Backseat multi-engine PIC time?
 

After a discussion today with some other CFIs, two ways were claimed to be legal ways to build Multi PIC time:

1) One CFI claimed you can fly backseat if you HAVE an MEI with another MEI and a student upfront (3 in the plane). Under this premise he stated you are the 'instructor' to the MEI in the front and that he is the students 'instructor'.

2) Another CFI stated that even if you aren't an MEI but you are multi rated, you can sit back seat, claim you are SP and log that.

#1 sounds feasible and #2 sounds far fetched. Anyone know "FAA law" on this?

JP

How exactly are you "sole manipulator of the controls" from a seat that has no controls?

I'd love to try explaining this one to a fed.

A CFI doesn't need to be sole manipulator. He only needs to be acting as an instructor. He could do that from a back seat, IMHO. This is stretching the intent of the FAR's, I think, but I see it as loggable if it's legit.

Back seat guy is a MEI and logs it as dual given. Right seat guy is safety pilot and left seat guy is sole manipulator. All three log PIC multi. Not all three are acting as PIC, though, but that's not the point.

Good point. Still don't know if I'd attempt that one for the reason you stated. Stretching things a bit there.

Give your local inspector a call and ask what he/she thinks of this proposal. They will likely have some good insight.

I would never rely on a local inspector, no matter which way they went.

Some years ago the Oakland FSDO did a program in which they isnisted that a CFI and a pilot cold not both log PIC on the same flight. A Buffalo FSDO posted on its web site that a student cross country did not count unless all legs were at least 50 NM long. Both public. Both out of the FSDO. Both wrong. Until FAA Legal stepped in, FSDOs accorss the US were going every which way about whether as CFI ride reset the BFR clock. Wrong information on regulatory interpretation, especially Part 61, has always been common.

If you look at the way 61.51 has been official interpreted, a good case could be made for the 3-pilot logging scenario. I don't think that FAA legal has passed on the issue, so we're just speculating.

FWIW, there's one that sounds legit to me: the sole manipulator-safety pilot-CFI scenario where the CFI has no medical.

It's the lack of medical that, to me, makes it legit. The CFI is allowed to teach without a medical, but not act as a safety pilot. So the addiitonal pilot is needed.

As for many of the others, my concern is not that 61.51 will be read more narrowly. It's that the whole set-up might be read as a sham. "The instructor of the instructor of the pilot"? There might be an argument if the instructor of the student was not a CFI-I and the instructor of the instructor was teaching him how to be one, but really....

I think we're getting into the territory of the case where two MEIs flew many flights together to build time and claimed that they instructed each other on every flight. Plenty of legal jargon was tossed around and there were plenty of other things going on in the final NTSB ruling, but IMO the decision that revoked all of their certificates came down to, "that's BS. Nobody believes for a second that these were instructional flights."

http://www.ntsb.gov/O_n_O/docs/AVIATION/4008.PDF

Maybe it's my browser, but this link appears either injured or dead.

Definition of PIC per FARs-
a person who:

1. Has final authority and responsibility for the operation and safety of the flight.
2. Has been designated as PIC before or during the flight.
3. Holds the appropriate catagory, class and type rating, if appropiate, for the
conduct of the flight.

Yes a pilot under certain conditions could log PIC in the back seat or as a "safety pilot", but why would you? Companys such as NetJets or JetBlue use rule #1 when looking through your logbook. Keep that in mind.

I agree with this 110%. I believe that, in the long run, you're better off accepting the more conservative and widely accepted definitions of various types of flight experience. If you have enough experience to think about it, and your gut tells you that you're in uncharted territory, assume HR and the FAA would feel the same way. Go with what's written in black and white without trying to bend it around. Then consider the spirit of the regulation as it was intended by its creators. Works everytime, right?

They changed the routing since I last accessed it. Try

http://ntsb.gov/alj/alj/O_n_O/docs/aviation/4008.PDF

To use FAA definitions to meet FAA requirements?

Then use Company A's definitions to meet Company A's requirements? And Company B's definitions to meet Company B's requirements? And Company C's definitions...?

There are so many discussions in which the advice - "log for the airlines, not the FAA" is given. Is this like the only industry where people say "don't collect the data to begin with" instead of "collect the data and then present it in the way a potential employer wants"?

Really, I've never heard a group of accountants say, "No. Don't ever work at McD's as a teenager because when you are applying for a job as an accountant, they won't think it's good experience."