Ahhhh ok. I see it now. You are 100% correct. Thanks man!

 

Don't feel bad, you aren't the first one to get confused on it. The PDP has made it worse IME for confusion.

 

14 CFR 61.159(a) states the requirement for pilot time, and 61.1 defines pilot time.

https://www.ecfr.gov/current/title-1...section-61.159

https://www.ecfr.gov/current/title-1...t-61/subpart-A

 

A much more interesting angle to pilot time IMO is whether you can credit UAS time towards the hour requirements of 135.243. While 61.8 says any Part 107 activity is not applicable to Part 61...we aren't talking about Part 61 anymore. The 135 reg says "x hours as a pilot", pretty open-ended. It's not even saying "pilot time".

 

Same applicability. Time as pilot, pilot time: either requires documentation and 14 CFR 61.51 spells out the logging, or documentation, of time as pilot or pilot time. 61.8 excludes UAS pilot time from Part 61, to include the logging of pilot time.

Moreover, Part 107 also provides an exclusion from that entire chapter, from air carrier operations:

https://www.ecfr.gov/current/title-1...ter-F/part-107
There is, thus, a double-exclusion if you will, to the use of Part 107 UAS "pilot" time toward 135.243, as well as other pilot certification and privilege, such as the ATP requirements of this thread. Part 107 contains no provision for logging pilot time or pilot-in-command time of any kind; neither a definition of that time, nor a logging requirement or regulation. 61.51 has so such provision. There's no legal basis to present UAS experience as pilot experience toward 135.243, or any other airman rating, or operating privilege or requirement.

While 135.243 is not found in Part 61, obviously, the requirement to document pilot time is found in Part 61, and thus 61.51 is directly applicable to determining the meaning of pilot experience requirements stated under 135.243.

 

Correct, this is the policy-read on it currently. I just thought it was an interesting angle because a few people had asked the question and I expect we'll see it more attempting to credit it more frequently now.

 

Stupid is as stupid does...I received a resume some years ago from someone claiming experience with an airline of which I'd never heard. Curious, I contacted the applicant directly to enquire. It was a "virtual airline," he said. I'd not heard of such a thing at the time, but was as it sounds: an imaginary airline that existed in virtual reality. He'd dress up in a pilot costume and get on his home computer at a scheduled time, as would someone else somewhere else in the country, and they'd "operate" a trip using some computer game software, as though they were actually flying a trip. He was logging the time.

He seemed shocked that I wouldn't accept that experience toward a job as a pilot. He had, after all, thousands of hours as a "virtual" airline pilot. No ATP, of course, but apparently a very nice costume and what he said was very realistic software.

There's always the Parker Pen crowd that logs time in airplanes that they see through the fence, and one might log paper airplane time. If I have enough time in freefall as a body-pilot, or under a parachute as a canopy-pilot, ought that not count? How about those falling-dreams, so long as one remembers to wake up? There's always logging time while driving, with an advanced-technology vehicle. That's one that uses GPS on a cell phone, to find the library, and of course, drives itself on autopilot.

A certain percentage of pilots have a lot of hours logged from...the bunk. Oddly, the logbooks don't break it down to bunk time, or even cite which one. At a minimum, that ought to be instrument conditions, once the light goes out...

 

I forget the airline but a new hire said he'd been flying at the base Aero Club while on active duty. It had come up during his interview. Someone, for reasons unknown, had decided to look into his Aero Club logged flight time. I don't recall if that occurred before or after he was hired but the answers came back after he'd been hired. He hadn't been a member of the Aero Club, hadn't flown airplanes there, and if I'm recalling correctly would check out the Aero Club planes flying while sitting on alert and would log them as his flights. Turns out he'd logged time and the investigation contacted guys who'd actually flown the plane that day that he'd logged for himself. Oops. Fired. The crazy part is he would have gotten hired without the fraudulent time. Everyone knows everyone, with 6 degrees of Kevin Bacon, in the flying business.

 

He should have gotten some points for originality though...that's pretty bold.

 

The classic urban legend that hung on forever was the parker-pen guy that showed up at a FSDO for a checkride with his logbooks, and was asked about a particular airplane in the log. The applicant insisted he'd flown the airplane, but was distressed to learn that the airplane he claimed to have logged time in belonged to the FAA inspector administering the practical test...and that inspector hadn't loaned his airplane to anyone. If one's going to falsify the time, one should at least take care to ensure the falsified time isn't in an airplane belonging to the inspector.

The story was cute, but suspect because a) everyone claimed to know of such a case; b) it persisted for decades and at every telling had "only just happened," and c) most inspectors couldn't afford an airplane. I did, however, know of one case in which it happened, though I don't know if the inspector actually owned the airplane, or just knew it well enough to know that the applicant didn't have time in that specific N-number.

I have seen an inspector measure routes in a logbook against a sectional chart to see if they met the cross country distance minimums, and dismiss an applicant because the inspector determined that the applicant lacked the necessary experience to apply, based on disqualifying the applicant's cross-country experience. That's a case of actual time logged, not being accepted which is similar to the concept of the original poster, as opposed to time that's completely falsified. I have also run into applicants (job-seekers) over the years who lacked qualification by logging incorrectly, or who had outright falsified their experience and were caught: claiming to have flown a particular job that they didn't fly, or aircraft, or background. I'm sure anyone who has done a sim pre-evaluation of screening has run into an applicant who claimed experience, but couldn't fly their way our of a wet paper bag, let alone the ubiquitous takeoff, hold, approach, missed scenario. I've seen it in live screening flights, too; enough to know it's not such an isolated thing as to be rare.

I knew the assistant chief pilot at a 135 operation years ago, who applied for work across town. I was at the location where a sim check was to be given him, and happened to see his picture on the wall of a flight school that ran the sim. Based on the date on his solo picture on the wall, all his stories and experience were false, and he flunked the sim check. I sat in on his interview, and his lack of experience showed up in the responses to questions. Likewise, I knew an applicant for a 121 position, who ultimately was fired, who claimed 1000 hours in a Hawker, when the applicant had worked as a receptionist for the firm with the Hawker...and didn't actually fly the airplane. The same applicant claimed helicopter time doing traffic watch, but couldn't talk on the radio, and while claiming 2,500 hours, turned out to have received the commercial certificate only two years prior. I'm sure anyone who has evaluated applicants has seen the same sort of thing.

I was present for the screening of an applicant in a tailwheel airplane many years ago, for a government operation, that required a unique combination of experience; utility tailwheel, low altitude, dispensing, and instrument work. Not a lot of applicants had that combination, and the flight screening was given in an armored S2R thrush airplane. This applicant struggled to taxi initially, and didn't know he had to put the stick forward to unlock the tailwheel: telling, given his claims of experience. Ultimately, he stacked the airplane up during the checkride, wrecking the only airplane available to do screening for applicants at the time; an expensive way to find out he lacked the experience to do the job. Not the first time I've seen that, and I'm sure, not the last.

So far as an applicant with UAS experience seeking a certificate, rating, or job, while the regulation seems clear on the matter, I think there's room for shades of grey in the experience; someone operating a more substantial reaper or global hawk isn't in the same experience category, practically speaking, as someone who's been flying their kid's quad-copter around the neighborhood. I don't know enough about the training and experience of a Global Hawk pilot to judge the applicability. I know RQ4 pilots at Beale were getting some aero club experience in a 172 to get a little exposure to actually flying, so not really a lot of practical experience even in the sophisticated unmanned equipment. I'm sure that as time goes on, the lines between unmanned and manned will begin to blur.