Logging IFR PIC before PPL

[SnoFlyer]

Hey folks

I’m waiting for my checkride (and waiting.. and waiting.. been signed off for 4 months and counting) but I was thinking I could start my IR while I bide my time for the checkride under 61.65(g)(1). I’d still do the ppl checkride separately, there’s nothing in there I can find that requires the joint checkride (the dangers of which are well known).

ny question is, when logging this time as XC PIC, I assume I’d also log that as dual received?

Any gotchas I’m not thinking of? Thanks.

 

[Greg Bockelman]

The only way you can log PIC before PPL is if you are sole occupant of the aircraft. (There is one very rare exception to that.) So that time can only be logged as instruction received. (Dual)

 

[MauleSkinner]

Hey folks

I’m waiting for my checkride (and waiting.. and waiting.. been signed off for 4 months and counting) but I was thinking I could start my IR while I bide my time for the checkride under 61.65(g)(1). I’d still do the ppl checkride separately, there’s nothing in there I can find that requires the joint checkride (the dangers of which are well known).

ny question is, when logging this time as XC PIC, I assume I’d also log that as dual received?

Any gotchas I’m not thinking of? Thanks.

Under what reg are you logging PIC without a PPL?

 

[SnoFlyer]

Under what reg are you logging PIC without a PPL?

61.65(g)(1), as stated:

(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;

 

[MauleSkinner]

61.65(g)(1), as stated:

Except that you stated you weren’t doing a combined program.

 

[RussR]

61.65(g)(1), as stated:

That's not PIC time, it's "PDPIC", which like on the Commercial rating exceptions, is not logged as PIC. It just can be used to meet the PIC time requirements as specified.

 

[midlifeflyer]

there’s nothing in there I can find that requires the joint checkride

You mean except that the combined checkride is the only thing it says it counts for?

There are a number of logging provisions that, like this one, say they apply only to - can only be counted toward - certain things. As @RussR said, this one says it allows you to count up to 45 hours if this activity toward the PIC requirements for the combined private/instrument. It is not general PIC time countable for any other purpose.

One similar in concept is in the very next two sections after the one you are looking at. They allow a certain amount of simulator/FTD/ATD to be counted toward flight time requirements. Flight time only takes place in an aircraft, not in a device tied to the ground. The section doesn't suddenly transform a Redbird bolted to the ground into an aircraft,

One more. An old one. Dufferent detail but the same idea. Look at the definitions of cross country time in 61.1. They are all about what types of flights are cross country depending on what you are counting it for.

 

[DesertNomad]

The only way you can log PIC before PPL is if you are sole occupant of the aircraft. (There is one very rare exception to that.) So that time can only be logged as instruction received. (Dual)

What is that rare exception? You can log PIC in the military without a civilian PPL and I think count it in civil aviation to some extent in nearly every case, but that would not be rare.

 

[EdFred]

What is that rare exception? You can log PIC in the military without a civilian PPL and I think count it in civil aviation to some extent in nearly every case, but that would not be rare.

Checkride.

 

[dmspilot]

What is that rare exception? You can log PIC in the military without a civilian PPL and I think count it in civil aviation to some extent in nearly every case, but that would not be rare.

Performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember

 

[DesertNomad]

Checkride.

I would not consider that rare.

 

[flyingron]

A private checkride is essentially solo. Examiners do not count as passengers under the rule. This is how examiners can avoid being PIC on those rides (the FAA strongly discourages, though doesn't prohibit DPEs from being PIC).

 

[midlifeflyer]

Checkride.

Sort of. I've definitely heard some interesting gymnastics to try to fit it in but IMO, logging PIC during a private checkride is more accepted custom than regulation.

 

[mandm]

Hey folks

I’m waiting for my checkride (and waiting.. and waiting.. been signed off for 4 months and counting) but I was thinking I could start my IR while I bide my time for the checkride under 61.65(g)(1). I’d still do the ppl checkride separately, there’s nothing in there I can find that requires the joint checkride (the dangers of which are well known).

ny question is, when logging this time as XC PIC, I assume I’d also log that as dual received?

Any gotchas I’m not thinking of? Thanks.

You’ll need to keep current flying with an instructor to keep your knowledge fresh and the sign off has an expiry too. Just try to get the checkride done. I would get more hood time and night time as it is good experience.

 

[mondtster]

You’ll need to keep current flying with an instructor to keep your knowledge fresh and the sign off has an expiry too. Just try to get the checkride done. I would get more hood time and night time as it is good experience.

He could also just work on his PIC cross country time that is required for the instrument rating by getting an instructor to endorse him for solo cross country trips. The instructor could also just start the traditional instrument training while they wait.

I’m a bit baffled at the path he’s trying to take as there are plenty of avenues to continue doing useful flying while they wait for a checkride that don’t involve the PIC gymnastics being discussed here.

 

[flyingron]

Sort of. I've definitely heard some interesting gymnastics to try to fit it in but IMO, logging PIC during a private checkride is more accepted custom than regulation.

Nope, it's regulation as I already pointed out. 61.47. Examiners are not PIC (unless they agree to be) nor counted as passengers.

 

[flyingron]

He could also just work on his PIC cross country time that is required for the instrument rating by getting an instructor to endorse him for solo cross country trips. The instructor could also just start the traditional instrument training while they wait.

I’m a bit baffled at the path he’s trying to take as there are plenty of avenues to continue doing useful flying while they wait for a checkride that don’t involve the PIC gymnastics being discussed here.

It's a real reach to log PIC instrument time solo without a rating. While technically there are times it could be done, it's a reach.

 

[dmspilot]

Nope, it's regulation as I already pointed out. 61.47. Examiners are not PIC (unless they agree to be) nor counted as passengers.

You should know as well as anyone else that acting and logging PIC are two different things. Logging of flight time is governed by 61.51, not 61.47.

 

[mondtster]

It's a real reach to log PIC instrument time solo without a rating. While technically there are times it could be done, it's a reach.

I wasn’t suggesting that.

 

[Greg Bockelman]

You should know as well as anyone else that acting and logging PIC are two different things. Logging of flight time is governed by 61.51, not 61.47.

He was talking about the examiner, not the examinee.

 

[dmspilot]

He was talking about the examiner, not the examinee.

No he wasn't.

midlife wrote: "logging PIC during a private checkride is more accepted custom than regulation"

to which flyingron replied "Nope...61.47"

 

[EdFred]

It's a real reach to log PIC instrument time solo without a rating. While technically there are times it could be done, it's a reach.

Ive done it VFR Over Lake Michigan on a moonless/overcast night. I was post IR, but would have still been legal if pre-IR.

Heck I had one hazy DAY where I logged it. There was no horizon.

 

[Greg Bockelman]

No he wasn't.

midlife wrote: "logging PIC during a private checkride is more accepted custom than regulation"

to which flyingron replied "Nope...61.47"

Well, I understand what Mark said, and I understand what Ron said in reply. What I don’t understand is how your response relates to what Ron said.

But whatever.

 

[dmspilot]

What I don’t understand is how your response relates to what Ron said.

Ron disagreed with Mark and cited an irrelevant reference that has no effect on Mark's position. Does that clear it up?

 

[Dana]

Nope, it's regulation as I already pointed out. 61.47. Examiners are not PIC (unless they agree to be) nor counted as passengers.

So how, if at all, does the examiner log it?

 

[Greg Bockelman]

I took Mark to mean that the examinee logging PIC was an accepted custom during a private checkride. (Which is entirely legitimate because they are.)

Normally, a pre-private pilot is not allowed to log PIC unless he is solo. Ed pointed out that a student pilot on his checkride was PIC. Mark in his post said “sort of” making his post about the student having to “do some interesting gymnastics” to fit it in the PIC box. Ron pointed out that 61.47 specifically states that the examiner is NOT the PIC unless he agrees to be. Therefore no gymnastics required as Mark indicated.

So, in my opinion, Ron’s reference was totally relevant.

 

[Greg Bockelman]

So how, if at all, does the examiner log it?

The examiner does NOT log it.

Do I have that right @tonycondon ?

 

[midlifeflyer]

Nope, it's regulation as I already pointed out. 61.47. Examiners are not PIC (unless they agree to be) nor counted as passengers.

I'm familiar with the regulation. But what does acting have to do with logging?

 

[dmspilot]

I took Mark to mean that the examinee logging PIC was an accepted custom during a private checkride.

He said it was a custom, rather than a regulation.

Ron pointed out that 61.47 specifically states that the examiner is NOT the PIC unless he agrees to be. Therefore no gymnastics required as Mark indicated.

And for the second time, you missed the distinction between acting PIC and logging PIC. 61.47 does not allow the examinee to log PIC, and 61.47 has nothing to do with logging. Making the reference not relevant. The reference for logging PIC is in 61.51. As I stated in my first post.

 

[midlifeflyer]

Nope, it's regulation as I already pointed out. 61.47. Examiners are not PIC (unless they agree to be) nor counted as passengers.

No? Then why 61.47(c)?

Notwithstanding the type of aircraft used during the practical test, the applicant and the examiner (and any other occupants authorized to be on board by the examiner) are not subject to the requirements or limitations for the carriage of passengers that are specified in this chapter​

 

[Greg Bockelman]

And for the second time, you missed the distinction between acting PIC and logging PIC. 61.47 does not allow the examinee to log PIC and 61.47 has nothing to do with logging.

I didn’t miss the distinction.

What 61.47 says is that the examiner is not the PIC. So 61.51 doesn’t even enter into it for the examiner. 61.47 only applies to the examiner.

61.51 applies to the examinee basically because he is the sole manipulator of the controls. But the examinee is also the acting PIC for the checkride. He has to be because 61.47 exempts the examiner from that responsibility. The examiner is quite literally along for the ride.

 

[Lindberg]

61.51 applies to the examinee basically because he is the sole manipulator of the controls.

But he isn't rated.

 

[dmspilot]

What 61.47 says is that the examiner is not the PIC. So 61.51 doesn’t even enter into it for the examiner. 61.47 only applies to the examiner.

Not understanding what your point your trying to make here. I didn't think anyone cared in this discussion what the DPE can or can't log.

61.51 applies to the examinee basically because he is the sole manipulator of the controls. But the examinee is also the acting PIC for the checkride.

You have yet to make a case for the applicant logging PIC time. Acting as PIC is not sufficient for logging PIC time. Neither is sole manipulator sufficient for logging PIC time. So yes, you did miss the distinction and continue to do so. Please read 61.51 again and tell us specifically which subparagraph(s) allow a student pilot to log PIC time when taking a practical test.

 

[Greg Bockelman]

If the examiner can’t log it, who can?

 

[MauleSkinner]

If the examiner can’t log it, who can?

Does anyone have to?

 

[Greg Bockelman]

I guess no one HAS to log it but since the applicant is the acting PIC and the examiner is literally just a passenger, the applicant is within his rights to log it.

 

[midlifeflyer]

Let's see...

A passenger who isn't a passenger but with a waiver for being a passenger.
Actually solo because the passenger isn't really there.
Acting PIC = logging PIC. There's really no distinction between logging and acting.
Sole manipulator of an aircraft the pilot is not rated for gets to log PIC because there's a passenger.

Nope, not a gymnast among you . I'm just sitting here enjoying the reactions to my innocuous off-hand remark about checkride logging being more accepted custom than something rooted in 61.51.

BTW, you missed one. The earliest one I've heard is still my favorite. When they get to the flight portion, applicants have already earned the certificate. They are already rated private pilots. The Examiner just has the power to take it back.

Which I guess leads to the next question: So, what does the applicant log if they fail the checkride?

 

[flyingron]

You should know as well as anyone else that acting and logging PIC are two different things. Logging of flight time is governed by 61.51, not 61.47.

Right, and 61.51 allows student pilots to log PIC if they are the sole occupant of the aircraft and 61.47 says examiners don't count as an extra body.

 

[MauleSkinner]

and 61.47 says examiners don't count as an extra body.

No, it says they aren’t subject to passenger carrying requirements and limitations. The applicant is allowed to carry these passengers on a checkride without being technically qualified to do so.

 

[dmspilot]

Right, and 61.51 allows student pilots to log PIC if they are the sole occupant of the aircraft and 61.47 says examiners don't count as an extra body.

"the applicant and the examiner...are not subject to the requirements or limitations for the carriage of passengers"

Does not imply that the examiner is not an occupant of the aircraft.