Logging PIC Clarification/Opinion

[desertdog71]

FAR Part 61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
(ii) Is the sole occupant of the aircraft; or
(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.

My question is: If recieving instruction for an instrument rating. A certificated Private Pilot could log such time "Under the hood" or "Actual IMC" as PIC time correct?

What are your opinions on this one?

[jrh]

Originally Posted by desertdog71

My question is: If recieving instruction for an instrument rating. A certificated Private Pilot could log such time "Under the hood" or "Actual IMC" as PIC time correct?

Correct, because they are sole manipulator of the controls and they are rated for the aircraft.

[meritflyer]

Originally Posted by desertdog71

FAR Part 61.51
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
(ii) Is the sole occupant of the aircraft; or
(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.

My question is: If recieving instruction for an instrument rating. A certificated Private Pilot could log such time "Under the hood" or "Actual IMC" as PIC time correct?

What are your opinions on this one?

Why not?? If you wanted to go out and practice flying on your instruments, instrument rated or not, with another PPL ASEL safety pilot, you could log that as PIC as well. You will want to log it as dual received along with PIC. If you are appropriately rated in the aircraft in which you are acting as PIC in, log it as PIC. For example, if you are a PPL ASEL receiving dual instruction in a twin in which you are not rated, you may not log it as PIC.

I'd say go for it.

[MidlifeFlyer]

I don't really have an opinion on this, but the FAA does.

My question is: If receiving instruction for an instrument rating. A certificated Private Pilot could log such time "Under the hood" or "Actual IMC" as PIC time correct?

The FAA says you are correct, the Chief Counsel's office issuing a legal opinion on this more than 25 years ago.

[Van_Hoolio]

What about while flying for a flight review or aircraft checkout?

Mike

[MidlifeFlyer]

Originally Posted by Van_Hoolio

What about while flying for a flight review or aircraft checkout?

Mike

Read the above posts that quote the regulation.

==============================
Logging pilot-in-command flight time.

A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person— Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges
==============================

Do you see a list that starts with "except..."? Me neither.

If you have a pilot certificate with the applicable aircraft category and class (and type if required) ratings written on the back (or, in the case of a sport pilot, an endorsement giving you privileges in the aircraft), and you are the sole manipulator of the flight controls, then you may log the time as PIC.

Period. There are no known exceptions. Not currency, not medical certificates, not instrument ratings, not flight reviews, not checkouts, not high performance, tailwheel, complex or pressurized endorsements. None.

[BrianNC]

Originally Posted by desertdog71

My question is: If recieving instruction for an instrument rating. A certificated Private Pilot could log such time "Under the hood" or "Actual IMC" as PIC time correct?

When I did my instrument training I had both and it was logged as such.

Obviously it goes without saying that there should be no "actual IMC" if the right seat is a safety pilot and not a CFII.

[MidlifeFlyer]

Originally Posted by BrianNC

When I did my instrument training I had both and it was logged as such.

Obviously it goes without saying that there should be no "actual IMC" if the right seat is a safety pilot and not a CFII.

Unless the safety pilot happens to have an instrument rating and is =both= willing and =capable= of assuming PIC duties.

[PanJet]

Originally Posted by MidlifeFlyer

...an aircraft for which the pilot is rated or has privileges...

...not high performance, tailwheel, complex or pressurized endorsements. None.

Wouldn't the first part of the statement limit this a little? I mean, does a private pilot actually have "privileges" in a complex or high performance aircraft without an endorsement? I'm not disputing, I'm asking as a question.

Also, does a CFI log PIC as well if the student is able to log PIC time such as during Instrument or Commercial training?

Originally Posted by MidlifeFlyer

Unless the safety pilot happens to have an instrument rating and is =both= willing and =capable= of assuming PIC duties.

Are you saying that a non-instrument rated pilot can log PIC actual so long as the safety pilot is instrument rated? Again, a question, not disputing you.

[jrh]

Originally Posted by PanJet

Wouldn't the first part of the statement limit this a little? I mean, does a private pilot actually have "privileges" in a complex or high performance aircraft without an endorsement?

I've never understood the "privileges" part of that reg either, but notice it says "rated OR has privileges," not "rated AND has privileges." Because "rated" covers a person who has the proper category and class, they don't have to worry about whatever "privileges" means.

Originally Posted by PanJet

Also, does a CFI log PIC as well if the student is able to log PIC time such as during Instrument or Commercial training?

CFIs always get to log PIC time when acting as an instructor. See 61.51(e)(3).

[VicariousLiving]

Originally Posted by jrh

I've never understood the "privileges" part of that reg either, but notice it says "rated OR has privileges," not "rated AND has privileges." Because "rated" covers a person who has the proper category and class, they don't have to worry about whatever "privileges" means.

"Privileges" refers to situations such as a PVT/ASEL pilot adding helicopter categroy/classs to his/her pilot certificate. During solo flight time in the helicopter the PVT/ASEL pilot isn't a student pilot, so the 61.51 PIC logging provisions refering to "a student pilot may" do not apply, yet the pilot must log PIC time in order to meet the aeronautical experience requirements for his/her intended new category/class. However, the pilot's CFI will have placed the appropriate helicopter solo endorsements in the pilot's logbook, the pilot then has "privileges" in a helicopter, and therefore s/he may then log PIC time.

[VicariousLiving]

Originally Posted by PanJet

Are you saying that a non-instrument rated pilot can log PIC actual so long as the safety pilot is instrument rated? Again, a question, not disputing you.

Strange as it may seem, if the flight enters actual IMC the sole manipulator pilot may log PIC time and actual instrument time even if not instrument rated, even if the safety pilot is not instrument rated, and even if there is no safety pilot at all. Yes, it would be a legal documentation of an FAR violation, but the PIC time would be legally logged and valid all the same.

[PanJet]

Originally Posted by VicariousLiving

Strange as it may seem, if the flight enters actual IMC the sole manipulator pilot may log PIC time and actual instrument time even if not instrument rated, even if the safety pilot is not instrument rated, and even if there is no safety pilot at all. Yes, it would be a legal documentation of an FAR violation, but the PIC time would be legally logged and valid all the same.

Hmm, I never knew that. Of course it doesn't sound like the brightest idea in the world.

[BrianNC]

Originally Posted by PanJet

Hmm, I never knew that. Of course it doesn't sound like the brightest idea in the world.

Of course not. It is a FAR violation to fly IMC when not instrument rated with no other instrument rated pilot on board. But what he is saying is that as long as there is an instrument rated pilot on board ready to assume PIC duties, there is no problem. It's not any different than flying in actual IMC with an instructor.

[Pilot Hopeful]

The DE for my instrument checkride approved the logging of PIC time in IMC when receiving instruction from a CFII but NOT when flying with an appropriately rated safety pilot. Although my understanding of the regulations does not concur with the latter provision, it is prudent to explore the interpretations of examiners and the regional FSDO, especially when a checkride is involved.

[Ralgha]

Originally Posted by Pilot Hopeful

The DE for my instrument checkride approved the logging of PIC time in IMC when receiving instruction from a CFII but NOT when flying with an appropriately rated safety pilot. Although my understanding of the regulations does not concur with the latter provision, it is prudent to explore the interpretations of examiners and the regional FSDO, especially when a checkride is involved.

That would be because once you enter the cloud, the safety pilot is no longer a required crewmember. Of course there is the school of thought that since the pilot is still wearing a view limiting device, the safety pilot is still required, even though he can't see a hand infront of the window.

[jrh]

Originally Posted by Pilot Hopeful

it is prudent to explore the interpretations of examiners and the regional FSDO, especially when a checkride is involved.

A point I'd like to remind people of...you only have to log what you need for currency or the minimum experience needed for a certificate or rating.

The reason I say that is because I think this is one of those times when 1) the situation is extremely rare to begin with, 2) you wouldn't usually get into this type of situation for the heck of it, you'd probably use it as a tool to get through some bad weather on a XC, and 3) most people aren't proficient enough to take a checkride with the bare minimum of hours, therefore if they don't log a small amount of time, it doesn't hurt them much.

I was in this situation one time with a friend. I was an instrument rated safety pilot and he was working on his instrument rating. We went on a cross country together and needed to climb through an overcast layer. My friend was flying under the hood, we got a pop up clearance, and my friend kept flying as we climbed.

When we talked about how to log it later, I said...shoot, it was only 0.2 hours. What do you say neither of us log it and we act like it didn't happen? I was certain what we did was legal, but I wasn't sure who exactly should log PIC and/or actual instrument time. We both agreed we'd rather lose the 0.2 hours than have something fishy in our logbooks.

[MidlifeFlyer]

Originally Posted by PanJet

Wouldn't the first part of the statement limit this a little? I mean, does a private pilot actually have "privileges" in a complex or high performance aircraft without an endorsement? I'm not disputing, I'm asking as a question.

"Privileges" was added to the regulation as part of the Sport Pilot amendment. Sport pilots aren't "rated" in anything. They have privileges by endorsement. (Besides, the word between "ratings" and "has privileges" is "or.")

Also, does a CFI log PIC as well if the student is able to log PIC time such as during Instrument or Commercial training?

Yup, but a CFI logs PIC by the act of giving instruction. Separate part of the "universal rule of logging" reg, 61.51

Are you saying that a non-instrument rated pilot can log PIC actual so long as the safety pilot is instrument rated? Again, a question, not disputing you.

Absolutely. Actually, the safety pilot doesn't have to be instrument rated. Going even further into the seemingly ridiculous, the non-instrument rated pilot can log PIC when flying all alone in IMC. (Although putting evidence of an illegal flight in your logbook is not the brightest thing to do).