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Old 04-16-2009, 01:31 PM   #1  
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Default How to log this very specific time

The situation:

1) I may be hired on at as a jump pilot, so I need to log 25 hrs of time in type to fall under the DZ's insurance.
2) Their current pilot is showing me how the plane works and the in's and out's of specifically being a jump pilot, but he is not a CFI. He will be sitting there for at least the first 25 hrs.
3) I am have a comm single, but am not single current.

I've gone over the reg's pretty thoroughly, and can't quite find anywhere that says how to log this time.

The problems:

A) How do you think I should log this time while "training"? Just log it as flight time, but not PIC or SIC or Dual Received? I believe I cannot currently log it as PIC because I am not current and there is a passenger on board (just the trainer after everyone jumps out).
B) Is it legal to not log it as PIC, but still log the landings so I can at least be current? It would be if he were a CFI, but I'm unsure if its possible to log landings not as PIC.

There are 2 obvious solutions. I go rent a 152 and CFI and go 3 times around. Or, the trainer is a CFI. Then I could log the landings as Dual Received just like I would in the 152.

Anyone got an idea or had a similar situation?
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Old 04-16-2009, 01:46 PM   #2  
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I'm assuming that insurance will require legit FAA loggable time. In a part 91 ASEL, that means PIC.

a) If you are not current in ASEL it is not loggable in the FAA sense, period. I know, I know, you can log anything you want but I would not pollute your logbook with something you will have to explain later...and will not be easily explainable.

b) Not on your life. If you were doing the landings out-of-currency with a pax on board, you are in clear violation of part 61. Another (non-CFI) pilot is just a pax in most ASEL.

Basically he is the PIC, and you are going for an airplane ride. Or you are the PIC, and violating part 61 by carrying a pax.

You need to stop everything (don't log a thing) and go get ASEL current. THEN (and only then) go fly you 25 hours with the guy. Since most ASEL doesn't require type training, you can log it even if you really don't know what you're doing as long as you're current (that's what the other guy is there for).

Might want to read up on the insurance requirements...the other guy CANNOT log PIC if you are going to do so. So you might be in violation (ie uninsured) while building time. Maybe get a letter from them saying that supervised PIC is OK.
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Old 04-16-2009, 01:51 PM   #3  
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All exactly what I figured. Just making sure I wasn't missing anything, but your understanding is the same as mine. Thanks.
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Old 04-16-2009, 06:37 PM   #4  
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Quote:
Originally Posted by 250 or point 65 View Post
I've gone over the reg's pretty thoroughly, and can't quite find anywhere that says how to log this time.
It's all in one reg - 61.51, the universal rule of logging flight time. You never have to look anywhere else unless 61.51 tells you to go there.

Using 61.51, my answers are a bit different than RickAir's.
Quote:
A) How do you think I should log this time while "training"? Just log it as flight time, but not PIC or SIC or Dual Received?
==============================
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;
==============================

Three and only three conditions to logging PIC: (1) at least a sport pilot certificate; (2) the applicable aircraft rating printed on the back of your pilot certificate (or endorsed sport pilot privileges); and (3) being the sole manipulator of the controls.

So, if you are comm single and the jump plane is a single that does not require a type rating, you can log PIC time for every .1 that you are the sole manipulator of the controls. Currency doesn't matter for logging.

==============================
61.51(h) Logging training time.
(1) A person may log training time when that person receives training from an authorized instructor in an aircraft, flight simulator, or flight training device.
==============================

You can't log dual. 61.51 says that instruction received may only be logged with an authorized instructor who endorses the instruction in your logbook. If your trainer is not a CFI, no dual.

==============================
61.57(1) ...no person may act as a pilot in command of an aircraft carrying passengers ... unless that person has made at least three takeoffs and three landings within the preceding 90 days, and -
(i) The person acted as the sole manipulator of the flight controls; and
(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required)...
==============================

The reg does not say you need to be the PIC to log the landings. And the reg does not say that you can't fly the airplane and ado the landings with someone else on board - just that you can't be the pilot in command when you do.

Is the trainer just a passenger?

Is the trainer a pilot? Is he current? Is he the one who is ACTING as PIC (responsible) during these training flights? Chances are the answer to all three is "yes." When you are at the controls, he's not the passenger, =you= are.

As the PIC, the trainer can let you be the sole manipulator of the controls.
So long as the trainer is willing to take the responsibility ob being the pilot in command of the flight while you fly and land the airplane, the time is yours to log as PIC and the landings count for currency.

That's the FAA stuff. Insurance might present different issues, but as far as the FAA is concerned, it's all legit flight time. And what I would be concerned with from a reg perspective isn't logging legit FAA time. I'd be concerned with a logbook that listed "flight time" only without also including a legit 61.51 category.
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Old 04-16-2009, 08:01 PM   #5  
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Quote:
Originally Posted by NoyGonnaDoIt View Post
It's all in one reg - 61.51, the universal rule of logging flight time. You never have to look anywhere else unless 61.51 tells you to go there. Not exactly, you have to add some other regs to determine how to log some types of flying, ie why safety pilot time is PIC.

Using 61.51, my answers are a bit different than RickAir's.


==============================
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;
==============================

Three and only three conditions to logging PIC: (1) at least a sport pilot certificate; (2) the applicable aircraft rating printed on the back of your pilot certificate (or endorsed sport pilot privileges); and (3) being the sole manipulator of the controls. aaaaand a student pilot on solo, aaaaand a CFI giving dual, aaaaand an ATP in 121.

So, if you are comm single and the jump plane is a single that does not require a type rating, you can log PIC time for every .1 that you are the sole manipulator of the controls. Currency doesn't matter for logging. I disagree with you here. Rickair is right on. There is no way that I can log or be PIC if I am not current if there are passengers on the plane. If neither of us are giving dual, one of us has to just be a passenger. I'm not allowed to carry passengers. Logging it *may* not be illegal, but it would definately be an admission of guilt.

==============================
61.51(h) Logging training time.
(1) A person may log training time when that person receives training from an authorized instructor in an aircraft, flight simulator, or flight training device.
==============================

You can't log dual. 61.51 says that instruction received may only be logged with an authorized instructor who endorses the instruction in your logbook. If your trainer is not a CFI, no dual.

==============================
61.57(1) ...no person may act as a pilot in command of an aircraft carrying passengers ... unless that person has made at least three takeoffs and three landings within the preceding 90 days, and -
(i) The person acted as the sole manipulator of the flight controls; and
(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required)...
==============================

The reg does not say you need to be the PIC to log the landings. And the reg does not say that you can't fly the airplane and ado the landings with someone else on board - just that you can't be the pilot in command when you do. I don't buy this either. Again, only one of us can be PIC at a time because neither of us are giving dual. The currency requirement is exactly that, for the time that I'm PIC, I cannot have a passenger on board.

Is the trainer just a passenger?

Is the trainer a pilot? Is he current? Is he the one who is ACTING as PIC (responsible) during these training flights? Chances are the answer to all three is "yes." When you are at the controls, he's not the passenger, =you= are. Ok, well, this would be giving dual that he's not able to give.

As the PIC, the trainer can let you be the sole manipulator of the controls.
So long as the trainer is willing to take the responsibility ob being the pilot in command of the flight while you fly and land the airplane, the time is yours to log as PIC and the landings count for currency.

That's the FAA stuff. Insurance might present different issues, but as far as the FAA is concerned, it's all legit flight time. And what I would be concerned with from a reg perspective isn't logging legit FAA time. I'd be concerned with a logbook that listed "flight time" only without also including a legit 61.51 category.
Yeah, I really don't feel comfortable putting that time down in my logbook according to your interpretations. Mr. FAA probably wouldn't buy it either. I don't feel comfortable that I could justify my logbook to a Fed with that interpretation.

My understanding of the regs was exactly as Rickair stated. What I was looking for was ANOTHER reg that may be an exemption to 61.51. Something like "supervised solo" or that a person in a management position can sign someone off for an SIC type rating. Perhaps there'd be something like that that allows a non-CFI to supervise time to achieve insurance requirements or company training requirements.
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Old 04-17-2009, 04:22 AM   #6  
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Quote:
Originally Posted by 250 or point 65 View Post
Yeah, I really don't feel comfortable putting that time down in my logbook according to your interpretations. Mr. FAA probably wouldn't buy it either. I don't feel comfortable that I could justify my logbook to a Fed with that interpretation...
Don't log anything you don't feel comfortable logging.

But you were asking what the FAA thought was legitimate to log. Those aren't my interpretations. Those are Mr. FAA's. The difference between "acting as PIC" and "logging PIC time" goes way, way back.
Quote:
Not exactly, you have to add some other regs to determine how to log some types of flying, ie why safety pilot time is PIC.
Yes, exactly. You need to go somewhere else on the safety pilot question because 61.51 tells you to go there. 61.51 tells you you can log PIC when acting as PIC in an operation that requires more than one pilot. Those other regs are telling you it's an operation that requires more than one pilot.
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Old 04-17-2009, 09:08 AM   #7  
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Quote:
Originally Posted by NoyGonnaDoIt View Post

The reg does not say you need to be the PIC to log the landings. And the reg does not say that you can't fly the airplane and ado the landings with someone else on board - just that you can't be the pilot in command when you do.

Is the trainer just a passenger?

Is the trainer a pilot? Is he current? Is he the one who is ACTING as PIC (responsible) during these training flights? Chances are the answer to all three is "yes." When you are at the controls, he's not the passenger, =you= are.

As the PIC, the trainer can let you be the sole manipulator of the controls.
So long as the trainer is willing to take the responsibility ob being the pilot in command of the flight while you fly and land the airplane, the time is yours to log as PIC and the landings count for currency.

That's the FAA stuff. Insurance might present different issues, but as far as the FAA is concerned, it's all legit flight time. And what I would be concerned with from a reg perspective isn't logging legit FAA time. I'd be concerned with a logbook that listed "flight time" only without also including a legit 61.51 category.
Maybe. The regs don't seem to specifically exclude this, but I personally would need to see an FAA legal opinion to feel comfortable. Without a written legal opinion, it seems that a particular FSDO could interpret this any way they wanted.
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