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Old 06-17-2009, 08:14 PM   #1  
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Default High alt. endors to log Dual+PIC in King Air?

Spoke with a DPE recently about this interesting issue. An Inspector told him that a High Altitude endorsement was necessary to log PIC in a King Air even while receiving Dual. Recently I came across some King Air time and according to this all I could log is dual with no PIC even though I have the other necessary qualifications. I'm curious on what everyone has to say about this and any other implications of both pilots logging PIC. Ok, not ok, etc?
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Old 06-19-2009, 10:58 AM   #2  
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I think you would need the endorsement to log PIC. I don't have the FAR's handy, but the high -alt endorsement is certainly required to act as PIC.

There may be some gray area about logging (not acting) PIC in an airplane for which you have category and class ratings, but lack an endorsement.

But I would err on the side of caution...employers might take a more literal interpretation, and an interview is the last place where you want to debate regulatory technicalities.
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Old 06-19-2009, 12:09 PM   #3  
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Originally Posted by rickair7777 View Post
There may be some gray area about logging (not acting) PIC in an airplane for which you have category and class ratings, but lack an endorsement.
There is no gray area about this at all. It's been clear as a bell for years.

While you may need the endorsement in order to log PIC, this endorsement is just like any other when it comes to logging PIC as sole manipulator under 61.51(e)(1)(i) - at least a recreational certificate with the appropriate category and class (and type if applicable) ratings. No other requirements. None. Zip.

Of course that's only the FAA. If you maintain your logbook for a bunch of employers who make up their own rules rather than follow the FAA's, you're on your own.
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Old 06-27-2009, 11:15 PM   #4  
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Thanks guys. That's kinda what I was figuring. I forgot to mention that the left seat pilot is an MEI. So he could be providing dual toward the high alt endorsement per 61.31(g)(2). Does that change anything? Also, I was thinking considering what we've discussed so far means commercial students can't log PIC in a complex airplane either. Another similar interesting thread here: Logging PIC during complex training - Jetcareers
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Old 06-28-2009, 04:18 PM   #5  
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Originally Posted by nciflyer View Post
Also, I was thinking considering what we've discussed so far means commercial students can't log PIC in a complex airplane either. Another similar interesting thread here: Logging PIC during complex training - Jetcareers
I'm not sure you understood. Rick and I disagree on this. The FAA says you =can= log PIC in a high performance complex pressurized tailwheel without any of those endorsements.
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Old 06-28-2009, 07:22 PM   #6  
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Originally Posted by NoyGonnaDoIt View Post
There is no gray area about this at all. It's been clear as a bell for years.

While you may need the endorsement in order to log PIC, this endorsement is just like any other when it comes to logging PIC as sole manipulator under 61.51(e)(1)(i) - at least a recreational certificate with the appropriate category and class (and type if applicable) ratings. No other requirements. None. Zip.

Of course that's only the FAA. If you maintain your logbook for a bunch of employers who make up their own rules rather than follow the FAA's, you're on your own.
Actually, you need to read your referenced Regulation a little more closely. The exact Reg says;
61.51
e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

I am a little confused on NoyGonnaDoIts response, first you say that

Quote:
Originally Posted by NoyGonnaDoIt View Post
While you may need the endorsement in order to log PIC,
Then you go on to say

Quote:
Originally Posted by NoyGonnaDoIt View Post
The FAA says you =can= log PIC in a high performance complex pressurized tailwheel without any of those endorsements.
Clairfy...



As for my response, you can't have privileges until you have the endorsment, so the answer is NO you cannot log it as PIC until you get the endorsement. Just like you can't log PIC in a complex until you get the endorsement.
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Old 06-29-2009, 05:14 AM   #7  
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Actually, you need to read your referenced Regulation a little more closely. The exact Reg says;
61.51
e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
Actually, you need to read it more closely:
61.51(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges

"Or" not "and." Either ratings "or" privileges; not ratings "and" privileges." "Privileges" was added as part of the sport pilot rule because sport pilots don't have ratings. (Are you suggesting that sport pilots can't ever log PIC since they only have privileges?)

Quote:
Clairfy...
Sure. Here's the "granddaddy" from almost 30 years ago...

Quote:
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
...and here's one from last month:
http://www.faa.gov/about/office_org/...009/Herman.pdf

I did make a mistake of the keyboard that you caught, though. I should have said:

Quote:
While you may need the endorsement in order to act as PIC...
Good catch. Sorry.
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Old 07-02-2009, 10:07 AM   #8  
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Thanks for the answers everyone. Thanks for the FAA letter NoyGonnaDoIt, it really helps make sense of things. I was pondering about the definition and context of "rated" when I read the reg and if it implied endorsement requirements or not. I wish the reg would just come out and say it.
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Old 07-02-2009, 11:54 AM   #9  
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OK, I'm with NoyGonnaDoIt on this one. The FAA legal opinions clarify the meaning of "rated".
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Old 07-02-2009, 04:23 PM   #10  
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Originally Posted by nciflyer View Post
I wish the reg would just come out and say it.
The reg =does= say it. Look at FAR 1.1.

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

The, of course, there's 61.5 which defines the known universe of pilot "ratings." Not a 61.31 endorsement in the lot.

When they start putting "high performance" on your pilot certificate under the heading "ratings" it will be a rating.

OTOH, if you mean they should also repeat the definitions every time they use the word rating in another reg, be careful what you wish for. A lot of folks think the FAR is way too long now. Can you imagine of every time an FAR used a defined term, it included the definition? :eek:

But you're not alone alone in the confusion. "Logging PIC has nothing to do with acting as PIC" is not the most intuitive concept.
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