MtoL

I came across this post in doing some homework on this topic. 61.51(f)(1) says


"Is qualified in accordance with the second-in-command requirements of § 61.55, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate"

The part about "occupies a crewmember station" suggests that bunk time does not count.

PilotX2

Define "crew member station" we have O2 in the bathroom, it "suggests" that that is a crew member station. I would log that .1 in the bathroom, unless it was a .2 bathroom trip.

Cujo665

crew rest seats, crew observer/jumpseats, crew bunks are all crewmember stations. They are not flight control stations, but they are crew member stations. Additionally, the PIC will assign your time (or approve) in the assigned crew rest station. It’s still a crew station, and it’s an assigned function for compliance with flight duty regulations. The flight may not exceed the flight time limits based upon the number of pilots. If you “remove” yourself as SIC on an augmented flight, you no longer have adequate pilots for the flight.
You are a required crewmember regardless where you are sitting.

Myfingershurt

Only crew members are allowed in the bunk so why would it not be a crew member station?

MtoL

There are oxygen bottles in the cabin as well. I'd think trying to get crewmember station to cover the bunk or bathroom is a bit of a stretch.

JohnBurke

The FAA Chief Legal Counsel has addressed the matter, but it may be worth considering aspects of how the matter is addressed. Regarding flight time, the Chief Counsel has held in multiple interpretations that it's block time which counts for accumulated time, when balanced against flight time limitations under the regulation. It's important to understand first that it's block time that's considered, and not just takeoff-to-landing flight time.

In a 2002 letter to a FSDO inspector, the Chief Legal Counsel addressed whether part, or all of the block time is counted against a crewmember's flight time limitations, noting that if the crew member has served at a crewmember station and is assigned to that crew, then ALL of the block time counts against that crewmember's regulatory flight time limits.

https://www.faa.gov/about/office_org...rpretation.pdf

As previously noted, be careful about the applicability of the regulation: the Chief Legal Counsel has not directly addressed logging the time, but notes that as crew members who have served at the pilot station (flying the airplane...let's not try to stretch that concept too much), being assigned to the crew and having operated at a pilot station not only allows, but REQUIRES the pilot to count the block time for the flight against his or her regulatory flight time limitations.

If I am on the hook for that flight time, I will log accordingly. The FAA clearly recognizes me as a crew member and the block time for that flight will be considered when I'm up against timing out, limited by the amount of hours I can fly. The company will likewise record my time on that flight not as a partial time, but as the block time for that leg. I'm not aware of an employer anywhere that will not accept another employer's record of flight time. If I print out a company record of my flight time, which the company is legally obligate to maintain, and which is maintained in accordance with the regulation and the Chief Legal Counsel's interpretation of the regulation, I do not see any room for anyone to question that time in that printout, or in my own logbook if I transfer that time to my logbook.

Moreover, as noted, if a regulatory violation or incident occurs during the course of my time on that flight, I am on the hook for that event because I am a member of that crew. I may have been away from the cockpit when the event occurred, but if ASAP reports are filed and I want coverage, I must also file one, even if it states nothing more than I was away from the cockpit at that time. Never the less, I am recorded as a crewmember for the duration of that flight, not piecemeal five minutes here or there...but beginning to end, block time, and I am a crewmember as a part of that crew should the crew come under scrutiny for an event that occurs during that time. Gross navigational error over the North Atlantic while I was in the bunk? I'm still part of a crew subject to that investigation. Moreover, if an ASAP report is filed and remedial training assigned, I'm going to have to undergo the same training, even if I was in the bunk...because I'm a part of that crew. I'm legally liable for my assignment to that crew, the entire block is levied against my flight time limitations, and I will be logging it accordingly.

If you feel inclined to log only a portion of it, so be it, but you're still on the hook for the whole enchilada.

Discussion excursions into red herring territory about bunks as crew stations, or sitting in the lav, are mildly humorous, but irrelevant, and clearly not what the FAA intended when identifying crew stations.

The same letter of interpretation quoted and linked above also states, in a footnote:

This is evidence that the example PIC, while not sitting at the controls, is still acting in a capacity of crewmember from the jump seat, and is still serving as a flight crewmember.

MtoL

Thanks. I was looking for something along those lines. You're right though, that that interpretation deals less with logbooks, and takes more of a "rest issue" approach. For the PIC, it's easy, you're always PIC. It seems like it could be a bit more nuanced for the FO's.

Who knew it could potentially be so hard to answer the question "how much time do you have in the 747"?

JohnBurke

It's not nuanced or difficult, at all.

The legal interpretation provided states that both PIC, and SIC, assigned as crew, taking a turn at the controls, are on the hook for the entire block time of the flight.

That is not a rest issue. That is a flight time limitation issue, but think about it: if your employer records your flight time in a record officially kept by that employer, which you can print out and present to others, including the FAA, which contains an account of your hours, your approaches, and your landings, and that record reflects the block time of the flight, are you really going to attempt to assert otherwise?

The legal interpretation backs up the company.

Hawkerdriver1

I added “heavy crew” to my logbook, when I started. Block times are added to total time & heavy crew only. But, I don’t log SIC when I am not in the seat. If I switch, in cruise, & do 4 hours on a 12 hour flight, I don’t long 12 hours of SIC. Just 4.


HD

JohnBurke

There is no such thing as total time without a classification of that time. Your reference to SIC indicates that you're an F/O; you're logging total time, but only part of it as SIC? The rest is simply recorded in an invented category? What's the regulatory or legal citation for "heavy crew" time? It sounds like flight time that doesn't actually fit a legal definition is simply thrown into the imaginary category to tidy things up. PIC/solo, SIC, instruction received (if not loggable by other means) and FE time should add to total time for a given line entry.

Were you assigned as SIC for the duration of the flight? Does your company record reflect the duration of the flight? If a regulatory violation occurred during that flight, would you have been subject to enforcement action as an assigned member of that crew? If an event occurred requiring an ASAP report, would you have been subject to filing it as a member of the crew (one files, all file)?

If you flew a 11 hour trip and logged 8 hours of SIC, is the other three simply existing in an imaginary logbook category ("heavy crew") and shown as total time? How can you have total time if it doesn't meet one of the requirements to log the time?