Logging vs acting PIC - thread #4252

[BrianR]

I know this topic is beat to death here, but it seems the issues surrounding logging vs acting PIC just don't die.

It's well-accepted here, and on all the aviation forums, that when a rated pilot is training for a new endorsement (let's say, high performance or complex, for purposes of this discussion) with a CFI, he/she is entitled to log PIC as long as you're doing the training in the appropriate class/category for which you're rated, and you're the sole manipulator.

But...each and every local CFI with which I've discussed this issue (probably three or four of them) disagree. These are all knowledgeable, intelligent folks, all actively instructing. They all regurgitate some belief that a pilot isn't appropriately "rated" for the airplane if you don't already hold the necessary endorsement.

I again encountered this when recently doing my first Mooney flight for the complex endorsement. After the flight, I filled out my logbook and handed it to the new-to-me CFI for his signature and the comments he wished to enter. "Ummm, you can't log this as PIC." I asked why he thought that was the case. He replied with a version of the above. I told him I disagreed, and referenced 14 CFR 61.51(e)(1)(i). He still argued the point. I said, "So if you are giving instrument instruction to me in a Cessna 172, would you claim that I could not log PIC because I am not yet instrument rated?" He thought about it, and agreed that in that scenario, I could log PIC. So I asked, "What is the difference between the two scenarios?"

He then said he thought it is "...FSDO specific. It is open to interpretation." I said no it isn't, it's in the FARs, black and white. He then asked me if I knew of any general counsel opinions on the topic, which I did not. Are there any, of which anyone is aware? (Yeah, yeah, I could go search...but if it exists, someone here will know.)

To my thinking, it doesn't rise to the level of needing a general counsel interpretation, because it's clear as written. If this was one rogue CFI, i wouldn't waste my time, but as I noted, it is an extremely common perception, at least in my neck of the woods.

Of course, it's not that big of a deal, because even if I can't convince him he's wrong, I'll just go back and add in the PIC time after I finish the endorsement training. But now it's irritating me, and I have a point to prove...

 

[poadeleted20]

It's well-accepted here, and on all the aviation forums, that when a rated pilot is training for a new endorsement (let's say, high performance or complex, for purposes of this discussion) with a CFI, he/she is entitled to log PIC as long as you're doing the training in the appropriate class/category for which you're rated, and you're the sole manipulator.

It's also well-accepted by the FAA Chief Counsel, which is the most important consideration.

But...each and every local CFI with which I've discussed this issue (probably three or four of them) disagree. These are all knowledgeable, intelligent folks, all actively instructing. They all regurgitate some belief that a pilot isn't appropriately "rated" for the airplane if you don't already hold the necessary endorsement.

Then have them ask the FAA Chief Counsel for a copy of Legal Interpretation # 92-60 dated July 30, 1992, which says "'Rated', as used under section 61.51(c)(2)(i) [now renumbered as section 61.51(e)(1)(i)], refers to the category, class, and type as appropriate."

He then said he thought it is "...FSDO specific. It is open to interpretation."

He is partly correct. It is open to interpretation, but by FAA Administrator edict, not by anyone in the FAA except the FAA Chief Counsel, and that interpretation has already been given in writing by that office.

I said no it isn't, it's in the FARs, black and white. He then asked me if I knew of any general counsel opinions on the topic, which I did not. Are there any, of which anyone is aware? (Yeah, yeah, I could go search...but if it exists, someone here will know.)

See above. It's echoed in many other Chief Counsel interpretations dating back over 30 years.

 

[nosehair]

To my thinking, it doesn't rise to the level of needing a general counsel interpretation, because it's clear as written. If this was one rogue CFI, i wouldn't waste my time, but as I noted, it is an extremely common perception, at least in my neck of the woods.

Of course, it's not that big of a deal, because even if I can't convince him he's wrong, I'll just go back and add in the PIC time after I finish the endorsement training. But now it's irritating me, and I have a point to prove...

So,..let me throw in my 2 cents on the subject.
Seems to me, the main disagreement, or mis-understanding, or area of mis-interpretation, is the intended definition of "sole manipulator" is.
That isn't addressed in the legal counsel's interpretation.
Is it just holding the yoke with no idea of what to do without directions, or does it mean that the yoke holder would, or should, be able to manipulate the controls effectively during the normal conditions that the certificate holder with the appropriate rating would encounter.

In other words, when the new instrument student, or new complex airplane student starts out, he/she might crash or cause harm at first until they get the hang of it, while the instructor is coaching, but not directly making control inputs, or maybe helping a little with rudder here or there, or even tuning up for an approach, etc.

Where is the "sole manipulator" line?

I always thought it was up to the instructor to make that determination during the initial training, so that the logging of PIC was when the student had, in fact, become capable of acting as "Solo". Not necessarily an endorsement, which would carry the weight of acting as a Private or Commercial Pilot for the full endorsement.

But, since the term "sole manipulator" has been used to mean simply having your hands (or hand) on the controls, or your finger to turn on the auto-pilot, it is used to define "sole manipulator" by people on the forums, and most anyone who is trying to "build time".

So, the sticking point is, when do you become the sole manipulator?

 

[Henning]

Unless I was getting paid to educate the guy instead of the other way around, I'd just wait till it was all done and then fill in the PIC column, it's your logbook.

 

[jesse]

It's one of the most common errors I see looking through people's logbooks. Other instructors constantly screw that up. I do not

 

[poadeleted20]

So,..let me throw in my 2 cents on the subject.
Seems to me, the main disagreement, or mis-understanding, or area of mis-interpretation, is the intended definition of "sole manipulator" is.

The issue is the term "rated," which his instructor wrongly believes includes the additional training endorsements required by 61.31 to act as PIC in some aircraft, but which in fact are not required to log PIC time under 61.51(e)(1)(i).

 

[JeffDG]

If the instructor can read this:
http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Herman.pdf

Although these endorsements are required before a pilot may act as a PIC of a high-performance and/or complex airplane, they are not required to log PIC time if the pilot is rated for and is the sole manipulator of the controls of the aircraft.

and still maintain that the student (with a PP certificate) seeking HP or Complex endorsement cannot log PIC time, then the instructor has some serious comprehension issues.

 

[nosehair]

The issue is the term "rated," which his instructor wrongly believes includes the additional training endorsements required by 61.31 to act as PIC in some aircraft, but which in fact are not required to log PIC time under 61.51(e)(1)(i).

That is probably the most common error in reading the reg, but then after the term "rated" is defined in the Chief counsel's definition, the concept of "sole manipulator" remains up for argument.

 

[Everskyward]

I'll bet if you took a poll of CFIs, more would interpret it wrong than right.

 

[TMetzinger]

That is probably the most common error in reading the reg, but then after the term "rated" is defined in the Chief counsel's definition, the concept of "sole manipulator" remains up for argument.

Not really. Particularly when doing training for "endorsements", a CFI doesn't need to take the controls. The rated pilot knows how to fly an airplane already. The one exception to this is probably the takeoff and landing phase of a tailwheel transition, but even then, the pilot under instruction is doing most of the flying, and the CFI can log all of it as PIC anyway.

I think that a lot of pilots and instructors feel that if you cant be ACTING as the PIC that it's somehow "cheating" to LOG the time as PIC. I can even sympathize with that view, a little.

But I can also read the regs, AND the legal interpretation of them from the FAA counsel, and as a result I log my time and teach my students to log their time in accordance with that guidance.

 

[Everskyward]

I think that a lot of pilots and instructors feel that if you cant be ACTING as the PIC that it's somehow "cheating" to LOG the time as PIC.

You'll see this especially in airplanes which require two pilots and it comes down to the question of what the SIC logs when he or she is flying. There's often heated commentary on both sides.

 

[Ted]

I'll bet if you took a poll of CFIs, more would interpret it wrong than right.

I'd bet you're right.

 

[Henning]

That is probably the most common error in reading the reg, but then after the term "rated" is defined in the Chief counsel's definition, the concept of "sole manipulator" remains up for argument.

To me 'sole manipulator' means a person who is physically flying the aircraft without requiring correction or instruction.

 

[BrianR]

If the instructor can read this:
http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Herman.pdf

and still maintain that the student (with a PP certificate) seeking HP or Complex endorsement cannot log PIC time, then the instructor has some serious comprehension issues.

Herman...that's it! Knew I'd read that somewhere. Thanks!

 

[BrianR]

Then have them ask the FAA Chief Counsel for a copy of Legal Interpretation # 92-60 dated July 30, 1992, which says "'Rated', as used under section 61.51(c)(2)(i) [now renumbered as section 61.51(e)(1)(i)], refers to the category, class, and type as appropriate."

Thanks Ron.

 

[BrianR]

Unless I was getting paid to educate the guy instead of the other way around, I'd just wait till it was all done and then fill in the PIC column, it's your logbook.

Yeah, but sometimes I can't help myself if they need educating...

 

[poadeleted20]

That is probably the most common error in reading the reg, but then after the term "rated" is defined in the Chief counsel's definition, the concept of "sole manipulator" remains up for argument.

I've never heard that one argued other than some folks being a little uncertain about whether pushing the buttons on the autopilot counts (and it does).

 

[poadeleted20]

You'll see this especially in airplanes which require two pilots and it comes down to the question of what the SIC logs when he or she is flying. There's often heated commentary on both sides.

There shouldn't be, as the Chief Counsel has discussed that one already. See Carpenter.

 

[poadeleted20]

To me 'sole manipulator' means a person who is physically flying the aircraft without requiring correction or instruction.

The Chief Counsel does not share your idea. Hands on controls -- that's it.

 

[Everskyward]

There shouldn't be, as the Chief Counsel has discussed that one already. See Carpenter.

Most of the argument is not about the legality but about the morality, or some such thing...

 

[poadeleted20]

Most of the argument is not about the legality but about the morality, or some such thing...

You can't legislate morality, or something like that. Whatever. If we wanted to do the "right thing," we'd all get refresher training more than every two years, but I don't see anyone claiming on moral grounds that one cannot act as PIC without having had a flight review more recently than the preceding 24th calendar month.

 

[Everskyward]

You can't legislate morality, or something like that. Whatever. If we wanted to do the "right thing," we'd all get refresher training more than every two years, but I don't see anyone claiming on moral grounds that one cannot act as PIC without having had a flight review more recently than the preceding 24th calendar month.

But I have seen people say that the SIC shouldn't log PIC time because they did not have the PIC authority. As Tim says, some see this as "cheating". I don't agree with them but the idea is out there.

 

[roddie]

I said, "So if you are giving instrument instruction to me in a Cessna 172, would you claim that I could not log PIC because I am not yet instrument rated?" He thought about it, and agreed that in that scenario, I could log PIC.

I learn something new every time I read one of these PIC threads --

I haven't started my Instrument training yet; I'm aiming for mid-13 for that. So, we're saying that for the duration of my Instrument training, I should be logging PIC time? What does the CFII log? We need some kind of matrix of scenarios that specifies what each person in the plane can log. The flow-chart is ok, but it doesn't really cover the scenarios cleanly (at least not to a new pilot), and the grey-area to me comes in when someone says "If you are acting as PIC, you log PIC time." I'd be happy to make one up.

A couple of weeks ago my CFI took me out in the C172 for a "checkout" (club/insurance rule), and he wrote in my book that it was DUAL received. I assume from what I've been reading, that I could legitimately log that flight as PIC? What would he log?

 

[poadeleted20]

So, we're saying that for the duration of my Instrument training, I should be logging PIC time?

Yes, assuming you're doing it in an aircraft for which you are rated, not, say, combining your IR training with a Multiengine add-on. And, of course, since you are receiving training from an authorized instructor, also "training received."

What does the CFII log?

PIC time, as well as "training given."

We need some kind of matrix of scenarios that specifies what each person in the plane can log. The flow-chart is ok, but it doesn't really cover the scenarios cleanly (at least not to a new pilot), and the grey-area to me comes in when someone says "If you are acting as PIC, you log PIC time." I'd be happy to make one up.

Let us get this one understood -- merely acting as PIC is not, in and of itself, license to log PIC time. Other conditions must attach before the PIC can log PIC time. And yes, I know that sounds nuts, but that is the way the regs are.

A couple of weeks ago my CFI took me out in the C172 for a "checkout" (club/insurance rule), and he wrote in my book that it was DUAL received. I assume from what I've been reading, that I could legitimately log that flight as PIC? What would he log?

You can legitimately log it as both training received and OIC time. The instructor can legitimately log it as training given and PIC time.

Read 61.51(e) carefully for the details on all this.

 

[roddie]

Thanks for the reply, Ron --

PIC time, as well as "training given."

This is where in my mind I wonder how the CFI can log PIC when he probably only has the controls for a few seconds while I put the hood on or take it off.

Let us get this one understood -- merely acting as PIC is not, in and of itself, license to log PIC time. Other conditions must attach before the PIC can log PIC time. And yes, I know that sounds nuts, but that is the way the regs are.

Right -- And that's why that answer has never sat well with me (I believe the flow-chart gets a bit ambiguous this way).

Thanks again!

 

[JeffDG]

Thanks for the reply, Ron --



This is where in my mind I wonder how the CFI can log PIC when he probably only has the controls for a few seconds while I put the hood on or take it off.

Because there is more than one section that allows you to log PIC time.

You can log PIC time if you are rated in the aircraft and you are either:

1) The sole manipulator of the controls
2) Acting as PIC and a required crew-member per FAA regs (like a safety pilot with a hooded pilot flying, an aircraft type certificated for two crewmembers, or a 135/121 operation with an Opspec requiring multiple pilots)
3) An appropriately rated instructor (CFI/CFII) giving instruction

There's an "OR" between those. The pilot flying logs based on 1, the CFII logs based on 3.

 

[poadeleted20]

This is where in my mind I wonder how the CFI can log PIC when he probably only has the controls for a few seconds while I put the hood on or take it off.

Jeff's given you the regulatory answer on that. As for the morality of it, I'll leave that to others, but it is most definitely legal. In fact, one can construct scenarios in which three or more people can be legally logging PIC time simultaneously, even though only one of them actually is the PIC.

Right -- And that's why that answer has never sat well with me (I believe the flow-chart gets a bit ambiguous this way).

Yes, the FAA really did a dumb thing in this matter by having one set of rules about being the PIC and the qualifications to be the PIC, and another, separate rule about logging something called "PIC time" which the PIC may in some cases not be allowed to log, and in some cases someone who is not PIC may be allowed to log. But considering this is the same agency which gave us three different definitions of "night" and seven different definitions of "cross-country flight time," it shouldn't surprise anyone that they'd boggle the "PIC" business so badly.

Thanks again!

Any time.

 

[JimNtexas]

I can't add anything to the Part 61 discussion here, but I always like to remind pilots about the official definition of 'Pilot in Command' contained FAR 1:

"Pilot-in-command means the
person who:
1. Has the final authority and
responsibility for the operation
and safety of the flight;
2. Has been designated as pilot-incommand before or during the
flight; and
3. Holds the appropriate category,
class, and type rating, if
appropriate, for the conduct of the
flight."

The best article I've seen on this subject is by Al German on the FAA website. Note his discussion of FAR 91.3.

I also strongly suggest that any pilot contemplating the possibility of applying for work as a professional pilot log the time that he or she is the 'real' PIC as defined in part 1 separately from the other flavors of PIC logging allowed by part 61.

The FAA might accept that 3 pilots can all log PIC time in a C-172 (co-pilot sole manipulation of the controls under the hood, FAR 1 PIC/safety pilot, and CFI in the back seat instructing).

A lot of commercial organizations consider that practice to be borderline fraud, and want applicants to claim as PIC time only that which fits in the Part 1 definition.

 

[poadeleted20]

I can't add anything to the Part 61 discussion here, but I always like to remind pilots about the official definition of 'Pilot in Command' contained FAR 1:



The best article I've seen on this subject is by Al German on the FAA website. Note his discussion of FAR 91.3.

I also strongly suggest that any pilot contemplating the possibility of applying for work as a professional pilot log the time that he or she is the 'real' PIC as defined in part 1 separately from the other flavors of PIC logging allowed by part 61.

The FAA might accept that 3 pilots can all log PIC time in a C-172 (co-pilot sole manipulation of the controls under the hood, FAR 1 PIC/safety pilot, and CFI in the back seat instructing).

A lot of commercial organizations consider that practice to be borderline fraud, and want applicants to claim as PIC time only that which fits in the Part 1 definition.

Fraud? Really? Following the FAA's regulations precisely is fraud?

If you fill out an airline application, do so the way they want -- put whatever time they say to put in whatever block of their applicatino they say to put it. But don't think for a minute that an airline will refuse to hire you because you handed them a totally FAA-compliant logbook to support that application.

And yes, when I was with the university's aviation program, we talked with airline hiring personnel a lot.

 

[Henning]

I've never heard that one argued other than some folks being a little uncertain about whether pushing the buttons on the autopilot counts (and it does).

If they are making the decision to push the buttons for operational safety of flight reasons at their own authority that would count as sole manipulator.

 

[midlifeflyer]

He then asked me if I knew of any general counsel opinions on the topic, which I did not. Are there any, of which anyone is aware?

Yes, going back at least 30 years.

Oldest that I have (I understand there is at least one older):

==============================
OCT. 28, 1980

WINSTON SCOTT JONES

Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61.

Section 61.51(c)(2)(i) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or

2. Is the sole occupant of the aircraft; or

3. Acts as pilot-in-command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted.

Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received.

Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(i) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).

There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.

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.

Sincerely,

EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division
==============================

Newest: http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Herman.pdf

 

[midlifeflyer]

Fraud? Really? Following the FAA's regulations precisely is fraud?

I guess the theory is that refusing to follow rules you don't like is a good thing. Personally, the place that concept leads to has always frightened me.

OTOH, if the application asks for PIC time and the instructions say that they only want "acting PIC" time or any other definition that they provide, it would of course be fraud to intentionally add other types of time into the application totals.

 

[denverpilot]

I'm always surprised that folks say that one should not have a Safety Pilot log the exact same number of hours exactly as the PIC during Simulated Instrument flight, because there's a little time during takeoff and landing that the PIC isn't under the hood...

But there's no similar scrutiny of a CFI saying "my aircraft" and demonstrating a maneuver to a student, where the student or rated pilot being taught isn't manipulating the controls for a small but significant period of time on most early flights, lessening as they gain ability.

Weird double standard.

 

[TMetzinger]

Not really. "Sole Manipulator" applies to PIC time... which doesn't apply for student pilots getting instruction. The student logs the flight time and the flight training received, but not PIC.

 

[Henning]

I'm always surprised that folks say that one should not have a Safety Pilot log the exact same number of hours exactly as the PIC during Simulated Instrument flight, because there's a little time during takeoff and landing that the PIC isn't under the hood...

But there's no similar scrutiny of a CFI saying "my aircraft" and demonstrating a maneuver to a student, where the student or rated pilot being taught isn't manipulating the controls for a small but significant period of time on most early flights, lessening as they gain ability.

Weird double standard.

On early flights, pre solo, the student isn't logging PIC either, at least nobody I'm aware of, in fact IIRC only PIC pre PP checkride was solo. The ride was the first time as PIC with a second person in the plane. There is record of guys getting caught out by using identical times.

 

[JimNtexas]

Fraud? Really? Following the FAA's regulations precisely is fraud?

If you fill out an airline application, do so the way they want -- put whatever time they say to put in whatever block of their applicatino they say to put it. But don't think for a minute that an airline will refuse to hire you because you handed them a totally FAA-compliant logbook to support that application.

And yes, when I was with the university's aviation program, we talked with airline hiring personnel a lot.

I didn't say it was fraud to include non-FAR 1 PIC time as 'PIC time on a job application , I said it is considered deceptive by many professional pilots to include non-FAR1 PIC time on any application that asks for 'PIC Time'. And that's true. The interviewer isn't going to call the cops, but he might well trash the application. Many, but not all, pilot application forms specify that they consider PIC to be only FAR-1 PIC time.

It's important for any pilot contenplating working as professional pilot to know the difference between what many call 'real, signed for airplane PIC' and 'sole-manipulator type PIC logging'.

Mix the two up in your logbook at your peril.

If the pilot has been logging FAR-1 PIC separately from his or her non FAR-1 'PIC' time then there won't be a problem. He or she can use both flavors of PIC time for FAA purposes, and when applying for a job can easily provide only the 'real' (FAR-1) PIC time to the potential employer.

I'm sure your university program logged time FAR1 and non-FAR1 PIC separately, but not every pilot knows to do that.

You and I may have legally logged F-111 'PIC Sole manipulation' time while we were Navs with FAA multi-engine ratings in the Air Force. There is no type rating for an F-111, and the bomber models all had full dual controls (except for wing sweep), and the regs allowed us to manipulate the controls.

We can I think use this time for some FAA logging purposes.

I really think it would be a bad idea to include our F-111 sole manipulator time in the PIC column of our logbooks in an application to Delta.

 

[poadeleted20]

I didn't say it was fraud to include non-FAR 1 PIC time as 'PIC time on a job application , I said it is considered deceptive by many professional pilots to include non-FAR1 PIC time on any application that asks for 'PIC Time'.

The question was logging the time in your FAA pilot logbook, and your exact words were:

I also strongly suggest that any pilot contemplating the possibility of applying for work as a professional pilot log the time that he or she is the 'real' PIC as defined in part 1 separately from the other flavors of PIC logging allowed by part 61.

The FAA might accept that 3 pilots can all log PIC time in a C-172 (co-pilot sole manipulation of the controls under the hood, FAR 1 PIC/safety pilot, and CFI in the back seat instructing).

A lot of commercial organizations consider that practice to be borderline fraud, and want applicants to claim as PIC time only that which fits in the Part 1 definition.

I say again -- I do not believe that any commercial airline will consider it "fraud" (borderline or otherwise) if you log PIC and SIC time IAW 61.51 as long as you fill out their application IAW their instructions, and it sounds like you've changed what you said to match that. So, it sounds like we're now on the same page.

And yes, I do have F-111 PIC time in my log book based on the 61.51(e)(1)(i), having been "rated" as the FAA defines it when I was flying that jet. However, at age 61, I'm not going to be applying for a job with any Part 121 operators. But if for some reason I did, I'd put the time they wanted on their application, while presenting with a clear conscience my logbook including that F-111 time. If they were such bozos that they considered that logbook to be "borderline fraud" on that basis, I wouldn't want to work for them anyway, and I sure wouldn't be worried about the reporting me to the FAA -- the FAA already inspected my log with that time in it a long time ago when I was getting my ATP, and they didn't say a word about it.

 

[HPNPilot1200]

I had this discussion with a CFI when I was a student. I wrote the chief council and they confirmed my understanding...

http://www.faa.gov/about/office_org.../interpretations/data/interps/2009/Herman.pdf

 

[JimNtexas]

The question was logging the time in your FAA pilot logbook, and your exact words were:

I say again -- I do not believe that any commercial airline will consider it "fraud" (borderline or otherwise) if you log PIC and SIC time IAW 61.51 as long as you fill out their application IAW their instructions, and it sounds like you've changed what you said to match that. So, it sounds like we're now on the same page.

If you are recommending that pilots log FAR 1 time separately from the 'logable' part 61 PIC time that doesn't fall under FAR 1, then yes, you've joined me on the same page. I brought up FAR 1 because nobody else in this thread had.

If you don't want to believe non-FAR 1 'PIC' time has a really bad smell to a lot of professional pilots, then that's fine.

 

[denverpilot]

Not really. "Sole Manipulator" applies to PIC time... which doesn't apply for student pilots getting instruction. The student logs the flight time and the flight training received, but not PIC.

You guys both missed my "or rated pilot" though. You're correct on a true pre-solo Student pilot.

Commercial rating instruction, may be a good example. If the CFI takes the controls to demonstrate a Chandelle or Lazy Eight, shouldn't the PIC time logged by the "student" be a couple tenths less than the CFI for the flight? Two pilots are not required when the CFI is demonstrating (unlike when a "student" is under the hood working on an IR).

Lots of people make a big deal about this for an Instrument pilot using a Safety Pilot for currency, with one agreed to act as PIC and the other required due to the view limiting device, but every logbook I've seen (granted not many) of a Commercial candidate and their CFI -- match minute for minute the PIC time to the tenth, during the hours leading up to the Commercial rating.

Same thing if an IR "student" is flying under real IMC with their instructor who filed for them. Instructor has the controls, "student" has to stop logging for those minutes, technically... there's only one PIC needed at that point.

I know it's not a lot of time, typically, but it's at least as much time as that VFR to "hooded" transition for a Pilot and Safety Pilot combo that even DPEs make a big deal about not having the same numbers written in the logbook.