Logging PIC time when carrying certified pilot

[Odai]

Hello,

I am currently looking at CPL hour building having gained my PPL earlier this year. Out of those hours, I have been looking into doing around 15 out of Amman, Jordan - in addition to being a great experience flying in another country, I have family there and visit regularly.

I have found a club there that may be able to offer a decent rate. However, the issue is as I do not have a Jordanian passport, I cannot get the Jordanian Civil Aviation Regulatory Commission to issue a Jordanian PPL on the basis of my EASA one. Otherwise, I am told the process is easy.

As a result, I will not be able to fly completely solo - I will need to carry a 'certified pilot' (safety pilot). They made it clear that I would still be logging any time as Pilot-in-Command, and they appear to have good knowledge of EASA regulations.

Does the UK CAA permit pilots to log time as PIC when carrying a safety pilot (in this case would be a CARC certified flight instructor), assuming the pilot is the sole manipulator of the controls?

I haven't had a look through CAP 804 yet but I thought I'd ask here too anyways.

Apologies also if this is in the wrong forum, wasn't sure whether to post here of the commercial training one.

Thanks

Odai.

[The_Pink_Panther]

Why wouldn't you log the time? Doesn't matter who or what you're carrying, you're flying the aircraft, you're PIC. Even if you have a friend who is an instructor, unless he's instructing you, he's just a passenger, you are PIC.

[dublinpilot]

1. Are you legally entitled to be pilot in command of the aircraft?
(EASA licence, Jordanian Aircraft, in Jordanian (and perhaps other) airspace). It might take a bit of research to find the correct answer here.

2. Are you actually the pilot in command of the aircraft?
What if the instructor and you disagree on something? Does he take over or are you in command?

[Agaricus bisporus]

If you don't hold the requisite licence and have to carry as safety pilot who does it's pretty clear-cut who is P1, isn't it? If you haven't got a suitable licence you can't sign for the aircraft - ergo you can't be P1.
How much P1 did you log in your CPL training with an instructor sitting next to you?

[Cobalt]

Dublinpilot has it.

If the state of registry of the aircraft accepts or validates you EASA licence, you can act as pilot in command.

In most countries, the pilot in command is whoever the operator says is the pilot in command. So if your name is in the PIC column of the tech log (or equivalent), you are by definition the pilot in command.

The other pilot would not be able to log this time as anything under EASA rules, or indeed under FAA rules. If he/she does [in Amman, probably he...], this is a bit of a warning sign.

Assuming you can get your licence validated, go for it! Just resist the temptation to have him do all the work... Getting experience in many different countries is better overall than just flying the same flight over and over again.

[Odai]

Thanks for the responses guys.

Dublinpilot, I doubt they would allow me to log the time as PIC if it were not permissible, but I'll double check just in case. I'm guessing you mean this is something I should check with JCARC, and not the UK CAA?

With regards to your second point, it's something I will discuss with them in more detail - but the guy who told me I can log PIC is a flight instructor with experience teaching at various places in the UK too so I'm guessing he's familiar with JAA/EASA intricacies.

How about the concept of a safety pilot in general, ignoring my own specific situation? Isn't the whole point of a safety pilot that they take over in case of the PIC failing in his duties in some way? I'm assuming it's similar to a skills test - where the candidate is assumed to be PIC unless they do something requiring the intervention of the examiner, in which case they become P/UT.

The following people in Spain also provide safety pilots for hour builders:

SERVICES | Hour Building Spain (http://www.hourbuildingspain.com/services-hbs/)

I think my situation would be almost exactly the same - except that the provision of a safety pilot is additionally mandated due to local law as opposed to just as a result of lack of experience with local operational procedures.

[Odai]

Cobalt, apologies - I missed your post.

Thanks for the tips. I won't be able to get my license validated or a Jordanian one issued as a result of not having a Jordanian passport, according to the club.

However, the operator are definitely happy for me to be listed as PIC. Will have to check whether they will also be allowing the instructor to log PIC (which I understand would be contrary to regulations).

I do hope it works out - it looks like a great place to fly and as you say flying in another country would be useful experience. The plane (C172S) is also miles better equipped than anything I've flown in the UK, with full G1000 avionics, AP etc. :p

[dublinpilot]

Dublinpilot, I doubt they would allow me to log the time as PIC if it were not permissible, but I'll double check just in case. I'm guessing you mean this is something I should check with JCARC, and not the UK CAA?

They probably don't care what you write in your log book. It's of little consequence to them.

Rules may also be different there. I understand that there are quite a number of situations in the US for example where more than one person can log PIC time at the same time. It might be similar in Jordan.

What I'm really getting at is that if it's illegal (under Jordanian rules) for you to be PIC, then doing your hour building and logging that could really backfire. Finding out that a lot of your hour building was done illegally won't help your future career. Given that it breaks the mould of hour building in the USA, or instructing/glider tugging, it might well be a talking point in an interview. So better make sure its right before getting caught out with difficult questions!

It's not a question for the CAA in the UK. It's really a question for the Jordanians. You are flying one of their aircraft in their airspace. They decide what licence you need to do that. Do they allow you to be in command of that aircraft on the basis of your EASA licence?

I have no knowledge of the answer to that, but would think it unusual that they would say "Yes, but only with a Jordanian safety pilot".

That may indeed be the case, but it's also likely is that the "safety pilot" is really the pilot in command (because you can't legally be) and the school don't really care what you write in your log book as that's your problem. But that is only a guess on my part. You'll have to make the appropriate enqueries to know if you can legally act at pilot in command of that aircraft or not.

How about the concept of a safety pilot in general, ignoring my own specific situation? Isn't the whole point of a safety pilot that they take over in case of the PIC failing in his duties in some way?
Off hand I can only think of two cases where a safety pilot is required.

1. Where it's required because of the pilot's medical condition. Here the sole role of the safety pilot is to take over if the pilot is incapacitated.

2. Where the pilot's view is restricted for practicing instrument flight. Here their role is to inform the pilot of any traffic/obstruction that they see.

In neither does the safety pilot take over because they don't agree with something that the pilot in command is doing or a decision that they are making or not making. That's what makes your 'PIC but with a local safety pilot' sound strange to me.

dp

[Cobalt]

Dublinpilot, I would add one: when the local pilot is doing the radio, or is dealing with authorities on the ground; for example where the PIC does not speak the local language, and knowing local customs can be vital for keeping the aircraft from being impounded, "fees" being imposed etc.

Odai - I would NOT rely on local rules who can log PIC and not. The rules that apply to you are the EASA rules. What the safety pilot logs is his problem. I have two completely different total PIC times, depending if EASA or the FAA ask.

[riverrock83]

I did some Googling:
:: Civil Aviation Regulatory Commission :: (http://www.carc.gov.jo/pages_en.php?type=page&id=3504)

As far as I can tell - you can only act as a flight crew member if you get your licence validated or converted. Converting looks easier (skills test and air law exam if you have 100 hours).
I've copied out lots of blurb below. The only mention of a safety pilot was to do with the medical restriction mentioned earlier.

Hope I've missed something though!


JCAR-FCL 1.010 (a)
(1) A person shall not act as a flight crew member of a civil airplane registered in Jordan unless that person holds a valid license and rating complying with the requirements of JCAR-FCL 1 and appropriate to the duties being performed, or an authorization as set out in JCAR-FCL 1.085 and /or 1.230. The license shall have been issued by :
(i) CARC or.
(ii) Another ICAO Contracting State and rendered valid in accordance with JCAR-FCL 1.015(b) or (c).

....

JCAR-FCL 1.015
(b) Licenses issued by an ICAO contracting states.

(1) A license issued by an ICAO contracting state may be rendered valid at the discretion of CARC for use on aircraft registered in Jordan in accordance with Appendix 1 to JCAR-FCL 1.015.

(2) Validation of a professional pilot license and a private pilot license with instrument rating shall not exceed (6) months from the date of validation, provided that the basic license remains valid.

Any further validation for use on aircraft registered in Jordan is subject to acceptance by CARC. The user of a license validated by CARC shall comply with the requirements stated in JCAR-FCL 1.


(3) The requirements stated in (1) and (2) above shall not apply where aircraft registered in Jordan are leased to a non-Jordanian operator, provided that the non-Jordanian operator has accepted for the period of lease the responsibility for the technical and/or operational supervision in accordance with JCAR-OPS 1.165. The licenses of the flight crews of the non Jordanian operator may be validated at the discretion of CARC, provided that the privileges of the flight crew license validation are restricted for use during the lease period only on nominated aircraft in specified operations not involving a Jordanian operator, directly or indirectly, through a wet lease or other commercial arrangement.

(4) In circumstances where validation of ICAO contracting state licensed pilot is requested to fulfill specific tasks of finite duration in accordance with Appendix 3 to JCAR-FCL 1.015, CARC may validate such a license for those tasks without the holder meeting the requirements of Appendix 1 to JCAR-FCL 1.015.

(c) Conversion of a license issued by an ICAO contracting state.

(1) A professional pilot license and /or IR issued by an ICAO contracting state may be converted to a JCAR-FCL1 license provided that an arrangement exists between CARC and the ICAO contracting state. This arrangement shall be established on the basis of reciprocity of license acceptance and shall ensure that an equivalent level of safety exists between the training and testing requirements of CARC and the ICAO contracting state. Any arrangement entered into will be reviewed periodically, as agreed by the ICAO contracting state and CARC. A license converted according to such arrangement shall have an entry indicating the ICAO contracting state upon which the conversion is based.

(2) A PPL (A), CPL (A) or ATPL (A) issued in accordance with ICAO Annex 1 may be converted to a JCAR-FCL 1 license with a single-pilot airplane class / type ratings by complying with the requirements shown in Appendix 2 to JCAR-FCL 1.015.


......


Appendix 1 to JCAR-FCL 1.015
Private Pilot Licenses with Instrument Rating.

3. A private pilot license with instrument rating issued in accordance with ICAO Annex 1 by an ICAO contracting states may be validated subject to conditions by CARC in order to permit flights (other than flight instruction) in airplanes registered in Jordan. To validate such licenses, the holder shall:

(a) Complete, as a skill test, the type/class and instrument rating of Appendix 1 and 2 to JCAR-FCL 1.210 and Appendix 3 to JCAR-FCL 1.240;

(b) Demonstrate to the satisfaction of CARC in accordance with Subpart J, that a knowledge of Air Law and the Aeronautical Weather codes, subject number 050 10 03 01, as well as the Flight Planning & Performance (IR), subject number 030 00 00 00, Human Performance subject number 040 00 00 00 in accordance with Appendix 1 to JCAR-FCL 1.470 has been acquired;

(c) Demonstrate a knowledge of English in accordance with JCAR-FCL 1.200;

(d) Hold at least a valid JCAR-Part Medical Class 2 medical certificate including hearing requirements in accordance with JCAR-FCL
3 .355(b);

(e) Hold R/T privileges acceptable to CARC,

(f) Comply with the experience requirements set out in column (2) of the following table:

.....

Appendix 2 to FCL 1.015
Conversion of a PPL issued by an ICAO contracting state to a JCAR-FCL 1 PPL.
(See FCL1.015(c) (2))

The minimum requirements for the conversion of a private pilot license issued by an ICAO contracting State to a FCL 1 license are:

(a) The applicant shall hold a license issued in accordance with ICAO Annex 1.

(b) The applicant shall hold at least a JCAR-Part Medical Class 2 medical certificate.

(c) To hold R/T privileges acceptable to CARC.

(d) The applicant shall comply with the flying experience requirements set out in the table below:

ICAO License held Experience requirement Any further JCAR-FCL requirements
Current and
Valid ICAO PPL ›100 hours as pilot of airplanes -Pass a written examination in Air Law and Human performance and Limitations
-Pass the PPL skill test as set out in Appendix 1 to JCAR-FCL1.130 and 1.135 and Appendix 2 to JCAR-FCL1.135
(c) Fulfill the relevant requirements of Subpart F

[dublinpilot]

Odai - I would NOT rely on local rules who can log PIC and not.

Agreed about logging rules. If he wants to use the hours to count against the issue of an EASA licence, then he needs to ensure that they comply with the logging rules of EASA.

But in relation to being allowed to be pilot in command, he needs to follow the local rules about what licence he needs. A Jordanian aircraft in Jordanian airspace= Jordan decides who can be in command and what licence they need.

[Cobalt]

From the above, it appears that Jordan is a JAR-FCL member state. In which case any JAR-FCL licence should do without any formality.

I have no idea if EASA licences still count as JAR-FCL licenses for that purpose, though - the Jordan authority should be able to answer that.

[Whopity]

I cannot get the Jordanian Civil Aviation Regulatory Commission to issue a Jordanian PPL on the basis of my EASA one.Then, if you require such a licence and you don't have one, you cannot legally fly the aircraft! If that is so, you cannot legally be PIC. Jordanian rules apply, no other rules have any bearing on the matter.

[dublinpilot]

From the above, it appears that Jordan is a JAR-FCL member state. In which case any JAR-FCL licence should do without any formality.

Cobalt,

I think you are misreading the regulations. I think you have speed read JCAR as JAR.

Jordan is not a member of JAR.

JCAR is probably short for Jordanian Civil Aviation Regulations.

dp

[jollyrog]

Can you find an EASA registered aircraft to use?

[Level Attitude]

Another point would be:
The plane (C172S) is also miles better equipped than anything I've flown
in the UK, with full G1000 avionics, AP

EASA requires you to have "differences training" for "Glass Cockpit" which
must be signed off in your Log Book before you could act as PIC (for EASA
Licensing purposes) in such an aeroplane.

[Cobalt]

Cobalt,

I think you are misreading the regulations. I think you have speed read JCAR as JAR.


:O

My excuse is that the wording and content is very familiar...

[Odai]

Many thanks again for all the excellent advice guys.

It looks like I will have to look into it a bit more and also discuss it with the club instructors. CARC are also based on the same airfield so I may have a chance to have a chat with them when I head back there this week.

I appreciate it's my responsibility to make sure the flight time logging complies with EASA regulations.

I'll try and report back when I've spoken to them!

Level Attitude, that was something I forgot to mention - out of the hours I'm planning on doing PIC the club made it clear I will be doing 1 or 2 dual P/UT hours to be familiar with the G1000 setup, and that they would be able to sign this off in my logbook as differences training.

[Odai]

Just got off the phone with CARC and the club.

CARC have said that the process of validating my PPL is not something they would do, only a conversion. Apparently, validation of licenses is only for CPL/ATPL level.

They advised me to speak to the club again. Having done so, they have elaborated that whilst they normally consider me the PIC (handling controls, communication etc), it seems that if anything were to go wrong the safety pilot would be taking over and that the Jordanian certified pilot is the one ultimately responsible for the safety of the flight. Assuming I understood them correctly, this seems somewhat off, and would suggest they haven't appreciated the definition of PIC.

I'm guessing it is also unacceptable under EASA, even if the club and CARC are happy to condone it.

They did guarantee me that the Jordanian certified pilot will not be logging PIC at the same time as me.

I think I will have to look into it further and either get an agreement that I remain PIC in case of an emergency or else pursue getting a Jordanian license if I remain set on some hour building here. By the time I am back in Jordan early next year, I should already have the 100 hours total time required, and possibly a passport sorted.

I've sent off an email to CARC's licensing team asking them to elaborate in any case, could be a while until I hear back from them though. The joys of dealing with Arab bureaucracy... :rolleyes:

With regards to the general concept of a safety pilot, I also previously have only heard of them in the context of instrument flight training and supporting pilots with medical limitations in case of incapacitation - situations in which their role is clearly defined. However, in addition to my example, there does seem to be another organisation offering 'safety pilot's for the purpose of hour building in a foreign country - the AGP based one I linked to above. Does anyone have any experience with this sort of thing?

[englishal]

There is another situation I can think of. The FAA have a definition of "performing the duties of PIC". This is quite useful in a situation similar to yours, whereby say a multi-engine CPL wannabe pilot needs to build hrs as PIC (for say the ME commercial certificate which requires 10 hrs of ME PIC time). This might also apply if someone say wanted to do a ME PPL without SE privileges, to enable the to PPL to "solo").

The FAA sensibly realised that no one in their right mind would rent a non-ME qualified pilot a twin to build these hours solo, so they allow a safety pilot / FI to be in the aeroplane, yet the sole manipulator to still log PIC.

[Agaricus bisporus]

Guys, what is so difficult about the fundamental concept that if you do not hold a valid licence/validation that allows you to fly the aircraft YOU CANNOT LOG THE TIME.

This is such basic, elementary stuff I'm astonished how often it comes up and all the imaginative ways people invent to blag sharp-pencil time they aren't entitled to.

What on earth are you thinking about going flying with an outfit that tells you that the "safety pilot" - actually P1, "will not be logging the time"?

Frankly, I'm gobsmacked by the whole debate.

[Ebbie 2003]

Simple - ssk the question of the regulator in Jordan and the renter.

"If there is an accident or incident and I am in the left hand seat, are you going to deem me or the locally certificated pilot in the right hand seat to be P1?"

If they BOTH say it's you the log the time - but I can't see how you can be, so far as they are concerned you are not certificated, I doubt if you could even log it as instruction time.

A further thought - the tentacles of US power reach far - maybe they would have a different view if you held an FAA PPL - ask, if it helps then get a piggy back FAA.

[mm_flynn]

Guys, what is so difficult about the fundamental concept that if you do not hold a valid licence/validation that allows you to fly the aircraft YOU CANNOT LOG THE TIME.

Possibly because that 'fundamental concept' is not actually true with regard to half the aircraft operating in the world.

(As in FAA land where there are various circumstances that can result in two people being P1 at the same time and both logging time. Some involve an aspect where pilot A is not fully rated to fly the aircraft)

As a note, appendix 1 was not fully reproduced and the base paragraph seemed to imply there were 'validation' options available to the Jordanians at their discretion that addressed situations which did not fully comply with the appendix. So it is not at all clear to me if it is or is not legal to fly the aircraft as PIC nor who under Jordanian law is actually PIC.

[Odai]

I have sent an email to the licensing unit at CARC - will post here again when I get a response.

I get the feeling however that CARC are going to be OK with the arrangement while it won't actually adhere to EASA regulations. :(