Logging PIC with no BFR

[midlifeflyer]

Yes, in the wacky world of the FAA and airplane can have any number of PICs, from zero to 900 (the maximum number of seats that can be stuffed into an A380).

Nope.

Only one PIC at a time - the person who has final authority and responsibility for the operation and safety of the flight; has been designated as pilot in command before or during the flight; and holds appropriate category, class (and type if required) ratings. Period.

Logging is about writing things down after the flight is over.

 

[MauleSkinner]

This could be read two ways. The first is that the PIC must relinquish logging PIC even though he remains PIC while the out-of-date pilot is flying and logging PIC. Or it means that it's not allowed, which seems the more reasonable interpretation.

Take the first.

 

[midlifeflyer]

So (not to sidetrack things here), based on what you're saying Mark (and what I'm reading from other posts) if I was in actual IMC on an IFR flight plan as an instrument student I could log PIC as sole manipulator, but the actual PIC would be the CFII in the seat next to me?

It goes even further than that and, technically, one doesn't even have to look at the question of who was the actual PIC. If you fit into a 61.51 "box" you log what the box permits. If you don't, you don't.

But to be specific, yes. In the situation you describe, the student logs PIC as sole manipulator of an aircraft the student is rated for and the CFI logs PIC, not because he is acting as PIC, but because he is giving instruction.

In fact, that was one of the 7 specific examples the Chief Counsel's office gave in the 35 year old letter:

You request interpretations of these regulations for situations in which:

1. The purpose of the flight is instruction in advanced maneuvers.

2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.

3. The purpose of the flight is instrument instruction actual IFR conditions.

4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.

5. The purpose of the flight is transition from tricycle to conventional landing gear.

6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).

7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates.

We trust that this discussion answers your questions.
​

I always found that last sentence funny.

 

[Caramon13]

Interesting..well, this thread has been rather illuminating then I think...thanks all!

 

[arnoha]

If you were to have presented me with this question, given my background (software engineer), I'd have told you that you have a data modeling problem. Instead of overloading the term (logging) PIC, there should be a category of logging for PIC (the in legal charge meaning) and one for sole manipulator.

Basic principles: if you record what happened (the facts), you can derive any inference from that that you like. If you record only the inference, you've lost the ability to make new inferences from the information. Also, as noted, holy crap, it's confusing.

I wonder if it's fixable. Or if yet another replacement of the rules would be even MORE confusing.

 

[MauleSkinner]

If you were to have presented me with this question, given my background (software engineer), I'd have told you that you have a data modeling problem. Instead of overloading the term (logging) PIC, there should be a category of logging for PIC (the in legal charge meaning) and one for sole manipulator.

Basic principles: if you record what happened (the facts), you can derive any inference from that that you like. If you record only the inference, you've lost the ability to make new inferences from the information. Also, as noted, holy crap, it's confusing.

I wonder if it's fixable. Or if yet another replacement of the rules would be even MORE confusing.

If you're saying the value of PIC time in the logbook has been watered down by what we're allowed to log as PIC, I'd definitely agree.

 

[Caramon13]

arnoha, yeah I understand what you're saying (I'm actually a developer) and..how you are saying it

I used to think of PIC as absolute and I guess it is from a "legal" standpoint, but those logbooks sure manage to dilute that term a lot as stated above..

 

[midlifeflyer]

If you were to have presented me with this question, given my background (software engineer), I'd have told you that you have a data modeling problem. Instead of overloading the term (logging) PIC, there should be a category of logging for PIC (the in legal charge meaning) and one for sole manipulator.

Basic principles: if you record what happened (the facts), you can derive any inference from that that you like. If you record only the inference, you've lost the ability to make new inferences from the information. Also, as noted, holy crap, it's confusing.

I wonder if it's fixable. Or if yet another replacement of the rules would be even MORE confusing.

I had a chance during a recuperation to look at some of the history. At one time, the FAA used the term "solo" for "sole manipulator." Of course that will cause confusion since "solo" is now defined as only person on board. You may be right that any cure might be worse than the disease.

The FAA definitely produced some level of confusion by using similar terms for two independent concepts. Might have been better to make up a word. But once one makes the small mental leap, it's really pretty easy to separate the two since they are so different.

From a regulatory perspective, there's no need for a "category of logging for PIC (the in legal charge meaning)". I don''t have to play the inference game - if it's in the PIC column I know exactly what it (should) means - time the FAA counts as PIC toward qualification and currency. Loggable flight time as clearly defined by 61.51 is the only thing the FAA tracks or counts for the purpose of showing qualification and currency, which, in turn, is the only regulatory purpose of a logbook.

There clearly is some value to a separate "really in command" category for those heading toward careers since many employers want to have that information. That's typically satisfied by pilots with those aspirations adding a "Part 1 PIC" column to their logbooks.

 

[Lindberg]

If you're saying the value of PIC time in the logbook has been watered down by what we're allowed to log as PIC, I'd definitely agree.

If anything, ours watered down by the times you can log it even though you're not some manipulator. I can't imagine the value of time logged simply because someone was "acting as PIC" even though not actually flying the plane.

 

[Everskyward]

It all makes perfect sense if you think about the purpose and significance of logging. In single-pilot ops, the "acting" PIC could be reading a book, sleeping, or joining the mile-high club while someone else is the sole manipulator. Meanwhile, the sole manipulator, is solely manipulating the plane. So who's getting the plane-flying experience?

But who is responsible?

Logging rules are what they are. They don't need to make sense.

 

[MauleSkinner]

If anything, ours watered down by the times you can log it even though you're not some manipulator. I can't imagine the value of time logged simply because someone was "acting as PIC" even though not actually flying the plane.

Making bad decisions probably kills more people than lack of time with your hands on the controls.

If my SIC can fly headings and altitudes while we're working a malfunction, I'll have him or her do that so that as the pilot acting as PIC I can manage the malfunction and decision making process more effectively.

Acting as PIC means substantially more than being able to log PIC, IMO.

 

[Lindberg]

But who is responsible?

Logging rules are what they are. They don't need to make sense.

Why does it matter who's responsible? Is a logbook intended as a record of your experience piloting an aircraft or your experience being responsible? I think it's the former (so does the FAA), but some think it's the latter. That's fine. But then I wonder whether the owner of the flight school or the chief instructor sold be able to log PIC for all instructional flights. I mean, they're responsible for the safety of those flights, aren't they?

 

[midlifeflyer]

Why does it matter who's responsible? Is a logbook intended as a record of your experience piloting an aircraft or your experience being responsible? I think it's the former (so does the FAA), but some think it's the latter. That's fine. But then I wonder whether the owner of the flight school or the chief instructor sold be able to log PIC for all instructional flights. I mean, they're responsible for the safety of those flights, aren't they?

The flight school as owner or lessee is responsible for the maintenance of the aircraft. The Chief instructor is responsible for instruction and the quality of the pilots. Neither is directly responsible for the safety of the conduct of a specific flight. That's the ultimate responsibility of the pilot in command.

I disagree with you on what the FAA thinks. The FAA has clearly said it's a record of what the FAA wants to see to show pilot qualification and currency. They represent policy choices of what to count, and those choices are not susceptible to being fit in to simple categories of hands-on piloting vs responsibility. And you will find examples of both ultimate flight responsibility and piloting in the logging rules.

Just two of them:

• The sole manipulator logs PIC time even if not responsible for the flight.Even if it's the very first time he's retracted the gear on a complex high performance airplane.
• The safety pilot who acts as PIC is logging flight responsibility time despite not touching the controls. And he's only entitled to log the time as PIC is he undertakes that responsibility, otherwise he's limited to logging SIC.

Same for the opposite:

• The instrument-rated pilot who allows the non-instrument rated pilot to fly in actual can't legitimately log anything despite complete responsibility for the flight and everything that happens.
• The ASEL sole manipulator of a multi-engine aircraft can't log PIC (unless alone and signed off for solo) no matter how well she handles the controls.