Question about counting dual time as PIC time

[cdf]

I started my flight training back in August and finally got to solo this past Sunday. Flying the helo is a lot funnier than flying a fixed wing.

 

When I started my training my instructor mentioned that I might be able to count my dual time in the helo as PIC time since I was already a rated pilot. Does anybody out there have any knowledge on this?

 

Thanks for your input

[Helihead]

k

Edited December 20, 2008 by Helihead

[joelpry]

I will attempt... I dont think you can... FAR 61.51 (e)1(i) states that a sport, rec., private, or commercial pilot may log PIC time only for that flight time during which the person is the sole manipulator of the controls of an aircraft for which the pilot is RATED. Your not rated in rotorcraft-helicopter so I dont thinnk you can log it.... Now where the FW license helps is in the amount of flying and the maneuvers required to complete before your able to take your practical test. No knowledge test needed.

[Jeff]

Joelpry is correct. If you are not rated in a helicopter (as in "Rotorcraft-Helicopter" on your pilot certificate) you may not log the dual time as PIC. The regulation does, however, mention something about operating privileges. You might think, since you are already a pilot, that once your instructor gives you a PIC endorsement, you can log dual time as PIC. That language of "operating privileges" only applies to Sport Pilots.

 

Jeff

[Eric Hunt]

Think about what PIC stands for - Pilot In Command.

 

If there is an instructor on board, he is in command. He is teaching you. If something needs to be done, he is the one making the final decision. He is the one responsible if it all rolls up in a ball. You are logging Dual time.

 

There can only be one person on board who is in command - the captain. If Dual, it is the instructor. If Solo, it is the student. If 2 students are flying together, one needs to be nominated as the captain, and he logs the PIC. When the other student is operating the controls (if authorized to do so) he may log that time as PIC, even if the real Captain is also logging that time.

 

Suck it up, log the dual time, the PIC will come later. When you only have 50 hours logged, 1 hr PIC is 2% of your total time, but the dual is 98%. Nothing wrong with that, I have 600 hrs dual time logged out of 13,000 hrs, so the percentages reverse after a while. Lots of check rides, endorsements on types, rating renewals etc, and that doesn't count the amount of time I spent as an instructor teaching and doing check rides on other people.

[apiaguy]

You are all WRONG!!!

 

If you are a rated pilot (fixed wing in this example) and you are doing an add-on rating you may log all of your time as PIC. You are already a pilot and merely adding a different category and class does not mean you "lose" your current status as a pilot. That's why you have VERY few limitations as a add-on student (at least as far as the feds are concerned) You just can't carry passengers.... you don't need any sign-off's for cross countries or any supervision.. you just need a solo endorsement and you can do whatever and go wherever you want. You can log the pic time even with the instructor on board as long as you are the one holding the controls.

[joker]

Apiaguy,

 

You are all WRONG!!!

 

Hmmm...

 

Care to explain? You are very confident with that, yet offer no proof.

 

Joker

 

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Eric,

 

I presume that you mean two rated pilots here, not 'Student Pilots'.

 

If 2 students are flying together, one needs to be nominated as the captain, and he logs the PIC. When the other student is operating the controls (if authorized to do so) he may log that time as PIC, even if the real Captain is also logging that time.

 

That aside, let's say the 'other' pilot is sole manipulator for the entire flight. On what basis can the 'nominated PIC' also log any PIC time?

 

Joker

 

 

JEFF - You ruined it...I was inviting Apiguy to explain that one...it would have been interesting!

Edited November 11, 2007 by joker

[Jeff]

You are all WRONG!!!

 

If you are a rated pilot (fixed wing in this example) and you are doing an add-on rating you may log all of your time as PIC. You are already a pilot and merely adding a different category and class does not mean you "lose" your current status as a pilot. That's why you have VERY few limitations as a add-on student (at least as far as the feds are concerned) You just can't carry passengers.... you don't need any sign-off's for cross countries or any supervision.. you just need a solo endorsement and you can do whatever and go wherever you want. You can log the pic time even with the instructor on board as long as you are the one holding the controls.

 

Sorry, but you are the one who is wrong. 14 CFR 61.51(e)(1)(i) specifically says: "A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges."

 

If you are a Private Pilot ASEL and are training for a Rotorcraft Helicopter additional category rating, you currently are not rated in helicopters. Therefore, you cannot log PIC time in a helicopter while receiving dual instruction. In the above-quoted FAR, the word "privileges" refers to sport pilots only, not the PIC privileges you would get when training for an additional category rating.

 

Jeff

[Jeff]

Apiaguy,

 

 

JEFF - You ruined it...I was inviting Apiguy to explain that one...it would have been intersting!

 

Sorry, Joker. It still might be interesting though! I'm looking forward to finding out what regs are out there that will prove me wrong.

[helonorth]

It seems clear enough that you must be rated in the aircraft or flying solo to log PIC. Although

it is true that a rated student can do just about anything they want with a PIC endorsement,

(not a solo endorsement, apiaguy) the instructor can put limitations on it. When doing an add-on,

I would put a expiration date on it as well as day VFR day limitations.

[apiaguy]

I rescind my comments and apologize. I was wrong.

[joker]

OK - Good to see we have that cleared up.

 

Just to add to Jeff's comments (regarding the use of the words 'for which they are rated') I mention 61.5

 

This little known FAR lists the certificates and ratings available from the FAA. If you don't have the appropriate rating in the ratings list (is it b?), then you may not log PIC (notwithstanding the other parts).

 

Eric, I don't think you are right with your assertation that both pilots can log PIC time.

 

Joker

[Helihead]

k

Edited December 20, 2008 by Helihead

[joker]

OK, I'm at work so this is totally off the top of my head.

 

Eric's scenario

 

Nowhere in 61.51(e) does it allow for two private pilots in the aircraft together to log PIC in persuant of a certificate or rating*.

 

Only the 'sole' manipulator can log any sort of PIC time. That is regardless of who will go to court if anything goes wrong (the nominated PIC).

 

61.51 is the only place where the regulations for LOGGING can be found. Again, no provision for two private pilots to log the PIC time.

 

Some people misunderstand the entry in 61.31(d) where it goes on about 'receiving training'. This is with respect to that flight. Therefore, the only time you can recieve training is when another instructor is on board. Of course when you are solo you have to be PIC.

 

*There is of course a time when two private pilots may both log some PIC at the same time. That is when they one is acting as a 'safety pilot' as required by 91.109. Then the last part of 61.51(e) mentions that a pilot may log PIC time when on a flight where two pilots are required by the FARs.

 

There it is.

 

If this is not clear, say so and when I get home, I'll explain further.

 

Joker

[Jeff]

I think that both pilots can log PIC, if one is the PIC and responsible for the final outcome of the flight, and during the flight the other pilot takes the controls then they can both log PIC since one is the sole manipulator and the other is the responsible if they crash, that is what I have heard..

 

The example being a safety pilot for another pilot under the hood. So I think both can log PIC but the one pilot can only log it while he is the sole manipulator of the flight controls.? anyone know if this is true I am not 100% on this,. the safety pilot is the one who is responsible for the outcome of the flight IE "the safety of the flight" /PIC and if the other one is under the hood and the sole manipulator of the controls then both can log PIC.

Here is what I have heard to adding to the safety pilot deal... they can both log PIC but the PIC who is responsible for the final outcome of the flight is the only one who can log cross country PIC if they go on a x-country flight not sure why that is but thats what I hear and what I can remember .

 

Helihead,

 

As you mention, it is perfectly legal for one rated pilot to fly under the hood and another rated pilot to act as safety pilot. Either pilot may act as pilot in command; this must be established prior to the flight. (Best to do it in writing and leave the paper on the ground for legal and insurance purpose if something goes wrong.) If the pilot under the hood is flying, then he may log PIC time. If the safety pilot is designated as pilot-in-command, then he may also log PIC time (Ref. 14 CFR 61.51 (e)(1)(iii)). If the pilot under the hood is designated as PIC, then the safety pilot cannot log PIC time, but may log SIC time (Ref. 14 CFR 61.51 (f)(2)).

 

But consider this. If you are acting as a safety pilot for someone, do you really want responsibily for the flight? Sure, you're still responsible for collision avoidance, but what if the pilot under the hood violates airspace? Or what if he follows a clearance wrong and gets a phone number to call? Do you REALLY want that responsibility? If you are an instructor, you automatically take on that responsibility, but you should know that already and pay more attention to what the pilot under the hood is doing.

 

Here's another scenario. Let's say you're an instrument-rated pilot. You go on a flight under IFR in IMC (weather probably doesn't matter in this case, just the fact that you are IFR). You let your friend who is a rated pilot with no instrument rating fly the aircraft. He can log PIC time (and actual instrument time if you're IMC) since he is the sole manipulator of the controls in an aircraft for which he is rated. You are, by default, the pilot-in-command. You therefore can log PIC time. You cannot log instrument time except for the time you are manipulating the controls by sole reference to the instrument, unless you are an instrument instructor. (Ref. 14 CFR 61.51(g))

 

Logging of cross-country time is not germane to this topic since it is not flight crewmember specific. Both pilots can log the cross-country time if it is a cross-country.

 

Jeff

[Jeff]

Just to add to my last post...

1. Being PIC and logging PIC are two different things.
   
2. There is a fine line between legal and safe!
   

Jeff

[joker]

Here's another scenario. Let's say you're an instrument-rated pilot. You go on a flight under IFR in IMC (weather probably doesn't matter in this case, just the fact that you are IFR). You let your friend who is a rated pilot with no instrument rating fly the aircraft. He can log PIC time (and actual instrument time if you're IMC) since he is the sole manipulator of the controls in an aircraft for which he is rated. You are, by default, the pilot-in-command. You therefore can log PIC time. You cannot log instrument time except for the time you are manipulating the controls by sole reference to the instrument, unless you are an instrument instructor. (Ref. 14 CFR 61.51(g))

 

Jeff,

 

I read this scenario and something immediately hit me as odd.

 

Then it struck me, that this is exactly the same as Eric's scenario, just with the added instrument rating. I am not happy with your assertion there that the instrument rated pilot can log PIC time, by virtue of his being designated to act as PIC.

 

You said, "You are, by default, the pilot-in-command. You therefore can log PIC time."

 

OK first, let's establish that we are talking about 'logging' time for the fulfilment of 61.51(a)(2) i.e.:

 

The aeronautical experience required for meeting the recent flight experience requirements of this part.

 

If that is then the case, the rest of 61.51 prevails and the regs about logging of 'pilot-in-command' time is contained in 61.51(e).

 

The only relevant part of 61.51(e) is:

 

(e) Logging pilot-in-command flight time.

(1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person--

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

(iii) Except for a recreational pilot, is 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.

 

Please explain to me then how this fits your scenario.

 

Put the other way, nowhere do I find evidence to suggest that just because you have been designated as PIC, you may log PIC.

 

I believe that only one pilot may log PIC at a time here. The time that a pilot is 'sole manipulator' is credited to him as PIC time. Any time he is not sole manipulator, he is just a passenger. That is irrespective of who has signed for the aircraft and goes to gaol if an airspace is busted.

 

Remember, 61.51 does not care about the 'legal' position pilots and who is designated as PIC as per 61.1

 

61.51 only cares about whether you got experience worth crediting towards a further rating or certificate.

 

OK, in a some book you might have a record of all the instances that you acted PIC. That's fine. You can do that. But the FAR does not ask for that time. That's what the courts want.

 

 

---------------------------------------------------------------------------

 

Similarly, on the logging of instrument time, no one gets credit for being the instrument rated pilot who filed the IFR flight plan.

 

61.51(g) is clear as the writing on the wall (or in the FAR).

 

(g) Logging instrument flight time. (1) A person may log instrument time only for that flight time when the person operates the aircraft solely by reference to instruments under actual or simulated instrument flight conditions.

 

If you sit there watching your non-instrument rated buddy flying whilst you are in the clouds on an IFR flight plan then you are simply an observer. I the idea is this. You have not been trained to monitor (as CFII) a person flying with reference to instruments. You have only been trained to do it yourself. Therefore, while he is flying you are not making 'decisions'. I'm sure though if anything went wrong though, you'd get your ass sued for letting a non-instrument rated pilot fly!

 

So again from your scenario, any time your friend is at the controls, you may not log PIC time or instrument time.

 

Well, its very late for me, so I could be wrong. But that's how I see it.

 

Joker

Edited November 12, 2007 by joker

[Jeff]

Joker,

 

Perhaps you are right. If I'm instrument rated and I'm letting my friend manipulate the controls during IMC, I might not be able to log PIC when I'm not manipulating the controls because the regulations under which the flight is conducted do not require two pilots. Or do they? Granted, my non-instrument rated buddy is not a required flight crewmember. I'm the only one who needs to be there. On the other hand, let's say my friend wants to get some hood time to practice some approaches on a severe clear day, and let's assume that I'm not an instructor. One could argue that the regs do not require two pilots to be on board. My friend under the hood is not a required flight crewmember since I am the only pilot really required.

 

Okay, so my point is this. The pilot under the hood or the non-instrument rated pilot in IMC may not absolutely have to be there; but that is the purpose of the flight. So in order for him to fly under those circumstances, a safety pilot is required. In VMC, the safety pilot can be any pilot rated in that aircraft who's current, etc., and in IMC, the safety pilot must have an instrument rating. In the case of the IMC, the instrument-rated safety pilot IS the PIC and may also LOG PIC because he IS the PIC and more than one pilot is required by the "regulations under which the flight is conducted."

 

This is merely academic since I'm an instructor as are you. But people on VR that aren't will hopefully benefit from our discussion.

 

Jeff

[cdf]

Thanks for all of the feed back.

 

cdf

[joker]

The pilot under the hood or the non-instrument rated pilot in IMC may not absolutely have to be there; but that is the purpose of the flight. So in order for him to fly under those circumstances, a safety pilot is required.

 

Jeff,

 

I know where you are trying to go with this, but I think it is a little farfetched. At least for the case of the IMC flight, so let's focus on that for the moment.

 

and in IMC, the safety pilot must have an instrument rating. In the case of the IMC, the instrument-rated safety pilot IS the PIC and may also LOG PIC

 

Where are you getting these rules from?

 

OK, as 'Safety Pilot' does not appear to be defined anywhere obvious, let's use a little logic to answer the question, 'What is a safety pilot (for)?" 91.109 is the only place I know that discusses 'safety pilots'.

 

Specifically, 91.109( states:

 

( No person may operate a civil aircraft in simulated instrument flight unless--

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

 

Note my emphasis on the words 'simulated instrument'. Is IMC simulated instrument? No. So any time you are IMC, the regulations regarding safety pilots do not apply.

 

Of course, VFR flight with a view limiting device for the purpose of instrument training or practice is simulated instrument. Then a safety pilot is required. More than one crew member is required.

 

Going back to 61.51(e)(iii):

 

(iii) Except for a recreational pilot, is 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.

 

Again, my emphasis is on the relevant words.

 

You are claiming that the minute a passenger puts on a hood in IMC and starts manipulating the controls, the other pilot (presumably instrument rated) suddenly becomes a 2nd required crew member and can log PIC under 61.51(e)(iii)

 

However, that rule will only allow logging of PIC when more than one pilot is required by (among other thing) regulations.

 

So the onus is on you to find those regulations where more than one crewmember is required for a flight in IMC.

 

Let's go back to the requirements for a safety pilot as per 91.109(. Why would this specifically say, "simulated instrument." Note here, that the rest of 91.109 describe how a safety pilot must be able to look outside (adequate vision forward and to each side of the aircraft).

 

Well, flight in IMC is not simulated instrument...it's actual instrument. So we must be talking about flight in VMC.

 

Flight in VMC (or flight in aircraft not authorised for IMC) is regulated so as to require outside references. If you are VFR, then you must look outside for traffic avoidance. If you are IFR, you must stay where you can see outside to have a good reliable horizon and visual cues. This is why a safety pilot is required. IMC of course, does not require any 'looking outside'; that would be silly. So no safety pilot is required when in IMC.

 

Before you and friend can go IMC, one of you is required to fulfill certain criterea - to be instrument rated and current and to receive a clearance. As this is you, all the pilot requirements have been fulfilled. You are no longer needed by the FAR. If your buddy, then puts a hood on, well going by my reasons above, you don't need to look outside...you have the instruments in front of you...the same ones he is looking at. You are not a safety pilot! You are not required anymore by the FAR.

 

There are no regulations which require a safety pilot to be present during IFR! Just as there are no regulations which allow two PPLs to simultaneously log PIC in a normal VFR flight.

 

Usual humble disclaimer: OK, I rambled because I've had a few tonight, so could be wrong. I actually really don't know of any OTHER time (other than simulated instrument) where an aircraft rated for single pilot flight, could require 2 crewmembers. Can anyone find another example?

 

I think I am done with this thread. Its fun, but to me the regs are logical, specific and clear on this one. Save for the special cases (safety pilot and general instruction) two people in a single pilot aircraft generally can't log PIC at the same time.

 

Too much double logging causes logbook inflation, and warps the space-time continuum as there are too many flight hours floating around.

 

That's all,

 

Thanks.

 

Joker

Edited November 14, 2007 by joker

[Jeff]

You raise a valid, logical point, Joker, about the safety pilot being required for IMC. I'm going to adopt your point of view for now until there is compelling evidence to cause me to look for a new one. Like I said before, it's really a moot point for me since I am an instrument instructor, but it was fun for me to challenge my paradigm.

 

Jeff

Edited November 14, 2007 by Jeff

[Helihead]

Just to add to my last post...

1. Being PIC and logging PIC are two different things.
   
2. There is a fine line between legal and safe!
   

Jeff

 

 

I agree, just looking to get hours as cheap as possible if I have to pay for them... and if acting as PIC and letting someone I trust manipulate the controls I am willing to pay half price for time I would have to pay otherwise.

 

thanks for all the input/advice