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Old 07-06-2012, 11:58 PM   #1  
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Default Log PIC in right seat with full type.

Got a question that came up while flying around and jumpseating today.

If you hold an ATP and type rating in the aircraft you are flying on the legs when you are the one flying (sole manipulator of controls)...

Can you sit right seat / first officer and log PIC time? Im specifically talking about the future regulations regarding First Officers getting ATP's and Full Types.
Technically you are qualified as a Captain but the only thing is you are not signing for the airplane.



Second,

Would that time be eligible to application minimums (1000TPIC Multi) because it doesn't say you had to sign for an airplane, just logged time?

Thanks !
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Old 07-07-2012, 12:12 AM   #2  
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Quote:
Originally Posted by sinsilvia666 View Post
Got a question that came up while flying around and jumpseating today.

If you hold an ATP and type rating in the aircraft you are flying on the legs when you are the one flying (sole manipulator of controls)...

Can you sit right seat / first officer and log PIC time? Im specifically talking about the future regulations regarding First Officers getting ATP's and Full Types.
Technically you are qualified as a Captain but the only thing is you are not signing for the airplane.



Second,

Would that time be eligible to application minimums (1000TPIC Multi) because it doesn't say you had to sign for an airplane, just logged time?

Thanks !
PIC is "Pilot in Command" i.e. who signs for the Jet! Who is ultimately in Charge.

The only time you can LOG PIC is when you are the Captain on Record.

Now if you are a Check Airman, you can LOG PIC from the right seat when you are giving IOE or a Check Ride.

Just because you are typed, does not mean you are PIC. If you are the Sole manipulator of Controls you can log the Stick Time as FP (First Pilot) but not PIC.
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Old 07-07-2012, 12:13 AM   #3  
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Can't log it as PIC, can't use it on the app unless your name is on the release as Captain.

Edit: beat me to it RedEye!
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Old 07-07-2012, 03:29 AM   #4  
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You can log PIC. Says who? The FAA via the FAR's. FAR 61.51 paragraph (e). You can count it toward a companies mins unless they say it has to be as captain. If they have a problem in the interview then they weren't specific enough. As far as I'm concerned, you can log it with an SIC type. I checked, an SIC type is in fact a type rating. Look up the definition for type rating in the FAR's.

Logging PIC vs. Acting as PIC = two different things. Again, I say, you CAN log it.

Last edited by CrakPipeOvrheat; 07-07-2012 at 03:42 AM.
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Old 07-07-2012, 05:34 AM   #5  
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The FAA says that you CAN log the time as sole manipulator as PIC when operating a multi-crew aircraft, regardless of the seat you are sitting in.

Whether or not that time is considered "valid" by a prospective employer or insurance company varies. Generally speaking, 121 carriers only consider PIC time to be that where the pilot was the ultimate responsible party for the flight (IE the person who signed for the aircraft).

In fact, the FAA considers a qualified SIC who only has an SIC qualification (IE no type rating) valid to log PIC provided that they have satisfactorily passed an initial qualification event.

See the FAA interpretation from FAA Legal Counsel:

____________________________________________
http://www.faa.gov/about/office_org/.../Carpenter.rtf

February 9, 1999

Bill Carpenter
12808 E. Pacific Drive, #302 Aurora, Colorado 80014

Dear Mr. Carpenter:

Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)

You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.

Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.

There is a distinction between acting as pilot in command and logging of pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:

2

(e) Logging pilot-in-command flight time.

(1) A 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_ (ii) Is the sole occupant of the aircraft: or (iii) Except for a recreational pilot is acting 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.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.

While it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. If the pilot is designated as PIC by the certificate holder, as required by FAR 121.385(c), that person is PIC for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft. The pilot who is the sole manipulator of the controls of the aircraft for which the pilot is rated may also log that flight as PIC.

It is important to remember that we are dealing with logging of flight time only for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the SIC is fully qualified as a PIC, or only as an SIC. This is important because even though an SIC can log PIC time, that pilot may not be qualified to serve as PIC under Part 121.

I hope this satisfactorily answers your questions. If we can be of further assistance, please contact us.

D. Brent Pope
Attorney, ANM-7H
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Old 07-07-2012, 05:38 AM   #6  
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Now, that said, I would not/did not personally choose to log time as an SIC in a part 135 or part 121 operation as PIC, even if I WAS the sole manipulator of the controls.

It's simply not considered "industry standard" when it comes to applying for jobs or sending resumes out. The only consideration that I might give is for insurance purposes where an insurer might require x number of PIC hours to be insured on a particular model aircraft. (This is much more of an issue in the part 91 world).

In short: Is it legal to log SIC time as PIC? Yes. Is it a generally accepted industry practice? No.
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Old 07-07-2012, 07:38 AM   #7  
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Originally Posted by CrakPipeOvrheat View Post
I checked, an SIC type is in fact a type rating. Look up the definition for type rating in the FAR's.
Nothing in FAR 1.1 for "type rating." Where are you looking?
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Old 07-07-2012, 08:14 AM   #8  
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appreciate the insights guys ! interesting argument for sure. i agree unless im in the left i wouldnt log the pic, but just curious as to if your needing time to fill blocks would it be legal.
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Old 07-07-2012, 08:41 AM   #9  
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Nothing in the FARs says you have to occupy the left seat to be "in command". In corporate and military, we swap sets all the time, but the designated PiC is the PIC.

GF
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Old 07-07-2012, 09:23 AM   #10  
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Sorry. I looked it up along time ago. The definition is for "rating".

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

FAR 61.51 says you need to be rated. I would say an sic type rating fits the definition of "rating".
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