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How do you log this?
Thanks! |
I assume this is for the ATP mins? My understanding is anytime you are doing the actual flying, even as SIC, you can log it as PIC, but the Capt. is always over-riding PIC in the abnormal situations. And I guess it never hurts to have another signature in your logbook.
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Originally Posted by oldveedubs
(Post 146186)
How do you log this in a 121 airline as an FO? Just ask the captain before the leg if you can log PIC? Any special notation to show that you got CA's approval?
Thanks! The regulation is 14 CFR part 61.51(e): Logging pilot-in-command time. 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... This is the so called "sole manipulator" rule. It allows you, only for the purpose of meeting FAA requirements for a certificate or rating, to log "PIC" flight time if you are rated in the aircraft. Rated means category, class, and type. For example, if you are an FO in a CRJ, you would have to have at a minimum a commercial certificate, with multi-engine, instrument, and (this is the biggy) a CRJ type rating. Without the type rating you would not be able to log any flight time under any circumstance as PIC under this regulation because you are not rated in the aircraft. Most regional airlines will not type you in the aircraft during initial training. Therefore unless you received the type rating elsewhere, you will not be able to log PIC time for the purposes of your ATP certificate. Don't confuse this regulation for PIC time with the definition of Pilot-in-command in 14 CFR Part 1.1. They are two very different things. The definition in part 1.1 is the guy who is really in charge of the aircraft and the one who has been designated as pilot in command before or during the flight. Note that in 61.51, there is no mention of the Airline Transport Certificate. Once you achieve that certificate, you may no longer under any circumstances log part 61.51(e) PIC time, regardless of whether you are rated (category, class, and type) in the aircraft or not. All your logged PIC time from that moment forward must be PIC time as defined in part 1.1. If you go to a part 121 regional airline with less than the FAA required PIC time for an ATP, and the airline does not type you in the aircraft, and you don't have the type rating for the aircraft from somewhere else, you will have to go find (buy?) flight time in an aircraft that you are rated for to meet the PIC requirements for the ATP. This has happened more than once. |
Alright, I understand the logic.
Now a follow up. When you are SIC typed in the a/c and you ask the ca for permission to log PIC...does he/she sign? And what does he/she log? Is it like flight instructors who still get PIC even if there student is acting as PIC? Thanks! |
Originally Posted by oldveedubs
(Post 147763)
Alright, I understand the logic.
Now a follow up. When you are SIC typed in the a/c and you ask the ca for permission to log PIC...does he/she sign? And what does he/she log? Is it like flight instructors who still get PIC even if there student is acting as PIC? Thanks! Opps I found it. Part 61.55. Hmmm. Good question. Ok, I've read the regulation completely. I don't think, but I couldn't find it expressively said in the reg, that a second-in-command type rating as defined in part 61.55 meets the requirements of "rated" as used in part 61.51(e). Part 61.55 does not apply to operations under subpart K of part 91, part 121, part 125, or part 135. And no pratical test is requried for a "SIC Privileges Only" pilot type rating. I would bet that the FAA would not recognize it as being rated in the aircraft for anything that allows "PIC" flight time. I will do some more research. |
Also I heard from a friend at a regional that you don't specifically need to meet ATP mins to get a captain upgrade. If you are trained under a part 121 program you can become a captain. Think of it like 141 mins instead of part 61. Any truth to this as well?
There are so many things that I could continue on from the original question. Thanks for the help! |
I dug around and did a little more research. I reviewed the FAA Inspector's Handbook to see if there was any guidance. I couldn't find any (which doesn't mean there isn't). Because a large portion of part 61.55 is new this year I suspect the question hasn't been asked formally yet of the FAA and an interpretation given.
That said, after reviewing the two regulations again and various definitions, I'm reversing myself. Part 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;... In the past "rated" had be defined by the FAA to mean "type rating" as defined in part 61.31 and in part 61.1 definitions. This has ment a "PIC type rating" as that was the only type available. With the advent of the expanded rule for second-in-command type ratings in part 61.55, I wonder if, with respect to 61.51(e), if that definition would change to "any type rating". In 61.55(d) and (e) the regulation refers to "SIC Privileges only" pilot type rating. Both those words, rated and privileges, are used in 61.51(e). And 61.51(e) allows you to log PIC time for the purposes of a certificate or privilege (that's 61.51(c)) as sole manipulator, as long as you don't have an ATP. So I think you can log PIC time with an SIC Privileges Only Type Rating when you are sole manipulator of the controls. However, if you are relying on that time to meet the minimums for an ATP certificate, I would get an interpertation from your training department or an FAA Inspector. |
Originally Posted by oldveedubs
(Post 147783)
Also I heard from a friend at a regional that you don't specifically need to meet ATP mins to get a captain upgrade. If you are trained under a part 121 program you can become a captain. Think of it like 141 mins instead of part 61. Any truth to this as well?
There are so many things that I could continue on from the original question. Thanks for the help! So technically you could get an ATP with 1475 hours flight time and 25 hours of flight training device/simulator time. This would meet the 1500 hour total requirement. There is no relief in the regulation for this rule if you received training from an airline under a part 121 training program. I'm not sure what your friend is refering to. |
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