Really? That's easy. Many people have an understandably difficult time with abstract concepts. In this case, the the term "pilot in command" is referring to two completely different and independent things, one of which has absolutely nothing to do with being "in command." If the FAA had used the term "flugbap" instead of logged PIC,
61.51(e) Logging
flugbap flight time.
(1) A sport, recreational, private, commercial, or airline transport pilot may log
flugbap 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;
61.65(d) Aeronautical experience for the instrument-airplane rating. A person who applies for an instrument-airplane rating must have logged:
(1) Except as provided in paragraph (g) of this section, 50 hours of cross-country flight time as flugbap, of which 10 hours must have been in an airplane; and
the issue probably wouldn't exist.
Still confused. I see nothing there that says you cant log PIC time for actual IMC or even SIM IMC while on (or not on) your IFR XC. I think the issue is more with the use of the term rating than PIC.
61.65(d) merely spells out that you need 50 hours of which 10 needs to be in an airplane.
61.51(e) however states that your "rating is appropriate" in which case I can see the argument that you aren't "rated" for IFR so you cant log your IFR XC as PIC but the key to that terminology is "class rated." An instrument "rating" is not a "class rating."
Private pilots wander in to IMC conditions all the time accidentally, by themselves with no one rated for that operation... If they manage to get themselves out of the situation without getting themselves killed and the FAA doesn't violate their certificate (the weather is predictably unpredictable at times) for operating outside of their rating, they are entitled to log that time as PIC & IMC.
This also answers why your PPL XC with instructor doesn't count because you aren't rated for the class of aircraft. Using your solo time is somewhat nebulous because though you aren't fully rated, there is no one else in the plane to assume responsibility and you're responsible for the operation (though Im sure some lawyer could and would make a civil case attaching liability to your CFI but I digress).
In addition, technically when you are signed off for solo you are signed off for a restricted "student pilot's license" and thus are "rated" for operation of the class of aircraft so your Pre-PPL solo XC(s) count but your Pre-PPL dual XCs do not. Sort of like the "restricted" or "junior" driver's licenses many states issue now for drivers between 16 and 18 that require they be off the road between certain hours among other potential restrictions.
I think this is a large part of why the FAA is making changes to the student pilot license. It's no longer just get a medical, get medical and endorsement in log book signed by instructor, go fly solo. The FAA now processes student license requests.
Frankly, I the FAA needs to overhaul the terminology used. I hear certificates, ratings and type ratings used interchangeably when they are all different and they're often used semi-interchangeably within the Regs (i.e. the regs say "type rated" or "class rated" or "category rated") and all people see is the "rated for operation." The same goes for their XC, Night and PIC definitions. I shouldnt have to check 14 (hyperbole but not far off; their are at least 3 different regs for night and 3 different regs for xc time plus a multitude of others for PIC definitions and certificate/rating definitions) different regs to determine what counts as night or xc or PIC. If the definition doesn't fit than they need to use more than 1 term or decide which standard they want to follow. There's no reason I should be able to log night flight but then not have my night flight count for night currency.
Perhaps an extreme example but in parts of Alaska, its possible to log night flight but never be able to get night current for the purpose of passengers. While it may be an extreme, it highlights quite clearly the issue with having multiple definitions for a term for regulatory purposes. Multiple definitions of night might work for common usage but not for legalese.
Flying a SEL tailwheel or complex or high perf or aircraft >12,500lb or pressurized cabin/high altitude or et al, doesnt mean I cant log PIC time for that aircraft as my class is SEL and as long as Im with an appropriately type-rated pilot, I can be the sole manipulator and log PIC.
There's nothing stopping me from solo flying a T182 (the turbo version of the C182) or the T182RG (retractable gear) if I have my high-performance rating and in the case of the later my complex as long as I dont try to take it to altitudes where the pressurization system becomes important... And even at mid-level altitudes, it'd be easy to skirt the type rating to a degree (though uncomfortable) by flying the plane unpressurized with supplemental oxygen.
Similarly, I can fly a amphib plane solo all day long as long as I limit myself to land based landings as that is what my rating permits. A C182 with floats is slower and more difficult to handle on account of the additional drag of the floats but landing it on land is ultimately not any different from a similar aircraft...
For that matter, I can replace my landing gear or floats with Ski's... Last time I checked there is no endorsement, type, class or category rating for Ski based landing gear.
At the end of the day, an instrument rating and a commercial rating are more stringent type ratings for which the requirements are specifically spelled out and you need to "retake the driver's test" to a higher standard where as a High-Perf or other type endorsement just requires you receive training and be deemed proficient by a rated instructor. A SEL vs SES or MEL/MES on the other hand are like private automobile vs private motorcyle, the rules of the road are the same but you aren't "retaking the test" because the tests are testing a completely different driving methodology.
Interesting discussion guys. Thanks! I'll research and talk to my CFII's and am seeing the DPE soon (CPL ride coming up).
It's only ~2.7 in actual so far, but I may as well take credit
.
50 hours is what you need for most of your ratings and certificates. If you plan on going for your ATP then you need 500 hours but at that point, I wouldn't stress over 2.7 hours; 3 hours is only 0.6% of your total XC time at that point and really is losing those 3 hours really going to make a difference? Yeah you have to go put 3 more ours in a plane but in the grand scheme of things you've already put 1500 hours and 497 hours XC in the plane what's 3 hours? Especially since the ATP requirement is easier to obtain since XC time is logged any time your route takes you greater than 50NM straightline distance; per the regs, you dont need to land 50NM away which suddenly makes flying really long STAR's look appealing.
