Logging PIC time during instrument training without PPL

FLYGUYRY

Pre-takeoff checklist
Joined
Jan 25, 2016
Messages
173
Location
Baltimore
Display Name

Display name:
Ryan_M
So I have sort of a weird situation that has confused my flight instructor and I. I have had to reschedule my PPL check ride a few times now due to weather but pushed on to my instrument training, now about 5 lessons in, while waiting for my next date. The guidance on logging PIC time is about clear as mud in this particular situation, so I was just wondering if anyone else has been in this situation before or if anyone knows if I can actually log PIC time during my instrument CC flights (had my first one last night).

Thanks for your help in advance to anyone who chimes in!
 
It's actually pretty clear. You are not rated. You can't log PIC. You don't have your PPL. For now, the only time you can log PIC is when you're solo. Waiting for someone to tell me, "well not quite.....":)
 
Last edited:
Yeah the not quite I think is where we are confused. I know I can't log it while in private training unless I'm solo because of the "sole manipulator" designation, but while in instrument training I am the sole manipulator even though I am not actually the pilot in command. The FARs talk about being rated or having privileges, and I guess the ambiguity lies there....I am endorsed to fly the aircraft solo and on cross country flights so is that not the same thing as privileges in this case?

Sorry if its a stupid question, my instructor nor anyone else at the school have ever had someone working on this instrument without their PPL
 
Yeah the not quite I think is where we are confused. I know I can't log it while in private training unless I'm solo because of the "sole manipulator" designation, but while in instrument training I am the sole manipulator even though I am not actually the pilot in command. The FARs talk about being rated or having privileges, and I guess the ambiguity lies there....I am endorsed to fly the aircraft so is that not the same thing as privileges in this case?

Sorry if its a stupid question my instructor or anyone else at the school has just never had someone working on this instrument without their PPL
Negative. The magic word is rated. You are not rated to fly the aircraft. You are endorsed to solo a specific make/model but you are not rated.
 
The logging requirements are exactly the same as the 3 hours of instrument training you already had to log before your private checkride. That means you can't log PIC as mentioned above.

Note that to take your instrument checkride you have to have "Fifty hours of cross country flight time as pilot in command" per 61.65(d)(1) so if you get ready for your instrument checkride too soon after getting your private, you won't meet that requirement (unless you did a ton of solo flight as a student, you do lots of flying in addition to your instrument training, or you have 50 hours of instrument training after you pass your private checkride and all of that training involves cross-country flights). I personally waited a year before starting instrument training so I could get some XC time.


-Paul
 
Ok cool, that's what we thought but just wanted to make sure I wasn't missing out on logging hours if it was possible somehow :)
 
I know I can't log it while in private training unless I'm solo because of the "sole manipulator" designation, but while in instrument training I am the sole manipulator even though I am not actually the pilot in command. The FARs talk about being rated or having privileges, and I guess the ambiguity lies there....I am endorsed to fly the aircraft so is that not the same thing as privileges in this case?

Sorry if its a stupid question, my instructor nor anyone else at the school have ever had someone working on this instrument without their PPL

None of that is relevant. You are not a sport, recreational, private, commercial, or airline transport pilot so nothing in 61.51(e)(1) applies to you. No ambiguity. See 61.51(e)(4). You are a student pilot. The only time you can log PIC time in an airplane is when you are the sole occupant.

FAR 61.51(e)(4) said:
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.
(My emphasis on "only").
 
ah ok there is the magic word, thank you. Guess I will scale it back a bit and do some sim training or work on holds/approaches till I get my ticket in a couple weeks.
 
If it's any consolation, everything counts toward the 250 required for the commercial...if you plan on going for that.
 
Yeah the not quite I think is where we are confused. I know I can't log it while in private training unless I'm solo because of the "sole manipulator" designation, but while in instrument training I am the sole manipulator even though I am not actually the pilot in command. The FARs talk about being rated or having privileges, and I guess the ambiguity lies there....I am endorsed to fly the aircraft solo and on cross country flights so is that not the same thing as privileges in this case?

Sorry if its a stupid question, my instructor nor anyone else at the school have ever had someone working on this instrument without their PPL
It's not a stupid question at all. But the rule is fairly clear. It does not talk about "having privileges." What it actually says is:

61.51(e)(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;​

The key is ya gotta actually read the words, not what you think the words are.

There are three requirements for logging PIC under the sole manipulator rule:
  1. sport, recreational, private, commercial or ATP certificate; and
  2. rated for or sport pilot privileges for the aircraft (sport pilots don't have ratings, they have privileges); and
  3. sole manipulator of the flight controls.
And of those three, you have...?

(Great answer by @dmspilot about the student PIC part of the rule, but figured since we were looking at the sole manipulator rule, it was a good idea to actually read it.)
 
If your instructor and everyone else at the school doesn't know the answer to this question, you might want to seek out another school and instructor. It is rather simple. They should be able to answer the question.
 
If your instructor and everyone else at the school doesn't know the answer to this question, you might want to seek out another school and instructor. It is rather simple. They should be able to answer the question.

Maybe the OP IS the instructor? :popcorn:
 
Not to mention you're wasting your time and money... How much XC PPL time do you have? (answer must be ZERO)

How much do you need for your IFR? 50

If you're going to fly while waiting to get your PPL done, do it all on mock test rides. There just isn't any skipping to be done at this point (unless your working on the 250 for total for commercial as mentioned previously)

Better off finishing and building time without paying for someone sitting next to you.
 
Not to mention you're wasting your time and money... How much XC PPL time do you have? (answer must be ZERO)

How much do you need for your IFR? 50
The 50 hours XC time for the instrument rating is XC PIC time, which a student pilot can log while solo assuming he is not breaking any rules by making the flight solo (see dmspilot's post above). So the OP could get endorsed for a long cross-country solo flight and make it a dozen times and it would count toward that requirement. But I agree that it's a waste to do that. Mock check rides or going up with an instructor on really windy days will be a better use of flying hours than lots of simulated instrument time.
 
Just to be completely accurate, the total 50 hr XC time requirement for the Instrument Rating is for part 61. There is no specific XC hr requirement if you go part 141.
 
Last edited:
You also can't log PIC time for training in a multi or a glider, if you have a PP-ASEL certificate.
 
Just to be completely accurate, the total 50 hr XC time requirement for the Instrument Rating is for part 61. There is no specific XC hr requirement if you go part 141.

Yup I'm part 141 and in a university program, will be going all the way through CFII

I should have clarified my question wasn't about logging PIC for instrument (as you stated there is no requirement for 141) but just about building my PIC time in general.

Thanks for all the input guys
 
Back
Top