Relay-Version: B 2.11 6/12/87; site scorn Path: uunet!mailrus!cornell!rochester!kodak!swamps!val From: val@swamps.UUCP (Val Christian) Newsgroups: rec.aviation Subject: Instrument Logging (Not Again!!!) Keywords: instrument time logging, PIC Message-ID: <244@swamps.UUCP> Date: Sat, 25 Aug 90 19:50:15 PDT Reply-To: val@swamps.UUCP (Val Christian) Organization: Swamp Systems Lines: 146 While preparing for an upcoming CFI initial checkride, I temporarily diverted myself, and started reviewing my collection of FAA letters. I find some of these interesting in their interpetation of regulations and often learn [something] from them. There are two points I will address in this posting: logging of actual instrument time by a pilot not instrument rated, and a lesser point of who may provide loggable instrument training. [Feb 7, 1980 Letter to FAA General Aviation News] ... If a pilot is flying by reference to instruments and is not instrument rated, may he log that time as Pilot in Command Instrument Time on FAA Form 8710? ... [FAA written response, 8 APR 1980, from James I Riddle, Chief, Certification Branch, AFO-840] ... Regarding your last question, Section 61.51(c)(2)(4) provides for the logging of flight time under the conditions stated in your letter. Specifically, a pilot who is flying by reference to instruments and is not instrument rated may log that time as pilot-in-command instrument time provided he meets the requirements of Section 61.51(c)(2)(i), i.e., sole manipulator and rated in aircraft. Further supporting this letter is FAA General Aviation News/Sept-Oct 1986, which restates by example a situation encompassed in the above letters. Here's my retyping of the 1986 article... * LOGGING INSTRUMENT TIME I recently went back through my back issues of FAA General Aviation News to try to find an answer to a question I have regarding logging of instrument time. I was unable to find quite what I was looking for, so I am writing for a specific answer. The situation is this: Pilot A is instrument rated and current. Pilot B is not instrument rated (but he wants to practice for the rating). Both pilots are current for the category and class of aircraft, with current medicals and BFRs. Both hold private pilot licenses (only, no CFI for Pilot A). According to the FAR's, when Pilot B is in VFR conditions with a hood and on an IFR flight plan, with Pilot A in the right seat as check pilot, Pilot B may log this time as PIC and Pilot A may (only) log this time as "check pilot" or "second in command". (Rightd, Pilot A _must_ be pilot-in-command as defined under FAR 1.1 (which identifies the pilot responsible for the operation and safety of an aircraft during flight time). It should be understood that although Pilot A is serving as "safety pilot" under FAR 91.21(b), he or she must still be pilot-in-command under FAR 1.1 and may log the time while serving as pilot-in-command in accordance with FAR 61.51(c)(2)(i). In the second situation, the above circumstances are changed only by the flight conditions being changed to _actual_ instrument meteorological conditions (IMC). Pilot B may still log the time during which he or she manipulates the controls as pilot-in-command in accordance with FAR 61.51(c)(2)(i). Pilot A _must_ be pilot-in-command as defined in FAR 1.1 and may, thus, log the time serving as pilot-in-command in accordance with FAR 61.51(c)(2)(i). If Pilot "A" were to become a certificated flight instructor, he or she _must still_ be pilot-in-command under FAR 1.1 and would then be serving a dual role as both safety pilot and flight instructor and may log the time as pilot-in-command under either FAR 61.51 (c)(2)(i) or 61.51 (c)(2)(iii) as he or she chooses. The flight experience gained under the above conditions is creditable toward an instrument rating and should be logged in accordance with the specific guidelines of FAR 61.51 (a), (b), and (c), (2), (4), and (5). Now, on to the next issue...the FAA has recently vascillated on the issue of under what conditions a simulator or training device may be used for rating times and currency. My previous understanding was that simulator time was creditable towards a rating when instruction was given. After an instrument rating, an individual could utilize a simulator to provide up to three hours and six approaches of the needed six hours and six approaches every six months. Well, things are different now. I'll explain it as best I can. I'll use several sources, including a letter dated Mar 26 1982 by Arthur C. Jones, Chief, Certification Branch, AFO-840. Simulator vs. training device. The new 8710 forms now provide for detailing of time logged using a simulator and time logged using a training device. My understanding is that something like an ATC 610 or ATC 710 is an approved training device. A Microsoft Flight Simulator is not. Time logged on an approved training device, credited for either an instrument rating or for currency, must be instrument instruction, provided by either an instrument ground instructor or a certified flight instructor with an instrument rating on his/her flight instructor certificate. Time spent on an approved training device (ATC 610, ATC 710, etc.) without the benefit of instruction, is not creditable towards rating or currency requirements. Now, to summarize this posting on instrument time logging, 1. An appropriately rated pilot, who is not instrument rated, may log PIC actual instrument time. In this case there must be another pilot on board who is acting PIC, under FAR 1.1. The acting PIC is required by regulations under which the flight is operated, and therefore may also log PIC time. 2. Required instruction time in an instrument ground trainer may be provided by either an instrument ground instructor or an instrument flight instructor. 3. Instrument instruction time creditable towards instrument currency, in an instrument ground trainer, may be provided by either an instrument ground instructor or an instrument flight instructor. Val Christian val@swamps.UUCP