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Logging of night, XC and instrument as SIC?

Old 02-10-2024, 02:03 PM
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Default Logging of night, XC and instrument as SIC?

Hey all,


I recently got a part 91 job flying SIC on a Citation 560 Encore. I completed a 61.55 SIC type rating last month and turned in all of my paperwork to the FSDO. The 560 Encore is certificated as a two pilot aircraft. 61.51(f) governs the logging of SIC time and says I can log SIC time if I've completed a 61.55 type rating and if the aircraft is certificated as a two pilot aircraft. My bases are covered for logging multi, TT and SIC time. However, what I want to know is, can I log night, XC and instrument time, while acting as SIC, regardless if I'm the PF or the PNF.


I have looked, and looked, and looked, but I cannot find anything that authoritatively answers my question. I even asked the FAA inspector who I turned my 61.55 training paperwork into and he didnít even know. The closest thing Iíve come to is when I found the Carpenter letter of legal interpretation (link below). This states that if you are a qualified SIC acting as a required crewmember on a two pilot aircraft, you may log instrument time, because, since you are a required crewmember, you are technically operating the aircraft. The only caveat is you must be the PF to log approaches. My problem with the Carpenter letter though, is this addresses the logging of time while operating under part 121. Iím operating solely under part 91. The Carpenter letter also does not address my question of night and XC. I ultimately want to move on to the airlines and I still need 400 hours of TT and about 80 hours of XC to meet my remaining ATP mins. Everything else is met but I want to make sure Iím doing things correctly, especially for that remaining XC time. Can anybody please tell me if I can log night, XC, and instrument time while acting as SIC under part 91? Please provide sources with any answers!


Also, before anyone asks:

No, my captain does not have a single pilot exemption.

No, I am not PIC typed in this aircraft. Only SIC typed under 61.55.

No, Iím not seeking advice on the logging of SIC time in single pilot aircraft. Again, Iím flying a two pilot aircraft.


Carpenter letter
https://www.faa.gov/about/office_org...rpretation.pdf
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Old 02-11-2024, 08:47 AM
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Yes, you can always log conditions of flight, along with TT, when serving a required crew member.

You can't log approaches or landings unless you're the pilot flying. When you're the PF, you can use the full capabilities of the autopilot and still log the LDG, even for a CAT-III autloand.
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Old 02-11-2024, 10:14 AM
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If you look at the construction of 14 CFR 61.51 (https://www.ecfr.gov/current/title-1.../section-61.51), a breakdown is given for certain classifications of flight time. For example, 61.51(b)(2) addresses types of pilot experience or training include solo, pilot in command, second in command, flight and ground training received from an authorized instructor, and training received in a full flight simulator, flight training device, or aviation training device. 61.51(b)(3) addresses the conditions of flight, which include day or night, actual instrument, simulated instrument, or the use of night vision goggles.

61.51(b)(2) is the type of pilot time you log. 61.51(b)(3) are the conditions in which that pilot time occurred. Consequently, you can be PIC at night, or SIC at night. You can be PIC in instrument conditions, or SIC in instrument conditions. Being SIC does not preclude logging the conditions in which you act as SIC, just as Rickair777 noted above.

Logging night is logging condition of flight, just as logging instrument time, and may be logged by both PIC and SIC; you're both in the aircraft as a required crewmember at night, so log it as SIC pilot time, and night time. Simple. You can be PIC and log instrument time, or night time, or both. You can be SIC and log instrument time, or night time, or both. Both pilots (PIC and SIC) may log instrument, as both are in instrument conditions as required crew. Both pilots (PIC and SIC) may log cross-country, as both are on the same cross country flight as required crew. Most of us, after meeting the requirements for ATP, don't ever bother logging cross-country again, even though a big chunk of our careers may have been flown cross-country, because for most of us it doesn't serve any purpose after the ATP, and there's no requirement to log it.

Note that 61.51 does not cover the logging of cross-country experience. Cross-country is defined under 61.1(b) (https://www.ecfr.gov/current/title-1...A/section-61.1). Cross-country time does not have to be flown as pilot in command. It must, however meet specific requirements as spelled out in the regulation, to qualify for a given level of pilot certification; generally it must include a landing at a point other than the point of departure, for example, and the distance between the two must be at least 50 miles to qualify the cross-country time for a commercial pilot certificate, or 25 miles for the sport pilot, etc. For the ATP, a landing at a point other than the point of departure is not required, but the farthest point of the flight must be 50 miles from the departure point. The defintion varies, but the regulation does not stipulate that the time must be flown as PIC or SIC. If you act in the capacity of a required crewmember on a flight that meets the cross-country definition for the certificatation you seek, it does not matter if you are PIC or SIC. It's still cross-country, because what defines it is not your position in the aircraft (PIC vs. SIC) but the distance and landing. Therefore, if you are SIC and you make a flight which extends at least 50 nm straight-line from the point of departure in an appropriate aircraft, using some form of navigation, you may log it as cross-country.

61.159(a)(1) (https://www.ecfr.gov/current/title-1...section-61.159) establishes the requirement for 500 hours of cross-country time to be eligible for the ATP. No requirement is established specifying that the cross-country time must be flown as PIC or SIC, but merely that 500 hours of cross-country are required. Accordingly, you may log 500 hours of SIC time toward your ATP certificate.

To further clarify the regulatory requirement for PIC vs. SIC time, look to 61.159(a)(5)(i)(A), which stipulates that you must have 250 hours pilot in command time, 100 of which is cross-country. This is notable, because the other 400 hours of your cross-country time do NOT need to be PIC time, but can be SIC. However, even this regulation makes allowance that the time can be second-in-command, performing the duties of pilot-in-command, under the supervision of a pilot-in-command. In other words, the regulation does not prohibit logging of cross-country time as second in command, and in fact, specifically allows it. 61.159(a) refers to "total pilot time" when introducing 61.51(a)(1), and does not stipulate PIC or SIC. Just total pilot time. Accordingly, you may log cross-country time as SIC.

https://www.faa.gov/sites/faa.gov/fi...rpretation.pdf

in a 2009 legal interpretation from Rebecca McPherson to Glenn, the question of a SIC logging cross country is directly answered:

In the third scenario, Pilot A and Pilot B, who hold commercial pilot certificates and ratings appropriate to the aircraft, are conducting an operation under part 135 that requires two pilots. PilotAactsasthePICandisthesolemanipulatorofthecont rols,andPilotBactsas the SIC. You ask whether Pilot B may log SIC and/or cross-country time for the entire flight.

The definition ofcross-country time inß 61.l(b)(3) does not limit that time to only a PIC. Any required flight crewmember for an operation could meet the entire definition of cross-country time provided the flight met that definition. Provided that two pilots are required by the aircraft's type certificate or by operating rule for the part 135 operation, both Pilot A and Pilot Bare required flight crewmembers. Accordingly, Pilot B, as a required flight crewmember for the entire flight, may log SIC and cross-country time for the entire flight.
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Old 02-11-2024, 10:17 AM
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Originally Posted by rickair7777 View Post
Yes, you can always log conditions of flight, along with TT, when serving a required crew member.

You can't log approaches or landings unless you're the pilot flying. Whe you're the PF, you can use the full capabilities of the autopilot and still log the LDG, even for a CAT-III autloand.
I keep hearing this, but is there a source that directly says I can do this under part 91? Letter of Legal Interpretation? FAR/AIM? Advisory Circular? My biggest concern is getting through the logbook review at Indoc with an airline. I've spoken to a lot of people about my new job and is seems like a lot of people do not understand that some Citations are certificated as two pilot. Most folks seem to think that they're all single pilot. It further seems even less common that two pilot planes are operated strictly under part 91, based on how people are reacting when I tell them about my situation. I'm anticipating these misunderstandings and questions will probably be brought up during indoc and I want to be able to fully defend the logging of my time. I've heard horror stories about how, if you have SIC time in your logbook, the airlines will request documentation to support the validity of your SIC time (probably fallout from the Boutique SIC mess). Hence, why I'm asking for a loud and clear source.
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Old 02-11-2024, 10:24 AM
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Thank you so much! You guys rock!! I've definitely met the 100 hours of PIC XC requirement, so these remaining 80 hours can be logged as SIC. I don't really need instrument or night because those requirements are met, but I like to log it all anyway, if I can. I appreciate the responses!
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Old 02-11-2024, 10:56 AM
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Originally Posted by JohnArt View Post
....I even asked the FAA inspector who I turned my 61.55 training paperwork into and he didnít even know. [size=33px]
That was your first mistake [/size]
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Old 02-11-2024, 11:10 AM
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Originally Posted by JohnBurke View Post
If you look at the construction of 14 CFR 61.51 (https://www.ecfr.gov/current/title-1.../section-61.51), a breakdown is given for certain classifications of flight time. For example, 61.51(b)(2) addresses types of pilot experience or training include solo, pilot in command, second in command, flight and ground training received from an authorized instructor, and training received in a full flight simulator, flight training device, or aviation training device. 61.51(b)(3) addresses the conditions of flight, which include day or night, actual instrument, simulated instrument, or the use of night vision goggles.

61.51(b)(2) is the type of pilot time you log. 61.51(b)(3) are the conditions in which that pilot time occurred. Consequently, you can be PIC at night, or SIC at night. You can be PIC in instrument conditions, or SIC in instrument conditions. Being SIC does not preclude logging the conditions in which you act as SIC, just as Rickair777 noted above.

Logging night is logging condition of flight, just as logging instrument time, and may be logged by both PIC and SIC; you're both in the aircraft as a required crewmember at night, so log it as SIC pilot time, and night time. Simple. You can be PIC and log instrument time, or night time, or both. You can be SIC and log instrument time, or night time, or both. Both pilots (PIC and SIC) may log instrument, as both are in instrument conditions as required crew. Both pilots (PIC and SIC) may log cross-country, as both are on the same cross country flight as required crew. Most of us, after meeting the requirements for ATP, don't ever bother logging cross-country again, even though a big chunk of our careers may have been flown cross-country, because for most of us it doesn't serve any purpose after the ATP, and there's no requirement to log it.

Note that 61.51 does not cover the logging of cross-country experience. Cross-country is defined under 61.1(b) (https://www.ecfr.gov/current/title-1...A/section-61.1). Cross-country time does not have to be flown as pilot in command. It must, however meet specific requirements as spelled out in the regulation, to qualify for a given level of pilot certification; generally it must include a landing at a point other than the point of departure, for example, and the distance between the two must be at least 50 miles to qualify the cross-country time for a commercial pilot certificate, or 25 miles for the sport pilot, etc. For the ATP, a landing at a point other than the point of departure is not required, but the farthest point of the flight must be 50 miles from the departure point. The defintion varies, but the regulation does not stipulate that the time must be flown as PIC or SIC. If you act in the capacity of a required crewmember on a flight that meets the cross-country definition for the certificatation you seek, it does not matter if you are PIC or SIC. It's still cross-country, because what defines it is not your position in the aircraft (PIC vs. SIC) but the distance and landing. Therefore, if you are SIC and you make a flight which extends at least 50 nm straight-line from the point of departure in an appropriate aircraft, using some form of navigation, you may log it as cross-country.

61.159(a)(1) (https://www.ecfr.gov/current/title-1...section-61.159) establishes the requirement for 500 hours of cross-country time to be eligible for the ATP. No requirement is established specifying that the cross-country time must be flown as PIC or SIC, but merely that 500 hours of cross-country are required. Accordingly, you may log 500 hours of SIC time toward your ATP certificate.

To further clarify the regulatory requirement for PIC vs. SIC time, look to 61.159(a)(5)(i)(A), which stipulates that you must have 250 hours pilot in command time, 100 of which is cross-country. This is notable, because the other 400 hours of your cross-country time do NOT need to be PIC time, but can be SIC. However, even this regulation makes allowance that the time can be second-in-command, performing the duties of pilot-in-command, under the supervision of a pilot-in-command. In other words, the regulation does not prohibit logging of cross-country time as second in command, and in fact, specifically allows it. 61.159(a) refers to "total pilot time" when introducing 61.51(a)(1), and does not stipulate PIC or SIC. Just total pilot time. Accordingly, you may log cross-country time as SIC.

https://www.faa.gov/sites/faa.gov/fi...rpretation.pdf

in a 2009 legal interpretation from Rebecca McPherson to Glenn, the question of a SIC logging cross country is directly answered:
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Old 02-11-2024, 11:19 AM
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Inspectors at the FSDO level, indeed anyone at the FSDO level, are never authorized to interpret the regulation. Accordingly, while one can ask an inpsector anything one wishes, the respose carries no interpretive weight, and at no point in time will one have a leg to stand upon by saying "I was told at the FSDO." The FSDO can reply verball, but that verbal response does not interpret the regulation, and if one acts upon counsel received at the FSDO level and runs afoul of the regulation, one cannot use the defense that one is doing what one was directed, by the FSDO. One is expected to know and understand the regulation. Each of us has every bit as much ability and responsibility to do so, as the inspector at the FSDO. The difference is that we're the one responsible for knowing the regulation and it's correct interpretation.

There are three means of understanding the regulation. The first is the Federal Register preamble when the regulation was made final. It's for this reason that the regulation includes references and citations to the Federal Register (see my post above for links to the ECFR site and scroll to the bottom of the regulation; you'll see links to the relevant editions of the Federal Register).

The second means of understanding the regulation are the Chief Legal Counsel letters of interpretation. As pilots, we ARE held accountable for knowing those interpretations, or more accurately, applying the regulation as it's been interpreted in both the Federal Register and the Chief Legal Counsel interpretations. The Chief and Regional legal counsels are the ONLY ones authorized and empowered by the FAA Administer, to interpret the regulation, and of course the FAA Administrator is the only one empowered by an Act of Congress (Federal Aviation Act of 1958, as ammended), to oversee and regulate aviation in the United States.

The third means of understanding the regulation is the regulation itself, by plain-english rendering of the language in the regulation. The means of understanding the regulation are given in correct order.

A fourth means which does not tell you how to apply the regulation, but how it has been applied in specific cases in the past, which do not set precedent nor define the regulation per se, are Administrative Law Judge decisions, through full-board NTSB decisions and appeals, regarding enforcement action. These give examples of how the regulation has been decided in specific cases, and an idea of the way the wind blows and the proverbial temperature in the room, but do not define the regulation, or establish a precedent for its application outside of those cases. The cases, however, can be illuminating.

Last edited by JohnBurke; 02-11-2024 at 11:36 AM.
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Old 02-11-2024, 11:26 AM
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All of this ^^^
The FAA is one of the most unstandardized government agencies.
Yes you need some pilot qualifications to become an ASI but total training time is like 3-4 months Monday - Friday 9-5.
Its not law school for 4 years where you go through every different scenario and rulings or jurisprudence on every single reg.
You know what you know when you go in amd thatís pretty much it.
So consider greatest common denominator when you ask these types of questions or any question when you deal with an ASI.
In addition to the Tribal Law practiced at a lot of FSDOís, they may have a standard interpretation for that FSDO and it may not be the correct one.
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Old 02-11-2024, 12:04 PM
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It's worth bearing in mind that one of the prime qualifications to be an avaition safety inspector is that one has had no more than two aircraft accidents in the past two years, for which one is responsible.

It's not exaclty a clarion call to aviation's top shelf.
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