FAA ATP Command Type Rated First Officer logging PIC Time. Yes or No?

[talk2jamesbond]

Hello Everyone,

I heard that If I do have FAA ATP Command Type Rated (Such as Boeing or
Airbus Fleet), First Officer (He/She) When they are flying as PF, is that
legally to able to logging as PIC ?

I asked one of American Airlines Boeing Fleet F/O,
He said If you holding FAA ATP and Type Rating without any restriction,
When he flies as PF, He logging as PIC.

If any U.S. Carrier pilots give me some direction would be very appreciated :)

[MarkerInbound]

Under FAA rules you can log the time as PIC. However you are not the PIC. It can lead to interesting conversations later on. There can be a difference between how much time you have logged as PIC and how much time you have as PIC.

[HEMS driver]

It is generally highly recommended that you create a separate column in your logbook for "sole manipulator of the controls," or something similar, and don't log this as PIC.

As Marker mentions, if you log SIC time as PIC you would be creating problems for yourself in the airline world. It's not "PIC" time as recognized by most of the world. Airline interviewers are not stupid.

[talk2jamesbond]

MarkerInbound, HEMS driver

Thank you very much for your answers,
I've got email from FAA guy in Delta Airlines,
He said also answer is "Yes" as same as American Airlines guy said.
I do believe it's only difference is Captain or First Officer...

I really appreciated for your answers :)

[bafanguy]

MarkerInbound,

How does the FAA FAR Part 1 definition of pilot in command influence the answer to the OP's question ?:

"Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight;

(2) Has been designated as pilot in command before or during the flight; and

(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight."

I seem to remember some wrinkle about PIC "under supervision" maybe in Part 61 as related to logging time for licensing purposes ? But for the purposes of job hunting, I've seen some ads make the distinction that only FAR Part 1 PIC time was applicable.

Maybe not the same elsewhere in the world ? This is above my pay grade.

[B2N2]

One of my favorite pet peeves, YES you can and that is what I do and have done.
Both previous on the C525 and currently on the B737 I have a full type rating which allows me to log PIC when I'm sole manipulator of the controls.
During IOE I logged both PIC and dual received because you're essentially receiving instruction from an ATP regardless if they hold a MEI.
Now on an interview or application they will specify if they want PIC time or Captain ( signed for the airplane) PIC time.
Then you just fill out 0 (zero) or look at when you did your upgrade line check and deduct from your total PIC.

You need to look at 61.51, not the definition in part 1.

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(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;

(ii) When the pilot is the sole occupant in the aircraft;

(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

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

(1) Preflight preparation;

(2) Preflight procedures;

(3) Takeoff and departure;

(4) In-flight maneuvers;

(5) Instrument procedures;

(6) Landings and approaches to landings;

(7) Normal and abnormal procedures;

(8) Emergency procedures; and

(9) Postflight procedures;

(C) The supervising pilot in command holds—

(1) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

(2) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

[MarkerInbound]

Bafanguy,

As pointed out above there is a total disconnect under FAA rules between your position on the flight under FAR 1 and what you can log under FAR 61.51. My current job even has a policy when the Captain of the flight is on a break one of the other pilots is supposed to note on the paperwork they were PIC. Really? Then why don't you pay me PIC rate for that time. If things start coming seriously unglued you better believe I'll ring him up and say, "You probably ought to come up here." It's his signature on the paperwork, my job is to keep him out of trouble.

But I digress. The other F/O on the trip I flew yesterday was saying he has applied to FedEx but they want 1000 hour turbojet PIC. And FedEx specifically says they want FAR 1 you signed the logbook PIC time. Not 61.51 PIC time. He only has about 900. If you've reached the peak of your aviation career you can put whatever you want in your logbook. Or not even keep a logbook. But if you think you might have to complete an interview process somewhere down the line in your aviation career it's probably best to go the conservative route and keep the FAR 1 and FAR 61.51 PIC time separate.

[bafanguy]

MarkerInbound,

Thanks for the clarity. I don't really have any "position" on the subject but just asked a couple of questions and admitted I didn't fully understand the seeming difference in Part 1 and what I remembered, or thought I remembered, from Part 61.

Having seen an ad or two specifying, as you showed, PIC wanted by some employers as only Part 1, the subject seemed worth understanding by those who might be job hunting...and having to explain their flight times to an interview panel.

I guess I've got a whole boatload more PIC time than I thought I had. I only logged "PIC" time when I was signing the dispatch release even though I was type rated in a couple of airplanes I flew as FO in Part 121.

Thanks. I'm not looking for a job...nor is any job looking for me. :-)

[MarkerInbound]

No problem. I log it the same way. If 9000 hours turbojet PIC isn't enough they're probably looking for Space Shuttle drivers with a missed approach logged.

[Check Airman]

Logging PIC (part 61) is not the same as acting as PIC(part 1).

Under the FAA, the FO can log PIC on his or her leg, but this really serves no purpose. My logbook has a PF column that I use for my own records.

It's legal to log PIC as FO, but not particularly smart.

[Check Airman]

B2N2,

During IOE I logged both PIC and dual received because you're essentially receiving instruction from an ATP regardless if they hold a MEI.

Never heard of anyone logging PIC during IOE. If you did, you'd only be able to log PIC on your legs. Even if you're doing IOE as a CA, the check airman (TRE) is still the PIC.

[MarkerInbound]

And that OE time doesn't count toward the hundred hours high mins.

[hikoushi]

For our 2-pilot crew part 121 flights, I do not, nor do I know ANYBODY who would EVER log PIC while acting as SIC. The only benefit you will get from logging "sole manipulator" PIC time in airline flying is a little bit of petty ego gratification while looking at an inflated number in your logbook. Any major airline interviewer who finds that half of your 737 or 767 F/O time was logged in the "PIC" column will not be comparably impressed. The "sole manipulator" rule is legitimately applied while flying empty legs in a Part 91 corporate type environment, or logging PIC while receiving dual instruction for your ATP or CFI certificate (since the CFI is likely also logging, and acting as, PIC).

For our 3 pilot crew flights, under the new FAR part 117 EVERYONE logs the ENTIRE flight under "total duration of flight", even while on break (see the ALPA guide to Part 117, scroll to question "Q-51":http://www3.alpa.org/portals/alpa/committees/ftdt/Part-117-Flight-Time-Limitations-and-Rest-Requirements.pdf). The designated Captain logs PIC the ENTIRE time, and the FO and IRO log SIC. The theory is that you are all REQUIRED to be there to make the Flight Duty Period legal, even if you are asleep at a given moment. So you log total duration, and your designated position for the entire flight time. You obviously don't log actual instrument time while you are asleep. Common sense.

In essence the IRO sitting in the left seat relieving the Captain is doing so under the Captain's instructions, therefore he is still SIC. The FO in the right seat at this point is really considered "third in command" but since there is no such term, he logs SIC too. Part of the crew-change briefing includes the Captain telling the IRO (who is taking the left seat) how he would like the flight conducted, and what kinds of things he wants to be woken up for. If anything really important or non-routine comes up, the final decision still comes from the Captain, unless it is of the immediate life-and-death variety. So the Captain still "commands by delegating" from the bunk, hence logs PIC while the other two log SIC.

To deepen the discussion, sometimes when we are short FOs for whatever reason, the IRO position is staffed with a line captain. We also have ULH flights with 4 pilot crews using 2 captain and 2 FOs. Even in those instances, the only person who should be logging PIC is the captain that signs the flight plan, ALL other crewmembers are acting as, and logging, SIC.

If you signed your name to the flight plan under part 121, log the whole thing as PIC. If somebody else signed their name to the flight plan under part 121, log the whole thing as SIC. You will NEVER get in trouble and your logbook will NEVER be questioned if you do this.

If sole manipulator or PF time matters to you for any particular reason, do as the others here suggest and log it as such in a separate column that does not contain the word "PIC".

[B2N2]

For our 2-pilot crew part 121 flights, I do not, nor do I know ANYBODY who would EVER log PIC while acting as SIC. The only benefit you will get from logging "sole manipulator" PIC time in airline flying is a little bit of petty ego gratification while looking at an inflated number in your logbook. Any major airline interviewer who finds that half of your 737 or 767 F/O time was logged in the "PIC" column will not be comparably impressed. The "sole manipulator" rule is legitimately applied while flying empty legs in a Part 91 corporate type environment, or logging PIC while receiving dual instruction for your ATP or CFI certificate (since the CFI is likely also logging, and acting as, PIC).

As far as the highlighted bit, no you can't.
A lot of Regional "Airlines" (121) do not provide a 'full' PIC type rating to their SIC/FO's so they can not legally log PIC as PF.
As a holder of a PIC Type rating I am already PIC qualified just not acting PIC.
When I am performing the duties of SIC I log SIC time and when I am the pilot flying I log they PIC time. This is also how the company logs my time.

Try interpreting the rules instead of going by "tribal Law".
Fact that nobody in your company does this doesn't make it correct.

So for future reference....my total PIC time includes PF time.
If they specify 'signed for the airplane time' then I deduct whatever PIC time I had before a line check for upgrade.
It's all legal..I used to teach this sh!t you know.:ok:

[zondaracer]

As far as the highlighted bit, no you can't.
A lot of Regional "Airlines" (121) do not provide a 'full' PIC type rating to their SIC/FO's so they can not legally log PIC as PF.


The new ATP regulation requires 121 FOs to have a PIC type rating. No more SIC type ratings at 121 carriers.

[hikoushi]

As far as the highlighted bit, no you can't.
A lot of Regional "Airlines" (121) do not provide a 'full' PIC type rating to their SIC/FO's so they can not legally log PIC as PF.
As a holder of a PIC Type rating I am already PIC qualified just not acting PIC.
When I am performing the duties of SIC I log SIC time and when I am the pilot flying I log they PIC time. This is also how the company logs my time.

Try interpreting the rules instead of going by "tribal Law".
Fact that nobody in your company does this doesn't make it correct.

So for future reference....my total PIC time includes PF time.
If they specify 'signed for the airplane time' then I deduct whatever PIC time I had before a line check for upgrade.
It's all legal..I used to teach this sh!t you know.:ok:

Are you currently (as in, post-Part 117) working in the USA at a Part 121 carrier? What does your POI say about logging PIC while PF as FO on live flights, even with a full type rating? I assume you are logging BOTH SIC AND PIC in this scenario? If you are both JUST logging PIC then you are technically not operating the aircraft in accordance with its type certificate or the regulations under which said LIVE part 121 flight is flown. Both require an SIC. Have you asked any major airline interviewers in the USA for their opinion? "PIC plus SIC plus a hundred or so hours for initial dual instruction received" is a "logbook reality check" many interviewers use, along with making sure that your single-engine plus multi-engine time equals your airplane total time.

I used to teach this stuff too, as a check airman at a 121 carrier. I HIGHLY recommend that you do NOT log PIC while you are concurrently logging SIC at a part 121 carrier, and will reiterate that I know NO ONE who does so. Not as PF with a command type rating, not as IRO in the left seat while the PIC is asleep, no one.

[A Squared]

What does your POI say about logging PIC while PF as FO on live flights, even with a full type rating?

The POI doesn't have any say over what a pilot puts in his personal logbook.

I assume you are logging BOTH SIC AND PIC in this scenario? If you are both JUST logging PIC then you are technically not operating the aircraft in accordance with its type certificate or the regulations under which said LIVE part 121 flight is flown. Both require an SIC.


Oooookay, now you're really reaching ... Not in accordance with the type certificate? Because of what someone writes in their personal logbook? Please tell me you're joking.


I think what we have here is a classic example of what often happens when this subject is discussed. Some get really confused on the difference between "What is legal" and "The way *I* think the world ought to be".

Just so I'm not misunderstood, I'll tell you the way *I* think the world ought to be: I think that it sould not be permitted to log PIC, unless you truly are the "signed for the airplane" "the buck stop here" no foolin' Pilot in Command. I don't like logging sole manipulation as PIC, and I do not do it myself.

That said, it is absolutely, positively, 100% legal in FAA land. Those are just the facts, as much as I think it should be different, the regs don't line up with my opinions on the matter.

It is true that many (most?) airlines expect you to report "PIC" time according to the definition in Part 1 on employment applications, and if you were discovered to be misrepresenting "sole manipulator "PIC" time as real PIC time, it would go badly for you in the interview. But that is the airline's policy, not the law.

THe law (or rather regulations) are pretty clear, it's legal.

[hikoushi]

Yeah I'll give you that, maybe the type certificate thing is pushing it a bit.

You gotta understand though that the purpose of this is not so much to tell you or the O.P. that it is ILLEGAL to log time in this way (it isn't), only that it is STUPID to do so. IF he is actually working as a part 121 pilot in the USA, and intends to ever present his logbook to a recruiter ever again, it is a BAD MOVE. It is ALSO to present, for his consideration, the fact that as a former check airman and current Part 121 airline pilot who has worked for both domestic and international carriers, that I have NEVER met any part 121 pilots who log their SIC time as PIC, even though they have full type ratings. Even if they are the designated relief for the sleeping captain, and even if they are line captains themselves and just happened to be assigned relief on that particular trip. They COULD log 61.51 PIC time, but they DON'T, because it is STUPID. They already have ATPs, they are not building time towards a certificate or rating under 61.51 (the intent of the "sole manipulator" rule). It is not a requirement to log PIC time for currency under part 121. So logging PIC sole-manipulator time in those cases would not be doing so under the intent of the law. While technically legal, it would simply be padding the logbook with "Parker time".

The regulations under which said flight were conducted (your F.O.M.) require an SIC. So you are logging both SIC and PIC at the same time, which is also not a good idea and does not make logical sense.

Whether logging real "I signed for the airplane" PIC (FAR part 1) or "sole manipulator" PIC (61.51), the FAA recognizes both as "PIC" time. There is no provision for anything like "PICUS". As a result it gets sticky separating this out between the various entities that actually have an interest in your logbook (FAA, airline people, insurance people). While one could create a second column for "Part 61.51 PIC" or some such thing if building time towards a rating or certificate, you must understand that that is what it is for, logging time towards a certificate or rating. If you are already ATP-certificated and simply padding your logbook with "sole manipulator" time, there is no real purpose to logging it in that manner, and it is not really in the "spirit" of 61.51. Although yes, by the strictest definition it is in fact, legal.

If you already have a full ATP and proceed to log 1500 of your next 3000 hours in the right seat at Virgin America as PIC because "I was PF", you might as well kiss your future job at Delta / AAL / UPS etc goodbye. Pretty decent chance that their people who check your logbook against your application will throw it out as fraudulent when they find that your 3000 jet PIC time was built while concurrently serving as a Part 121 SIC. The interviewers will likely not offer you an additional cup of coffee. You will also not impress an insurance agent AT ALL with a logbook padded with Part 121 "sole manipulator" SIC/PIC time when you try to get signed on to a policy as captain somewhere.

Read this legal interpretation by the FAA if you need more clarification, or if you are like most people who don't have to deal with American bureaucracy and are unfamiliar with the way arcane FAA rules interact with everyday reality:

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/1999/carpenter%20-%20(1999)%20legal%20interpretation.pdf

[AC560]

Whether logging real "I signed for the airplane" PIC (FAR part 1) or "sole manipulator" PIC (61.51), the FAA recognizes both as "PIC" time.

Minutia I realize but then again these discussions always are, there is no provision for logging PIC under PART 1 it is all under 61.51. An ATP logs time under 61.51 while being PIC (part 1) under an operation requiring an ATP certificate.

Personally I just go sit my plane with the intent to fly and drink coffee, I think I am up to 50,000hrs now....

[hikoushi]

There is indeed a point where it just doesn't matter anymore.... However, I am assuming that the guy who initially asked the question is not there yet, no? It most certainly matters to him, if he is in the USA and planning on making a career here.

[HPIC]

Speaking from the point of a former interviewer, if a pilot claimed on an application to have XXX hours of PIC, only to find out in the interview that they were logging that time as PIC even though they were not the person that signed for the aircraft, it was game over.

That happened a lot back in the day, unfortunately. Often times pilots defended with "I was told that I can log it under XXX FAR".

These days, pilots are largely excluded from interviews, and they are primarily conducted by HR types that don't understand the nuances of real PIC vs logged PIC...thus, we see a lot of pilots claiming to have certain times but in reality they don't. This becomes clearly evident to us during training.

I've always said "Log what you can, but be prepared to defend it". If you can legally log PIC, go ahead and do it if you'd like...but don't put it on a resume or application as PIC if you didn't sign for the aircraft. Your logbook, your business....but if you come to an interview with me, it becomes my business.

Perhaps 20 years as a Captain has made me jaded...but my SIC time was all logged as such.

[B2N2]

There is also an FAA Council ruling:

February 9, 1999

Bill Carpenter
12808 E. Pacific Drive, #302 Aurora, Colorado 80014

Dear Mr. Carpenter:

Thank you for your letter of January 25, 1999, in which you ask questions about logging pilot in command (PIC) time and second in command (SIC) time when operating under Part 121 of the Federal Aviation Regulations (FAR)

You first ask whether it would be proper under FAR 61.51(g) for a properly qualified SIC to log instrument flight time flown during instrument conditions while serving as the SIC in Part 121 operations on an aircraft that requires two crewmembers. The answer is yes. As a qualified SIC, and as a required crewmember, you are "operating" the aircraft within the meaning of FAR 61.51(g). Therefore, as the SIC operating the aircraft "solely by reference to instruments under actual or simulated instrument flight conditions," you would log that time as SIC flown in instrument conditions. Naturally, the PIC logs the time as PIC flown in instrument conditions.

You then ask if, for the purposes of maintaining instrument currency, an instrument approach on the above flight flown by the PIC can be logged as an instrument approach by the SIC. The answer is no. As the SIC you have not "performed" the approach as contemplated by FAR 61.57(c) because you were not the sole manipulator of the controls during the approach.

Lastly, you present the following scenario: under a Part 121 operation the air carrier has designated a pilot and a copilot as required by FAR 121.385(c). The pilot is the authorized PIC and the copilot is the authorized SIC. The PIC is also the company check airman. During the course of the flight, the SIC is the sole manipulator of the controls for the flight. Additionally, he has passed the competency checks required for Part 121 operations, at least as SIC. You ask whether the SIC can log PIC time for that portion of the flight in which he is the sole manipulator of the controls for the flight. The answer is yes.

There is a distinction between acting as pilot in command and logging of pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience:

2

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

(1) A 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_ (ii) Is the sole occupant of the aircraft: or (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.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.

While it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. If the pilot is designated as PIC by the certificate holder, as required by FAR 121.385(c), that person is PIC for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft. The pilot who is the sole manipulator of the controls of the aircraft for which the pilot is rated may also log that flight as PIC.

It is important to remember that we are dealing with logging of flight time only for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the SIC is fully qualified as a PIC, or only as an SIC. This is important because even though an SIC can log PIC time, that pilot may not be qualified to serve as PIC under Part 121.

I hope this satisfactorily answers your questions. If we can be of further assistance, please contact us.

D. Brent Pope
Attorney, ANM-7H


So I log PIC with the understanding that I WOULD NOT USE THIS TIME TOWARDS MY JET PIC IN CASE OF AN INTERVIEW....
Just to make things clear.
I'm logging it (legally) PIC so I know how much I've flown vs the other guy.

[westhawk]

Perfectly explained B2N2. It's about time someone recognized the difference between acting as the PIC and logging PIC flight time as defined in 61.51.

Having not been aware until now of the FAA legal council interpretation letter, I've still looged all my PIC time as per 61.51, but kept a separate column in my logs to separately record flight time spent as the PIC per part 1. If I were to conduct an interview with a candidate who recognized the difference between the two and kept their records accordingly, I would be favorably impressed.

[B2N2]

Thank you Westhawk, it's one of my pet peeves.