recall something (I think more "official" than the document malready mentioned) that said that when you apply for a certificate and rating, the time that "counts" is the time that qualifies at the time of the application. So if you had 10 hours of 1994 student solo time and applied for a commercial certificate in 1999, your student solo time counted toward PIC requirements. How you happened to log it in 1994 is basically irrelevant.

To me "correction" is a bookkeeping question, not a regulatory one.

No, I don't have the references to either statement handy. The Part 61 revision Final Rule is available on the Federal Register website and I'm sure someone interested in "proof" one way or the other (not me :D) could find the references I recall.
 
denverpilot said:
Same problem which you haven't addressed, why was the change necessary at all? Just Bearcats circle jerking. Feels good, no real purpose. Certainly no purpose based on the FAA charter of safety and efficiency of air travel.

The change to "what if it was yesterday" was hypothetical to prove the point, and was not the point being made, and you know that. You're not that dumb. You're just avoiding answering the question I raised about the real point, as hard as you can.

Let's try again...

Why change logging rules as it relates to what FAA is paid to accomplish?

Certainly their goal wasn't to "help out" pilots get 20 more hours of PIC? Why would they do that?

No pressure from any groups to give more PIC hours to anyone back then, that I'm aware of.

Just a bureaucrat somewhere, wasting everyone's time.
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The change was useful to some people. It didn't hurt anyone. Why do you care whether or not it was changed? Why is it so hard to believe that the FAA wouldn't make it easier for pilots to reach your their hour goals when they have in other ways that I have named?
 
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