Logging Turbine PIC

[dakovich]

just wondering everyones take on my situation. I'm flying SIC in a Kingair for a 135 company. My question is, can i log PIC turbine on dead legs when i am the sole manilpulator of the controls?? been to training at Simuflite for the Kingair (SIC only though), am multi-engine rated, and the aircraft is under 12500. i know i can only log SIC when we are carrying passangers under 135, but the empty 91 legs are the question.

[kellwolf]

I'd say if you're sole manipulator on the 91 legs, you can. Just be ready to back it up if it comes up in an interview.

[C650CPT]

Are you typed in it?

[tgrayson]

Originally Posted by dakovich

i know i can only log SIC when we are carrying passangers under 135, but the empty 91 legs are the question.

You can log PIC any time you are sole manipulator and rated in the aircraft under Part 61. Whether it's 135 or 91 is irrelevant. Whether an airline is interested in seeing that sort of PIC time is a different question.

[kellwolf]

Originally Posted by C650CPT

Are you typed in it?

the aircraft is under 12500.

[jtrain609]

Originally Posted by tgrayson

You can log PIC any time you are sole manipulator and rated in the aircraft under Part 61. Whether it's 135 or 91 is irrelevant. Whether an airline is interested in seeing that sort of PIC time is a different question.

You don't work under 135 rules I see.

Log your 135 legs as SIC, and if the captain will let you, ask if you can have the 91 legs to log as PIC time. As long as you ARE flying a King Air under 12,500 lbs. gross weight, you're fine. There's something to be said about who the plane is dispatched to, blah blah blah.

[C650CPT]

I have a BE-200 type rating

[jtrain609]

Seriously? How can you have a type in an airplane that comes in under 12,500 pounds, is not a jet and hasn't been mandated by the FAA to require a type rating? Is it next to your Citation type on the back of your certificate?

[C650CPT]

Originally Posted by jtrain609

Seriously? How can you have a type in an airplane that comes in under 12,500 pounds, is not a jet and hasn't been mandated by the FAA to require a type rating? Is it next to your Citation type on the back of your certificate?

John
I mean Jtrain
I actually do have the BE-200 type on my certificate, right next to my other types ...

It doesn't do me any good as the Civilian King Airs do not require the type. The BE-200 I fly for the Army has an AWR allowing us to operate at 14000 max take off weight ... so the FAA allowed us to receive an FAA type rating. The biggest advantage was early in my career when I didn't have any other type ratings and was able to check the yes block on insurance papers ... it just looked good ... the other advantage was when I went for my first Jet type rating ... because I already had a type rating I got the unrestricted type from the simulator training program.

This was just my ill attempt at humor ... sorry

Jim

[tgrayson]

Originally Posted by jtrain609

You don't work under 135 rules I see..

None of the Part 135 regulations have any bearing on this issue.

Perhaps you are unaware of the distinction between logging PIC and acting PIC? You may log PIC time as specified under 61.51. There is nothing there about whether the flight is Part 135, Part 121, or Part 91. However, the OP is not qualified to ACT as PIC of the 135 flight.

I do have an FAA Letter of Interpretation on this issue, which I cannot post until I get home. But all it does is point out the regulations that I already mentioned.

[jtrain609]

Originally Posted by tgrayson

None of the Part 135 regulations have any bearing on this issue.

Perhaps you are unaware of the distinction between logging PIC and acting PIC? You may log PIC time as specified under 61.51. There is nothing there about whether the flight is Part 135, Part 121, or Part 91. However, the OP is not qualified to ACT as PIC of the 135 flight.

I do have an FAA Letter of Interpretation on this issue, which I cannot post until I get home. But all it does is point out the regulations that I already mentioned.

That's not the discussion that's happening right here, though. You say it doesn't matter if he's under 135 or 91 regs, but it absolutely DOES matter. If he only had a part 135 SIC checkout, then he can't legally log PIC time on ANY of those 135 legs no matter whether he's functioning as the sole manipulator of the controls. You are REQUIRED to have a part 135 PIC check done because you can act as or log PIC time while operating under part 135 rules.

If the flight is operated part 91 then you are correct, who is flying the plane matters; but not under 121 or 135 rules. If what you're saying is correct, then 121 FO's or 135 FO's could log PIC time on their legs, but they can't; they don't have the requisite checkouts and ratings to do so.

[jtrain609]

Originally Posted by C650CPT

John
I mean Jtrain
I actually do have the BE-200 type on my certificate, right next to my other types ...

It doesn't do me any good as the Civilian King Airs do not require the type. The BE-200 I fly for the Army has an AWR allowing us to operate at 14000 max take off weight ... so the FAA allowed us to receive an FAA type rating. The biggest advantage was early in my career when I didn't have any other type ratings and was able to check the yes block on insurance papers ... it just looked good ... the other advantage was when I went for my first Jet type rating ... because I already had a type rating I got the unrestricted type from the simulator training program.

This was just my ill attempt at humor ... sorry

Jim

That's interesting, Jim. I figured it had to do with your military flying and I also figured you guys had to have a different gross weight on that thing than a regular King Air 200.

BTW If you ever make it out to Socal in your jet give me a ring, I'm here for about a year.

[wheelsup]

Originally Posted by jtrain609

. If he only had a part 135 SIC checkout, then he can't legally log PIC time on ANY of those 135 legs no matter whether he's functioning as the sole manipulator of the controls.

Any SIC's at Airnet here? I believe the SIC's log PIC while they are flying, even though they only have an SIC checkout.

[jtrain609]

Nope, they log SIC time.

135 is no different than 121 in that reguard; if you're an SIC, you log SIC time. If you're a PIC, you log PIC time.

[wheelsup]

Originally Posted by jtrain609

Nope, they log SIC time.

135 is no different than 121 in that reguard; if you're an SIC, you log SIC time. If you're a PIC, you log PIC time.

Craig Washka - the pilot recruiter at Airnet, and the FAA, would disagree with you:

Since the pilot can now legally be a flight crew member, the pilot also can manipulate the aircraft’s flight controls. How a pilot logs the flight time is found in 14 CFR 61.51(e)1. If a pilot assigned as SIC manipulates the flight controls of an aircraft in which that pilot is rated, that pilot may log the time as PIC. This does NOT change who is assigned as pilot in command.

This program and method of logging flight time is supported not only by Federal Aviation Regulations, but also by legal interpretations

Found here

[jtrain609]

That's not what the FAA has told my company to do, and we operate the same aircraft. We log SIC time in the same situations.

[tgrayson]

Originally Posted by jtrain609

That's not the discussion that's happening right here, though.

That's exactly the discussion, because Part 135 does not address logging of PIC time, only the acting.

Originally Posted by jtrain609

You say it doesn't matter if he's under 135 or 91 regs, but it absolutely DOES matter. If he only had a part 135 SIC checkout, then he can't legally log PIC time on ANY of those 135 legs no matter whether he's functioning as the sole manipulator of the controls. You are REQUIRED to have a part 135 PIC check done because you can act as or log PIC time while operating under part 135 rules.

Can you cite me a regulation that says this?

[wheelsup]

Originally Posted by jtrain609

That's not what the FAA has told my company to do, and we operate the same aircraft. We log SIC time in the same situations.

huh? the only aircraft amf flies that is the same as airnet is the lear - which requires a type to log PIC hence why the FO's couldn't log it as PIC.

[tgrayson]

Here's a letter of interpretation I found via Google. I can't absolutely vouch for its authenticity, since I didn't get it off my Summit CD, but it matches the interps I have. I've bolded the pertinent sections.


Mr. Michael G. Tarsa


Dear Mr. Tarsa:

Thank you for your letter of April 3, 1991, in which you ask questions about logging pilot in command (PIC) and second in command (SIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR). We apologize that staff shortages, regulatory matters, and interpretation requests received prior to yours prevented us from answering your questions sooner.

Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.

You correctly state that while the SIC is flying the airplane, he can log PIC time in accordance with FAR 61.51(c)(2)(i) because he is appropriately rated and current, and is the sole manipulator of the controls. Additionally, he has passed the competency checks required for Part 135 operations, at least as SIC.

You then ask two questions. The first asks whether the pilot designated as PIC by the employer, as required by FAR 135.109, can log PIC time while the SIC is actually flying the airplane. The answer is yes.

FAR 1.1 defines pilot in command:

(1) Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time.


FAR 91.3 describes the pilot in command:

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

There is a difference between serving as PIC and logging PIC time. Part 61 deals with logging flight time, and it is important to note that section 61.51, Pilot logbooks, only regulates the recording of:

(a) The aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of this part.

FAR 61.51(c) addresses logging of pilot time:

(2) Pilot in command flight time. (i) A recreational, private, or commercial pilot may log pilot in command time only that flight time during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or when the pilot is the sole occupant of the aircraft, or, except for a recreational pilot, when 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.

(ii) An airline transport pilot may log as pilot in command time all of the flight time during which he acts as pilot in command.

(iii) (omitted).

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second 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.

As you can see, there are two ways to log pilot in command flight time that are pertinent to your question. The first is as the pilot responsible for the safety and operation of an aircraft during flight time. If a pilot is designated as PIC for a flight by the certificate holder, as required by FAR 135.109, that person is pilot in command for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft.

The second way to log PIC flight time that is pertinent to your question is to be the sole manipulator of the controls of an aircraft for which the pilot is rated, as you mention in your letter. Thus, a multiengine airplane flown under Part 135 by two pilots can have both pilots logging time as pilot in command when the appropriately rated second in command is manipulating the controls.

We stress, however, that here we are discussing logging of flight time for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the second pilot in your example is fully qualified as a PIC, or only as an SIC. This is important, because even though an SIC can log PIC time, that pilot has not qualified to serve as a PIC under Part 135.

An example of this difference is FAR 135.225(d), which raises IFR landing minimums for pilots in command of turbine powered airplanes flown under Part 135 who have not served at least 100 hours as PIC in that type of airplane. Served and logged are not the same in this context, and no matter how the SIC logs his time, he has not served as a PIC until he has completed the training and check rides necessary for certification as a Part 135 PIC.

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51(c)(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations and Enforcement Division

[wheelsup]

tgrayson is a smart mo-fo

[jtrain609]

Originally Posted by wheelsup

huh? the only aircraft amf flies that is the same as airnet is the lear - which requires a type to log PIC hence why the FO's couldn't log it as PIC.

Chieftain/Navajo

[wheelsup]

Originally Posted by jtrain609

Chieftain/Navajo

Ah, I gotcha. Didn't know that!

[jtrain609]

Hey wheelsup,


I'll tell you what. I'll go and tell my director of flight ops that I'm gonna start logging PIC time even though I'm an SIC on a leg and when he asks my reasoning I'll tell him that Airnet gets to do it so I can too. You can go ahead and tell them the same thing at your company. $10 says we both get laughed our of our bosses respective offices.

[Minnesota_Flyer]

Originally Posted by jtrain609

Hey wheelsup,


I'll tell you what. I'll go and tell my director of flight ops that I'm gonna start logging PIC time even though I'm an SIC on a leg and when he asks my reasoning I'll tell him that Airnet gets to do it so I can too. You can go ahead and tell them the same thing at your company. $10 says we both get laughed our of our bosses respective offices.

Why does your director of flight operations care what you log in your logbook?

[wheelsup]

Originally Posted by jtrain609

Hey wheelsup,


I'll tell you what. I'll go and tell my director of flight ops that I'm gonna start logging PIC time even though I'm an SIC on a leg and when he asks my reasoning I'll tell him that Airnet gets to do it so I can too. You can go ahead and tell them the same thing at your company. $10 says we both get laughed our of our bosses respective offices.

I could care less what you do! Just don't shoot the messenger!

If I did it I would get laughed at - I don't have an ATP or a PIC type in the CL-65.