Envoy 2019
#891
Line Holder
Joined APC: May 2015
Posts: 92
That was my thought about Part 91 on this issue. Clearly, it means nothing under 121. However, if you ever wanted to own/rent/insure an aircraft down the road, Part 61 PIC time does affect your insurance premiums. I guess one could always just take half their SIC time as a SWAG and be close.
I would be extremely careful about telling a rental/insurance company that you have a bunch of PIC time that's not actually PIC. If something happens they could very easily construe this as "pencil whipping" your logbook and you'll very quickly find out that aviation lawyers are only slightly less expensive than aviation lawsuits.
*The one exception to this is when a line check airman is giving IOE to a not yet qualified captain. Things get a little fuzzy legally with who is responsible for what but IIRC the CA candidate still logs SIC. Ask a LCA if you want to be sure.
#892
Gets Weekends Off
Joined APC: Feb 2019
Posts: 133
That was my thought about Part 91 on this issue. Clearly, it means nothing under 121. However, if you ever wanted to own/rent/insure an aircraft down the road, Part 61 PIC time does affect your insurance premiums. I guess one could always just take half their SIC time as a SWAG and be close.
Time as an FO in the 121 world for an aircraft requiring more than one pilot is only SIC time, regardless of who’s actually flying. Unless your captain is incapacitated... In that case you should determine if they’re senior to you or not. If they are, reduce thrust and start the clock.
Just kidding...
Edit: The grey area regarding “sole manipulator of the controls” may allow you to log that time, but you’re still not acting as PIC in the 121 world. The lawyers would have a field day trying to sort that out if it ever came down to that... not a can of worms worth opening IMHO.
Last edited by dash8trash; 04-15-2019 at 06:52 PM.
#893
Logging vs Acting
Correct! We were talking about LOGGING PIC time, you were talking about acting as PIC. Pilots can definitely log PIC time even in situations where they can't serve as PIC.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
#894
Gets Weekends Off
Joined APC: Nov 2017
Position: Upright
Posts: 396
Correct! We were talking about LOGGING PIC time, you were talking about acting as PIC. Pilots can definitely log PIC time even in situations where they can't serve as PIC.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
I wasn't even going to bother responding, as it is all too clear many individuals posting cannot read or comprehend the written word, and are more interested in trying to appear authoritative.
I appreciate you actually reading what I posted.
Cheers.
#895
Gets Weekends Off
Joined APC: Jun 2006
Posts: 1,523
Pilot flying does not mean pilot in command . If you are the FO you are earning SIC and only SIC regardless of who's physically flying the airplane. PIC has nothing to do with flying and everything to do with being the individual responsible for the operation of the aircraft.*
I would be extremely careful about telling a rental/insurance company that you have a bunch of PIC time that's not actually PIC. If something happens they could very easily construe this as "pencil whipping" your logbook and you'll very quickly find out that aviation lawyers are only slightly less expensive than aviation lawsuits.
*The one exception to this is when a line check airman is giving IOE to a not yet qualified captain. Things get a little fuzzy legally with who is responsible for what but IIRC the CA candidate still logs SIC. Ask a LCA if you want to be sure.
I would be extremely careful about telling a rental/insurance company that you have a bunch of PIC time that's not actually PIC. If something happens they could very easily construe this as "pencil whipping" your logbook and you'll very quickly find out that aviation lawyers are only slightly less expensive than aviation lawsuits.
*The one exception to this is when a line check airman is giving IOE to a not yet qualified captain. Things get a little fuzzy legally with who is responsible for what but IIRC the CA candidate still logs SIC. Ask a LCA if you want to be sure.
#896
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,494
That verbiage is more applicable to things like 2 pilot operation in a PC12 under 135 IFR, where the SIC is a required crewmember (unless PIC has 297(g) check), but can also log PIC as sole manipulator of controls even when he is not acting PIC.
#897
The problem is that on a plane that requires 2 pilots, you are never _SOLE_ manipulator of controls.
That verbiage is more applicable to things like 2 pilot operation in a PC12 under 135 IFR, where the SIC is a required crewmember (unless PIC has 297(g) check), but can also log PIC as sole manipulator of controls even when he is not acting PIC.
That verbiage is more applicable to things like 2 pilot operation in a PC12 under 135 IFR, where the SIC is a required crewmember (unless PIC has 297(g) check), but can also log PIC as sole manipulator of controls even when he is not acting PIC.
#898
Gets Weekends Off
Joined APC: Nov 2017
Position: Upright
Posts: 396
The problem is that on a plane that requires 2 pilots, you are never _SOLE_ manipulator of controls.
That verbiage is more applicable to things like 2 pilot operation in a PC12 under 135 IFR, where the SIC is a required crewmember (unless PIC has 297(g) check), but can also log PIC as sole manipulator of controls even when he is not acting PIC.
That verbiage is more applicable to things like 2 pilot operation in a PC12 under 135 IFR, where the SIC is a required crewmember (unless PIC has 297(g) check), but can also log PIC as sole manipulator of controls even when he is not acting PIC.
#899
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,494
I can't find anything regarding logging PIC as sole manipulator of controls in an airplane requiring two crewmembers? But since you know so much more about this than I do, please enlighten me.
I would say a reasonable interpretation of the regs is, that if you are the sole manipulator of controls in an airplane requiring two pilots, you are in an emergency. Then I'd agree you can log PIC under 61.51(e)(1)(i).
61.51(e)(1)(iii) directly contradicts you anyway.
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted
ACTS as a pilot in command.
Sorry, but you are 100% wrong if you think you can log PIC by being sole manipulator of controls, in a plane requiring two pilots.
Unless you can find a chief counsel letter that contradicts this.
#900
In a land of unicorns
Joined APC: Apr 2014
Position: Whale FO
Posts: 6,494
Correct! We were talking about LOGGING PIC time, you were talking about acting as PIC. Pilots can definitely log PIC time even in situations where they can't serve as PIC.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) Except when logging flight time under §61.159(c), 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;
This is clearly the common situation where a PT 121 SIC is PF, sole manipulator. Since 121 has its own requirements, such logged PIC time clearly only has value in 91/135 situations.
The 61.159c exception applies to cases where 91/135 operators have written opsecs to allow co-pilots to log SIC time in airplanes that are not certificated to require a co-pilot. Not applicable to Pt121.
Your GOM might have required it, but it wasn't an opspec, and it didn't allow anything - GOM is accepted, not approved material.
You are never a sole manipulator of controls in an airplane requiring two pilots, unless you are in an emergency.
Well. Someone might say "oh but what about when the captain is in the bathroom". Yeah go ahead and log those...
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