FAA ATP Command Type Rated First Officer logging PIC Time. Yes or No?
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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.
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.
There is also an FAA Council ruling:
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.
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
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.
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.
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.
