Originally Posted by
TimetoClimb
Hey Guys, currently at 750 hours right now, flying the pilatus from the right seat as a qualified FO in 135 ops.
I've heard so many damn conflicting opinions on this, done searches to kalamazoo and read FAA letters of interpretation and I just wanna make I've got my ducks in a row when i hit 1500 hrs.
So for the last time. 61.51 clearly says you log PIC when you are rated and the sole manipulator, plain and simple.
The ATP requirement in 61.59 for 250 hrs of PIC (also the XC PIC) should be met by this operating experience then!? I cannot for the life of me understand why people would say It doesn't, when the FAA clearly says you can 'log PIC' even when you're not 'acting as PIC'. Why is everyone hung up on this, thinking they're using 'common sense' "bro, you can't log pic if you're not the captain or solo" .
Can someone in a 121 training department chime in? Am i gonna get water splashed on my face that i need to go get 'true' PIC time if between 250-1500 hours I was a 135 FO and half the time I was hand flying the freakin' aircraft?
In other words, can someone help me find my 'smoking gun' reg interpretation that it's well within the definition and intent of the ATP requirements?
It boggles the mind that people can be a professional in the industry and still not understand the regulation. It really is dirt simple
Yes: if you're sole manipulator, you may log PIC.
Yes: if you log PIC while not the acting PIC, it may be met with distain or disapproval at both Part 121 and 135 operations, as well as many Part 91 operations.
Yes: your sole manipulator time at the controls of an aircraft for which you are rated may be logged as pilot in command time, and used toward the requirements of a certificate or rating that requires pilot in command time.
Yes: "rated" means category and class (and where appropriate, type). In your case, Airplane category, single engine land class. If you hold this as a category/class rating on your pilot certificate, and you're sole manipulator, you can log it as PIC.
Having said this: if you're not qualified as PIC in the aircraft and are not PIC under Part 135, other employers may view your decision to log PIC in the aircraft as a negative.
A regional may not care; if you're a warm body and meet the minimums, and don't have orange antennas growing out of your head, you'll probably get hired. By the time you've buried your past experience under a logbook or two, nobody will notice or care what you did in the first few hours of your career.
There's no "smoking gun." Read the damn regulation. It's quite clear.