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Originally Posted by Mason32
(Post 723905)
He can not.
If he is flying as an SIC and the operators Operations Specifications require an SIC, then he can not by definition be PIC. There is tremendous case law available on this, and a fairly well documented enforcement action involving a King Air 200 (also certified for single pilot) but the company Ops Specs required two pilots. The FO was logging time as sole manipulator of the controls on the part 91 legs. Some six months after being employed there, a minor gound incident - not with the FO controlling - resulted in the company records being looked at including the logbooks of both pilots. The FO was violated for EACH time he signed his name to a logbook page with PIC time listed for the part 91 King Air legs. His case was appealed tot he full NTSB panel, and the FAA's suspension was upheld. The entire case, and many others, are available on the AOPA website in their legal case studies section. Go ahead and log it if you like; but the case law is not on your side. Very interesting, but this goes against everything i have been told at my company. (not by the company but by other pilots working there) we fly a part 91 whose OPS specify 2 pilots though two pilots are not required to fly the plane. it seems that by majority agreement the PICs log all flight time as PIC, but the FOs have been logging SIC except for the time they are sole manipulator of the controls; for that time they are logging PIC. as we have seen on this thread, there are those who think this is acceptable and those who dont. im not sure i know the answer either. but i put this question to you based on some other case law and written accounts of incidents i have read about in AOPA magazine: no matter who is actually the PIC and no matter who is actually at the controls, it seems that the person the NTSB goes after after an accident is the person on board with the most experience in the plane, even if that person is in the back seat without access to the flight controls; (and i put this question to my FOs) if my FO has more ratings and experience than i do, although im the PIC and theyre the SIC do they really think it is my ticket on the line or is the SIC liable to catch the blame for a mistake i make only because they have more time than i? i can tell you, that if i stand to take the blame in any situation while i am in a plane that i am rated to fly i think i should be allowed to log that time as PIC. i took a friend of mine flying in my plane (he has 20k+ hours) and i asked him if i were to crash the plane or bust bravo etc. who did he think the FAA or NTSB would come after. his answer was "him". |
Originally Posted by Mason32
(Post 723905)
He can not.
If he is flying as an SIC and the operators Operations Specifications require an SIC, then he can not by definition be PIC. There is tremendous case law available on this, and a fairly well documented enforcement action involving a King Air 200 (also certified for single pilot) but the company Ops Specs required two pilots. The FO was logging time as sole manipulator of the controls on the part 91 legs. Some six months after being employed there, a minor gound incident - not with the FO controlling - resulted in the company records being looked at including the logbooks of both pilots. The FO was violated for EACH time he signed his name to a logbook page with PIC time listed for the part 91 King Air legs. His case was appealed tot he full NTSB panel, and the FAA's suspension was upheld. The entire case, and many others, are available on the AOPA website in their legal case studies section. AOPA's website is pretty big when you search, "Logging PIC Enforcement Action." |
Originally Posted by zak90272
(Post 723947)
it seems that by majority agreement the PICs log all flight time as PIC, but the FOs have been logging SIC except for the time they are sole manipulator of the controls; for that time they are logging PIC.
Even for people who think they understand the FAA's separation between logging flight time and the capacity in which one acts as a crewmember or passenger, it's questions like this that show that the concept remains a difficult one. My bad example of properly logging an illegal activity is really just an illustration of that. To really understand it, one has to finally grasp that the flight time boxes in 61.51 are independent of any operational regulations other than ones that 61.51 tells you to look at. For example, 61.51(e)(1)(i) says: ============================== (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights- (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated... ============================== That's a clear box: At least for recreational pilots and above, appropriate aircraft rating + sole manipulator = permission to log PIC time. There are no other conditions. It doesn't say, for example ============================== When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated... unless he's the SIC in a Part 135 operation ============================== or, to be completely ridiculous, even ============================== When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, unless it's a stolen airplane ============================== It really is that simple and there's more that 20 years of consistent FAA Chief Counsel opinion that says so. But the FAA's decision to use the term PIC to mean two completely different things depending on whether the context is operating or logging will probably always give people trouble. |
QUESTION: What would the FAA expect to see as proof to verify that the time was honest “. . . second in command performing the duties of pilot in command while under the supervision of a pilot in command . . .” in § 61.159(a)(4)?
ANSWER: Ref. § 61.159(a)(4); The SIC should have the real PIC endorse each entry in his/her logbook or training record when “. . . performing the duties of pilot in command . . .” as follows: Recommended Endorsement: “Performed duties as a supervised PIC in accordance with § 61.159(a)(4)” John T. Realpic, ATP #123456789 QUESTION: How would the pilot log the time when the pilot is the “ . . . second in command performing the duties of pilot in command while under the supervision of a pilot in command . . .” in § 61.159(a)(4)? ANSWER: Ref. § 61.159(a)(4); As for how the time would or could be logged, that time would still only be able to be logged as SIC time. As shown in the answer above, the SIC should have the real PIC would endorse each entry in his/her logbook or training record as follows: Recommended Endorsement: “Performed duties as a supervised PIC in accordance with § 61.159(a)(4)” John T. Realpic, ATP #123456789 [FONT='Times New Roman','serif']FREQUENTLY ASKED QUESTIONS[/font] 14 CFR, PART 61 ARRANGED BY SECTION CHANGE NOTICE General Aviation and Commercial Division, AFS-800 John D. Lynch, E-Mail: [email protected] Phone: (202) 267-3844 It appears that the time must still be logged as SIC and remarks made that it was acting as PIC in comment section. However, I have never seen anyone try to follow these procedures. Has any PIC here ever had an SIC ask for this endorsement? If so, were you willing to sign it or were you concerned about liabilty? |
Originally Posted by NoyGonnaDoIt
(Post 724235)
...which they may do under the "sole manipulator" clause.
Even for people who think they understand the FAA's separation between logging flight time and the capacity in which one acts as a crewmember or passenger, it's questions like this that show that the concept remains a difficult one. My bad example of properly logging an illegal activity is really just an illustration of that. To really understand it, one has to finally grasp that the flight time boxes in 61.51 are independent of any operational regulations other than ones that 61.51 tells you to look at. For example, 61.51(e)(1)(i) says: ============================== (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights- (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated... ============================== That's a clear box: At least for recreational pilots and above, appropriate aircraft rating + sole manipulator = permission to log PIC time. There are no other conditions. It doesn't say, for example ============================== When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated... unless he's the SIC in a Part 135 operation ============================== or, to be completely ridiculous, even ============================== When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, unless it's a stolen airplane ============================== It really is that simple and there's more that 20 years of consistent FAA Chief Counsel opinion that says so. But the FAA's decision to use the term PIC to mean two completely different things depending on whether the context is operating or logging will probably always give people trouble. By your reasoning they should be able to, yet they can't. |
I think Joe Lynch's answer covers it.
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Originally Posted by zak90272
(Post 723947)
Very interesting, but this goes against everything i have been told at my company. (not by the company but by other pilots working there) we fly a part 91 whose OPS specify 2 pilots though two pilots are not required to fly the plane.
it seems that by majority agreement the PICs log all flight time as PIC, but the FOs have been logging SIC except for the time they are sole manipulator of the controls; for that time they are logging PIC.
Originally Posted by zak90272
(Post 723947)
no matter who is actually the PIC and no matter who is actually at the controls, it seems that the person the NTSB goes after after an accident is the person on board with the most experience in the plane, even if that person is in the back seat without access to the flight controls; (and i put this question to my FOs) if my FO has more ratings and experience than i do, although im the PIC and theyre the SIC do they really think it is my ticket on the line or is the SIC liable to catch the blame for a mistake i make only because they have more time than i?
i can tell you, that if i stand to take the blame in any situation while i am in a plane that i am rated to fly i think i should be allowed to log that time as PIC. i took a friend of mine flying in my plane (he has 20k+ hours) and i asked him if i were to crash the plane or bust bravo etc. who did he think the FAA or NTSB would come after. his answer was "him". |
Originally Posted by Mason32
(Post 724318)
Really? Perhaps you could explain the several companies, majors included, where all pilots are typed on the aircraft, yet FO's may not legally log PIC time on their legs....
By your reasoning they should be able to, yet they can't. Personally, I found the best way was to add a column to my electronic logbook titled "Part 1 PIC" for when I'm actually the boss. When I'm manipulating the flight controls, the time goes into "PIC" column and when it comes time for applications and interviews, you just sort it out accordingly. But legally, yes...the typed FO may log PIC time per 61.51.
Originally Posted by propjunkie
(Post 724457)
I am a little skeptical about logging SIC on a single pilot airplane operated under part 91. there are no "legal" opspecs that require an sic.
-mini |
Originally Posted by propjunkie
(Post 724457)
I am a little skeptical about logging SIC on a single pilot airplane operated under part 91. there are no "legal" opspecs that require an sic.
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Originally Posted by Mason32
(Post 724318)
Really? Perhaps you could explain the several companies, majors included, where all pilots are typed on the aircraft, yet FO's may not legally log PIC time on their legs....
By your reasoning they should be able to, yet they can't. |
I can only speak for myself. I know what the FAA defines as PIC under 61. I however became a pilot as a carrier, that being said I began logging time under the most conservative interpritation of all of the definitions having been described to me as what a PIC is (when I am assigned by a company to act as PIC of an aircraft) I realize that this is just my standard for myself, but every interview I have every done was made very easy by only logging PIC in this manor. When the question gets asked about PIC time I could answer with confidence that I was asssigned the PIC by a company I was flying for. (it also makes filling out applications real easy as well) I let the lawyers figure out all the legal jargin, I just fly airplanes.
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Logging PIC
I too am confused between the FARs and what actually occurs in reality. In my company many of the pilots have operated the King Air 200 single piloted for years. But when they fly with certain customers on board, the contract dictates two pilots. Some have said both qualified captains log PIC. I am not too comfortable with that myself. Therefore, I chose to log PIC when the company assigns me as the PIC for the day or a particular leg to be flown. I too feel this is conservative even if I do 50% of the flying and take an approach to landing. However, it would be easier to explain under scrutiny. I think at this juncture of most of our careers (judging from the experience I read) we are not looking for every .1 of PIC we can get.
The only real question I have is when flying with an instructor or check airman are they logging PIC time or can they log I time and let you legally log PIC time?:confused: |
Originally Posted by Climbto450
(Post 724482)
I can only speak for myself. I know what the FAA defines as PIC under 61. I however became a pilot as a carrier, that being said I began logging time under the most conservative interpritation of all of the definitions having been described to me as what a PIC is (when I am assigned by a company to act as PIC of an aircraft) I realize that this is just my standard for myself, but every interview I have every done was made very easy by only logging PIC in this manor. When the question gets asked about PIC time I could answer with confidence that I was asssigned the PIC by a company I was flying for. (it also makes filling out applications real easy as well) I let the lawyers figure out all the legal jargin, I just fly airplanes.
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Originally Posted by propjunkie
(Post 724617)
Well said. There truly should only be 1 person at a time logging PIC, anything other than that is a true manipulation of the FAR's and going to be hard to explain in an interview.
Bottom line: If you already have your ATP it doesn't matter. Your PIC time, from an FAA standpoint is irrelevant. There aren't any FAA currency requirements I know of that require PIC time and you might as well log per what the airlines will want you to tell them on an application (assuming they are consistent with each other; if not you might as well have a dozen logbooks). OTOH, if you are still a low-timer working on your instrument rating, commercial or ATP, you're only short-changing yourself. If you want to fly and pay for extra hours instead of using the FAA's rules to meet the FAA's requirements that's absolutely your prerogative. But, with all the anti-PFT sentiment around, it's seems to me to be a little ironic to force yourself to pay for those extra hours if you don't have to. |
Originally Posted by GWW5
(Post 724530)
I too am confused between the FARs and what actually occurs in reality. In my company many of the pilots have operated the King Air 200 single piloted for years. But when they fly with certain customers on board, the contract dictates two pilots. Some have said both qualified captains log PIC. I am not too comfortable with that myself.
Therefore, I chose to log PIC when the company assigns me as the PIC for the day or a particular leg to be flown. |
Originally Posted by NoyGonnaDoIt
(Post 724682)
Here's the weird part: You may be violating the FARs and falsifying your logbook if you are not also the pilot flying. That's not really very conservative.
Ref. 61.51 (E) (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted |
Originally Posted by Mason32
(Post 723905)
He can not.
If he is flying as an SIC and the operators Operations Specifications require an SIC, then he can not by definition be PIC. There is tremendous case law available on this, and a fairly well documented enforcement action involving a King Air 200 (also certified for single pilot) but the company Ops Specs required two pilots. The FO was logging time as sole manipulator of the controls on the part 91 legs. Some six months after being employed there, a minor gound incident - not with the FO controlling - resulted in the company records being looked at including the logbooks of both pilots. The FO was violated for EACH time he signed his name to a logbook page with PIC time listed for the part 91 King Air legs. His case was appealed tot he full NTSB panel, and the FAA's suspension was upheld. The entire case, and many others, are available on the AOPA website in their legal case studies section. Go ahead and log it if you like; but the case law is not on your side. |
Originally Posted by NoyGonnaDoIt
(Post 724682)
Good. You should be.
Here's the weird part: You may be violating the FARs and falsifying your logbook if you are not also the pilot flying. That's not really very conservative. What I was implying before is that these guys feel that when we are not flying a sortie for a customer whose contracts stipulates two pilots then the King Air reverts back to a single piloted aircraft as it was type certificated that way. And therefore, only one pilot can legally log the PIC time. The contradictory opinion of some at the office is that because there are two type rated captains (we fly the king airs over 12,500 lbs often) that both can log the PIC time whether or not the mission has a requirement for two pilots. Thoughts? and thank you for clarification. I have spent the majority of my time flying military hardware and am delving into the FAR/AIM slowly. |
Originally Posted by GWW5
(Post 724530)
I too am confused between the FARs and what actually occurs in reality. In my company many of the pilots have operated the King Air 200 single piloted for years. But when they fly with certain customers on board, the contract dictates two pilots. Some have said both qualified captains log PIC. I am not too comfortable with that myself. Therefore, I chose to log PIC when the company assigns me as the PIC for the day or a particular leg to be flown. I too feel this is conservative even if I do 50% of the flying and take an approach to landing. However, it would be easier to explain under scrutiny. I think at this juncture of most of our careers (judging from the experience I read) we are not looking for every .1 of PIC we can get.
The only real question I have is when flying with an instructor or check airman are they logging PIC time or can they log I time and let you legally log PIC time?:confused: A Co-Captain situation would not warrant both pilots logging PIC time concurrently. "Some have said both qualified captains log PIC." Wrong, unless in a flight training scenario. (Part 61/91) |
Thank you for the clarification.
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Originally Posted by GWW5
(Post 724903)
So do you think then it is ok to not only log PIC time when you sign the release form but also if you are assigned as the FO for the leg/day for the time you are manipulating the controls?
61.51(e)(1)(iii) allows a pilot to log PIC time "When the pilot ...acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted..." In addition, an ATP may log PIC time any time acting in command of a flight operation that requires an ATP under 61.51(3)(2) So the "real" PIC can always log PIC time when he or she is in command of a required multi-pilot crew, whether the requirement for more than only pilot is because of aircraft certification or regulatory operational requirements (including OpSpecs that require 2-pilot crews). Fortunately that's going to cover the PIC most typical 135 and all 121 operations. There are a number that can fall between regulatory cracks. For example, a Part 135 cargo flight in a single-pilot-certified aircraft without an OpSpec that requires (not authorizes, requires) a second pilot. In those situations, at least in theory, the only pilot authorized by the regs to log anything is the pilot who is doing the flying. Seems silly, but remember that this is the same reg that allows more than one pilot to log PIC at a time. |
Yeah, have to read and digest this one a bit. It's tough when all of us are ATPs, Captains and type rated in the aircraft as well as the regs requiring two pilots.
Have to admit the way we did it flying C-12s in the Navy was easier. If you signed for the plane you log PIC time. Even if I was an instructor on board but not doing an instructional hop flying SIC I just logged SIC. This was the case even though I might have been flying with a junior Captain and most likely passing on knowledge. So in situation 1 you are basically saying that 95% of the time whomever signs the plane out as the PIC should log it when the mission dictates two rated pilots are required and the other guy sucks it up and logs SIC. However, the FO could legally log PIC as well when he is manipulating the controls. That's too much time to keep track of personally. But hey.. In situation 2: If two pilots aren't required and it's a single piloted certified aircraft like our King Air 200s then only the time when actually manipulating the controls is logged as PIC. That makes sense. Thanks again. |
I think the differing viewpoints in this thread are directly related to some not understanding the difference between acting as PIC and merely logging PIC time and when each are allowed.
-mini |
Originally Posted by minitour
(Post 725282)
I think the differing viewpoints in this thread are directly related to some not understanding the difference between acting as PIC and merely logging PIC time and when each are allowed.
-mini To take it out of the Part 135 context for a moment, I know you've come across threads by UND private pilots saying that UND won't "allow" them to log PIC when receiving instruction. It's hard get past the idea that your school's (or your company's) rules are not the FAA's. |
Originally Posted by NoyGonnaDoIt
(Post 725387)
I know you've come across threads by UND private pilots saying that UND won't "allow" them to log PIC when receiving instruction.
-mini |
Originally Posted by minitour
(Post 725520)
I haven't, but if I were at UND, I'd tell them to pound sand.
-mini |
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