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Old 09-10-2019, 04:36 PM   #1  
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Question Logging PIC time in 91/135 vs 121

Questions with regards to logging PIC time in the 91/135 world vs 121. I've heard that the airlines wants to see PIC time as "Captain Time" only, not necessarily counting "sole manipulator of the controls" time and I'm wanting to ensure my logbook is absolutely correct. Here are a few examples:

1) Private pilot flying in a C172 with an instructor. Can the student (who is a Private Pilot) log PIC and Instruction Received?

2) Two appropriately rated pilots fly a Part 91 leg in a non-type required King Air 90. Can the FO (who is PF) log PIC time?

3) Two PIC typed pilots fly a Part 91 leg in a type required jet. Can the FO (who is PF) log PIC time?

Until now I have kept a separate column for "Captain of Record." Just wondering where the airlines stand on logging PIC time without being labeled Captain of the trip.
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Old 09-10-2019, 05:08 PM   #2  
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1) Private pilot flying in a C172 with an instructor. Can the student (who is a Private Pilot) log PIC and Instruction Received?
Yes.

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2) Two appropriately rated pilots fly a Part 91 leg in a non-type required King Air 90. Can the FO (who is PF) log PIC time?
So yes, per the FAA since you're "Sole Manipulator." Per the airlines I think also yes. Only the PF in this case would log PIC time and the PM wouldn't be able to log anything. Unless the PM is an MEI and performing dual given.

I think there are some caveats for if an SIC is required per the operating certificate or insurance you can log SIC time.

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3) Two PIC typed pilots fly a Part 91 leg in a type required jet. Can the FO (who is PF) log PIC time?
The PIC would be the captain even if you're flying as the FO period is my understanding. Sure technically it's PIC per the FAA's definition but airlines would not count that as PIC because as the FO you are not the "Captain of Record."

I think the black and white answer is when you're Captain of Record in the left seat you can log PIC. I can log "PIC" time as a FO for my regional when it's my leg, but no way a major would accept that. "Captain" time is all that matters.
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Old 09-10-2019, 07:25 PM   #3  
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The majors/legacies (at least some of them) specify the type of PIC time they want for their minimums. A few of them want actual PIC information, as in you are signing for and ultimately in charge of the aircraft. Not a bad idea to keep them separate to make it easier down the road.
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Old 09-10-2019, 11:29 PM   #4  
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Yes.


So yes, per the FAA since you're "Sole Manipulator." Per the airlines I think also yes. Only the PF in this case would log PIC time and the PM wouldn't be able to log anything. Unless the PM is an MEI and performing dual given.

I think there are some caveats for if an SIC is required per the operating certificate or insurance you can log SIC time.



The PIC would be the captain even if you're flying as the FO period is my understanding. Sure technically it's PIC per the FAA's definition but airlines would not count that as PIC because as the FO you are not the "Captain of Record."

I think the black and white answer is when you're Captain of Record in the left seat you can log PIC. I can log "PIC" time as a FO for my regional when it's my leg, but no way a major would accept that. "Captain" time is all that matters.
I can be just as wrong as the next guy, but I only counted PIC if I was the only pilot or the Captain. So far that has worked for me...
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Old 09-11-2019, 02:51 AM   #5  
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Here is a little secret: There will never be an investigation into your PIC time unless you have an accident or are bragging to your buddies at the bar about how you cheated on PIC time.

I had peers at the same airline who ended up getting way more instrument time than me. After a while I figured out that they were a lot more liberal in their counting of instrument hours than I was.

Unfortunately, insurance companies now dictate what planes we can fly, when we can fly them, and what kind of future you will have.

If I had a nickle for every dumb insurance hour requirement I saw, I would be a millionaire.
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Old 09-11-2019, 04:42 AM   #6  
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I think there are some caveats for if an SIC is required per the operating certificate or insurance you can log SIC time.
If 135 OPS Spec requires an SIC then yes you could log it.

If insurance requires an SIC or the boss wants an SIC or the mailmanís uncles Dr.ís brother in law wants an SIC, etc. you can not log it. Has to be required per regulations. Anything else does not matter including insurance.

If itís a KA 350 and the PIC does not require an SIC per his Type Rating but the company installs one of the baggage area seats (does not have to be occupied), then an SIC is required (10 pax seats) and can log the time. Or in the standard configuration (9 pax seats), if the autopilot is MELíd inop then an SIC is required and can log the time (autopilot in lieu of SIC).
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Old 09-11-2019, 05:10 AM   #7  
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Quote:
Originally Posted by gordonam View Post
Questions with regards to logging PIC time in the 91/135 world vs 121. I've heard that the airlines wants to see PIC time as "Captain Time" only, not necessarily counting "sole manipulator of the controls" time and I'm wanting to ensure my logbook is absolutely correct. Here are a few examples:

1) Private pilot flying in a C172 with an instructor. Can the student (who is a Private Pilot) log PIC and Instruction Received?

2) Two appropriately rated pilots fly a Part 91 leg in a non-type required King Air 90. Can the FO (who is PF) log PIC time?

3) Two PIC typed pilots fly a Part 91 leg in a type required jet. Can the FO (who is PF) log PIC time?

Until now I have kept a separate column for "Captain of Record." Just wondering where the airlines stand on logging PIC time without being labeled Captain of the trip.
For part 135 there are loopholes that allow you to log sole manipulator time as PIC but part 121 is a different ballgame.

The PIC has the final authority over the operation of the aircraft, is listed as PIC on the release, signs for the aircraft, is the in flight security coordinator etc. Just because you're typed in the aircraft and are manipulating the controls doesn't mean you're the PIC.

If you're an F.O. at a 121 carrier but are logging PIC time you will have a lot of explaining to do at a major carrier interview.
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Old 09-11-2019, 06:49 AM   #8  
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Hereís one: anyone else ever been the legal PIC and unable to log the time? E.g. single pilot airplane on a 91 repo leg where the SIC is PF?
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Old 09-11-2019, 07:56 PM   #9  
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If 135 OPS Spec requires an SIC then yes you could log it.

If insurance requires an SIC or the boss wants an SIC or the mailmanís uncles Dr.ís brother in law wants an SIC, etc. you can not log it. Has to be required per regulations. Anything else does not matter including insurance.

If itís a KA 350 and the PIC does not require an SIC per his Type Rating but the company installs one of the baggage area seats (does not have to be occupied), then an SIC is required (10 pax seats) and can log the time. Or in the standard configuration (9 pax seats), if the autopilot is MELíd inop then an SIC is required and can log the time (autopilot in lieu of SIC).
Almost. Part 135 passenger ops always requires an SIC (135.101), no matter the seats, UNLESS the operator has OPSPEC A015 which allows an autopilot in lieu of SIC AND the aircraft has 9 passenger seats or less. (135.105)
If the aircraft has more than 9 passenger seats, you canít use A015 and therefore an SIC is always required. 135.99 (b)
My company doesnít have A015 therefore, under 135, an SIC is required even though we only have 9 passenger seats.
In other words, the regulations require an SIC. The OPSPECS give you relief under A015.
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Old 09-11-2019, 09:07 PM   #10  
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Almost. Part 135 passenger ops always requires an SIC (135.101), no matter the seats, UNLESS the operator has OPSPEC A015 which allows an autopilot in lieu of SIC AND the aircraft has 9 passenger seats or less. (135.105)
If the aircraft has more than 9 passenger seats, you canít use A015 and therefore an SIC is always required. 135.99 (b)
My company doesnít have A015 therefore, under 135, an SIC is required even though we only have 9 passenger seats.
In other words, the regulations require an SIC. The OPSPECS give you relief under A015.
That pretty much sums it up for 135. Good summary with the references.

As for 91, you can go to the FAAís Chief Counsel webpage and look up the Cato, Nichols, and Herman Letters of Interpretation and get your answers from the proverbial horseís mouth.
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