Thank you for posting the letter. I agrees with my position
IMHO. The question is whether you note the time as 61.51 or
1.1 time.

I wonder what cases have gone through in the past 14 years
to further clarify the issue?


"Bob Moore" wrote in message
46.128...
| Jim Macklin wrote
| Yes, please post the entire letter.
|
| How many times do we have to argue this issue?
| Every year?
|
| Here is the Chief Counsel decision on the matter:
|
| ---
| October 30, l992
|
|
| Mr. David M. Reid
|
|
| Dear Mr. Reid:
|
| Thank you for your letter of June 12, 1992, concerning the
| logging of pilot-in-command (PIC) time under the Federal
Aviation
| Regulations (FAR).
|
| In your letter you ask four questions. First, you ask
whether
| there are "any circumstances when, during a normal flight,
two
| Private Pilots may simultaneously act as (and therefore
log the
| time as) Pilot-In-Command?" The answer is two private
pilots may
| not simultaneously act as PIC but they may, under certain
| circumstances, simultaneously log PIC time.
|
| There is a difference between serving as PIC and logging
PIC
| time. PIC, as defined in FAR 1.1, means the pilot
responsible
| for the operation and safety of an aircraft during flight
time.
| FAR 61.51 deals with logging PIC flight time, and it
provides
| that a private or commercial pilot may log as PIC time
only that
| flight time during which he is the sole manipulator of the
| controls of an aircraft for which he is rated, or when he
is the
| sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR
61.51 only
| regulates the recording of PIC time used to meet the
requirements
| toward a higher certificate, higher rating, or for recent
flight
| experience.
|
| Therefore, 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. PIC flight time may be logged by
both the
| PIC responsible for the operation and safety of the
aircraft
| during flight time in accordance with FAR 1.1, and by the
pilot
| who acts as the sole manipulator of the controls of the
aircraft
| for which the pilot is rated under FAR 61.51. Enclosed
please
| find two prior FAA interpretations concerning logging of
PIC
| time. We hope that these will be of further assistance to
you.
|
| In your second question you ask "[h]ow shall two Private
Pilots
| log their flight time when one pilot is under the hood for
| simulated instrument time and the other pilot acts as
safety
| pilot?" The answer is the pilot who is under the hood may
log
| PIC time for that flight time in which he is the sole
manipulator
| of the controls of the aircraft, provided he is rated for
that
| aircraft. The appropriately rated safety pilot may
concurrently
| log as second in command (SIC) that time during which he
is
| acting as safety pilot.
|
| The two pilots may, however, agree prior to initiating the
flight
| that the safety pilot will be the PIC responsible for the
| operation and safety of the aircraft during the flight.
If this
| is done, then the safety pilot may log all the flight time
as PIC
| time in accordance with FAR 1.1 and the pilot under the
hood may
| log, concurrently, all of the flight time during which he
is the
| sole manipulator of the controls as PIC time in accordance
with
| FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
| interpretation concerning the logging of flight time under
| simulated instrument flight conditions. We hope that this
| interpretation will be of further assistance to you.
|
| In your third question you ask "[d]uring instrument
training, how
| shall a VFR Private Pilot log the following flight time:
Pilot-In-
| Command time, Simulated Instrument time, and Actual
Instrument
| time, when that pilot is...A)...under the hood? B)...in
actual
| instrument conditions? C)...under the hood in actual
instrument
| conditions?" The answer is the VFR private pilot may log
all of
| the flight time you described as PIC flight time under FAR
| 61.51(c)(2)(i) if he was the sole manipulator of the
controls of
| an aircraft for which he is rated. Under FAR 61.51(c)(4)
the
| pilot may log as instrument flight time only that time
during
| which he operates the aircraft solely by reference to
| instruments, under actual or simulated instrument flight
| conditions. Please note that the FARs do not distinguish
between
| "actual" and "simulated" instrument flight time. Enclosed
is a
| prior FAA interpretation concerning the logging of
instrument
| flight time. We hope this interpretation will further
assist
| you.
|
| Finally you ask "[d]oes FAR 61.57 affect how the VFR
Private
| Pilot shall log Pilot-In-Command time during instrument
training,
| either before or after meeting the 6/6/6 requirement, and
if so,
| how?" FAR 61.57 does not affect how a pilot logs PIC time
during
| instrument training; FAR 61.51(c)(2) and
| (4) govern logging of instrument flight time. FAR
61.57(e)
| provides currency requirements for acting as PIC under
instrument
| flight rules (IFR) or in weather conditions less than the
| minimums for visual flight rules (VFR). Enclosed
| please find a prior FAA interpretation on instrument
flight time
| and FAR 61.57(e). We hope this interpretation will
further
| assist you.
|
| We hope this satisfactorily answers your questions.
|
| Sincerely,
|
| Donald P. Byrne
| Assistant Chief Counsel
| Regulations Division
|
|
|