Logging PIC time during Instrument training

[Blackhawk]

Originally Posted by Joe Gremlin

1. The regs aren't law. Laws are law, regs are regs. I know its just symantics but there is a difference and one should never be confused for the other IMO.

2. Be careful about questioning the professional integrity of anyone before you've walked a mile in their shoes.

Part 61 is actuall 14 CFR part 61. CFR stands for Code of Federal Regulations. Legal definition of code:

code n. a collection of written laws gathered together, usually covering specific subject matter.

Some might argue that since the regulation was created by a regulatory agency and not the legislature that they are not laws; while this can be rightfully debated on technical grounds what is beyond a doubt is that the CFR does have the force of law. Don't think so? Try violating one and see what happens.

[MidlifeFlyer]

Originally Posted by shdw

Midlife: Was that last paragraph a better way to put it than just read it literally every time and you'll always be right? I altered that definition slightly from some of my past posts.

Beats me. Whatever way lets someone get their minds around it so they really understand it is the right way.

[Holocene]

Originally Posted by FlyingOfficer

I'm currently a Private Pilot training for my Instrument Rating. I've had several flights under the hood performing instrument approaches, holding, and intercepting and tracking. According to my instructor, I should not log this as PIC time apparently because the airlines frown upon it since there is more than one PIC which is "impossible". I know for a fact that two pilots can log PIC time when one is acting as a safety pilot, so I know that it is possible, but do the airlines really frown upon it for some reason?

My understanding is, that after I have completed/logged 6 approaches (in an airplane/sim/FTD), I may begin logging PIC time while under the hood, as long as I remain current.

Am I mistaken?

All my instrument training flights were PIC.

[shdw]

Originally Posted by mshunter

Come on shdw, you should be able to figure this one out on your own. I know you know the answer to this question. Say you are solo on a solo x-country, and log it in the solo/pic column. Does this answer your question.

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

[drunkenbeagle]

Originally Posted by shdw

You seem to be crossing some wires here, believing the endorsement is a PIC endorsement, it is not, it is a solo endorsement unless applied to type ratings as the section you mentioned implies (poser this should answer your question).

A PIC endorsement is an endorsement to act PIC. If the FAA intended it to be solo and not PIC time, they would have called it a solo endorsement. AC61-65E, sec 62.

For several ratings, there are both PIC and solo time requirements, of differing amounts.

[MidlifeFlyer]

Originally Posted by shdw

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

It did at one time. The part of 61.51 that permits a solo student pilot lo log PIC was added in 1997. Before then, soloing student pilots could not log PIC time, and so had nothing to count from it toward advanced certificates and ratings.

Maybe the schools that don't "allow" pilots to properly log their time just don't like change – even 12 year old change.

[MikeD]

Originally Posted by shdw

Well of course that is what I figured, but hey there are sometimes weird regs put in weird places that stipulate things that baffle the minds of pilots everywhere. Hearing that a school forced this made me wonder if one such reg existed or if the ppl were just crazy.

newbies.....

[Joe Gremlin]

Originally Posted by Blackhawk

while this can be rightfully debated on technical grounds what is beyond a doubt is that the CFR does have the force of law. Don't think so? Try violating one and see what happens.

Actually that's kind of what I was talking about.

Get caught driving a car without a license and compare that to what happens to you when you get caught flying a plane without a certificate. They might both 'carry the force of law' but I know which group I'd rather get caught violating if given the choice.

[shdw]

Originally Posted by drunkenbeagle

A PIC endorsement is an endorsement to act PIC.

I understand what a PIC endorsement is, I also understand that it is applicable to type ratings, not a pre private student.

A regulation is nothing more than an outline, meaning each subpart of a given regulation (indented sections below) is bound to the wording of the regulation it lies in. Here is the regulation in question:

61.31 Type rating requirements, additional training, and authorization requirements.

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must

(3) Have received training required by this part that is appropriate to the aircraft category, class, and type rating (if a class or type rating is required) for the aircraft to be flown, and have received the required endorsements from an instructor who is authorized to provide the required endorsements for solo flight in that aircraft.

Notice your endorsement is under the part regarding type ratings and additional training. It does not and cannot be applies to a pre-private student. I would question its application to any other rating as well, with the exception of, as tgray mentions, some of the new sport pilot ratings for which I am unfamiliar.

Think of it this way, if you could do this you would be able to completely circumvent 61.51 for any pre private student, as well as logging for multi engine as PIC without a rating, which is also not allowed.

[drunkenbeagle]

Originally Posted by shdw

Think of it this way, if you could do this you would be able to completely circumvent 61.51 for any pre private student, as well as logging for multi engine as PIC without a rating, which is also not allowed.

No one said this was for a student, it only applies to certificated pilots.

Nothing stops you from logging multi PIC without a rating (other than maybe insurance companies). If you hold a pilot certificate and get a PIC AMEL endorsement, you can act PIC and log multi PIC time solo.

[shdw]

Originally Posted by drunkenbeagle

Nothing stops you from logging multi PIC without a rating (other than maybe insurance companies).

You are still confusing PIC and solo. The insurance doesn't stop you from logging PIC, they could care less who writes PIC in their log book, they do however care about students soloing.

Originally Posted by drunkenbeagle

If you hold a pilot certificate and get a PIC AMEL endorsement, you can act PIC and log multi PIC time solo.

Do you have any documentation that confirms this? You can do it solo that has already been covered, you cannot log PIC in a multi without a multi certificate. This endorsement cannot be applied to that, unless you have some documentation I, and I suspect most of us here, have not seen. It would seem stupid to have an "acting as PIC" stipulation in the regulations for the purposes of multi training if you could just use this endorsement, wouldn't you think?

[drunkenbeagle]

Originally Posted by shdw

It would seem stupid to have an "acting as PIC" stipulation in the regulations for the purposes of multi training if you could just use this endorsement, wouldn't you think?

If you have an insurance company that will insure you, and an MEI that will sign off on it, go for it (the lack of both of these generally makes it moot).

[tgrayson]

Originally Posted by shdw

It would seem stupid to have an "acting as PIC" stipulation in the regulations for the purposes of multi training if you could just use this endorsement, wouldn't you think?

The "acting as PIC" exists solely because the FAA realizes that insurance companies are unlikely to insure a non-rated pilot. With the proper endorsement, a multi student can indeed solo a twin.

[shdw]

Originally Posted by drunkenbeagle

If you have an insurance company that will insure you, and an MEI that will sign off on it, go for it (the lack of both of these generally makes it moot).

I give up, go ahead give that endorsement to your multi applicant, let them log multi PIC w/o their rating, and let us know how that turns out.

[floridaCFII]

Originally Posted by shdw

I give up, go ahead give that endorsement to your multi applicant, let them log multi PIC w/o their rating, and let us know how that turns out.

61.51 allows any pilot to log PIC when they are the sole occupant of the aircraft. How would solo time in a twin ever not be PIC?

Like the previous poster mentioned, good luck finding an MEI who will solo you in a twin, but if you can, and your insurance agrees, then more power to you.

[shdw]

Originally Posted by tgrayson

The "acting as PIC" exists solely because the FAA realizes that insurance companies are unlikely to insure a non-rated pilot. With the proper endorsement, a multi student can indeed solo a twin.

I know, I was pointing it out to show that even other regulations support the inability to using the PIC endorsement to log multi PIC unless you are rated. If it could be applied for this application than there would be no need for "acting PIC," just give the PIC endorsement and you would be set, which you cannot do.

Damn those insurance companies.

[shdw]

Originally Posted by floridaCFII

61.51 allows any pilot to log PIC when they are the sole occupant of the aircraft. How would solo time in a twin ever not be PIC?

When did I argue otherwise?

I even said this already myself:

Originally Posted by shdw

In the case of a solo endorsement you have the privileges to fly solo and the act of flying solo gives you the privilege to log PIC.

[floridaCFII]

Originally Posted by shdw

When did I argue otherwise?

I even said this already myself:

You said:

Originally Posted by shdw

I give up, go ahead give that endorsement to your multi applicant, let them log multi PIC w/o their rating, and let us know how that turns out.

How else am I supposed to interpret that?

[tgrayson]

Originally Posted by shdw

I was pointing it out to show that even other regulations support the inability to using the PIC endorsement to log multi PIC unless you are rated.

If you have the solo endorsement, then you can fly solo. If you can fly solo, then you can log the flight time as PIC.

[shdw]

Originally Posted by tgrayson

If you have the solo endorsement, then you can fly solo. If you can fly solo, then you can log the flight time as PIC.

I referred to the PIC endorsement, not the solo endorsement, what are you talking about?

[shdw]

Originally Posted by floridaCFII

How else am I supposed to interpret that?

We have been talking about the PIC endorsement, as was mentioned in post 59 when I quoted the endorsement under discussion, not the solo endorsement.

[tgrayson]

Originally Posted by shdw

We have been talking about the PIC endorsement

That's what I'm talking about.

[shdw]

Originally Posted by tgrayson

That's what I'm talking about.

Then what was the point of mentioning the solo endorsement above? You have totally lost me bud, I can only hope you're just screwing around.

[tgrayson]

Originally Posted by shdw

Then what was the point of mentioning the solo endorsement above?

The PIC endorsement is functionally equivalent to the solo endorsement for a student pilot. It allows a post-student certificated pilot to act as PIC for an aircraft for which he lacks a class or category rating.

[shdw]

Originally Posted by tgrayson

The PIC endorsement is functionally equivalent to the solo endorsement for a student pilot. It allows a post-student certificated pilot to act as PIC for an aircraft for which he lacks a class or category rating.

Is there an FAA documentation agreeing with this? It would seem unlikely as it wouldn't cover any sections of 61.87 required for solo in the actual endorsement and it lacks the "permitted to fly solo" wording. I would find that a questionable statement without backing.