Complex time and PIC
#11
61.31(d)2. Limitations on operating an aircraft as the Pilot in Command. To serve as the Pilot in Command of an aircraft, a person must......
Be recieveing training for the purpose of obtaining an additional pilot certificate and rating that are appropriate to that aircraft, and be under the supervision of an authorized instructor.
Seems to me that according to this as long as the training is going towards their commercial pilot cert. they can log the time as PIC. As long as before they solo it or take it up with a non-instructor they get their endorsment there shouldn't be a problem.
Be recieveing training for the purpose of obtaining an additional pilot certificate and rating that are appropriate to that aircraft, and be under the supervision of an authorized instructor.
Seems to me that according to this as long as the training is going towards their commercial pilot cert. they can log the time as PIC. As long as before they solo it or take it up with a non-instructor they get their endorsment there shouldn't be a problem.
The wording looks like maybe you can log it pre-endorsement. Maybe.
But I wouldn't do it. How many hours does it take to earn a complex endorsement...maybe two or so? It would not be worth the potential confusion at a future job interview for an extra 2 hours of SE piston PIC.
But I wouldn't do it. How many hours does it take to earn a complex endorsement...maybe two or so? It would not be worth the potential confusion at a future job interview for an extra 2 hours of SE piston PIC.
I'm not sure either way.
I would give the student the choice, since there seems to be arguments on both sides.
Personally I would just log dual, not PIC, that is the safest choice.
#12
it is logged as dual recieved AND pic
I have given many tailwheel endorsements (same idea, complex, high perf etc) and every hour they are in that SINGLE ENGINE LAND airplane they are logging PIC and dual recieved.
the only time it is not PIC is if they took the plane on their own solo before the endorsement, which is not legal
I have given many tailwheel endorsements (same idea, complex, high perf etc) and every hour they are in that SINGLE ENGINE LAND airplane they are logging PIC and dual recieved.
the only time it is not PIC is if they took the plane on their own solo before the endorsement, which is not legal
#13
it is logged as dual recieved AND pic
I have given many tailwheel endorsements (same idea, complex, high perf etc) and every hour they are in that SINGLE ENGINE LAND airplane they are logging PIC and dual recieved.
the only time it is not PIC is if they took the plane on their own solo before the endorsement, which is not legal
I have given many tailwheel endorsements (same idea, complex, high perf etc) and every hour they are in that SINGLE ENGINE LAND airplane they are logging PIC and dual recieved.
the only time it is not PIC is if they took the plane on their own solo before the endorsement, which is not legal
#14
Gets Weekends Off
Joined APC: Jan 2006
Posts: 762
Here you guys go (my emphasizes added)
From the FAA Website
In this case the student does not have the privileges to operate in IMC, yet is still able to log the time as PIC.
They cannot ACT as PIC but can LOG PIC, there is a very distinct difference between the two.
The FAA interpretation that prompted this column addresses an interesting question, and in doing so focuses on the difference between logging PIC time and acting as PIC. The situation presented to the FAA was that of a private pilot with an airplane single-engine land rating who is receiving training in a complex or high-performance airplane specifically for the purpose of complying with these additional training requirements. The question is: May the pilot log the training time as pilot in command even though the pilot does not yet meet the requirements of FAR 61.31(e) or (f)? The FAA answered the question, "Yes," such a pilot may log the training time as PIC during the time that he or she is the sole manipulator of the controls.
In reaching this answer, the FAA referred to FAR 61.51(e), which governs the logging of pilot-in-command time. It says that a recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. The term rated refers to the pilot holding the appropriate aircraft rating (category, class, and type, if a type rating is required). In the situation presented, the private pilot had an airplane single-engine land rating, and so may log the time as PIC.
The interpretation was careful to draw the distinction between acting as pilot in command and logging pilot-in-command time. This is a subtle distinction not always well understood in the pilot community, except among those involved in flight training. The FAA explained that in order to act as pilot in command (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a person must not only be properly rated in the aircraft but must also be authorized to conduct the flight. In order to log PIC time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.
Article
In reaching this answer, the FAA referred to FAR 61.51(e), which governs the logging of pilot-in-command time. It says that a recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. The term rated refers to the pilot holding the appropriate aircraft rating (category, class, and type, if a type rating is required). In the situation presented, the private pilot had an airplane single-engine land rating, and so may log the time as PIC.
The interpretation was careful to draw the distinction between acting as pilot in command and logging pilot-in-command time. This is a subtle distinction not always well understood in the pilot community, except among those involved in flight training. The FAA explained that in order to act as pilot in command (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a person must not only be properly rated in the aircraft but must also be authorized to conduct the flight. In order to log PIC time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.
Article
A private or commercial pilot may log PIC time if that person is "the sole manipulator of the controls of an aircraft for which the pilot is rated" [61.51 (e)(1)(i)]
Thus a non-instrument rated pilot taking instrument flight instruction, if rated in the aircraft, may log PIC based on the "sole manipulator of the controls" rule. Since there is nothing in the rules that addresses meteorological conditions, the pilot may log PIC while in the clouds. This is supported by FAA chief counsel opinions [Federal Regulations Explained-Jeppesen].
Article
Thus a non-instrument rated pilot taking instrument flight instruction, if rated in the aircraft, may log PIC based on the "sole manipulator of the controls" rule. Since there is nothing in the rules that addresses meteorological conditions, the pilot may log PIC while in the clouds. This is supported by FAA chief counsel opinions [Federal Regulations Explained-Jeppesen].
Article
They cannot ACT as PIC but can LOG PIC, there is a very distinct difference between the two.
Last edited by NE_Pilot; 10-20-2007 at 09:01 AM.
#15
Gets Weekends Off
Joined APC: Jan 2006
Posts: 762
I'm sure this has been discussed before but does that apply to Student Pilot certificates? Meaning that a student pilot (Pre-private) logs dual and PIC while working toward their Private? Or do you not log PIC until after you have received your Private and are pursuing Instrument, Comm, etc.?
A holder of a Student Pilot Certificate may only log PIC when solo (and is legal to solo with the correct and current endorsements) or on the checkride. Other than that it is all Dual time since the student is not properly rated in the aircraft.
#16
If a pilot can't log PIC while training for the high-performance or tailwheel endorsements, a pilot would also be unable to log PIC during a BFR. Most wouldn't think twice about the latter scenario. It falls in the same general pattern. We log the BFR as PIC and either get a signoff or don't.
#17
If a pilot can't log PIC while training for the high-performance or tailwheel endorsements, a pilot would also be unable to log PIC during a BFR. Most wouldn't think twice about the latter scenario. It falls in the same general pattern. We log the BFR as PIC and either get a signoff or don't.
#18
Thanks NE, appreciate it! But it is okay for both the CFI and the student to log PIC once the student has their Private (ie: is rated to fly the aircraft)
#19
#20
Gets Weekends Off
Joined APC: Jan 2006
Posts: 762
Yes, that is one of the situations where both pilots can log PIC, the CFI is the acting PIC (i.e. if something goes wrong it is on their certificate), whereas the student is logging PIC since they are the sole-manipulator of the controls for an aircraft which they are rated to fly.
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