Oh wise guru, please enlighten.

Because if you want to look at sole manipulator under 61, there is an exception :"(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under parts 91 and 121 for that certificate holder if the pilot in command is in compliance with §§121.435 or 121.436, as applicable, and §121.439 of this chapter."

You are quoting 61.57. The applicable reg is 61.51(e). 61.51 is the only reg that addresses pilot logbooks. Like I said, you don't understand what you're talking about.

Fine. 61.51.e.iii

(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; or

The flight would be operated under 121. Still can't log it.

Try again.

You can try again because all that's says it the PIC can always log PIC time, says nothing about the SIC. English is such a difficult language.

So let's bring this back to reality...

Is it legal to log? YES!

Will it be respected on a resume? NO! (with very few exceptions).

Log your time in a way that is easy to tally depending on what prospective employers want.

Simple enough for everybody?

Also can we sticky this since it comes up about once a week?

It doesn't specify PIC or SIC. It says pilot. The logging of flight time would be controlled under 121/ops specs .

I'll have to disagree with you depending on the country we are talking about. Chinese contract folk seemed more than willing in fact encouraged the practice. I have no idea about Japan or Korea. My situation was a few years back I had 700 +/- PIC hours on the A-320/319 with about 1500 TT on that airframe. Out of curiosity had filled out several letters of interest with a couple of different Chinese contract outfits. They all told me that I could use sole manipulator time if I had been a type rated F/O to fulfill the 1,000 hour PIC requirement. I never took any of them up on the offers so I can't verify how it would have turned out.

But I will say this one more time just so it is clear. DO NOT log type rated FAR 121 sole manipulator time as PIC in your log book for the purpose of fulfilling PIC requirements for any U.S. airline. I wouldn't do it under any circumstances, if some foreign contract outfit wants to credit you with sole manipulator time then you can work out the details as necessary.

Yes, you can log it. There are several interpretations. I've copied one below.

As has been noted, most (if not all) airlines will NOT count that time as PIC so you'll need a way to remove it easily from your totals when filling out job applications.

That leaves the question of whether or not you should log it. I don't because there's no reason to log it.

Legal Interpretation # 92-46

August 3, 1992

Mr. William Clay Cunningham

Dear Mr. Cunningham:

Thank you for your letter of September 28, 1991, in which you ask
a question about the logging of pilot-in-command (PIC) time when
operating under Part 135 of the Federal Aviation Regulations
(FAR).

Before addressing your question, I would like to first apologize
for the delay in responding to your letter. In recent months, a
large number of priority projects have been assigned to this
division that have prevented us from responding in a more timely
manner to the many requests for interpretations. Mr. Irshad A.
Haqq of my staff recently discussed this situation and the
question raised in your letter with you via telephone. This
letter constitutes our formal reply.

In your letter, you pose the following scenario: under a part
135 operation, the flight crew of a 19 seat deHaviland Twin Otter
(DHC-6-300) consists of a captain and first officer, neither of
whom is required to possess a type rating to act as a flight
crewmember. You then ask whether the first officer may log PIC
time for the period during which he is the sole manipulator of
the controls of the aircraft. You also explain that you have
received conflicting answers from local FAA personnel to whom you
have posed this question.

The answer to your question is yes. Under Section 61.51(c)(2) of
the FAR, the first officer may log as PIC time that time during
which he is the sole manipulator of the controls of the aircraft.
In fact, both the captain, assuming he is the designated PIC
required under Section 135.109, and the first officer may
simultaneously log as PIC time that time during which the first
officer is the sole manipulator of the controls.

We recently rendered an interpretation encompassing the issue you
raise as well as other questions related to the logging of PIC
time under the FAR. A copy of that June 25, interpretation
addressed to Mr. Dallas Butler is enclosed for your reference and
convenience. The sections of the FAR that are pertinent to this
issue are cited in that letter.

We hope this satisfactorily answers your question.

Sincerely,


/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division

My take on this issue is yes it is legal to log it, but the flight time is only valid for the furtherance of a certificate or rating. Most Legacies or Majors will not recognize that time towards their applicable minimums. If there is a PIC requirement, it almost always is the Part 1 definition. Also, there are enough questions during the course of an interview, why would you want to expand the range of questions? Especially, since you would be on the wrong side of this issue. Ultimately, it is the hiring airline that decides which time is applicable towards their respective minimums.

Perhaps you need to try again, because like I said, you don't understand the regulations. Subpart (e) deals with pilot in command.

61.51 (e)(iii) is one way you are allowed to log Pilot in Command. Sections i, ii, iii, and iv are all different ways you are allowed to log Pilot in Command.

The pertinent regulation is 61.51(e)(i):

It doesn't matter if the flight is operated under 91, 135, 121, or any other reg. If the pilot is rated in the aircraft and the sole manipulator, they can log it as PIC.

Is it a good idea? For 121, absolutely not. Is it legal? Yes.

I'm only a 135 guy, not 121, but I haven't seen an Ops Specs that said anything about logging flight time in a pilot logbook.

Once you get hired by an airline they don't care how you log your time.