PDPIC and simulated (or actual) instrument - okay?

[RussR]

I am training a multi-engine Commercial applicant. This is his initial Commercial certificate, which means he must meet the experience requirements of 61.129b, including the 10 hours of solo or PDPIC* time. For the typical reasons, I will be the "ballast CFI" as he does his PDPIC time.

During his 10 hours of PDPIC time, he would certainly benefit from flying some instrument approaches.

Question 1 - if it's simulated IFR, I am required to be there as a Safety Pilot, and am no longer truly a "ballast CFI". I have to imagine this is okay, because 10 hours of PDPIC is being flown in multiengine training all the time, and those people have to be practicing at least some approaches I would think.

Question 2 - if we get a good day of actual IMC, can we go fly and count it towards the PDPIC time? I think so. He cannot act as PIC under IFR since he isn't rated, but that's okay because he's doing PDPIC anyway, and I am the PIC.

So I think both of these scenarios are okay, but it took typing this up for me to work through it. And now that I've typed it up, I'm not going to just delete it.

I would appreciate hearing any comments on this. I did search the FAA interpretations to no avail.

* = Performing Duties as PIC, i.e. with a "ballast CFI" who isn't supposed to teach or help, riding along for insurance purposes. I understand "ballast CFI" isn't an official term, but it does seem to represent the intent of the PDPIC rules.

 

[midlifeflyer]

Question 1. Obviously not authoritative but I'd say no, Russ. PDPIC is an insurance-driven substitute for solo flight. I actually use the terms "solo substitute" or "pretend solo" instead of PDPIC to constantly remind me this was designed and intended as an insurance-driven accommodation for solo requirements. . The instructor being merely "ballast" as you put it, maybe "cargo" is a better term, is a requirement. It's what keeps it a "solo" flight. We can go crazy and say that even conversation changes the dynamic but that's obviously ridiculous and probably humanly impossible. OTOH, once the instructor takes on an official role as an instructor or required crewmember, we are no longer even dealing with a "pretend solo" flight.

Question 2 is interesting. The ballast is there specifically to act as PIC. I haven't looked at the related solo question, but the answer to that is my answer to this: Would the pilot be able to fly IFR is this was a solo with a 61.31 solo endorsement?

 

[flyingron]

My reading sort of is in line with Mark's. The student needs to meet the general solo requirements, if he wants to count it to those ten hours. The CFI dummy is only there to cover the fact that people won't rent such planes to solo students, not to provide for some deficiency that the student has (if he has such, he needs more dual or whatever).

 

[Ryan F.]

Question 1 - if it's simulated IFR, I am required to be there as a Safety Pilot, and am no longer truly a "ballast CFI". I have to imagine this is okay, because 10 hours of PDPIC is being flown in multiengine training all the time, and those people have to be practicing at least some approaches I would think.

You're certainly wandering into some areas which would require an actual legal interpretation for a definitive answer, but I would feel fairly comfortable saying no. Your student is unable to act as PIC or log PIC in this scenario. You stated that in this scenario you'd act as safety pilot; however, the student is unable to log PIC since he/she is not rated in the class of aircraft being flown. Furthermore "logging" is not "acting as" and PDPIC is about acting as PIC. Therefore in my view it would be impossible for the student to log "PDPIC" as you have abbreviated it.

Question 2 - if we get a good day of actual IMC, can we go fly and count it towards the PDPIC time? I think so. He cannot act as PIC under IFR since he isn't rated, but that's okay because he's doing PDPIC anyway, and I am the PIC.

I would again say no for the same reason stated above. The student is not qualified to act as PIC in this scenario. Your presence is required as an instructor for this activity. In fact, in both of these cases, what you're proposing is completely legal under the cover of dual instruction, but not as "PDPIC."