Logging dual when student is acting PIC...

[ander8ae]

So the same old question with a different spin. At the school I work at, most students do the commercial initial in the multi. Per the regs the students need "10 hours performing the duties of PIC", part of that being a 300 NM cross country. The question is, am I supposed to log this flight as dual given seeing as it's "supervised solo", "acting PIC", "performing the duties of PIC" (whatever you want to call it) since I'm not really teaching during the flight, more just an insurance requirement, sitting and making sure nothing goes wrong...

[Sidious]

You bet, it says either 10 hours solo or 10 hours with an authorized instructor. Whenever you are acting as an authorized instructor you can log PIC per 61.51 (e) 3 p.53 2008 FAR/AIM

[tgrayson]

Originally Posted by ander8ae

"supervised solo", "acting PIC", "performing the duties of PIC" (whatever you want to call it) since I'm not really teaching during the flight, more just an insurance requirement, sitting and making sure nothing goes wrong...

Note that the student is not acting as PIC (since he isn't legal to do so), nor is he logging it as such (not rated in the aircraft).

[Old Pete]

Originally Posted by tgrayson

Note that the student is not acting as PIC (since he isn't legal to do so), nor is he logging it as such (not rated in the aircraft).

Why isn't he legal to act as PIC? Assuming he is a private pilot, multi-engine rated, working on his commercial?

[bdhill1979]

Originally Posted by Old Pete

Why isn't he legal to act as PIC? Assuming he is a private pilot, multi-engine rated, working on his commercial?

That would be the exception

[tgrayson]

Originally Posted by Old Pete

WAssuming he is a private pilot, multi-engine rated, working on his commercial?

Because the assumption of the OP was that this was not the case.

[Old Pete]

Originally Posted by ander8ae

So the same old question with a different spin. At the school I work at, most students do the commercial initial in the multi. Per the regs the students need "10 hours performing the duties of PIC", part of that being a 300 NM cross country. The question is, am I supposed to log this flight as dual given seeing as it's "supervised solo", "acting PIC", "performing the duties of PIC" (whatever you want to call it) since I'm not really teaching during the flight, more just an insurance requirement, sitting and making sure nothing goes wrong...

I think some people would say it would not be proper to log it as dual given if it is to meet the requirements of 61.129b (4)

On the other side of the coin (the student's), I have met a DPE who had a big problem if a student logged any time to meet the requirements of 61.129b (4)as dual received.

[Old Pete]

Originally Posted by tgrayson

Because the assumption of the OP was that this was not the case.

I think you were assuming that, not the OP.

[tgrayson]

Originally Posted by Old Pete

I think you were assuming that, not the OP.

If the student were ME rated, he wouldn't need this "performing the duties of pilot in command" scam, he could just get the solo time.

[tgrayson]

Originally Posted by Old Pete

I have met a DPE who had a big problem if a student logged any time to meet the requirements of 61.129b (4)as dual received.

That DPE would need to be reeducated. The FAA has specified that training should occur, but said that it should fall under CRM-type training.

[Old Pete]

Originally Posted by tgrayson

If the student were ME rated, he wouldn't need this "performing the duties of pilot in command" scam, he could just get the solo time.

Sure he could, IF the school he were training at allowed him to go solo. Many schools require higher time requirements for solo flight in a twin(or don't allow solo flight at all) than the bare minimum time it takes to get a private multi. Therefore, they use the "performing the duties of pilot in command" "scam" as you put it.

[ander8ae]

To clarify, the students are not ME rated.

Secondly, my question isn't related to the logging of PIC, which I, as the one rated and responsible, am logging. It's whether or not it can/should be logged as dual given. And as a side note, if not, would it count toward the maximum 8 hours in 24 consecutive hour period? Just curious....

Thanks for the help so far.

[MidlifeFlyer]

Originally Posted by tgrayson

That DPE would need to be reeducated. The FAA has specified that training should occur, but said that it should fall under CRM-type training.

Got a reference for that? The "duties performing" is one of those interesting regulatory creatures that, since I'm not multi-rated, I haven't really looked at.

Originally Posted by ander8ae

Secondly, my question isn't related to the logging of PIC, which I, as the one rated and responsible, am logging. It's whether or not it can/should be logged as dual given. And as a side note, if not, would it count toward the maximum 8 hours in 24 consecutive hour period? Just curious....

Interesting question.

First of all being "rated and responsible" doesn't automatically authorize you to log squat under 61.51; it's it's "acting as an authorized instructor" (61.51(e)(3)) that gives you the sole basis to logging PIC.

And you are, since 61.129(b)(4) talks about "performing the duties of pilot in command in a multiengine airplane with an authorized instructor."

"Dual given"? Well since there's no such category in the FAR, it depends on what your definition is. But under mine, I would include all time in which I was acting as an authorized instructor in flight. And my vote would be that it counts toward the 8 hour max.

[ander8ae]

Anybody else have any opinions on this? Whether or not that "acting PIC" time for the student would be considered dual given for the instructor...?

[tgrayson]

Originally Posted by ander8ae

Anybody else have any opinions on this? Whether or not that "acting PIC" time for the student would be considered dual given for the instructor...?

The old Part 61 FAQ's put it thusly:

In answer to your question concerning whether it is possible for you to receive instruction while also "performing the duties of PIC." The intent of this provision in § 61.129(b)(4) [i.e., “. . . performing the duties of pilot in command . . . with an authorized instructor . . .”] is to permit an authorized instructor to be aboard the multiengine airplane and the instructor should only act like an SIC. The instructor should observe, evaluate, and may train the student on performing the duties of pilot in command in a multiengine airplane (e.g., CRM training). The instructor should confine their activities to giving training on “. . . performing the duties of pilot in command . . . on the areas of operation listed in § 61.127(b)(2) . . .” The instructor should put more emphasis on acting like an SIC so the applicant gets the benefit and experience of performing the duties of a pilot in command in crew concept setting (e.g. CRM training). The intent of § 61.129(b)(4), in essence, is to provide for the kind of training that is commonly referred to as crew resource management (CRM) training.

[Nihon_Ni]

Originally Posted by ander8ae

Anybody else have any opinions on this? Whether or not that "acting PIC" time for the student would be considered dual given for the instructor...?

If you take the position that this time does count towards the 8 in 24 hrs limit, you'll be safe no matter what the FAA's opinion is. If you take the opposite position you could find yourself at odds with a FSDO who interprets it differently. Personally, I would just assume it is included in the 8/24 limit and sleep easy at night.

[Codyjp]

Originally Posted by Nihon_Ni

If you take the position that this time does count towards the 8 in 24 hrs limit, you'll be safe no matter what the FAA's opinion is. If you take the opposite position you could find yourself at odds with a FSDO who interprets it differently. Personally, I would just assume it is included in the 8/24 limit and sleep easy at night.

I can't imagine wanting to fly more than 8 hours in one day. No thanks! Above is the very safe and logical answer to your question.