xdashdriver

Well-Known Member
We operate in this domain and although we very seldom use SIC's, our POI insists that they autopilot be physically disabled if they are to log time.
History is full of POIs insisting their own personal interpretation of the regulations is correct and valid. That's probably how @MidlifeFlyer makes part of his living.

FAA Letter of Interpretation - Nichols (2009)

Pretty clear in the letter of interpretation that you can log SIC time under 135 with an approved, operative autopilot installed, provided it is not used.
 

milleR

Well-Known Member
So 135 actually requires a two person crew when flying passengers under IFR.

However, there's an exemption you can get, if you have fewer than 10 passenger seats, which allows you to use a (iirc) 3 axis autopilot in lieu of a first officer. Cape Air has that exemption.

Since an FO is required under the part of the regulations they operate under, any time an FO is in the seat, they can log SIC time. When I was there the FAA came out with an interpretation that on those legs the autopilot couldn't be used if the FO wanted to log the time. I'm sure that's followed to the letter. :)
Yes, I flew for Cape Air ‘08-‘11 which I believe is when they introduced that rule. What I can’t remember is if the FO’s logged their flight time as PIC when they were flying.
 

milleR

Well-Known Member
The only FARs which deal with logging flight time are in Part 61. If the questions is "which FAR’s you’ve logged PIC under" the only real answer answer is 61.51. There are no Part 1 or Part 135 or 121 logging rules. There may be employer rules, but those aren't FAR rules. That's basic.

That's the problem in a nutshell. You don't know. Are they asking whether you meet the minimum regulatory requirements for the job? That's PIC flight time as defined by regulation. Or are they asking for what your government authorized as PIC flight time? Again that's Part 61. Or are they asking whether you have 1,000 hours of command responsibility, which may or may not be loggable flight time from a regulatory standpoint (not all in command flight time is loggable)? Or are they asking whether you meet some standard they define in the application or job description (which is the best solution - tell me what you want and I'll give you what you want)? Or are they using some undefined standard and asking you to guess at the answer?

Here's an example I've heard a number of times - logging PIC as a safety pilot in a Cessna 152. In your opinion, should it be included in your hypothetical application? It is not only Part 61 PIC time, but it is also, by definition, Part 1 PIC time.

But lets move from academic to practical. If your answer to the above questions is, "they are asking me to guess," by all means use the most restrictive answer you can come up with if you meet the requirements and don't see a downside to putting in less time than you might be able to if you did know what they wanted.
I would argue that the verbiage “No certificate holder may use a pilot, nor may any person serve, as a pilot in command of an aircraft” that opens 135.297 and 135.299 should preclude using the part 61 definition to justify logging PIC if the appropriate requirements haven’t been met. But this gets circular right quick, so I’ll simply close with- be ready to explain your flight time to the people across the table that have more than a casual relationship with the relative definition of Pilot in Command.
 

MidlifeFlyer

Well-Known Member
I would argue that the verbiage “No certificate holder may use a pilot, nor may any person serve, as a pilot in command of an aircraft” that opens 135.297 and 135.299 should preclude using the part 61 definition to justify logging PIC if the appropriate requirements haven’t been met. But this gets circular right quick, so I’ll simply close with- be ready to explain your flight time to the people across the table that have more than a casual relationship with the relative definition of Pilot in Command.
Part 61 and 91 also has rules about serving as pilot in command. Currency, endorsements for certain aircraft, instrument ratings for IFR flight, medical certification. etc. None of them are required to log PIC time as sole manipulator, not even one. Rated + sole manipulator = authority to put numbers in the PIC column. No known exceptions.

Point is "serve as" and "log" are not related terms in any part of the FAR. That's been the official and consistent FAA word for more than 40 years. Understanding that is literally 100% of the requirement to understanding the FAA's logging rules.

For better or worse, it's the way it is from a regulatory standpoint. Liking it is a choice.
 

milleR

Well-Known Member
Part 61 and 91 also has rules about serving as pilot in command. Currency, endorsements for certain aircraft, instrument ratings for IFR flight, medical certification. etc. None of them are required to log PIC time as sole manipulator, not even one. Rated + sole manipulator = authority to put numbers in the PIC column. No known exceptions.

Point is "serve as" and "log" are not related terms in any part of the FAR. That's been the official and consistent FAA word for more than 40 years. Understanding that is literally 100% of the requirement to understanding the FAA's logging rules.

For better or worse, it's the way it is from a regulatory standpoint. Liking it is a choice.
Re-reading the OP’s question I see they’re asking about logging the time for a rating, which I suppose is a different proposition that logging it to present at an interview. In that case I would say sure, if you meet the requirements to log it as PIC for a rating then go for it. But if you’re going to represent that time to a potential employer as PIC, be prepared for a conversation that’s unlikely to go all that well, which was my only point. Just because the FAA says it’s good doesn’t mean the CP and HR person across the table are going to see it the same way.
 

MidlifeFlyer

Well-Known Member
Re-reading the OP’s question I see they’re asking about logging the time for a rating, which I suppose is a different proposition that logging it to present at an interview. In that case I would say sure, if you meet the requirements to log it as PIC for a rating then go for it. But if you’re going to represent that time to a potential employer as PIC, be prepared for a conversation that’s unlikely to go all that well, which was my only point. Just because the FAA says it’s good doesn’t mean the CP and HR person across the table are going to see it the same way.
Agreed. It's about data collection vs presentation. If a potential employer is asking about time actually in command of a flight, that is what you give them. There are plenty of extra logbook columns, especially in a eLog, to collect what you need.
 

word302

Well-Known Member
I appreciate you fighting the good fight, @MidlifeFlyer. I literally gave up on trying to teach people anything about logging time.
The thing is that most people understand what you can legally log. We also understand there is a difference between what you CAN log and what you SHOULD log.
 

Acrofox

All fox
The thing is that most people understand what you can legally log.
No, they don’t. Thread after thread, debate after debate, thousands and thousands of posts across various fora, have made this abundantly clear. Most people’s understanding of regulations is simplistic, flawed, and highly factually-inaccurate, and their statements bear it out continuously.
We also understand there is a difference between what you CAN log and what you SHOULD log.
...
So you think first officers should log their legs as PIC?
Is a PIC type-rated first officer, fully-qualified in the airplane, entitled to log PIC on her legs as PF?

-Fox
 

MidlifeFlyer

Well-Known Member
No, they don’t. Thread after thread, debate after debate, thousands and thousands of posts across various fora, have made this abundantly clear. Most people’s understanding of regulations is simplistic, flawed, and highly factually-inaccurate, and their statements bear it out continuously.
It is much much better than it used to be, in large part because it has been discussed ad nauseam. It has also been a topic for FIRC and CFI practical tests.

Most who participate in online forums in 2019, I think, do understand the basics of the logging rules. I just did an article on logging slated to appear soon in IFR Magazine. Mostly an academic discussion on how to look at them and understand them, I'll be curious to see the response since the readership is a bit different than those who hang out online.

Acceptance in the context of career goals is less. Ability and willingness to log in a way which deals with regulatory requirements and an accurate 8710-1, while at the same time dealing with career presentation of experience can be a challenge for some.
 

word302

Well-Known Member
No, they don’t. Thread after thread, debate after debate, thousands and thousands of posts across various fora, have made this abundantly clear. Most people’s understanding of regulations is simplistic, flawed, and highly factually-inaccurate, and their statements bear it out continuously.


Is a PIC type-rated first officer, fully-qualified in the airplane, entitled to log PIC on her legs as PF?

-Fox
Nevermind. You obviously missed the point.
 

jtrain609

I'm a carnal, organic anagram.
"Before I go, what other regs doesn't this company like?"

Reminds me of a conversation with an FAA Attorney about Part 135 pilots getting nailed for a violation their employers insisted on.
Yeah but in this case it would be more restrictive than the regulations require, not less, thus putting you in compliance with the regulation.

Airlines are conformity factories. It's hard to understand how pervasive it is until you're inside one.
 
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