zak90272

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".

Fly Boy Knight

Could you provide a link for this particular enforcement action deposition? I, and I am sure others on this thread, am interested in reading the FAA/NTSB's rational for upholding the violation.

AOPA's website is pretty big when you search, "Logging PIC Enforcement Action."

NoyGonnaDoIt

...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.

skybob

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]


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?

Mason32

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.

skybob

I think Joe Lynch's answer covers it.

propjunkie

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.

That may happen in small 91 operations but for 121/135 the PIC (name on release) takes the heat, regardless of who has more experience.

minitour

Yeah, they legally can. Read 61.51. It says nothing about who is the PIC. It says that if you are rated or have privileges in the aircraft and you are the sole manipulator of the flight controls that you may log that time as Pilot In Command. In that situation, you are acting as SIC and manipulating the flight controls, so you may log both PIC and SIC.

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.
Maybe he meant 91k?

-mini

NoyGonnaDoIt

The only one under regular Part 91 ops is safety pilot ops under 91.109, If the safety pilot is not the one acting as PIC, he is considered to be a SIC and permitted to log it as SIC. So much so that under 61.55, if the safety pilot op is done under IFR (say in VMC but on an IFR flight plan) the safety pilot must be instrument rated.

NoyGonnaDoIt

Maybe they can't under company rules (which would not make it illegal) but they can under FAA rules.