Logging PIC time as a FO
07-05-2014, 06:17 PM
#31
Gets Weekends Off
Joined APC: Dec 2007
Posts: 453
Oh wise guru, please enlighten.
Because if you want to look at sole manipulator under 61, there is an exception :"(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under parts 91 and 121 for that certificate holder if the pilot in command is in compliance with §§121.435 or 121.436, as applicable, and §121.439 of this chapter."
Because if you want to look at sole manipulator under 61, there is an exception :"(2) This section does not apply to a pilot in command who is employed by a part 119 certificate holder authorized to conduct operations under part 121 when the pilot is engaged in a flight operation under parts 91 and 121 for that certificate holder if the pilot in command is in compliance with §§121.435 or 121.436, as applicable, and §121.439 of this chapter."
07-05-2014, 08:10 PM
#32
Where's my Mai Tai?
Joined APC: Aug 2006
Position: fins to the left, fins to the right
Posts: 1,755
Fine. 61.51.e.iii
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or
The flight would be operated under 121. Still can't log it.
Try again.
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or
The flight would be operated under 121. Still can't log it.
Try again.
07-05-2014, 08:13 PM
#33
Banned
Joined APC: Oct 2008
Position: Window Seat
Posts: 1,430
So let's bring this back to reality...
Is it legal to log? YES!
Will it be respected on a resume? NO! (with very few exceptions).
Log your time in a way that is easy to tally depending on what prospective employers want.
Simple enough for everybody?
Also can we sticky this since it comes up about once a week?
07-05-2014, 08:25 PM
#34
Where's my Mai Tai?
Joined APC: Aug 2006
Position: fins to the left, fins to the right
Posts: 1,755
It doesn't specify PIC or SIC. It says pilot. The logging of flight time would be controlled under 121/ops specs .
07-05-2014, 09:18 PM
#35
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Joined APC: Apr 2008
Position: Sleeping in the black swan’s nest.
Posts: 5,726
That has not been my experience, most of the jobs that I know of abroad actually do NOT accept this time at all.....! As a matter of fact, most don't even accept the PIC time some people write while they were doing their IOE...., since it is really dual received time because your instructor/check airman is the one listed on the release as the PIC. You are on the left seat manipulating the controls and still they won't accept it.
But I will say this one more time just so it is clear. DO NOT log type rated FAR 121 sole manipulator time as PIC in your log book for the purpose of fulfilling PIC requirements for any U.S. airline. I wouldn't do it under any circumstances, if some foreign contract outfit wants to credit you with sole manipulator time then you can work out the details as necessary.
07-06-2014, 04:45 AM
#36
Gets Weekends Off
Joined APC: Jul 2008
Posts: 864
Yes, you can log it. There are several interpretations. I've copied one below.
As has been noted, most (if not all) airlines will NOT count that time as PIC so you'll need a way to remove it easily from your totals when filling out job applications.
That leaves the question of whether or not you should log it. I don't because there's no reason to log it.
Legal Interpretation # 92-46
August 3, 1992
Mr. William Clay Cunningham
Dear Mr. Cunningham:
Thank you for your letter of September 28, 1991, in which you ask
a question about the logging of pilot-in-command (PIC) time when
operating under Part 135 of the Federal Aviation Regulations
(FAR).
Before addressing your question, I would like to first apologize
for the delay in responding to your letter. In recent months, a
large number of priority projects have been assigned to this
division that have prevented us from responding in a more timely
manner to the many requests for interpretations. Mr. Irshad A.
Haqq of my staff recently discussed this situation and the
question raised in your letter with you via telephone. This
letter constitutes our formal reply.
In your letter, you pose the following scenario: under a part
135 operation, the flight crew of a 19 seat deHaviland Twin Otter
(DHC-6-300) consists of a captain and first officer, neither of
whom is required to possess a type rating to act as a flight
crewmember. You then ask whether the first officer may log PIC
time for the period during which he is the sole manipulator of
the controls of the aircraft. You also explain that you have
received conflicting answers from local FAA personnel to whom you
have posed this question.
The answer to your question is yes. Under Section 61.51(c)(2) of
the FAR, the first officer may log as PIC time that time during
which he is the sole manipulator of the controls of the aircraft.
In fact, both the captain, assuming he is the designated PIC
required under Section 135.109, and the first officer may
simultaneously log as PIC time that time during which the first
officer is the sole manipulator of the controls.
We recently rendered an interpretation encompassing the issue you
raise as well as other questions related to the logging of PIC
time under the FAR. A copy of that June 25, interpretation
addressed to Mr. Dallas Butler is enclosed for your reference and
convenience. The sections of the FAR that are pertinent to this
issue are cited in that letter.
We hope this satisfactorily answers your question.
Sincerely,
/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division
As has been noted, most (if not all) airlines will NOT count that time as PIC so you'll need a way to remove it easily from your totals when filling out job applications.
That leaves the question of whether or not you should log it. I don't because there's no reason to log it.
Legal Interpretation # 92-46
August 3, 1992
Mr. William Clay Cunningham
Dear Mr. Cunningham:
Thank you for your letter of September 28, 1991, in which you ask
a question about the logging of pilot-in-command (PIC) time when
operating under Part 135 of the Federal Aviation Regulations
(FAR).
Before addressing your question, I would like to first apologize
for the delay in responding to your letter. In recent months, a
large number of priority projects have been assigned to this
division that have prevented us from responding in a more timely
manner to the many requests for interpretations. Mr. Irshad A.
Haqq of my staff recently discussed this situation and the
question raised in your letter with you via telephone. This
letter constitutes our formal reply.
In your letter, you pose the following scenario: under a part
135 operation, the flight crew of a 19 seat deHaviland Twin Otter
(DHC-6-300) consists of a captain and first officer, neither of
whom is required to possess a type rating to act as a flight
crewmember. You then ask whether the first officer may log PIC
time for the period during which he is the sole manipulator of
the controls of the aircraft. You also explain that you have
received conflicting answers from local FAA personnel to whom you
have posed this question.
The answer to your question is yes. Under Section 61.51(c)(2) of
the FAR, the first officer may log as PIC time that time during
which he is the sole manipulator of the controls of the aircraft.
In fact, both the captain, assuming he is the designated PIC
required under Section 135.109, and the first officer may
simultaneously log as PIC time that time during which the first
officer is the sole manipulator of the controls.
We recently rendered an interpretation encompassing the issue you
raise as well as other questions related to the logging of PIC
time under the FAR. A copy of that June 25, interpretation
addressed to Mr. Dallas Butler is enclosed for your reference and
convenience. The sections of the FAR that are pertinent to this
issue are cited in that letter.
We hope this satisfactorily answers your question.
Sincerely,
/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division
07-06-2014, 05:01 AM
#37
Gets Weekends Off
Joined APC: Mar 2006
Position: SFO Guppy CA
Posts: 1,112
My take on this issue is yes it is legal to log it, but the flight time is only valid for the furtherance of a certificate or rating. Most Legacies or Majors will not recognize that time towards their applicable minimums. If there is a PIC requirement, it almost always is the Part 1 definition. Also, there are enough questions during the course of an interview, why would you want to expand the range of questions? Especially, since you would be on the wrong side of this issue. Ultimately, it is the hiring airline that decides which time is applicable towards their respective minimums.
07-06-2014, 06:14 AM
#38
Gets Weekends Off
Joined APC: Dec 2007
Posts: 453
Fine. 61.51.e.iii
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or
The flight would be operated under 121. Still can't log it.
Try again.
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or
The flight would be operated under 121. Still can't log it.
Try again.
61.51 (e)(iii) is one way you are allowed to log Pilot in Command. Sections i, ii, iii, and iv are all different ways you are allowed to log Pilot in Command.
The pertinent regulation is 61.51(e)(i):
When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
Is it a good idea? For 121, absolutely not. Is it legal? Yes.
I'm only a 135 guy, not 121, but I haven't seen an Ops Specs that said anything about logging flight time in a pilot logbook.
07-06-2014, 06:24 AM
#39
Gets Weekends Off
Joined APC: Apr 2008
Position: Sleeping in the black swan’s nest.
Posts: 5,726
Once you get hired by an airline they don't care how you log your time.
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