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Question about Logging EASA IFR PIC and Cross country under FAA

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Question about Logging EASA IFR PIC and Cross country under FAA

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Old 1st May 2024, 21:01
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Question about Logging EASA IFR PIC and Cross country under FAA

Hello folks, I hope my message finds you all well.

I am in the US building time and need to know how EASA looks at cross country simulated time, it seems that EASA member have different interpretation of the rules.
I was told and read here in the forum that I can use all my simulated Instrument cross country time , under FAA Flying under the hood with another safety pilot (CFI or another PPL) could count toward both the cross country and simulated IR and also counts as PIC. I read here in the forums that this time could also count toward building time toward my EASA frozen ATPL.

So I contacted Czech and Austro control, Austro Control sent a generic Email which didn't answer my question but Czech CAA sent the following :"Under EASA system there is only 1 PIC during the flight. Pilot-in-command" (PIC) means the pilot designated as being in command and charged with the safe conduct of the flight. Simulated VMC training flights (flying under the goggles/hood/restrictive vision device) are only allowed with flight instructor and these are dual instruction flight time for the student.

The flight time may be logged as PIC in the following cases:

(i) the holder of a licence may log as PIC time all of the flight time during which he or she is the PIC;

(ii) the applicant for, or holder of, a pilot licence may log as PIC time all solo flight time, flight time as SPIC and flight time under supervision provided that such SPIC time and flight time under supervision are countersigned by the instructor;

(iii) the holder of an instructor certificate may log as PIC all flight time during which he or she acts as an instructor in an aircraft;

(iv) the holder of an examiner’s certificate may log as PIC all flight time during which he or she occupies a pilot’s seat and acts as an examiner in an aircraft;

(v) a co-pilot acting as PICUS on an aircraft on which more than one pilot is required under the type certification of the aircraft or as required by operational requirements provided that such PICUS time is countersigned by the PIC;

(vi) if the holder of a pilot licence carries out a number of flights upon the same day returning on each occasion to the same place of departure and the interval between successive flights does not exceed 30 minutes, such series of flights may be recorded as a single entry;

(vii) where Regulation (EU) No 965/2012 requires the pilot to act as PIC under the supervision of another pilot (supervisor), both the pilot and the supervisor may log the flight time as PIC (this is required for air carriers under AOC).

Kind Regards,"

-According to the previous email, does that mean that my simulated instrument PIC cross country doesn't count at all because it was flown with a regular pilot not a CFI holder ?
-Other question that begs itself, what about when I am the SAFETY pilot, do I log that in my EASA logbook as PIC Cross country since EASA considering the one under the hood nonexistent ? Because under FAA I can only log PIC but not cross country when acting as a "safety pilot"
I most likely will do my license under Austro Control, I am trying to plan ahead as advised and fly good quality cross country hours that fulfills as much as possible of the requirements.
Also what about the 50 IFR hours required for my FAA -EASA CB conversion, if safety pilot is not allowed, and I cant log it as CFII because, does it mean I have to rent a plane solo, file an IFR flight plan to log that for EASA?

Please advise and thanks in advance for your contribution.






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Old 1st May 2024, 21:51
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Under FAA rules you can be PIC under EASA you cannot.
You’re doing well practicing IFR under the hood with a safety pilot but you can only log the PIC time one way:

FAA compliant or EASA compliant.

Europa-land doesn’t know or understand the “safety pilot” part.
Even under FAA it was never intended as a time building excercise.

The rule has been abused as “we can both log PIC”, one for looking out and being responsible and the other as “manipulating the controls”.
Pick your poison.
I always recommended my European students to differentiate in their logbook between FAA and EASA PIC.

As an example under FAA your entire instrument rating can be logged PIC and dual received as you’re rated in the airplane.
Under EASA you could log the FAA IR as dual received only.
Hence a European student that came to the USA for a 0-CPL would have 180-200 hrs PIC under FAA and only 100 hrs EASA PIC.
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Old 1st May 2024, 21:56
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Originally Posted by B2N2
Under FAA rules you can be PIC under EASA you cannot.
You’re doing well practicing IFR under the hood with a safety pilot but you can only log the PIC time one way:

FAA compliant or EASA compliant.
how about if I get my CFII, how does EASA look at my IFR time if I am giving instructions?
I read that EASA is “rule based, so to fly IFR I must file a flight plan but then as a CFII you are a required crew.
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Old 1st May 2024, 22:04
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Do you hold a FAA licence with Instrument Rating?

EASA really only recognises a flight time as either under VFR or IFR, not as the FAA do it Actual/Simulated Instrument time. The FAA are looking at time with sole reference to the instruments either in actual IMC or under the hood. The FAA allow you to fly VFR, using the hood with a Safety Pilot to keep a look out for traffic, to build instrument time. That time would not count as IFR for EASA, would count as VFR PIC, assuming you hold a valid licence to fly said aircraft as PIC.

When you are flying as the safety pilot, then no you cannot log that under EASA at all.
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Old 2nd May 2024, 00:26
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So it seems I need to rent a plane and file IFR plan.
OR how would EASA treat time logged if I get MY CFII (instrument instructor), under FAA that would both dual given ,PIC and instrument if we are under a flight plan ?
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Old 2nd May 2024, 00:31
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yes i have the rating, would that (time logging change if I get my CFII and teach? can I log both PIC and instrument if we have an ifr flight plan in place. the Czech email above states "(iii) the holder of an instructor certificate may log as PIC all flight time during which he or she acts as an instructor in an aircraft "

I assume FAA recognizes instrument instructors time as both PIC and real instrument PIC even thought technically the flight instructor is not always "manipulating controls", unless I am misinterpreting something.
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Old 2nd May 2024, 03:03
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Under FAA rules as an instructor you actually need to teach “something” in order to log PIC as an instructor.
You can’t just log ‘dual given’ without specifying what you taught and to whom.
So ‘straight and level flight 8.0 hrs’ doesn’t cut it.
There are numerous cases where the FAA went after instructors flying with each other and both logging PIC.
As in what were you teaching when both of you are instructors?!


So as a CFII can you fly with a time builder?
Yes, you can.
Just make it a meaningful flight and practice
things like VOR tracking and holds, instrument approaches, unusual attitude recovery etc etc
Keep a record of all training you provide and it’s legitimate PIC
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Old 2nd May 2024, 03:22
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Originally Posted by B2N2
Under FAA rules as an instructor you actually need to teach “something” in order to log PIC as an instructor.
You can’t just log ‘dual given’ without specifying what you taught and to whom.
So ‘straight and level flight 8.0 hrs’ doesn’t cut it.
There are numerous cases where the FAA went after instructors flying with each other and both logging PIC.
As in what were you teaching when both of you are instructors?!


So as a CFII can you fly with a time builder?
Yes, you can.
Just make it a meaningful flight and practice
things like VOR tracking and holds, instrument approaches, unusual attitude recovery etc etc
Keep a record of all training you provide and it’s legitimate PIC

thanks for the extra elaboration and yes I wouldn’t go through a CFII to just log the pic instrument time, it would be cheaper for me to just rent an airplane and fly it around then going through that.

since you mentioned that, I have seen part 91 operation (jet) hire/let an sic and without a pilot development program, the sic logs dual received and pic just because the pic has a CFI MEI, I am not so sure the legality of that but oh well to each their own.
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Old 2nd May 2024, 14:15
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Originally Posted by MojoATPL
thanks for the extra elaboration and yes I wouldn’t go through a CFII to just log the pic instrument time, it would be cheaper for me to just rent an airplane and fly it around then going through that.

since you mentioned that, I have seen part 91 operation (jet) hire/let an sic and without a pilot development program, the sic logs dual received and pic just because the pic has a CFI MEI, I am not so sure the legality of that but oh well to each their own.
Under 61.55 it’s actually remarkably easy to get a SIC sign off if you only fly within the 48 states.
https://nbaa.org/flight-department-a...personnel/sic/

Still wide open to fraudulent logging and abuse.
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Old 2nd May 2024, 15:26
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Doesn't the regulation for CBIR state 50 hours as PIC under IFR? I don't remember seeing anything mentioned about IMC or simulated instrument flight.

'Hood time' with a CFI or safety pilot is what you need to get the rating. The rating allows you to log PIC, so we're talking about the next 50 hours.
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Old 2nd May 2024, 16:45
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Originally Posted by rudestuff
Doesn't the regulation for CBIR state 50 hours as PIC under IFR? I don't remember seeing anything mentioned about IMC or simulated instrument flight.

'Hood time' with a CFI or safety pilot is what you need to get the rating. The rating allows you to log PIC, so we're talking about the next 50 hours.
so EASA wants you to log pretty much solo time, from my understanding. I have seen post where people used their time with a CFII ( dual received) as pic but EASA I think only accepts that if the CFII doesn’t log dual given. I think it’s also the same area of confusion faa pilot come across when trying to document their Ifr and Cpl cross country combined. From the Czech interpretation above, I can only log instrument if I am pic under a flight plan or if I becomes an instructor.

Donno of Austro control will accept my time with CFII onboard as pic I am waiting for them to reply. But this is exactly why it’s wise to maintain two logbooks, my EASA logbook will not have any simulated instrument because it is not even recognized as previously mentioned
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Old 2nd May 2024, 17:17
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Yeah. Forget any FAA PIC time under the hood training for the IR etc. None of that counts. Get your IR - THEN fly another 50 hours. Do NOT fly with an instructor as dual received will not be recognised as PIC. You just need to fly under Instrument flight RULES, whether you have a hood on or not or a safety pilot is irrelevant. Log it as IFR and fly some Airways and approaches to legitimise it all and you should be OK. The whole safety pilot thing is a red herring. I fly IFR every time I go to work, 90% of it in clear blue skies.
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Old 2nd May 2024, 17:56
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Flying IFR and flying IMC are two totally different things.
When you timebuild IFR then it would help if you do the following:
  • File an IFR flightplan and print it out or otherwise keep a reliable record.
  • Ask the flight school for a printed receipt for every single flight you do.
This will allow you to put three documents next to each other,

Here is my logbook,
Here is the flightplan filed with me as PIC
Here is the receipt I paid for this flight.

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Old 2nd May 2024, 18:10
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And now for the biggest elephant in the room:

Make sure you spend a decent amount of those 50 hours practicing NDB holds and approaches as well as doing PBN and ILS, localiser, VOR etc...
Find out what is expected from the EASA/CAA examiner in your local area and practise.

Just because you CAN get 50 hours and go straight into the EASA IR test with no training it doesn't mean you'll pass it!
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Old 2nd May 2024, 18:34
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Exactly ^^^
50 hrs straight and level is not going to help you much.
Pick airports relatively close together but still more then 50NM so that it qualifies as XC.
ATC in the US is usually very accommodating to IFR training flights.
If you can’t find a working NDB then you can still use a VOR as such if you have an RMI or if you have an HSI with a second needle.
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Old 2nd May 2024, 20:01
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I have not logged any IFR time and I hold FAA instrument airplane and instrument instructor ratings. There is no place in any of my log books to record IFR time. I have only recorded instrument time and that is subdivided into "actual" and "simulated".

Does EASA actually place some value on flying in VMC on an instrument fight plan. What particular skill does that require?
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Old 2nd May 2024, 22:17
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Originally Posted by EXDAC
I have not logged any IFR time and I hold FAA instrument airplane and instrument instructor ratings. There is no place in any of my log books to record IFR time. I have only recorded instrument time and that is subdivided into "actual" and "simulated".

Does EASA actually place some value on flying in VMC on an instrument fight plan. What particular skill does that require?
Some logbooks like the Jeppesen ones have empty columns that you can assign.
Otherwise you can change a column that you’re not using like Rotorcraft.
More then one option.
And yes, participating in the IFR system has value, lots of it.
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Old 3rd May 2024, 08:22
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Originally Posted by EXDAC
I have not logged any IFR time and I hold FAA instrument airplane and instrument instructor ratings. There is no place in any of my log books to record IFR time. I have only recorded instrument time and that is subdivided into "actual" and "simulated".
To log actual or simulated IMC you would have been IFR. As a CFII teaching for the IR you would have been IFR for every flight. As PIC. Most IFR training flights don't actually land, so you might not often meet the FAA definition of cross country but I believe you would meet the EASA definition just by doing an approach. You might find that all you need is a pen.
Originally Posted by EXDAC
Does EASA actually place some value on flying in VMC on an instrument fight plan. What particular skill does that require?
Remember this particular CBIR route is all about converting an IR to an IR so you've already demonstrated that you can fly on instruments. The 50 hours PIC under IFR is there to offer those with some IFR experience but no ATP a test-only option, whilst stopping the masses from skipping the regular 15 hour route.
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Old 3rd May 2024, 12:03
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Originally Posted by rudestuff
To log actual or simulated IMC you would have been IFR.
Would you please explain how someone flying hooded instrument approaches for practice and/or currency is "IFR". Such approaches are conducted in VMC, do not require a flight plan, and many I have done don't require any contact with ATC.
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Old 3rd May 2024, 13:17
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Originally Posted by EXDAC
Would you please explain how someone flying hooded instrument approaches for practice and/or currency is "IFR". Such approaches are conducted in VMC, do not require a flight plan, and many I have done don't require any contact with ATC.
File a flight plan, bring a rated pilot as a lookout and wear a view limiting device.
PIC - IFR- XC- sim instr. conditions
There is a FAA ruling floating around somewhere that you can log XC when you’ve passed either the IAF or the FAF without a landing.
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