Cross-country time

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AnnaG

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AnnaG
I'm a fairly recent Private Pilot, just starting my instrument training under Part 91.

The question I have relates to the 50-hour cross-country time requirement. And specifically, to this:

If I am flying with another pilot (not an instructor) in a complex single-engine (Mooney) and he "gives" me the cross-country PIC time - can I use that time as part of my cross-country requirements?

What I can't figure out is whether I can officially log time in a complex aircraft, even though I am not rated for that aircraft?

Or do I need to stick to my trusty 172 for all of my log-able cross-country flight time?
 
AnnaG said:
If I am flying with another pilot (not an instructor) in a complex single-engine (Mooney) and he "gives" me the cross-country PIC time - can I use that time as part of my cross-country requirements?
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I don't see why not. The regulation specifies Pilot in Command time. It does not specify what KIND of PIC time. (Unless, of course, I am missing something)

What I can't figure out is whether I can officially log time in a complex aircraft, even though I am not rated for that aircraft?
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Well, you ARE rated, if you hold a PP Single engine Land. You just are not endorsed. Two separate things. So yeah, you can log it as long as your friend can actually act as PIC. I will let someone else get nit picky here, as I am sure they will.

Or do I need to stick to my trusty 172 for all of my log-able cross-country flight time?
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Not necessary. However, I suspect you won't get a whole lot of PIC Mooney time.

But here's a thought. Why not get your friend to let you get a complex endorsement in his plane? That would make all of the above pretty much moot.
 
Provided you are the "sole manipulator of the controls" for the flight, including the takeoff and landing, you can use that as PIC time.

Now, if your friend flies the plane and "gives" you the PIC time, that's a different matter.
 
AnnaG said:
If I am flying with another pilot (not an instructor) in a complex single-engine (Mooney) and he "gives" me the cross-country PIC time - can I use that time as part of my cross-country requirements?
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Exactly what do you mean by "gives me the cross country PIC time?"

It's either yours because you were the one who did the flight from takeoff to landing in an aircraft you are rated for (endorsements don't count) or is isn;t yours because you were not.
 
My DPE for my IFR was in the middle of this situation and we were discussing it among a few pilots and instructors with him. Same scenario, new PPL went on a long XC flight in a twin complex with a CFII buddy traveling. After takeoff, he was handed controls and logged it as PIC time towards his IFR XC time. DPE said no, does not qualify and sent it up the flagpole to the FAA.

Determination from FFA was that since the PPL was not HP, complex or twin endorsed if the PPL was receiving "dual instruction" then the time is logable towards the XC time, otherwise it is not since he can not legally be PIC of that aircraft. The CFI went back and signed the time off as "dual instruction" and they let it pass.

The DPE did not think that was the right decision as the purpose of the 50 hour requirement is not only about pointing the plane in the right directions, but the preflight planning, landing at unfamiliar airports and all that goes into a cross country trip, none of which this PPL obviously and admittedly did.

With your co pilot not being CFI, then it will get shot down if you are trying to count it towards a rating.
 
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Thank you! I was assuming that, because I don't have a complex endorsement, that I couldn't officially log the time.

And yes, the flight was mine - from take off to landing. I've flown the Mooney a few previous times, to get used to the higher power, retractable gear, etc. But this time, PIC in total.

This last weekend, we flew a nice 120nm round trip that would be useful for building time for my instrument rating.

Agree that it might be good to get the endorsement. It wasn't "top of my list" initially, but might be worth it in order to log time.

I hope that makes sense.
 
AnnaG said:
Thank you! I was assuming that, because I don't have a complex endorsement, that I couldn't officially log the time.

And yes, the flight was mine - from take off to landing. I've flown the Mooney a few previous times, to get used to the higher power, retractable gear, etc. But this time, PIC in total.

This last weekend, we flew a nice 120nm round trip that would be useful for building time for my instrument rating.

Agree that it might be good to get the endorsement. It wasn't "top of my list" initially, but might be worth it in order to log time.

I hope that makes sense.
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But you CAN log the time! On your license it says, Private Pilot, Single Engine Land Airplane. If you are the sole manipulators of the Mooney, you can log that time as PIC.
 
AnnaG said:
Thank you! I was assuming that, because I don't have a complex endorsement, that I couldn't officially log the time.

And yes, the flight was mine - from take off to landing. I've flown the Mooney a few previous times, to get used to the higher power, retractable gear, etc. But this time, PIC in total.

This last weekend, we flew a nice 120nm round trip that would be useful for building time for my instrument rating.

Agree that it might be good to get the endorsement. It wasn't "top of my list" initially, but might be worth it in order to log time.

I hope that makes sense.
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FYI, the insurance won't cover you, generally they require both the complex endorsement and 10 hrs of specialized mooney training, if you break it, you bought it, your friend is taking a big risk.
 
jordane93 said:
But you CAN log the time! On your license it says, Private Pilot, Single Engine Land Airplane. If you are the sole manipulators of the Mooney, you can log that time as PIC.
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But he is missing his complex endorsement....and his buddy is nothing more than a passenger even though endorsed. He can not fly that plane legally solo as PIC and both people in plane can not be PIC simultaneously.
 
That is my understanding. I was PIC for all of my tailwheel training. I would not be PIC should I train for MEL or SES or something for which I am not rated unless I was solo.
 
Shawn said:
No.

My DPE for my IFR was in the middle of this situation and we were discussing it among a few pilots and instructors with him. Same scenario, new PPL went on a long XC flight in a twin complex with a CFII buddy traveling. After takeoff, he was handed controls and logged it as PIC time towards his IFR XC time. DPE said no, does not qualify and sent it up the flagpole to the FAA.
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Difference is, twin is a rating, complex is an endorsement.

You can't log time in a twin without a rating. For a single complex, so long as you have ASEL, you're OK to log it as PIC.
 
Shawn said:
But he is missing his complex endorsement....and his buddy is nothing more than a passenger even though endorsed. He can not fly that plane legally solo as PIC and both people in plane can not be PIC simultaneously.
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JeffDG said:
Difference is, twin is a rating, complex is an endorsement.

You can't log time in a twin without a rating. For a single complex, so long as you have ASEL, you're OK to log it as PIC.
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Yes. See Jeff's explanation.
 
Shawn said:
But he is missing his complex endorsement....and his buddy is nothing more than a passenger even though endorsed. He can not fly that plane legally solo as PIC and both people in plane can not be PIC simultaneously.
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Buddy is acting as PIC, but cannot log PIC time (exception for operations where more than one pilot required, like under the hood)

You (not-rated) are logging PIC but not acting as PIC under the "sole manipulator" provision.
 
Shawn said:
...or receiving "dual instruction".
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If you're an ASEL receiving instruction in a twin, you cannot log PIC time for that instruction. In order to log PIC under the sole manipulator, you must be rated in Category (Airplane) and Class (Multi Engine Land), and if needed Type (highly unusual in light aircraft).
 
ChrisK said:
That is my understanding. I was PIC for all of my tailwheel training. I would not be PIC should I train for MEL or SES or something for which I am not rated unless I was solo.
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Correct.

The only time you can log PIC time in an A/C for which you are not rated (as opposed to endorsed for) is when you are solo.

Basically, if your pilot certificate (the card only) has everything you need to fly the plane, regardless of what endorsements you have in your logbook, you can log sole manipulator time.
 
Shawn said:
My DPE for my IFR was in the middle of this situation and we were discussing it among a few pilots and instructors with him. Same scenario, new PPL went on a long XC flight in a twin complex with a CFII buddy traveling. After takeoff, he was handed controls and logged it as PIC time towards his IFR XC time. DPE said no, does not qualify and sent it up the flagpole to the FAA.

Determination from FFA was that since the PPL was not HP, complex or twin endorsed if the PPL was receiving "dual instruction" then the time is logable towards the XC time, otherwise it is not since he can not legally be PIC of that aircraft. The CFI went back and signed the time off as "dual instruction" and they let it pass.

The DPE did not think that was the right decision as the purpose of the 50 hour requirement is not only about pointing the plane in the right directions, but the preflight planning, landing at unfamiliar airports and all that goes into a cross country trip, none of which this PPL obviously and admittedly did.

With your co pilot not being CFI, then it will get shot down if you are trying to count it towards a rating.
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That "determination" was incorrect based on what the regulations say as interpreted by the FAA for more than 30 years.
 
Shawn said:
But he is missing his complex endorsement....and his buddy is nothing more than a passenger even though endorsed. He can not fly that plane legally solo as PIC and both people in plane can not be PIC simultaneously.
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Of course not. But "being" PIC has almost nothing to do with the rules on "logging" PIC time.

The reg is even in English:

==============================
(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;
==============================

For a recreational and higher pilot

Sole manipulator + applicable aircraft rating* = authority to log PIC.

Nothing else matters. And "endorsements" are not "ratings." Easy enough to find that in the FAR.
 
See the Herman letter previously linked.

For the PP-ASEL who tried to log AMEL time as PIC, the determining factor would be whether he was twin-rated or not (he apparently wasn't). If he had a twin rating, but no HP or complex endorsement it would be legal if he was sole manipulator.

For the Mooney, as long as the Acting PIC is properly endorsed, you can log PIC time when you fly.
 
Shawn said:
My DPE for my IFR was in the middle of this situation and we were discussing it among a few pilots and instructors with him. Same scenario, new PPL went on a long XC flight in a twin complex with a CFII buddy traveling. After takeoff, he was handed controls and logged it as PIC time towards his IFR XC time. DPE said no, does not qualify and sent it up the flagpole to the FAA.

Determination from FFA was that since the PPL was not HP, complex or twin endorsed if the PPL was receiving "dual instruction" then the time is logable towards the XC time, otherwise it is not since he can not legally be PIC of that aircraft. The CFI went back and signed the time off as "dual instruction" and they let it pass.
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I don't know who in the FAA would have told you this, but it is wrong. The pilot involved cannot log it towards the 50-hour PIC time requirement no matter what the CFI puts in the logbook. In the initial situation, lack of the 61.31 endorsements is irrelevant, because they are not required in order to log PIC time as sole manipulator of the controls of an aircraft in which you are rated. However, since this new PPL had only a single-engine rating, he could not log it as PIC time even with an instructor signing it as training time.

The DPE did not think that was the right decision as the purpose of the 50 hour requirement is not only about pointing the plane in the right directions, but the preflight planning, landing at unfamiliar airports and all that goes into a cross country trip, none of which this PPL obviously and admittedly did.
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The DPE was correct -- time in a twin cannot be logged as PIC time by a PP-ASEL no matter what unless that PP is the sole occupant of the aircraft, and that woulld require a bunch of training in that twin and a special solo endorsement for that twin.
 
Shawn said:
But he is missing his complex endorsement....and his buddy is nothing more than a passenger even though endorsed. He can not fly that plane legally solo as PIC and both people in plane can not be PIC simultaneously.
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You are confusing being the PIC with logging PIC time. The other pilot was still the PIC, and had to have all those endorsements. However, one can log PIC time without being the PIC if one is the sole manipulator of the controls and rated in the aircraft (and that only includes the ratings on your pilot certificate, not logbook endorsements). 14 CFR 51.51(e)(1)(i) applies. So, the OP, having an ASEL rating and being the sole manipulator of the controls from takeoff to landing can legally log it as XC PIC time towards the XC PIC requirement for the instrument rating.
 
ChrisK said:
That is my understanding. I was PIC for all of my tailwheel training. I would not be PIC should I train for MEL or SES or something for which I am not rated unless I was solo.
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You may have been able to log PIC time during your tailwheel training, since you were sole manipulator of an aircrft for which you were rated, but you were not PIC -- your instructor was. If you go for ME or seaplane training, you will not be rated in that aircraft and will not be able to log PIC time until you get that new rating.
 
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Shawn said:
...or receiving "dual instruction".
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Receiving training from an authorized instructor doesn't change anything. Either you are rated in the aircraft and can log PIC time or you are not rated and cannot log PIC time.
 
Ron Levy said:
You may have been able to log PIC time during your tailwheel training, since you were sole manipulator of an aircrft for which you were rated, but you were not PIC -- your instructor was. If you go for ME or seaplane training, you will not be rated in that aircraft and will not be able to log PIC time until you get that new rating.
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Fair point. I LOGGED it.
 
JeffDG said:
Difference is, twin is a rating, complex is an endorsement.

You can't log time in a twin without a rating. For a single complex, so long as you have ASEL, you're OK to log it as PIC.
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Yup

Like someone else said, just go get your complex and high performance, its really easy and won't cost much.

Especially if you're going to be doing this often.
 
midlifeflyer said:
That "determination" was incorrect based on what the regulations say as interpreted by the FAA for more than 30 years.
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Actually, the determination was correct, but had nothing to do with HP or Complex, but with ASEL vs. AMEL.
 
Only thing I'd add to the OP (which was mentioned but not emphasized):

You can now log PIC time for any time you're the sole manipulator of controls for any single-engine land airplane that doesn't require a type rating. (Doesn't matter if it's high performance, complex, pressurized, tailwheel, or flying IFR.)

However, it only counts as cross-country time if you fly both the takeoff and landing all by yourself. Depending on how protective your friend is with his plane, this might be the part that comes back to bite you.
 
mcmanigle said:
You can now log PIC time for any time you're the sole manipulator of controls for any single-engine land airplane that doesn't require a type rating. (Doesn't matter if it's high performance, complex, pressurized, tailwheel, or flying IFR.
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Why the "now"? Because the poster "now" has a certificate? :confused:
 
mcmanigle said:
Yes; that's what I was getting at. Probably more likely to just be misread as "not" though, given it's kind of superfluous. Sorry.
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I didn't misread as "not." I was wondering if you thought the rule about the sole manipulator logging based solely on ratings was new, which would have surprised me.
 
Shawn said:
Determination from FFA was that since the PPL was not HP, complex or twin endorsed if the PPL was receiving "dual instruction" then the time is logable towards the XC time, otherwise it is not since he can not legally be PIC of that aircraft. The CFI went back and signed the time off as "dual instruction" and they let it pass.
Click to expand...

midlifeflyer said:
That "determination" was incorrect based on what the regulations say as interpreted by the FAA for more than 30 years.
Click to expand...

JeffDG said:
Actually, the determination was correct, but had nothing to do with HP or Complex, but with ASEL vs. AMEL.
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midlifeflyer said:
Yes. Ultimate answer correct, reasoning not.
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This isn't the first time arguing lawyers have left me in the dust. :)

In both the OP's and Shawn's "twin" scenario the private pilots already are licensed, so don't qualify for the 61.65(a)(1) "concurrent" private and instrument rating which allows logging of 45 dual cross country hours under the exception to 61.65(d) of 61.65(g)(1). So, to my way of thinking, everybody's wrong except me.

dtuuri
 
dtuuri said:
In both the OP's and Shawn's "twin" scenario the private pilots already are licensed, so don't qualify for the 61.65(a)(1) "concurrent" private and instrument rating which allows logging of 45 dual cross country hours under the exception to 61.65(d) of 61.65(g)(1).
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That regulation does not allow the trainee to log PIC time during those dual XC's, only to apply that dual XC time towards the time required to be eligible for a combined PP/IR practical test.
 
Ron Levy said:
That regulation does not allow the trainee to log PIC time during those dual XC's, only to apply that dual XC time towards the time required to be eligible for a combined PP/IR practical test.
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Looks like the FAA's got it wrong again then:
"The student pilot may log crosscountry PIC time toward the balance of the 50-hour requirement if the training is conducted during cross-country flight with an instructor on board the aircraft."​

See the preamble to the final rule:
http://www.gpo.gov/fdsys/pkg/FR-2011-08-31/pdf/2011-22308.pdf

dtuuri
 
dtuuri said:
Looks like the FAA's got it wrong again then:
"The student pilot may log crosscountry PIC time toward the balance of the 50-hour requirement if the training is conducted during cross-country flight with an instructor on board the aircraft."​

See the preamble to the final rule:
http://www.gpo.gov/fdsys/pkg/FR-2011-08-31/pdf/2011-22308.pdf

dtuuri
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S'matter? Not enough time to read the whole paragraph and see they were talking about crediting time toward PIC time while "performing the duties" of PIC with an authorized instructor on board and not actual logged PIC time under 61.51? And that the specific provision being discussed, 61.65(g), "applies only to training conducted for a combined private pilot certificate and instrument rating."

Yes, it lacks a certain level of linguistic perfection but that's the way it goes.
 
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midlifeflyer said:
S'matter? Not enough time to read the whole paragraph and see they were talking about crediting time toward PIC time while "performing the duties" of PIC with an authorized instructor on board and not actual logged PIC time under 61.51? And that the specific provision being discussed, 61.65(g), "applies only to training conducted for a combined private pilot certificate and instrument rating."

Yes, it lacks a certain level of linguistic perfection but that's the way it goes.
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I read it before and just read it again. It still says student pilots can log PIC time while training for a combined private pilot certificate and instrument rating. At the end of the paragraph they refer to such (logged) time as a "credit". So, as long as you don't have a certificate allowing you to actually BE a PIC, i.e., you're a student pilot, you can still log cross country PIC time if you're doing all the duties and functions of one while taking dual and working toward a combined certificate. That appears to be the intent and the source of the erroneous thinking that a licensed pilot could do it too. It intends for the student to log PIC cross country time without needing solo sign-offs all the time and is deemed safer than letting them fly solo. It lessens the financial barrier to acquire an instrument rating too. I preferred it the old way, but that's what it says.

Are you saying the hours can't be logged and therefore won't count toward the commercial cross-country requirement--that they must essentially be repeated, i.e., reinstate the financial hardship?

dtuuri
 
dtuuri said:
Are you saying the hours can't be logged and therefore won't count toward the commercial cross-country requirement--that they must essentially be repeated, i.e., reinstate the financial hardship?

dtuuri
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If they qualify as "performing the duties..." flights they are subject to the rules on the crediting of that type of time in those other certificates and ratings.

It doesn't matter if the guy writing the explanation for the Federal Register preamble said "log PIC time" instead of "credit as PIC time." And the reg says:

==============================
(g) An applicant for a combined private pilot certificate with an instrument rating may satisfy the cross-country flight time requirements of this section by crediting:
(1) For an instrument-airplane rating or an instrument-powered-lift rating, up to 45 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor; or
(2) For an instrument-helicopter rating, up to 47 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor.
==============================

No one word about logging PIC. And none in 61.51 which specifically deals with logging flight time.

As the Chief Counsel's office once said about the contents of the Federal Register when there is no language of the regulations conflicts (one of my favorite FAA regulatory errors):
==============================
Preambles to final rules serve two purposes; they explain the reasons for adopting the new rule, including responses to public comments, and they provide interpretive guidance on operation of the rule. However, when the rule and the preamble conflict, the rule controls.
==============================

There is also support in the Chief Counsel opinions for the notion that "performing the duties" time is not PIC time for the simple reason that 61.51 doesn't say it is (and neither does anything else).
 
mcmanigle said:
However, it only counts as cross-country time if you fly both the takeoff and landing all by yourself. Depending on how protective your friend is with his plane, this might be the part that comes back to bite you.
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Not just the takeoff and landing, but the entire flight. From a chief counsel opinion issued in 2009:


...That interpretation did not address how two pilots who trade off manipulation of the controls may log cross-country time. However, that interpretation is applicable to this scenario. The rationale behind the cross-country requirement is to provide a pilot with aeronautical experience flying a significant distance to and landing at an airport that is not the pilot's home airport. Section 61.65 contemplates that one pilot is gaining that aeronautical experience. Sections §§ 61.109 and 61.129 contemplate the same. Accordingly, in this scenario, neither pilot may log cross-country time to meet the cross-country requirements under §§ 61.65( d), 61.109, or 61.129.
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