Logging PIC

StikRudr

StikRudr

Filing Flight Plan
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StikRudr
I'm just returning to the skies after 12 years. I have a ASEL, high performance endorsement and a glider rating. I've bought and sold a few planes, flown a lot of x-country so now that I'm retired I'm just looking to rent, or maybe find a partner to buy, a Champ, Cub, T-Craft, Fly Baby, etc. and fly strictly as a sport pilot. As such I don't intend to renew my expired 3rd class medical.

I'm working on my BFR and taking some dual in a 7ECA. My instructor believes that because it's over the light sport aircraft max of 1320 lbs and that I don't have a current medical, any dual can't be logged as PIC. Can another CFI verify this?
 
So it seems my instructor is misinformed, now to convince him of that.
 
Have him show you the appropriate regulations. :D

There is a difference between ACTING as PIC and LOGGING PIC.

If you are rated in the aircraft (Category and class) you can LOG PIC any time you are sole manipulator of the controls. As CLEARLY stated in the regs.
 
StikRudr said:
So it seems my instructor is misinformed, now to convince him of that.
Click to expand...

And if you can't, just wait until he signs you off for the FR, then go back and correct the entries by adding the time in the PIC column.

Or of course you could get another instructor who knows the rules, but that may not be financially worthwhile at this point.
 
RussR said:
And if you can't, just wait until he signs you off for the FR, then go back and correct the entries by adding the time in the PIC column.

Or of course you could get another instructor who knows the rules, but that may not be financially worthwhile at this point.
Click to expand...
A simple solution. I actually did that a long time ago. The official interpretations of the logging rules were not as well known and many if not most equated logging with acting. I went back at some point and filled in the PIC column for my high performance endorsement training,
 
RussR said:
And if you can't, just wait until he signs you off for the FR, then go back and correct the entries by adding the time in the PIC column.
Click to expand...
Although in the case of the OP, would it really matter whether or not it’s logged PIC?
 
In case you were wondering, here is 61.61(e). Appropriate part is bolded. 61.159(c) deals with logging second in command time by a commercial pilot, flying for a Part 119 carrier, towards aeronautical experience for an ATP rating.

Logging pilot-in-command flight time.

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) Except when logging flight time under § 61.159(c), 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;

(ii) When the pilot is the sole occupant in the aircraft;

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided -

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation -

1)" style="margin-left: 60px;">(1) Preflight preparation;

2)" style="margin-left: 60px;">(2) Preflight procedures;

3)" style="margin-left: 60px;">(3) Takeoff and departure;

4)" style="margin-left: 60px;">(4) In-flight maneuvers;

5)" style="margin-left: 60px;">(5) Instrument procedures;

6)" style="margin-left: 60px;">(6) Landings and approaches to landings;

7)" style="margin-left: 60px;">(7) Normal and abnormal procedures;

8)" style="margin-left: 60px;">(8) Emergency procedures; and

9)" style="margin-left: 60px;">(9) Postflight procedures;

(C) The supervising pilot in command holds -

1)" style="margin-left: 60px;">(1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

2)" style="margin-left: 60px;">(2) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.

(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

(3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

(4) 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.

(5) A commercial pilot or airline transport pilot may log all flight time while acting as pilot in command of an operation in accordance with § 135.99(c) of this chapter if the flight is conducted in accordance with an approved second-in-command professional development program that meets the requirements of § 135.99(c) of this chapter.
 
MauleSkinner said:
Although in the case of the OP, would it really matter whether or not it’s logged PIC?
Click to expand...

Only the OP can determine whether it matters to them or not, but the fact that they are asking implies that it matters.

Insurance forms maybe.
School rental/currency policy maybe. *
Or just for the sake of being correct.

* I seem to remember renting from some school or club where there were increased currency requirements for someone who had less than XXX hours PIC.
 
RussR said:
Only the OP can determine whether it matters to them or not, but the fact that they are asking implies that it matters.

Insurance forms maybe.
School rental/currency policy maybe. *
Or just for the sake of being correct.

* I seem to remember renting from some school or club where there were increased currency requirements for someone who had less than XXX hours PIC.
Click to expand...
True enough, although I would question the use of the word “correct”. “Maximum legal”, maybe, but the reg doesn’t say you MUST log it as PIC, so it wouldn’t be “incorrect” not to.
 
StikRudr said:
I'm just returning to the skies after 12 years. I have a ASEL, high performance endorsement and a glider rating. I've bought and sold a few planes, flown a lot of x-country so now that I'm retired I'm just looking to rent, or maybe find a partner to buy, a Champ, Cub, T-Craft, Fly Baby, etc. and fly strictly as a sport pilot. As such I don't intend to renew my expired 3rd class medical.

I'm working on my BFR and taking some dual in a 7ECA. My instructor believes that because it's over the light sport aircraft max of 1320 lbs and that I don't have a current medical, any dual can't be logged as PIC. Can another CFI verify this?
Click to expand...


You do realize that if you were flying legally 12 years ago, you can go with Basic Med, right? No need to renew your Class 3 or provide any medical info to the FAA. Just an exam by any state-licensed physician and an online training course. Easy peasy.

You can fly LSAs if you want, of course, but even then getting Basic Med would open up options for you.
 
RussR said:
Only the OP can determine whether it matters to them or not, but the fact that they are asking implies that it matters.

Insurance forms maybe.
School rental/currency policy maybe. *
Or just for the sake of being correct.

* I seem to remember renting from some school or club where there were increased currency requirements for someone who had less than XXX hours PIC.
Click to expand...

Thanks for everyone's response. It's not that big of a deal one way or the other, I'm not trying to build time. Actually the question would never had occurred to me if he hadn't written a zero in the PIC column. Initially he thought he wouldn't be able to give me a flight review at all without a medical. He's a super nice guy but I think he's a relatively new CFI.
 
StikRudr said:
Thanks for everyone's response. It's not that big of a deal one way or the other, I'm not trying to build time. Actually the question would never had occurred to me if he hadn't written a zero in the PIC column. Initially he thought he wouldn't be able to give me a flight review at all without a medical. He's a super nice guy but I think he's a relatively new CFI.
Click to expand...
That's a little surprising. Usually it's the older CFIs who don't hang out online who never learned the logging rules. Not necessarily drilled down to this degree but they tend to be covered now in CFI orals.
 
Pinecone said:
...(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) Except when logging flight time under § 61.159(c), 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;...
Click to expand...

Also relevant is this definition from 14 CFR 1.1:

Rating means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.​

Since endorsements are not part of a certificate, that's why you don't have to have endorsements for things like high performance, complex, tailwheel, etc. to log PIC in such aircraft (provided, of course, that someone who does have the appropriate endorsement is acting as PIC during the flight).
 
https://www.ecfr.gov/current/title-14/chapter-I/subchapter-D/part-61#p-61.51(e)
Pinecone said:
In case you were wondering, here is 61.61(e). Appropriate part is bolded. 61.159(c) deals with logging second in command time by a commercial pilot, flying for a Part 119 carrier, towards aeronautical experience for an ATP rating.

Logging pilot-in-command flight time.

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) Except when logging flight time under § 61.159(c), 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;

(ii) When the pilot is the sole occupant in the aircraft;

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided -

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation -

1)" style="margin-left: 60px;">(1) Preflight preparation;

2)" style="margin-left: 60px;">(2) Preflight procedures;

3)" style="margin-left: 60px;">(3) Takeoff and departure;

4)" style="margin-left: 60px;">(4) In-flight maneuvers;

5)" style="margin-left: 60px;">(5) Instrument procedures;

6)" style="margin-left: 60px;">(6) Landings and approaches to landings;

7)" style="margin-left: 60px;">(7) Normal and abnormal procedures;

8)" style="margin-left: 60px;">(8) Emergency procedures; and

9)" style="margin-left: 60px;">(9) Postflight procedures;

(C) The supervising pilot in command holds -

1)" style="margin-left: 60px;">(1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

2)" style="margin-left: 60px;">(2) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.

(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

(3) A certificated flight instructor may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.

(4) 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.

(5) A commercial pilot or airline transport pilot may log all flight time while acting as pilot in command of an operation in accordance with § 135.99(c) of this chapter if the flight is conducted in accordance with an approved second-in-command professional development program that meets the requirements of § 135.99(c) of this chapter.
Click to expand...
FWIW- miskey no doubt, but it's 61.51(e), not 61.61(e) lest anyone try to look this up.
 
The major benefit of logging PIC time would be for insurance requirements. Go basic med and go fly.
 
StikRudr said:
Thanks for everyone's response. It's not that big of a deal one way or the other, I'm not trying to build time. Actually the question would never had occurred to me if he hadn't written a zero in the PIC column. Initially he thought he wouldn't be able to give me a flight review at all without a medical. He's a super nice guy but I think he's a relatively new CFI.
Click to expand...
Show him this thread.
 
Palmpilot said:
Also relevant is this definition from 14 CFR 1.1:

Rating means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.​

Since endorsements are not part of a certificate, that's why you don't have to have endorsements for things like high performance, complex, tailwheel, etc. to log PIC in such aircraft (provided, of course, that someone who does have the appropriate endorsement is acting as PIC during the flight).
Click to expand...
And oddly enough, logging PIC in your friend’s complex or high performance airplane without an endorsement prior to 1997 grandfathers you into not needing an endorsement, even though an endorsement has been required since the 1970s.
 
midlifeflyer said:
That's a little surprising. Usually it's the older CFIs who don't hang out online who never learned the logging rules. Not necessarily drilled down to this degree but they tend to be covered now in CFI orals.
Click to expand...

In this case he's an 'older' gentlemen (like me :) ) who's been instructing, I believe for about a year. He hasn't soloed anyone yet.
 
Twice I have taken off time from flying. Both times, when I returned I did my flight review prior to doing my medical.

Logged both as PIC.
 
Not to beat a dead horse here, but just in case the question comes up. The term, 'sole manipulator of the controls' is used. During our first flight of an hour the instructor took off and made the first landing. So if he wanted to, he could could log my PIC time as .8 rather than 1.0, correct?
 
StikRudr said:
Not to beat a dead horse here, but just in case the question comes up. The term, 'sole manipulator of the controls' is used. During our first flight of an hour the instructor took off and made the first landing. So if he wanted to, he could could log my PIC time as .8 rather than 1.0, correct?
Click to expand...
He would be falsifying your logbook if he logged it all as PIC.
 
MauleSkinner said:
He would be falsifying your logbook if he logged it all as PIC.
Click to expand...

Well, yes, technically, but a common enough, and small enough fiction in instructional flights that I for one am not concerned with.

I certainly don't start a stopwatch every time I take the controls to demonstrate something and then subtract that PIC time from the total flight time for their logbook. Very seldom would it ever total up to more than 0.1 though for a rated pilot. Maybe a tenth or two for a new airplane checkout, tailwheel endorsement, aerobatics training or something like that. I doubt many people subtract that time off the total for the PIC entry.

I never even thought about doing it. Does that make me an unintentional scofflaw?
 
RussR said:
Well, yes, technically, but a common enough, and small enough fiction in instructional flights that I for one am not concerned with.

I certainly don't start a stopwatch every time I take the controls to demonstrate something and then subtract that PIC time from the total flight time for their logbook. Very seldom would it ever total up to more than 0.1 though for a rated pilot. Maybe a tenth or two for a new airplane checkout, tailwheel endorsement, aerobatics training or something like that. I doubt many people subtract that time off the total for the PIC entry.

I never even thought about doing it. Does that make me an unintentional scofflaw?
Click to expand...
Makes you an intentional scofflaw now that you’ve thought about it. ;)

not saying I disagree with you, but the thread is largely about the “letter of the law”.
 
RussR said:
Well, yes, technically, but a common enough, and small enough fiction in instructional flights that I for one am not concerned with.

I certainly don't start a stopwatch every time I take the controls to demonstrate something and then subtract that PIC time from the total flight time for their logbook. Very seldom would it ever total up to more than 0.1 though for a rated pilot. Maybe a tenth or two for a new airplane checkout, tailwheel endorsement, aerobatics training or something like that. I doubt many people subtract that time off the total for the PIC entry.

I never even thought about doing it. Does that make me an unintentional scofflaw?
Click to expand...


What about those times when a student is following the CFI on the controls, or when a CFI is covering a student landing and giving the controls an occasional nudge? Neither is the “sole manipulator” so I guess no one can log PIC.
;)
 
Half Fast said:
What about those times when a student is following the CFI on the controls, or when a CFI is covering a student landing and giving the controls an occasional nudge? Neither is the “sole manipulator” so I guess no one can log PIC.
;)
Click to expand...
Just look at how many pilots of crew airplanes violate the PIC logging reg. I’ve been sole manipulator of the flight controls in a two-pilot jet, but only with a truly incompetent SIC.
 
Half Fast said:
What about those times when a student is following the CFI on the controls, or when a CFI is covering a student landing and giving the controls an occasional nudge? Neither is the “sole manipulator” so I guess no one can log PIC.
;)
Click to expand...
Is the student rated or a pre-PVT student? If he's pre-private, he doesn't log any PIC time when when flying with a CFI.

MauleSkinner said:
Just look at how many pilots of crew airplanes violate the PIC logging reg. I’ve been sole manipulator of the flight controls in a two-pilot jet, but only with a truly incompetent SIC.
Click to expand...
Different part of 61.51. The PIC logs PIC for the time that he is acting as PIC and the SIC logs SIC for the time that he is acting as SIC. Doesn't make any difference who flies the leg.
 
Larry in TN said:
Different part of 61.51. The PIC logs PIC for the time that he is acting as PIC and the SIC logs SIC for the time that he is acting as SIC. Doesn't make any difference who flies the leg.
Click to expand...
Maybe in he airline world, but far from universal otherwise.
 
Half Fast said:
What about those times when a student is following the CFI on the controls, or when a CFI is covering a student landing and giving the controls an occasional nudge? Neither is the “sole manipulator” so I guess no one can log PIC.
;)
Click to expand...
The instructor can.

If the student is a student pilot, can't log it even if sole manipulator.

how come? Read the rules. They tell you in fairly simple language.
 
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Larry in TN said:
Different part of 61.51. The PIC logs PIC for the time that he is acting as PIC and the SIC logs SIC for the time that he is acting as SIC. Doesn't make any difference who flies the leg.
Click to expand...

If the airplane or operation requires two crewmembers, the SIC can log PIC if he/she is the pilot flying, as long as the SIC is PIC type-rated (if applicable) in the airplane.

The Counsil interpretation specifically asked about Part 121 flying, but there is nothing in there that wouldn't also pertain to 135 flying or 91 flying, or any similar operation with a two-crew airplane.

https://www.faa.gov/about/office_or...ps/2012/Counsil_2012_Legal_Interpretation.pdf
 
Larry in TN said:
Is the student rated or a pre-PVT student? If he's pre-private, he doesn't log any PIC time when when flying with a CFI.
Click to expand...



Not necessarily true.

When I was training for my PP, I already had a SP certificate and I was training in a Tecnam LSA. I was pre-private, but I was eligible to be PIC and logged it that way.
 
midlifeflyer said:
Yeah but the best Chief Counsel logging response is this one.

View attachment 109252
2015 Murphy letter.
Click to expand...

Mark, I'm not sure who your response was to, but if it was to me, then I really wasn't discussing that issue of logging SIC and PIC. Just that the SIC can log PIC if sole manipulator and rated. Given a choice between legitimately logging PIC or logging SIC for the same flight, I'm pretty sure most people would choose to log PIC.

Now, the 2015 Murphy letter is interesting in that it doesn't actually prohibit logging both simultaneously. It almost says that but then throws in a weird last sentence. The regulations if read in isolation do pretty clearly allow you to log both at the same time (as Murphy asks), why someone would do that I have no idea, but it does allow it. The 2015 letter only says that you can't "double log" it in a way that would misrepresent your total time - that last sentence. But if you log 1.0 PIC, 1.0 SIC and 1.0 total, that's weird but doesn't necessarily misrepresent your time - you said right there that your total time was 1.0. I also think it's dumb, though, because then maybe you end up with 10,000 total hours, including 9000 PIC and 9000 SIC, which is just dumb.
 
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Half Fast said:
What about those times when a student is following the CFI on the controls, or when a CFI is covering a student landing and giving the controls an occasional nudge? Neither is the “sole manipulator” so I guess no one can log PIC.
;)
Click to expand...

CFI can log all the time acting as an instructor as PIC.

And student pilot cannot log PIC at all. Not rated.
 
RussR said:
Mark, I'm not sure who your response was to, but if it was to me, then I really wasn't discussing that issue of logging SIC and PIC. Just that the SIC can log PIC if sole manipulator and rated. Given a choice between legitimately logging PIC or logging SIC for the same flight, I'm pretty sure most people would choose to log PIC.

Now, the 2015 Murphy letter is interesting in that it doesn't actually prohibit logging both simultaneously. It almost says that but then throws in a weird last sentence. The regulations if read in isolation do pretty clearly allow you to log both at the same time (as Murphy asks), why someone would do that I have no idea, but it does allow it. The 2015 letter only says that you can't "double log" it in a way that would misrepresent your total time - that last sentence. But if you log 1.0 PIC, 1.0 SIC and 1.0 total, that's weird but doesn't necessarily misrepresent your time - you said right there that your total time was 1.0. I also think it's dumb, though, because then maybe you end up with 10,000 total hours, including 9000 PIC and 9000 SIC, which is just dumb.
Click to expand...
I responded to your post because you were talking about both PIC and SIC. Just triggered my memory of one of the sillier Chief Counsel Q&As.
 
Half Fast said:
Not necessarily true.

When I was training for my PP, I already had a SP certificate and I was training in a Tecnam LSA. I was pre-private, but I was eligible to be PIC and logged it that way.
Click to expand...
He was probably thinking "student pilot" when he said "pre-PVT." If you already have a Sport or Recreational Pilot certificate, you fit in the "sole manipulator" box if flying an aircraft you are rated or have sport pilot privileges for. You are not a "student pilot."
 
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