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Dual received / dual given


Pi/mech
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Can anyone give any insight into companies hiring at 1000 hrs, do they look into dual received/dual given or is it just a numbers game where all they want to see is a lump sum of total time? I ask because I did all my training at the minimums but at this time some of my peers, who trained at a 141 school, have 150+ hours from my total time from repeat of labs and such.

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When I was interviewing candidates, many moons ago, when I was young and innocent, I found myself looking suspiciously at "dual given" on people's resumes. The reason being some remarkably dubious hours claimed!

The classic case involved two Swiss gentlemen, both applying for a position, who, amazingly, had the same TT of dual instruction given! I asked for their logbooks, and went digging.

Well...

what these chappies had done was gotten their Commercial and CFI ratings, then gone out and split the costs of hiring an R-22, flown 150+ hours all around the great USA, and...

 

each logged those hours as dual given to the other...

 

They didn't get the job.

 

:rolleyes:

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FM, but what they did technically wasn't against regulations, was it? I can see why you didnt hire the two, but if only one applied, you would have been none the wiser, right? At what point is a cfi a cfi during a flight? They surely dont give verbal instructions during every hour of every flight. Will one comment such as "watch your altitude", "bird!", or anything suffice?

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FM, but what they did technically wasn't against regulations, was it? I can see why you didnt hire the two, but if only one applied, you would have been none the wiser, right? At what point is a cfi a cfi during a flight? They surely dont give verbal instructions during every hour of every flight. Will one comment such as "watch your altitude", "bird!", or anything suffice?

 

Maybe in this case, the difference is, an employed CFI providing flight instruction to a bonafide student who is paying for the service, compared to two pilots with CFI certificates burning time….. The true difference is, with one, there is documentation providing proof what was accomplished during the flight. The other, no documentation and no proof…..

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but if only one applied, you would have been none the wiser, right?

 

Firstly, I think technically (and morally) it IS wrong.

They were representing "CFI on a variety of students experience" they did not actually have. Secondly: Next thing is that an examination of the logbook would show ONE (very slow?) student? (Boy, that guy sure was struggling with straight and level flying. Here he goes from Orlando to Albuquerque, and he STILL needs instruction on S&L flying??)

Thirdly: Most potential employers are going to fly with you. And pretend to be a sloppy student. Okay, TEACH ME... :wacko:

 

I think most experienced interviewer CFII's will spot a "raw" CFI pretty quickly. Some things only come with time and experience.

 

I understand the hurt to get employed, I almost admire the enterprise, but that's not the way to go. I also agree with what Spike says above.

 

:ph34r:

Edited by Francis Meyrick
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FM, but what they did technically wasn't against regulations, was it? I can see why you didnt hire the two, but if only one applied, you would have been none the wiser, right? At what point is a cfi a cfi during a flight? They surely dont give verbal instructions during every hour of every flight. Will one comment such as "watch your altitude", "bird!", or anything suffice?

Well they don't both teach at the same time. This is more legit then the dual pic's with the hood on though.

 

Maybe they both had learned some extremly rare straight and level techniques that they traded with each other

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Well they don't both teach at the same time. This is more legit then the dual pic's with the hood on though.

 

Maybe they both had learned some extremly rare straight and level techniques that they traded with each other

 

That's the problem. Both guys logged it all as dual given. They can't both be actively teaching each other as instructors. At some point one of them has to become the student and log dual received.

 

It is absolutely NOT more legit than two PIC's when one is under the hood. The FAA has stated in many Letters of Interpretation than both can log PIC (one as the sole manipulator or the controls, one taking all the liability of ACTUALLY being PIC). If you were to take this "two instructors teaching each other at the same time" thing to the FAA, what exactly do you think they would say? I bet they would ask to "see" your certificate...

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I always interpreted being safety pilot is loggable as sic only based on the fars.

 

61.55 describes the requirements to qualify as sic. 61.55(f) specifically references that a safety pilot is exempt from certain sic training if acting as a safety pilot to meet the requirement for part 91.109.

 

91.109 states a safety pilot is required for simulated instrument flight and the requirements to qualify as a safety pilot.

 

To me it sounds like the fars make it a 2 pilot operation by requiring a safety pilot (91.109). And based on the 61.55, the safety pilot is considered an sic. It allows the reg private pilot to bypass the training required to normally qualify to be an sic.

 

To me, the only way to log flight time with 2 pics is if 1 is logging dual given and one dual received which is why i think the 2 cfi thing could be more legit then the safety pilot thing.

 

Now if the faa has written letters of interpretation differently, then who am I to disagree?

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Two pilots may log pilot in command time under at least three distinct circumstances.

 

A pilot acting as pilot in command of an aircraft requiring more than one crew member may log that time spent as PIC as PIC. If that pilot is not manipulating the controls, the pilot who is manipulating the controls (and rated in the aircraft) may also log the time as PIC.

 

A pilot who is rated in the aircraft and sole manipulator of the controls may log PIC; if instruction is being provided to that pilot, the instructor, acting as an authorized instructor, may also log PIC.

 

An ATP may log PIC when acting as PIC of any operation for which he is rated, that requires an ATP.

 

Two instructors flying together may log PIC. If one is acting as sole manipulator of the controls while the other is providing instruction, both may log PIC. In such a case, it really doesn't matter if the one acting as sole manipulator of the controls is a CFI or not.

 

An instructor who simply sits in the other seat and isn't actively providing instruction and acting as an authorized instructor, may not simply log PIC on the virtue of holding an instructor certificate. If he or she does provide instruction, then he or she must maintain a student record, and must endorse the logbook of the other pilot. If an instructor is receiving instruction, he generally won't be legitimately acting as an authorized instructor at the same time.

 

A case in which a pilot is acting as safety pilot makes that pilot a required crewmember, even in a single pilot airplane. A crew member may be required by the aircraft type certification, or the regulations under which the flight is conducted (IFR under 135, for example, or simulated instrument flight). In such a case, the safety pilot may be the SIC, or the PIC, depending on the agreement and arrangement between the two pilots. The pilot manipulating the controls may lot the time spent as sole manipulator, if rated in the aircraft. the safety pilot, if acting as PIC of an aircraft requiring more than one crewmember, may also log PIC. If the safety pilot is acting as SIC, he or she must also meet the requirements of 61.55 (second in command qualifications).

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I always interpreted being safety pilot is loggable as sic only based on the fars.

 

61.55 describes the requirements to qualify as sic. 61.55(f) specifically references that a safety pilot is exempt from certain sic training if acting as a safety pilot to meet the requirement for part 91.109.

 

91.109 states a safety pilot is required for simulated instrument flight and the requirements to qualify as a safety pilot.

 

To me it sounds like the fars make it a 2 pilot operation by requiring a safety pilot (91.109). And based on the 61.55, the safety pilot is considered an sic. It allows the reg private pilot to bypass the training required to normally qualify to be an sic.

 

To me, the only way to log flight time with 2 pics is if 1 is logging dual given and one dual received which is why i think the 2 cfi thing could be more legit then the safety pilot thing.

 

Now if the faa has written letters of interpretation differently, then who am I to disagree?

 

In order to log SIC, you have to be trained and rated and the aircraft has to require a second pilot as per its type certificate. If I'm flying an R44 around and the person next to me is a pilot, he can't log SIC just because he's occupying a seat. The aircraft doesn't require an second pilot. Same goes if I'm under the hood.

 

I think the following letter explains this all pretty well.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/louis%20glenn%20-%20(2009)%20legal%20interpretation.pdf

 

That letter also explains how two people can log PIC. It also explains how much of that time that the safety pilot can actually log as PIC, which is nice.

 

 

 

EDIT: Reference this letter instead. Second page, first paragraph after the bold ones. Reading beyond that first paragraph get into other things that we aren't discussing.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/trussell%20-%20(2012)%20legal%20interpretation.pdf

Edited by ridethisbike
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In order to log SIC, you have to be trained and rated and the aircraft has to require a second pilot as per its type certificate. If I'm flying an R44 around and the person next to me is a pilot, he can't log SIC just because he's occupying a seat. The aircraft doesn't require an second pilot. Same goes if I'm under the hood.

 

The regs I quoted in my last post explain that when in you're flying your R44 around, it becomes a 2 pilot operation when one pilot is under the hood. 91.109c states a safety pilot is required when the pic is wearing a hood and how one qualifies to act as a safety pilot. (Your faa letter references this in scenario 1 though they reference 91.109b instead of c. b is the wrong section of that reg. Maybe a typo or mistake on the faa's part). So yes, the aircraft does require a 2nd pilot if you are under the hood. But only during that time you are under the hood.

 

As far as the sic training required, 61.55b decsribes the familiarization training required to qualify as sic but 61.55f lists the exemptions to when that training is required. One of those exemptions is when acting as safety pilot to meet the 91.109 requirements.

 

Like I said before, I interpret that as my little R44, R22, cessna 150 etc, requires 2 pilots if one is under the hood and he is considered sic by the sic regs.

 

As far as the interpretation letter.....it is clear as mud consistant with the faa. Scenario 1 and scenario 2 both describe the exact same thing. Basically scenario 1 says the 2nd pilot can log only sic when the pic has a hood on because that is the only time a 2nd pilot is required. Then in scenario b, it says the 2nd pilot can only log pic while the 1st pilot is under the hood becauses that is the only time 2 pilits are required.

 

The letter to me seems to say log pic or sic. It's up to you. While I may not agree with that interpretation, who am I to argue with the faa?

Edited by rotormandan
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In order to log SIC, you have to be trained and rated and the aircraft has to require a second pilot as per its type certificate. If I'm flying an R44 around and the person next to me is a pilot, he can't log SIC just because he's occupying a seat. The aircraft doesn't require an second pilot. Same goes if I'm under the hood.

 

I think the following letter explains this all pretty well.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/louis%20glenn%20-%20(2009)%20legal%20interpretation.pdf

 

That letter also explains how two people can log PIC. It also explains how much of that time that the safety pilot can actually log as PIC, which is nice.

 

Negative; in order to log SIC, either the type certification for the aircraft must require a SIC, OR the regulations under which the aircraft is operated. In other words, the SIC must be required. It is not only the type certification of the aircraft that can require it. Operations as safety pilot, per the FAA Chief Legal Counsel, allow the logging of SIC time, as to 135 operations under IFR in which a second pilot is required in a multi engine aircraft (even if the aircraft type certification is single pilot).

 

Your post states that one cannot log SIC in an aircraft that's type certificated as single pilot, when conducting "under the hood" operations. This is not true. In fact, the legal interpretation you linked says just the opposite; SIC time can be logged during that time, if the safety pilot is acting as SIC.

 

If the safety pilot is acting as PIC (is the legal PIC for the flight), both pilots may log PIC.

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As far as the interpretation letter.....it is clear as mud consistant with the faa. Scenario 1 and scenario 2 both describe the exact same thing. Basically scenario 1 says the 2nd pilot can log only sic when the pic has a hood on because that is the only time a 2nd pilot is required. Then in scenario b, it says the 2nd pilot can only log pic while the 1st pilot is under the hood becauses that is the only time 2 pilits are required.

 

The letter to me seems to say log pic or sic. It's up to you. While I may not agree with that interpretation, who am I to argue with the faa?

 

Negative.

 

In a "safety pilot situation," the safety pilot may log SIC if the safety pilot in not the acting pilot in command. If the pilot manipulating the controls is the acting pilot in command, then the safety pilot may NOT log pilot in command, but SIC only.

 

The two situations are not identical; whether the safety pilot can log SiC depends on his or her legal status during the flight.

 

There is a difference between LOGGING pilot in command time, and ACTING as pilot in command, and it is that difference that's addressed by the letter.

 

If one is safety pilot and the ACTING pilot in command, one may log PIC as one is the pilot in command of an aircraft requiring more than one crew member under the regulations under which it is operated. In this case, both pilot may log PIC.

 

If one is safety pilot and not the ACTING pilot in command, one may log SIC only, as one is not the pilot in command of an aircraft requiring more than one crew member. In this case, only the pilot manipulating the controls, who is also acting as pilot in command, may log the time as PIC.

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Negative.

 

In a "safety pilot situation," the safety pilot may log SIC if the safety pilot in not the acting pilot in command. If the pilot manipulating the controls is the acting pilot in command, then the safety pilot may NOT log pilot in command, but SIC only.

 

The two situations are not identical; whether the safety pilot can log SiC depends on his or her legal status during the flight.

 

There is a difference between LOGGING pilot in command time, and ACTING as pilot in command, and it is that difference that's addressed by the letter.

 

If one is safety pilot and the ACTING pilot in command, one may log PIC as one is the pilot in command of an aircraft requiring more than one crew member under the regulations under which it is operated. In this case, both pilot may log PIC.

 

If one is safety pilot and not the ACTING pilot in command, one may log SIC only, as one is not the pilot in command of an aircraft requiring more than one crew member. In this case, only the pilot manipulating the controls, who is also acting as pilot in command, may log the time as PIC.

Like I said clear as mud.

 

Ok. So someone tell me then. I'm the 2nd pilot in an R44. I can't log any sic or pic time unless the 1st pilot is flying simulated instrument. Once the 1st pilot goes under the hood, how exactly do I "ACT" any differently whether I'm acting as a pic safety pilot or acting as an sic safety pilot? Either way I'm going to keep an eye on traffic, obstacles, and keep us from actually going imc. Either a pic or a sic can run the radios, navigate, keep an eye on temps/pressures or take care of an emergency and either pilot in this situation can be handling those things depending on the level of experience of the pilot under the hood.

 

In practice: There's no difference.

 

In wording: It's who's "ACTING" as what? It depends what word you want to use and what you want to log today.

 

I don't agree with the 2 pic thing but I see it's completly legit if worded correctly. Too bad the letter only came out in 2009 because I could've used that wording to save a few bucks about 10 years ago. Guess I missed out.

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Ok. So someone tell me then. I'm the 2nd pilot in an R44. I can't log any sic or pic time unless the 1st pilot is flying simulated instrument. Once the 1st pilot goes under the hood, how exactly do I "ACT" any differently whether I'm acting as a pic safety pilot or acting as an sic safety pilot?

 

Once a hood goes on during a VFR flight, someone needs to be legally responsible and the hooded guy isn’t that guy. Simply put, the “V” in VFR means something. If the hooded guy was legal, then he wouldn’t need a safety pilot…. Obviously, it’s not the guy under the hood who is responsible as he is just the guy at the controls…… You, the safely pilot, are responsible and why you must be rated to do so…….

 

I routinely fly in a helicopter as a crewmember (in the left seat with dual controls) where I’m not in the PIC seat, nor am I the sole manipulator. In this case, both pilots are CFI’s. I never log this time as PIC time. Why? I’m not performing the “duties of” or the “responsibilities of” (acting) as an instructor. Simple eh? The mere fact the rating is a Certified Flight INSTRUCTOR rating implies that instruction is given and thus allowing CFI’s to log the time…. Short of that, it’s a no go in my book…..

Edited by Spike
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Like I said clear as mud.

 

No, it's quite clear. Seek first to understand the regulation, and that begins with reading.

 

First you need to understand the difference between being/acting as pilot in command, and logging PIC. The two are NOT the same.

 

Acting as pilot in command means you're the person responsible for the safe outcome of the flight. You're ultimately responsible. You ARE the pilot in command. Yours is the final word regarding the conduct of the flight, and you are taking legal responsibility for the flight in all its respects.

 

If your'e acting as pilot in command, this is by agreement; the pilot in command must be known and designated in advance. If you're undertaking a flight with another pilot in the cockpit, there needs to be a very clear understanding about who is pilot in command, and that should never be in doubt. If there's a mishap or problem or violation of the regulation, you're the guy on the hook. You're the PIC.

 

Logging PIC means writing something down on paper. It's not at all the same as acting as pilot in command. Logging is about what's written down after the flight. You do not need to have been the pilot in command in order to log PIC, as 14 CFR 61.51(e) provides a number of means by which a pilot may log PIC.

 

 

 

Ok. So someone tell me then. I'm the 2nd pilot in an R44. I can't log any sic or pic time unless the 1st pilot is flying simulated instrument. Once the 1st pilot goes under the hood, how exactly do I "ACT" any differently whether I'm acting as a pic safety pilot or acting as an sic safety pilot? Either way I'm going to keep an eye on traffic, obstacles, and keep us from actually going imc. Either a pic or a sic can run the radios, navigate, keep an eye on temps/pressures or take care of an emergency and either pilot in this situation can be handling those things depending on the level of experience of the pilot under the hood.

 

In practice: There's no difference.

 

 

 

No, in practice, there's a BIG difference. If you're acting as pilot in command, you're God Almighty in that cockpit. There is no authority greater than yours regarding the conduct and safe outcome of that flight. You may deviate from any rule or regulation in order to meet the requirements of an emergency. Your authority is outlined in the regulation. If your'e acting as pilot in command, in other words being pilot in command, in other words ARE the pilot in command, then it's your ship and your aircraft and you're in charge.

 

In a crew cockpit environment, one pilot is pilot in command, and everyone else operating in that cockpit answers to the pilot in command.

 

The R44 is a single pilot cockpit. That changes during simulated instrument flight, when a SIC is required. When the pilot, who is flying the aircraft as sole manipulator of the flight controls, wears a view limiting device, you become a required crew member if you're acting as safety pilot. If the two of you have agreed beforehand that you will be the pilot in command, that makes you the acting PIC. If your'e acting as PIC of the aircraft during the time simulated instrument flight is conducted, you may log that time as PIC under the regulation. In that case, you're both acting as PIC (you ARE the pilot in command), and you're logging pilot in command (two very different things).

 

If prior to beginning the flight you agree with the other pilot that he is the acting pilot in command, then you cannot be pilot in command. There may be only one pilot in command in an aircraft. More than one person may log PIC time, but logging time is not the same as actually being the pilot in command. In this case, in the R44 with the pilot under the hood, who is flying, acting as PIC, you may log SIC time only. You are the second in command in that aircraft. You are neither sole manipulator of the controls, nor are you the acting pilot in command. In this case, you do not have the authority of PIC, nor the responsibility, and are not the final authority regarding the operation of the aircraft. You may not log the time as PIC.

 

If as the safety pilot in the R44 during simulated instrument flight you are acting as pilot in command (again: if you ARE the pilot in command), you may log the time as PIC. You are filling two roles: safety pilot, and pilot in command. This is by prior agreement between you and the other pilot. If during this time, the other pilot removes his view limiting device, you are no longer required as a safety pilot, and although you are acting as pilot in command, you may are no longer acting as pilot in command of an aircraft requiring more than one crew member. You are the pilot in command, but you may not log the time as PIC because you do not fill any regulatory allowance for logging that time. You may log neither PIC nor SIC. You are still pilot in command, however.

 

There are times when one pilot may log PIC, when both pilots may log PIC, and time when no one may log PIC. Understanding the regulation, which is not very complicated at all, is key.

 

 

In wording: It's who's "ACTING" as what? It depends what word you want to use and what you want to log today.

 

I don't agree with the 2 pic thing but I see it's completly legit if worded correctly. Too bad the letter only came out in 2009 because I could've used that wording to save a few bucks about 10 years ago. Guess I missed out.

 

 

You needn't agree with the regulation or it's interpretation; it exists regardless of whether you like it or not. The regulation has allowed the logging of pilot in command by two pilots for over 30 years, and numerous legal interpretations over the years have affirmed that. This is not new. jj

 

It's far more than wording; it goes back to the very essence of the buck-stops-here designation and responsibility of BEING the pilot in command.

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(Your faa letter references this in scenario 1 though they reference 91.109b instead of c. b is the wrong section of that reg. Maybe a typo or mistake on the faa's part).

 

 

 

The FAA isn't wrong, and the FAA didn't make a mistake. 91.109( b ) used to be there reference ,and the regulation was recodified to place the requirement for a safety pilot under 91.109( c ). When the legal interpretation was issued, the correct reference was 91.109( b ), which is why you see that in the letter.

 

There are three means to understanding the regulation, and gain the correct interpretation thereof:

 

1. The regulation itself

 

2. Federal Register Preambles (the information contained with the regulation at the time it was released as a final rule in the Federal Register)

 

3. FAA Chief Legal Counsel letters of interpretation (also called legal opinions).

 

Some like to ask the inspector at the local FSDO, but that is not correct; the FAA does not authorize the inspector at the FSDO level to interpret the regulation, and anything you get that that level, whether spoken in person or in writing, is not defensible as an interpretation of the regulation. You must look to the correct sources. The only entity authorized by the Administrator to interpret the regulation is the Chief and Regional Legal counsel's office.

 

Chief Legal Counsel interpretations are defensible, and ARE how the regulation will be viewed during the enforcement and appeal process. It's not uncommon to find inspectors at the FSDO level who who dot understand the regulation, and who would interpret it incorrectly, and those who enforce it incorrectly, too. This is partially why the enforcement process is really built around the appeals process.

 

Something else that many pilots don't fully appreciate is how the regulation works. When dealing with the FAA and regulation and violations and enforcement, one isn't dealing with criminal law or civil law; this is administrative law. It works differently than what you may think. You may be familiar with the concept of "innocent until proven guilty," and think that applies to you when dealing with the FAA. This is an error; with the FAA under Administrative law, you are guilty until proven innocent, which is why you're convicted before you have a chance to defend yourself. You're violated, and THEN you get to appeal. Many pilots don't truly understand this, and it can cause a lot of grief; know and understand the regulation in advance to avoid becoming the subject of enforcement action, and take the regulation very seriously. The FAA does.

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This isn't a response to any of the above posts as I haven't read them. I misread the letter I posted above. I think I might have been hasty in choosing which one to post. I swear I read somewhere that both pilots could log PIC. Doing some digging now...

 

 

Done. Second page. States both pilots may log PIC.

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2012/trussell%20-%20(2012)%20legal%20interpretation.pdf

Edited by ridethisbike
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No wonder pokey doesn't like you. More often than not, I feel like you get a bad rap, but for someone who is always bashing on people for calling you names, you sure do have a way with words, don't you?

 

I HAVE read them. How do you think I would even know about them? I glossed over them this time, I know... how dare I... Covered in great detail or not, I've posted links to verifiable references on the topic. I may have missed the specific section in the first letter where it said two pilots may log PIC, but the second letter was spot on. If that's not good enough for you, nothing must be. Good day.

Edited by ridethisbike
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you guys don't have to love each other, but you might try liking one another just a little bit...?

 

Brother pilots...?

 

:huh:

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No wonder pokey doesn't like you.

 

Heh, just Pokey? You should read the private messages and emails and FB messages *I* get! Holy cow.

 

Avbug used to annoy the piss out of me. Now I just...I dunno...I guess I feel sorry for him. And every day of my life I get down on my knees and thank Jesus that I don't have to work with him, or for him, or that he doesn't work for me, and that I'm not related to him. I mean, damn! I thought that divorced, angry atheist chick that drives that red R-44 was insufferable! (She is.) How does aviation attract such...such...such people? I do not know.

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you guys don't have to love each other, but you might try liking one another just a little bit...?

 

Brother pilots...?

 

:huh:

 

Generally speaking, I have no issue with him. A lot of his posts are informative. That being said, he does spend a lot of time trying to defend himself and tear down others for name calling and making posts that have no bearing on the topic at hand. I feel like those posts aren't needed. You know what though? Who am I to say he, or anyone for that matter, can't exercise their right to free speech? That's the point of a forum, isn't it? To let people "talk"? I'm not going to get upset over something someone said on the internet. It's pointless. And if he were to want to go get a beer some time, I wouldn't decline. I bet he's got some great stories!

 

 

 

 

Heh, just Pokey? You should read the private messages and emails and FB messages *I* get! Holy cow.

 

Avbug used to annoy the piss out of me. Now I just...I dunno...I guess I feel sorry for him. And every day of my life I get down on my knees and thank Jesus that I don't have to work with him, or for him, or that he doesn't work for me, and that I'm not related to him. I mean, damn! I thought that divorced, angry atheist chick that drives that red R-44 was insufferable! (She is.) How does aviation attract such...such...such people? I do not know.

 

 

Really? From him specifically, or just people in general?

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