but then you're logging hands on time when you're not hands on.


Well, I had to call it =something=. That's why I called it by its acronym
(to evoke hotshot) rather than "HandsOn time". And anyway, are you 'hands on'
when you engage the autopilot and sit back? (but let's not start another
thread on whether that is "real" flying)


I took Top Dog to be "acting (or serving) as PIC" and HOT to
be "loggable time for a rating under 61.51."


Exactly right. And then I stayed away from the potentially confusing "PIC"
word.


But my point is that there is only one situation I'm aware
of where you can log time legally solely because you ARE TOP
DOG even though that time does not appear under 61.51 (which
I equated to your "HOT" logging.) That time is where
there's only one pilot, he's acting as PIC (TOP DOG) and
he's not manipulating the controls, but a non-pilot is.
Take a look at 61.51 (e) (which I equated to HOT time) and
try to justify the Chief Counsel's Interpretation that
permits this logging. It isn't HOT time, but the CC says
it's loggable because it's TOP DOG time...


Chief Counsel disagrees with a straight interpretation of the regs. Not the
first time. It's in "our favor". That's probably a first.


thus I say you're
logging TOP DOG time in this one situation, and HOT time in
all the others.


.... and I say the rules let you log HOT in this situation. The non-pilot is a
human autopilot.


Fine, if you want to separate the concepts of
authority/responsibility from the concept of making records,
then you're right.


Exactly what I was trying to do.


OTOH, if you are separating time that's
loggable under 61.51 from time that's not loggable under
61.51, but is loggable because you're TOP DOG, then my
comment makes sense.


Not what I was doing, and in any case "loggable because you're Top Dog (of a
one dog plane with a cat in it)" is only an opinion from Chief Council. It's
not in the FARs. Were we to get into a discussion about what non-FAR time is
loggable, or even what non-FAR activity is permissible (wanna talk icing?) it
could go on forever, and not be sorted out until the accident, and even then
only for that case and the new rule that evolves from it.

Jose



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