Logging PIC time
 

So I had a question on this that I was pondering. Lets say that I was flying in a caravan as part of a 135 operation in the right seat. Obviously it doesn't require a type. Lets say I have 1000 hours. I know you need the 1200 and all that stuff to be PIC while its under 135 for IFR.

Now lets say drop off the pax and return back empty. At that point it would be considered under part 91 so assuming I was the one manipulating the controls could I log the PIC time, even though technically the other guy was designated PIC by the company for the whole trip?

My guess is yes, but before I start penciling it in pen in the logbook I figure I'll get some other opinions.

I say no: CFR 14 1.1. If the 135 operation will designate you as P.I.C. prior to the return flight then yes, but if you aren't listed as P.I.C. on any of the operator's paper work/release then no.

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight;

(2) Has been designated as pilot in command before or during the flight; and

(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

a lot of debate over this, some say "according to part whatever, you are allowed to log it", or "according to part whatever, you are not".

From my interviewing experience, they don't care about whether or not you are typed, whether or not you are allowed to log it or CFR part ###..... for interviewing purposes, PIC means who's name appears on the release as the PIC

regardless of what the FAR/AIM says, this question might come up during an interview "you logged it as PIC, were you the actual PIC of this flight?" that won't be easy to explain

again my experience, you do whatever you want

I say yes, you can log it under 61.51, so I think it is easy to explain. The FAA says you can log it. Now the company may disallow that time, just be prepared to give them whatever they want/need.

I've done applications and interviews where they've even disallowed all flight instruction PIC time, where I'm PIC in every sense of the meaning. It's all down to the people you're interviewing with.

ppilot,

61.51 states:

(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

At my company it is very clear who is the acting P.I.C. Although our FOs are allowed to fly from the left seat on empty legs and are typed in the aircraft, our flight-release, the duties and responsibilities, and even the paycheck make it very obvious who the operator has designated as the acting pilot in command. Even though I am fully qualfied to act as pic, I have clearly not been designated prior to flight as the acting captain while flying as a copilot.

IP

see, this is what I'm saying, some will say you should log it and some will say you should not.... you're going to get 20 more responses, half will say yes, half will say no....

I'm not saying log it or don't.... What I'm saying is PIC time looks really good on the resume, but keep in mind you might have to explain how you got that time during an interview...

log your flight time so that when you walk into any interview you have a quick explination of how you logged your time. I only log time that my company designates me as PIC, that way it is an easier explination (for me)during an interview.

Yea, I have been doing the same debate in my head. Hmm...like you all said, I have seen and heard of it being brought up in interviews before. I should just do a coin flip. :confused:

Then the real question becomes heads or tails.

Sure, agreed. But the Caravan does not require more than one pilot under the type certification or under part 91. So the pilot can log the time as PIC under the 'sole manipulator' part of the rule.

I'm not telling the poster to do this. Just saying that as I interpret it, that he CAN. In fact, I don't think there's any other way that he CAN log the flight time under pt 91, right?

Cloudchaser, one thing to think about...did you take a checkride? Unless you have a signed 8410 form showing proficiency and dated within the last 12 months, you can't log the 135 legs.

You may be right but my argument is that since the PIC has been designated by the company, then the other shall not log PIC time. I used to work for a night freight outfit that would hire SICs into barons and would only allow them to log TT time as they were working toward 135 mins. I also have a coworker who was kicked out of an ExpressJet interview (10 yrs ago so things may have changed) who had logged PIC time on the empty legs in the Caravan that he was flying.

On LogBook Pro you can set up custom columns beyond the standard ones.

Set one column up as 'PIC-61' or what ever. That way you can 'break out' Part 61 PIC time if an employer wants/accepts it.

I lost a job because I strictly interpreted Part 1 vs. 61 PIC time and came up 100 hours short of PIC time. The strong impression I got was that they would have accepted Part 61.51 (e) (1) (i) time as a means to meet insurance requirements. They knew I had the knowledge experience but were bound by insurance mins too. At the time I didn't agree with it or feel comfortable with that interpretation, now I realize the difference between the two. Is it right? I don't know, but I keep Part 61 now if it's legal. I just keep it in a way that I can break it out if necessary and add it to the Part 1 PIC. I can explain the differences of Part 1 & 61 in an interview and allow the interviewer to make up their mind and let the pieces fall as they may.

I know when I was 'signed' for an Aircraft and when I was the 'sole manipulator'.

Part 135 vs Part 91 legs is another issue also. I personally don't see why someone on a part 91 leg in a Caravan can't log it if they meet the requirements. A company can be more selective but 'sole manipulator' is just what it is.

What am I missing?

Acting as PIC and logging PIC are totally different things for recreational/private/commercial pilots. The company can designate a PIC, but the person flying can be someone different and completely within their rights to log PIC.

Your ExpressJet interview point is a good one though. If it were me (and it's not) I would count that time as PIC to qualify for a rating or insurance, but would not credit the time towards requirements for employment. I wouldn't be worried that someone would 'throw me out' for having logged it, BUT if they had say a 2000 hr PIC requirement, and I don't have that 2000 hours without counting that 'soft' PIC time, they're completely within their rights to not want to hire me. YMMV, but that is how I would look at it.

Hobbit64, I agree with you completely.

I'm with you. I won't tell someone they can't log it in this situation, but really, I don't see any point where it will more likely lead to you back peddling in an interview than actually impressing them. Set yourself off on the right foot with your future employer by not giving them any reason to distrust you.

Logging and Acting
 

Logging PIC time is not the same as Acting as PIC. To log PIC time on a flight that you are not acting as PIC, you must be the sole manipulator of the flight controls in an aircraft for which you are appropriately rated. It's in the regs under Logging Flight Time. To manipulate the flight controls under Part 135, you must be Qualified (potentially long discussion) even if you are the SIC.

Ok, I can see the validity of an argument to one can log PIC time if two pilots are not required per type certification or operating regs.

If two pilots are required though, the question as to whom acting as PIC is very relevant to logging PIC. In the "Logging Flight Time" (61.51) regulation it specifically states that if not acting as a PIC in such an aircraft, then the only time that one should log PIC time is:

"(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation— etc [ed]"

IP

This has been debated in the past and will certainly continue as people interpret the regs. If you're logging PIC, do you expect the gentleman officially designated by the company as PIC (name on the release, log book, flight plan etc, flying with you not to log it? He is directly responsible for the safe operation of the a/c, if there is an altitude violation or incident he's taking the fall. When I was Captain on the Lear we sometimes used co-captains due to F/O shortages, it's typed for a PIC and SIC. Occasionally I flew as co-captain; usually in the left seat for my leg, and I always logged it as SIC since I was never designated on the paperwork as PIC for that flight. I guess it's your call, always subject to interpretation

I was a CFI for almost 3 years and I have ran around this question 80,000 times and the major problem where this arguement even comes from is that 14 CFR 61.51 Pilot Logbooks does not actual say you must BE THE PIC to LOG "Pilot In Command" Time. In my head, it is not very smart on the part of the law making body that made this rule but whatever.

As for my, more or less, "opinion," I believe you may log PIC time EVEN THOUGH you are not actually the designated PIC for that leg or flight.

My reason comes from... 61.51

(e) Logging pilot-in-command flight time: A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights...
When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

To try to put normal word to this rule...
-This basically means that a pilot (commercial/private etc) may log PIC time WHENEVER YOU...

1. Are the SOLE MANIPULATOR (pilot flying I guess is the term) of the aircraft AND...
2. You are rated in that airplane (Pilot license with appropriate Cat/Class Rating)

Finally, in this situation, EVEN THOUGH you are NOT ACTUALLY THE PIC, you MAY still log pilot in command time because...
1. You are the sole manipulator and...
2. You have a license with an ASEL rating.

Anyways, remember....this is all IMHO :)

Well I emailed the Chief Pilot and got his thoughts. He just sent me a very simple response "Log the time PIC when you are the manipulator of the flight controls."

And I have taken an SIC checkride for 135 in the last 12 months, so that is a non-issue.

I think i'll end up logging it as PIC and it will come down to how good I can explain it in future interviews.

Oh and a random fact the caravan is a breeze to fly, could see people getting very complacent in that.

So here is another question then.

If I log the time that I am flying as PIC, on the legs that I don't fly should I log them as SIC time?

The ops specs require an SIC onboard, even though the caravan is good for single pilot so that is another point of confusion for me. I think it would look weird in the logbook for a 6 hour trip to have 3 hours of PIC and 3 hours of SIC.

Any new thoughts on that topic?

Like PIC time in the multi-pilot situation, the regs allow loging SIC time in one of two situations: the aircraft requires more than one pilot or the operation requires more than one pilot.

If the OpSpecs require (that's require not just permit) an SIC then "more than one pilot is required under ... the regulations under which the flight is being conducted," permitting the logging of SIC time under 61.51(f).

On that 3 and 3, nothing at all wrong with it. But remember that each basis for logging time under the regs stands on its own. If your time qualifies as night, dual received, instrument cross-country and multi, then you can log all of them. Likewise, there's no reason (other than it looking a bit weirder than even the 3 and 3) that you can log 6 hours of SIC (acting as SIC in an op requiring more than one pilot) and 3 hours of PIC (sole manipulator of the controls) on that 6 hour flight.

Whether you might run into someone along the way that just doesn't like that is another issue. Read a number of logging threads and you'll find references to all sorts of people who don't like the logging that the FAA allows.

Good response. And yes it does require it. Fun fun fun

I agree that you should log that time as SIC.

Be prepared to intelligently explain it in an airline interview though. People that have done this with our company have always told me they've been questioned about it when being interviewed. It's never cost anyone the job.

I thought I'd put the reg up and let you guys interpet it. I personally don't think there is much to interpet but that is what discussion is for, eh?
135.109 Pilot in command or second in command: Designation required.

(a) Each certificate holder shall designate a—

(1) Pilot in command for each flight; and

(2) Second in command for each flight requiring two pilots.

(b) The pilot in command, as designated by the certificate holder, shall remain the pilot in command at all times during that flight.

I agree. Not much to interpret. A 135 certificate holder must designate an acting PIC for every flight. If the operation requires two pilots, the certificate holder must designate an acting SIC. And those designations do not change during the flight.

It's connection to the logging question is also pretty straightforward.

The designated PIC "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" so she logs PIC under 61.51(e)(1)(iii) whether or not at the controls.

The designated SIC is acting as SIC on a flight where "more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted" so he logs SIC under 61.51(f)(2) whether or not at the controls.

And, of course, completely independent of either of those regs, whoever has the proper aircraft rating and is the sole manipulator of the controls gets to log his or her hands-on time as PIC under 61.51(e)(1)(i).

I interviewed at Atlantic Coast Airlines (1999).... they used to bring in 2 at a time... my interview buddy logged some time as PIC because according to the FAR/AIM "I'm allowed" and he was...he was typed in the excel, however you guys should've see him trying to explain that during the interview... the more he spoke, the uglier it got...

He is discussing flying during '91' legs though, correct?

That was my understanding.

It moved around even the OP went from talking about the empty leg (Par 91) to OpSpecs requirements (Part 135).

You're right though; the logging would be a little different since, according to the posts, the 135 leg would require who an SIC (per OpSepcs) while the Part 91 leg would not. That would mean differences in logging under 61.51(e)(1)(iii) and (f)(2) (ops requiring more than one pilot) although it wouldn't affect logging under (e)(1)(i) (the sole manipulator clause)

On the 135 legs log it all as SIC. because the opspec requires it you are a required SIC. you cannot log pic on a 135 leg.

On the 91 legs log it as pic when you are manipulating the controls but you cannot log sic on a 91 leg. You can only log the time you fly.

I agree with this post. In the example of a 6 hour flight with 3 hours of it being PIC, log it as 3 hours SIC and 3 hours PIC. I think the other person got confused when they said to log 6 hours SIC and 3 hours PIC.

I also agree with the people that stated if you cannot explain the time, don't log it. If it is clear that these are part 91 legs, and you're sole manipulator... I guess you can log it as PIC. And log the 135 legs as SIC..

I have experienced the same with interviews at SWA, TWA, NWA and United.

Logging Part 135 time
 

The only time you can actually touch anything in the cockpit (legally) when an aircraft is being operated under Part 135 is if you are qualified under part 135. That means that the operator has ops specs that approve the seat you are flying in, they have a training program for the pilot seat you are operating, you have been through that training program and it is correctly documented, and you have been through the appropriate checkride with your POI or his/her designee. If that is not the case, you can't legally touch anything on the 135 legs, so you can't log anything on the 135 legs. We have clients that request a second pilot in aircraft that only require one pilot. When that happens, the second pilot can't log anything because, although our ops specs allow two pilots, we don't have a SIC training program, and nobody has taken an SIC checkride, so they are only there in the event the PIC decides to go Tango Uniform.

You can log the Part 91 legs if you are appropriately rated and the sole manipulator of the flight controls. We generally log these legs as PIC and dual received, and then make the appropriate entries in the pilot's training folder.

Source?

-mini

§ 135.115 Manipulation of controls.

No pilot in command may allow any person to manipulate the flight controls of an aircraft during flight conducted under this part, nor may any person manipulate the controls during such flight unless that person is—

(a) A pilot employed by the certificate holder and qualified in the aircraft; or

(b) An authorized safety representative of the Administrator who has the permission of the pilot in command, is qualified in the aircraft, and is checking flight operations.

I missed that part. Carry on.

Although...being a contract pilot, I am not "employed" by the certificate holder. Interesting choice of words in the reg.

-mini

Well, technically you can since 61.51's "sole manipulator" clause doesn't care about such things.

But it =is= generally considered very bad form to document an FAR violation in ones logbook. :o

No. 61.51 deals with logging time. You cannot be the sole manipulator of the controls on a 121, or 135 leg unless you are employed by the company, company trained, and line checked. (reference in previous post) And because your not the sole manipulator of the controls you cannot log PIC. There is absolutely no way to log pic, or sic for that matter on a 135 leg without a checkride.

135 legs = Only 135 pilots (SIC too if ops spec says yes) may log stuff (PIC and SIC as appropriate)

91 legs = Sole Manipulator w/ Proper FAA Pilot License may "LOG" PIC time (Regardless if he/she is actually the PIC listed by the 135 operator) however, no one may log SIC time (Not required = no logging)

*If during the PART 91 LEG, the pilot hands the controls to that right seat guy, he becomes the sole manipulator and therefore can log PIC time

**The pilot is NOT ALLOWED to hand the controls over on the 135 legs unless that person is... (already mentioned above)

I think you misunderstood my bad attempt at humor.

If the PIC of a Part 135 flight illegally handed the controls over to a non-qualified pilot, the non qualified pilot could log the time as PIC under 61.51, since 61.51 doesn't care whether the activity is legal or not.

Just an extreme example of the difference between the logging rules of 61.51 and the operational rules in other parts of the FAR.

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.