Logging PIC for a multi add-on
03-31-2023, 11:25 AM
#1
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Logging PIC for a multi add-on
My son is working his way towards ATP quals while flight instructing and still lacks a ME class rating. The thinking is to get the ME, buy time to reach the 15 hours PIC requirements for MEI and build time to meet the 25 hours ME requirements regional require as mins for hiring. In discussing his (future) training, he asked/advised me that the time required under instruction toward the ME could not be logged as PIC due to the fact that it was a different airplane class. Intrigued (mainly because it's going to ultimately cost me more $$$$) I have been digging into the regs. First I verified that 15 hours PIC of ME is the minimum required for a MEI add-on to a CFIA. The next part is my question, seeking advice from those with a better understanding of the reg.
FAR 61.51 deals with logbooks and defines (among other things) the requirements for logging PIC. My drilling down gets me to 61.51 (e) (1) (iv) (B), which I'll share.
(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation -........
My question is, What qualifies as an, "approved pilot in command training program that includes ground and flight training", as far as the FAA is concerned? . Must it be "approved" as in an FAR 141 school, or can a 61 program at an FBO be approved, as far as the letter of the law? Logging training as PIC from the start of ME training vs waiting to have the fresh ticket would mean several thousand of dollars not spent towards the 15 hour PIC requirement for the MEI. Looking at advertising online from several ME programs (that I assume are not 141) it isn't clear, they don't address the PIC issue when pricing a MEI add-on.
FAR 61.51 deals with logbooks and defines (among other things) the requirements for logging PIC. My drilling down gets me to 61.51 (e) (1) (iv) (B), which I'll share.
(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation -........
My question is, What qualifies as an, "approved pilot in command training program that includes ground and flight training", as far as the FAA is concerned? . Must it be "approved" as in an FAR 141 school, or can a 61 program at an FBO be approved, as far as the letter of the law? Logging training as PIC from the start of ME training vs waiting to have the fresh ticket would mean several thousand of dollars not spent towards the 15 hour PIC requirement for the MEI. Looking at advertising online from several ME programs (that I assume are not 141) it isn't clear, they don't address the PIC issue when pricing a MEI add-on.
03-31-2023, 12:59 PM
#2
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Posts: 6,026
The approved flight training program under 14 CFR 61.51(e)(1)(iv) is a program which is specifically approved for the purpose, such as a program for training someone in airline operations.
If you break 61.51(e)(1)(iv) down, it contains several requirements:
61.51(e)(1)(iv)(A): the person performing the duties of PIC must hold a commercial or ATP pilot certificate, appropriate to category and class: airplane, multi-engine land, or airplane, multi-engine sea)
AND
61.51(e)(1)(iv)(B): the person performing the duties of PIC must be undergoing an approved pilot in command training program (eg, airline type program).
It's the first requirement above, 61.51(e)(1)(iv)(A), which specifies that the person logging the time under 61.51(e)(1)(iv) must have a pilot certificate that is appropriate to both category (here, airplane) and class (here, multi-engine land or sea, as appropriate). Specific to your question, a person logging time under this regulation must already hold a multi-engine rating. Training toward the multi-engine rating is not pilot in command experience, even if it's part of an approved program. The requirement is category, and class. Category is airplane, and the class is multi engine (land, or sea).
It sounds like you're cherrypicking the regulation, meaning that you're looking to choose either 61.51(e)(1)(iv)(A) OR 61.51(e)(1)(iv)(B). If you read the regulation, both (A) AND (B) are requirements for logging time under 61.51(e)(1)(iv).
This rule was adopted in 2009, as published in the Federal Register at the time. The link is below as well as the specific language from the Federal Register concerning the specific subparagraphs in your question. When looking for an understanding of the regulation; three sources are used: the first source is the Federal Register preamble, which explains the regulation and the purpose for it, or the change to it; the second are FAA Chief Legal Counsel letters of interpretation, and the third source, in order, is the regulation itself.
https://www.federalregister.gov/docu...-certification
The pilot performing the duties of a PIC will be required to hold a commercial pilot certificate or airline transport pilot certificate with the aircraft rating appropriate to the category and class of aircraft being flown, if a class rating is appropriate. The pilot must be under the supervision of an appropriately qualified PIC. Additionally, the pilot who is performing PIC duties is required to undergo an approved PIC training program consisting of ground and flight training on the following areas of operation: pre-flight preparation, preflight procedures, takeoff and departure phase, in-flight maneuvers, instrument procedures, landings and approaches to landings, normal and abnormal procedures, emergency procedures, and post-flight procedures.
The supervising PIC will be required to hold either a commercial pilot certificate or ATP certificate, and flight instructor certificate. In addition, the supervising PIC must hold the appropriate aircraft rating (i.e., category, class, and type of aircraft being flown, if a class or type rating is required). The supervising PIC must log the PIC training given in the pilot's logbook, certify having given the PIC training in the pilot's logbook, and attest to that certification with his/her signature, flight instructor certificate number, and expiration date, or ATP certificate number, as appropriate. This revision parallels and further clarifies the provisions in revised § 61.129 and existing §§ 61.31(d), 61.159(a)(4), 61.161(a)(3), and 61.163(a)(3) for PIC aeronautical experience.
AOPA supported the concept, but believed the proposed rule was unclear and would lead to confusion. AOPA recommended rewriting the proposed regulatory text to include a matrix text showing conditions under which a pilot may log time as PIC. Four commenters supported the proposed provisions clarifying logging of PIC flight time by pilots acting as PIC under supervision. One commenter questioned whether the proposed provisions are targeted toward pilots working toward advanced certificates, ratings, or authorizations after receiving their commercial pilot certificates.
Four commenters asserted the proposed provisions are unnecessary, as pilots acting as PIC under supervision are already permitted to log PIC flight time under other sections of the regulations. The Greater St. Louis Flight Instructor Association objected to the proposed provisions arguing there is a trend toward pilots having inadequate true solo experience; it believes the proposed rule would result in pilots building time without accruing real experience. One commenter opposed application of the proposed provision other than in operations or aircraft requiring a second in command (SIC) (e.g., operation of light single engine airplanes under part 91). The commenter did not consider a required safety pilot to be an SIC. One commenter objected to requiring endorsement of the acting PIC's logbook by the supervising PIC. The commenter asserted that the training contemplated by the proposed rule is recorded in training records, not logbooks. One commenter recommended pilots logging PIC flight time under supervision also be required to log dual instruction time.
This rule is designed to allow operators to train new hires to eventually become PICs. The rule was initially petitioned for by Saudi Aramco. Saudi Aramco wanted permission to allow new hires' training in their Bell 214 helicopter to eventually become PICs in the company and allow logging PIC flight time while under the supervision of more experienced and senior PICs. This rule does require pilots to hold at least a commercial pilot certificate and requires those performing supervising PIC duties must hold either a commercial pilot certificate or airline transport pilot certificate, and flight instructor certificate with the appropriate category and class of aircraft being flown, if a class rating is appropriate.
A pilot may log PIC flight time when performing the duties of the PIC while under the supervision of the § 1.1 PIC. The FAA believes the rule is abundantly clear that a person may log PIC flight time when performing the duties of the PIC while under the supervision of the PIC, provided both the person who is performing the duties of the PIC and the supervising PIC meet the requirements of the rule.
After consideration of all the comments received, the FAA is adopting the revision as proposed in the NPRM.
Despite the FAA's assurance in the preamble that the regulation is "abundantly clear" it's evident from reading the regulation, and from your question, that it's not that clear. The FAA explains that the rule was developed in response to a request by Saudi Aramco, which is a US/Saudi venture, operating under US regulations and also under Saudi regulations, which were built on, and modeled after the US regulation. Aramco wasn't looking to train pilots from scratch or train them toward pilot certificates or ratings. They were hiring pilots and wanted to be able to have them start logging PIC time during their new-hire training. Aramco was hiring qualified pilots and putting them through their company training program. Rather the intent was to allow someone who showed up with the certifications necessary to do the job, but who was not yet assigned as a pilot in command in that operation, to be logging PIC while performing the duties of PIC...even though that person was not the pilot in command.
Relevant to your question to log that time, in the case of an airplane category, multi-engine land airplane, the pilot would need to hold either a commercial or ATP level pilot certificate, with an airplane category and multi-engine land rating.
Rebecca MacPherson, FAA Assistant Chief Legal Counsel for Regulations, clarified 61.51(e)(1)(iv) in response to a question about logging flight time for someone who held a rating. In this case, she clarifies the difference between logging under 61.51(e)(1)(i) as sole manipulator of the controls (in an aircraft for which one is rated), vs. logging PIC under 61.51(e)(1)(iv), which is performing the duties of PIC (so long as one meets the requirements of that regulation. The FAA uses the term "rated" to mean category and class, and where appropriate, type rating. 61.51(e)(1)(iv) uses language other than saying "rated in the airplane", and clarifies that category and class are required, but doesn't use the full definition of "rated" as applied elsewhere, such as 61.51(e)(1)(i).
https://www.faa.gov/about/office_org...rpretation.pdf
If you break 61.51(e)(1)(iv) down, it contains several requirements:
61.51(e)(1)(iv)(A): the person performing the duties of PIC must hold a commercial or ATP pilot certificate, appropriate to category and class: airplane, multi-engine land, or airplane, multi-engine sea)
AND
61.51(e)(1)(iv)(B): the person performing the duties of PIC must be undergoing an approved pilot in command training program (eg, airline type program).
It's the first requirement above, 61.51(e)(1)(iv)(A), which specifies that the person logging the time under 61.51(e)(1)(iv) must have a pilot certificate that is appropriate to both category (here, airplane) and class (here, multi-engine land or sea, as appropriate). Specific to your question, a person logging time under this regulation must already hold a multi-engine rating. Training toward the multi-engine rating is not pilot in command experience, even if it's part of an approved program. The requirement is category, and class. Category is airplane, and the class is multi engine (land, or sea).
It sounds like you're cherrypicking the regulation, meaning that you're looking to choose either 61.51(e)(1)(iv)(A) OR 61.51(e)(1)(iv)(B). If you read the regulation, both (A) AND (B) are requirements for logging time under 61.51(e)(1)(iv).
This rule was adopted in 2009, as published in the Federal Register at the time. The link is below as well as the specific language from the Federal Register concerning the specific subparagraphs in your question. When looking for an understanding of the regulation; three sources are used: the first source is the Federal Register preamble, which explains the regulation and the purpose for it, or the change to it; the second are FAA Chief Legal Counsel letters of interpretation, and the third source, in order, is the regulation itself.
https://www.federalregister.gov/docu...-certification
26. This revision of § 61.51(e)(1)(iv) will permit a pilot performing the duties of pilot in command while under the supervision of a qualified pilot in command to log pilot in command flight time
Revised § 61.51(e)(1)(iv) will allow a pilot performing the duties of a pilot in command (PIC) while under the supervision of a qualified PIC to log PIC flight time. The FAA is making this revision to provide another way for commercial pilot certificate or airline transport pilot certificate holders to log PIC flight time.The pilot performing the duties of a PIC will be required to hold a commercial pilot certificate or airline transport pilot certificate with the aircraft rating appropriate to the category and class of aircraft being flown, if a class rating is appropriate. The pilot must be under the supervision of an appropriately qualified PIC. Additionally, the pilot who is performing PIC duties is required to undergo an approved PIC training program consisting of ground and flight training on the following areas of operation: pre-flight preparation, preflight procedures, takeoff and departure phase, in-flight maneuvers, instrument procedures, landings and approaches to landings, normal and abnormal procedures, emergency procedures, and post-flight procedures.
The supervising PIC will be required to hold either a commercial pilot certificate or ATP certificate, and flight instructor certificate. In addition, the supervising PIC must hold the appropriate aircraft rating (i.e., category, class, and type of aircraft being flown, if a class or type rating is required). The supervising PIC must log the PIC training given in the pilot's logbook, certify having given the PIC training in the pilot's logbook, and attest to that certification with his/her signature, flight instructor certificate number, and expiration date, or ATP certificate number, as appropriate. This revision parallels and further clarifies the provisions in revised § 61.129 and existing §§ 61.31(d), 61.159(a)(4), 61.161(a)(3), and 61.163(a)(3) for PIC aeronautical experience.
AOPA supported the concept, but believed the proposed rule was unclear and would lead to confusion. AOPA recommended rewriting the proposed regulatory text to include a matrix text showing conditions under which a pilot may log time as PIC. Four commenters supported the proposed provisions clarifying logging of PIC flight time by pilots acting as PIC under supervision. One commenter questioned whether the proposed provisions are targeted toward pilots working toward advanced certificates, ratings, or authorizations after receiving their commercial pilot certificates.
Four commenters asserted the proposed provisions are unnecessary, as pilots acting as PIC under supervision are already permitted to log PIC flight time under other sections of the regulations. The Greater St. Louis Flight Instructor Association objected to the proposed provisions arguing there is a trend toward pilots having inadequate true solo experience; it believes the proposed rule would result in pilots building time without accruing real experience. One commenter opposed application of the proposed provision other than in operations or aircraft requiring a second in command (SIC) (e.g., operation of light single engine airplanes under part 91). The commenter did not consider a required safety pilot to be an SIC. One commenter objected to requiring endorsement of the acting PIC's logbook by the supervising PIC. The commenter asserted that the training contemplated by the proposed rule is recorded in training records, not logbooks. One commenter recommended pilots logging PIC flight time under supervision also be required to log dual instruction time.
This rule is designed to allow operators to train new hires to eventually become PICs. The rule was initially petitioned for by Saudi Aramco. Saudi Aramco wanted permission to allow new hires' training in their Bell 214 helicopter to eventually become PICs in the company and allow logging PIC flight time while under the supervision of more experienced and senior PICs. This rule does require pilots to hold at least a commercial pilot certificate and requires those performing supervising PIC duties must hold either a commercial pilot certificate or airline transport pilot certificate, and flight instructor certificate with the appropriate category and class of aircraft being flown, if a class rating is appropriate.
A pilot may log PIC flight time when performing the duties of the PIC while under the supervision of the § 1.1 PIC. The FAA believes the rule is abundantly clear that a person may log PIC flight time when performing the duties of the PIC while under the supervision of the PIC, provided both the person who is performing the duties of the PIC and the supervising PIC meet the requirements of the rule.
After consideration of all the comments received, the FAA is adopting the revision as proposed in the NPRM.
Relevant to your question to log that time, in the case of an airplane category, multi-engine land airplane, the pilot would need to hold either a commercial or ATP level pilot certificate, with an airplane category and multi-engine land rating.
Rebecca MacPherson, FAA Assistant Chief Legal Counsel for Regulations, clarified 61.51(e)(1)(iv) in response to a question about logging flight time for someone who held a rating. In this case, she clarifies the difference between logging under 61.51(e)(1)(i) as sole manipulator of the controls (in an aircraft for which one is rated), vs. logging PIC under 61.51(e)(1)(iv), which is performing the duties of PIC (so long as one meets the requirements of that regulation. The FAA uses the term "rated" to mean category and class, and where appropriate, type rating. 61.51(e)(1)(iv) uses language other than saying "rated in the airplane", and clarifies that category and class are required, but doesn't use the full definition of "rated" as applied elsewhere, such as 61.51(e)(1)(i).
https://www.faa.gov/about/office_org...rpretation.pdf
04-01-2023, 09:09 AM
#3
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I’m not sure if you needed this info or not (because you were specifically asking for help interpreting a reg) but your son will not be able to log PIC until the check ride. So if it takes 8 hours of training to be checkride ready, and 2 hrs for the ride itself, he will start with 10hrs multi, of that, 2hrs being PIC. Add 15hrs PIC after that and then there’s 25 hrs in a multi that is required for a regional and 15 PIC to add an MEI. Now, he can log PIC time while prepping for the MEI ride with an instructor so there is no need to log that 15 PIC first before starting MEI training.
04-01-2023, 12:57 PM
#4
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Originally Posted by JohnBurke
The approved flight training program under 14 CFR 61.51(e)(1)(iv) is a program which is specifically approved for the purpose, such as a program for training someone in airline operations.
If you break 61.51(e)(1)(iv) down, it contains several requirements:
61.51(e)(1)(iv)(A): the person performing the duties of PIC must hold a commercial or ATP pilot certificate, appropriate to category and class: airplane, multi-engine land, or airplane, multi-engine sea)
AND
61.51(e)(1)(iv)(B): the person performing the duties of PIC must be undergoing an approved pilot in command training program (eg, airline type program).
It's the first requirement above, 61.51(e)(1)(iv)(A), which specifies that the person logging the time under 61.51(e)(1)(iv) must have a pilot certificate that is appropriate to both category (here, airplane) and class (here, multi-engine land or sea, as appropriate). Specific to your question, a person logging time under this regulation must already hold a multi-engine rating. Training toward the multi-engine rating is not pilot in command experience, even if it's part of an approved program. The requirement is category, and class. Category is airplane, and the class is multi engine (land, or sea).
It sounds like you're cherrypicking the regulation, meaning that you're looking to choose either 61.51(e)(1)(iv)(A) OR 61.51(e)(1)(iv)(B). If you read the regulation, both (A) AND (B) are requirements for logging time under 61.51(e)(1)(iv).
If you break 61.51(e)(1)(iv) down, it contains several requirements:
61.51(e)(1)(iv)(A): the person performing the duties of PIC must hold a commercial or ATP pilot certificate, appropriate to category and class: airplane, multi-engine land, or airplane, multi-engine sea)
AND
61.51(e)(1)(iv)(B): the person performing the duties of PIC must be undergoing an approved pilot in command training program (eg, airline type program).
It's the first requirement above, 61.51(e)(1)(iv)(A), which specifies that the person logging the time under 61.51(e)(1)(iv) must have a pilot certificate that is appropriate to both category (here, airplane) and class (here, multi-engine land or sea, as appropriate). Specific to your question, a person logging time under this regulation must already hold a multi-engine rating. Training toward the multi-engine rating is not pilot in command experience, even if it's part of an approved program. The requirement is category, and class. Category is airplane, and the class is multi engine (land, or sea).
It sounds like you're cherrypicking the regulation, meaning that you're looking to choose either 61.51(e)(1)(iv)(A) OR 61.51(e)(1)(iv)(B). If you read the regulation, both (A) AND (B) are requirements for logging time under 61.51(e)(1)(iv).
04-01-2023, 01:09 PM
#5
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Originally Posted by QRH Bingo
.............. 2 hrs for the ride itself, he will start with 10hrs multi, of that, 2hrs being PIC. Add 15hrs PIC after that and then there’s 25 hrs in a multi that is required for a regional and 15 PIC to add an MEI. Now, he can log PIC time while prepping for the MEI ride with an instructor so there is no need to log that 15 PIC first before starting MEI training.
04-01-2023, 11:14 PM
#6
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Originally Posted by 12oclockHi
Its disappointing in that I believe it is in some sense counter productive in producing a quality aviator as 61.63 is pretty permissive in what they allow for a class add on.
It's important to understand that flying the airplane, and logging the time, are completely different subjects. The best way to illustrate that, without breaking it down to detail, is that there are times when one can fly an airplane but not log the time, and there are times when one can fly the airplane, but log it in various ways. For example, one can be the pilot in command, and be able to log pilot in command time, but there are also times when one may be the pilot in command, but may only be able to log second in command time. There are also times when one may be the pilot in command, but may not be able to log any flight time. The reasons come down to the way in which the flight is conducted and the specifics of the operation: logging time isn't the same as flying the airplane.
One may get a add-on multi engine airplane land rating in the course of a few hours, but until the checkride, one can't log that few hours as pilot in command time, even if performing the duties of PIC under supervision. One can log it as instruction received, along with an endorsement from an authorized instructor. During the checkride, the examiner can't be the pilot in command; the student logs PIC for that time. After the student has obtained his or her multi-engine land class rating to go with his or her airplane category rating, then the door is open to logging PIC time under 61.51(e).
Originally Posted by 12oclockHi
If 61.183 didn't have the PIC requirement of the 15 hours flight time, then (I) would have no problem with a 10 hour training towards the ME. As it stands now, I will have to buy 15 hours of ME (which agreed could all be training towards the MEI) but I would have rather had him getting better at flying the AC while in the initial ME course.
Today, students are hyper-focused on getting minimum hours and trotting off to the airplanes with as little qualification as possible, for that all-important seniority number. Traditionally, this is not how it worked. A student would find a VFR job, instructing or doing tours, etc, then eventually an IFR job. The fledgling pilot might fly jumpers or two banners or do aerial photography, etc. At some point (s)he would begin doing charter or ambulance or freight and begin working up and after two or three thousand hours, find a commuter or regional, and after a few thousand hours of that, look beyond. Today, students expect to get minimal training and go to an airline and never leave that environment. There is a LOT of material and experience left behind that's never obtained. I have run into pilots who are on their third or fourth job, including individuals flying on widebody equipment, who did not know or understand what latitude/longitude was, and could not find a coordinate on a chart. It's nearly incomprehensible that anyone could reach a point beyond student pilot and not have mastered this, but we live in a world of minimal qualification and automation where students learn to follow little magenta lines on computer screens, and little else.
The hardest part of learning to fly is paying for it, and it's become quite expensive.
In the case of your son, the least expensive course is going to be to knock out multi-rating as efficiently as possible (meaning the minimum time to get the rating AND learn the material ), to enable him to begin logging multi PIC.
While the 15 hour requirement might seem like a lot (in terms of expense, think of it in terms of the student; would you prefer that your son learn to fly multi-engine airplanes from someone who has no experience in multi-engine airplanes? The nature of instruction is that it's often provided by the least experienced people in the industry; low-time pilots trying to "build hours." Inexperience teaching inexperience; a heirarchy of learning with no experience to pass along. 15 hours sounds like a lot, but it's not much experience to have, to turn around and train other multi-engine pilots. It's simply provided as a bare-minum baseline requirement before an individual is allowed to begin teaching others to fly multi-engine equipment, having just barely learned to fly that equipment himself, or herself.
Buying one's way to the 25 hour requirement has traditionally been unnecessary, because fledgling pilots would gain their initial hours instructing or doing other jobs. Today, individuals want to get to the airlines without instructing or doing other work to gain experience, and so end up buying their flight time instead of earning it by working. Consequently, it can be expensive. Personally, I'd much rather see someone go out and get experience, but today the up-and-coming are often in too big a rush to run before they can walk, and to get to an airline. A poster here once opined that everybody ought to have some experience flying ratty airplanes in the ice and weather, and other experience-building elements in their background, but it's too often missing, with folks simply buying the time. The lay of the land today, I suppose.
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