Can you log PIC time in a Mooney without Complex Rating?

[201er]

A complex endorsement is required to act as PIC of a complex airplane such as all Mooney M20's with the exception of the D model (if a fixed gear one still exists). Additionally a high performance endorsement is required to act as PIC of all post J Mooneys as they have over 200HP. So is there any way for a not yet HP/Complex endorsed Private Pilot to log PIC time in a Mooney? Yes! As long as they fly with another pilot or instructor who is qualified to act as PIC in a Mooney (including BFR, current, medical, and Complex/HP endorsements).

More about that and the story of how I got kicked out of a flight school for knowing more than the instructor here:

 

[ragedracer1977]

Tag to remind myself to watch later

[Steve W]

They're not 'Loopholes' they're simply the rules.

Also watch people's heads explode when you can tell them a non instrument rated pilot can log PIC in actual. (And even better, the Instrument rated non-instructor-rated 'safety pilot' acting as PIC doesn't get to log anything.)

[Jerry 5TJ]

11 minutes ago, Steve W said:

Also watch people's heads explode when you can tell them a non instrument rated pilot can log PIC in actual. (And even better, the Instrument rated non-instructor-rated 'safety pilot' acting as PIC doesn't get to log anything.)

A case against a non-instrument rated pilot logging PIC in actual is 61.3 (e) which says an instrument rating is required to act as PIC under IFR.  If the flight is under IFR and in actual IMC then 91.173 applies and the non-rated pilot may not fly.  If actual IMC prevails there is no requirement for a safety pilot so the non-rated pilot is not required crew as under 91.109 (c) and shouldn't log PIC as required crew.  So both could log PIC in simulated IFR, but not in actual. That said....

... there is long-standing precedent for flight training 'tolerance' of the practice (cf the FAA Jones Letter of about 40 years ago) and in practice, sure, do log PIC if in fact you are either (A) required crew for simulated IFR, or (B) are the sole manipulator of the controls in IMC while a rated pilot is actually the PIC for filing the flight plan.    As a CFII when possible I file so that my non-instrument rated students may fly in the clouds as I monitor.  They log dual received and PIC time.  

No heads need explode.

[carusoam]

 

Interesting bite sized review of the FARs, 201er!

When to Act as PIC...  vs. when to Log as PIC...

Constant learning... 

Lots of details...

How often do two people actually log PIC time on the same flight at the same time?

• PIC
• Sole manipulator of the controls
• SIC

The rules are so well written... they allow flexibility for things that evolve over time....

One question, very important.... Is that a mahogany Long body on your back shelf...  

Thanks for sharing the review...

Best regards,

-a-

[RobertGary1]

The confusion is only because serving as pic and logging pic really shouldn’t have both used the term pic because the two are very often not coincidental. Both are covered under different sections of the fars and have different rules. 
99% of the time GA people log pic not because they are serving as pic but because they are sole manipulator.

-Robert 

[midlifeflyer]

Logging vs Being PIC.

[mikefox]

Yes, you can log PIC time in a Mooney without having the complex endorsement, as long as there is someone on-board who can "act as PIC" for the flight - in other words, take responsibility for safety of the flight.  You are logging PIC time as sole manipulator of the controls in an aircraft for which you are appropriately rated, and rating does not include endorsements!

[skydvrboy]

Related question on this topic. Two fully rated, capable, current pilots decide to go for a flight.  What, if anything, prevents one from saying I’ll act as PIC, you operate the controls, then we can both log the time?

[PT20J]

20 minutes ago, skydvrboy said:

Related question on this topic. Two fully rated, capable, current pilots decide to go for a flight.  What, if anything, prevents one from saying I’ll act as PIC, you operate the controls, then we can both log the time?

That works only if the pilot not operating the controls is a flight instructor giving instruction or if the aircraft type certificate or regulation under which it is operated requires two pilots. 

91.109 requires a safety pilot for simulated instrument flight. If the pilots agree that the safety pilot will be pilot in command, then they can both log it.  This actually makes sense since the safety pilot is in a better position to be responsible for the flight.

Skip

[RobertGary1]

1 hour ago, skydvrboy said:

Related question on this topic. Two fully rated, capable, current pilots decide to go for a flight.  What, if anything, prevents one from saying I’ll act as PIC, you operate the controls, then we can both log the time?

Sure you can do that. But only the guy flying can log pic. 61.51 doesn’t allow pilots to log pic only because they are pic of the flight. 
 

-Robert 

[jaylw314]

2 hours ago, RobertGary1 said:

Sure you can do that. But only the guy flying can log pic. 61.51 doesn’t allow pilots to log pic only because they are pic of the flight. 
 

-Robert 

IIRC, it does allow you to log PIC if you only operate the controls or if you only act as PIC.  It just doesn't allow more than both pilots to log PIC for the same time.

Maybe a more intuitive way of thinking about it is that if the plane and flight only requires one PIC, only one person can log PIC (either the flyer or the pilot who is PIC).  Things that require more than one PIC include:

• Planes that require two pilots for all operations
• Flight instruction with a CFI
• Simulated instrument training

Only one thing requires no PIC (so no time can be logged):

• Solo flight during private pilot training

Are there any planes out there that require three or more pilots?  I wonder if three pilots could then log PIC...

One "gotcha" is that I've had friends safety pilot for me while I've done simulated instrument training.  They can only log PIC for my hood time if they have a complex endorsement, since to log it they'd have to "act as PIC", and they can't do that without a complex endorsement.  Weirdly, if they went under the hood in my plane without a complex endorsement, then we'd both be able to log it.  Luckily, a couple of them have complex endorsements even though they own Skyhawks, so I remind them to log complex PIC to help with their insurance hours if they ever get a complex plane.

Edited October 31, 2020 by jaylw314

[RobertGary1]

5 hours ago, jaylw314 said:

IIRC, it does allow you to log PIC if you only operate the controls or if you only act as PIC.  It just doesn't allow more than both pilots to log PIC for the same time.

 

I think you’re making it much more confusing.  There is never more than one pic in any flight ever, even instructional.  But being pic alone never allows logging pic  There must be other conditions.

To make it easier I tell students to go through 61.51 and know which reads they’re using   

 Best way to think about it is just that logging pic and serving as pic are vastly different things with an unfortunate same name  

-Robert

[Cruiser]

The best way I have heard to understand this is that 

one person can LOG the flight time when he/she is doing the flying

while 

another person is ACTING as PIC for the flight.

Both get to put the time in their log books. 

[RobertGary1]

11 minutes ago, Cruiser said:

The best way I have heard to understand this is that 

one person can LOG the flight time when he/she is doing the flying

while 

another person is ACTING as PIC for the flight.

Both get to put the time in their log books. 

That’s not correct though. You can’t put anything in your logbook for acting as pic unless you also meet one of the unusual conditions of 61.51e. Logging pic is very clearly spelled out in the fars with a list of very specific ways to log pic. 

 

-Robert

[PT20J]

The usual way that people make mistakes interpreting the FARs is to look at one regulation in isolation. If you read many legal interpretations, you will see that a common theme is the need to look at all the regulations applicable to a particular situation taken together as a whole. 61.51 is very specific about who may log PIC time. It is clear that an appropriately rated "sole manipulator of the controls" may always log PIC time. In certain circumstances specifically listed in 61.51, another pilot may simultaneously log PIC time if that pilot is acting as Pilot in Command. However, there are other regulations that must be met for that pilot to be eligible to act as PIC such as 61.3, 61.31, 61.57.

The regulations actually provide a lot of leeway. Suppose you haven't done your three takeoffs and landings in the last 90 days. You want to fly off VFR to get a $100 hamburger with your appropriately rated and current pilot friend who has no Mooney time. Can you legally do this with you flying the airplane? Sure. You simply agree that your friend is PIC, and you fly the airplane. Can you log the flight as PIC? Sure, since you were the sole manipulator of the controls. Can your friend log it since he was the legal PIC? No, because two pilots were not required by the type certificate or regulation under which the flight was conducted. There is no requirement that the PIC actually fly the airplane. In this case you were technically a passenger. That's why you need to get agreement before the flight about who is PIC because if you forget to put the gear down, the other pilot can be held responsible.

Skip

 

[gsxrpilot]

9 hours ago, jaylw314 said:

One "gotcha" is that I've had friends safety pilot for me while I've done simulated instrument training.  They can only log PIC for my hood time if they have a complex endorsement, since to log it they'd have to "act as PIC", and they can't do that without a complex endorsement.  Weirdly, if they went under the hood in my plane without a complex endorsement, then we'd both be able to log it.  Luckily, a couple of them have complex endorsements even though they own Skyhawks, so I remind them to log complex PIC to help with their insurance hours if they ever get a complex plane.

That is not how I read 61.51. All it says is rated for Category and Class. So as long as my safety pilot is rated for Airplane Single Engine Land.. he can log the PIC time while I'm under the hood. There is nothing about HP/Complex endorsement or any other endorsements.

[midlifeflyer]

24 minutes ago, gsxrpilot said:

That is not how I read 61.51. All it says is rated for Category and Class. So as long as my safety pilot is rated for Airplane Single Engine Land.. he can log the PIC time while I'm under the hood. There is nothing about HP/Complex endorsement or any other endorsements.

But is is how the FAA reads it. 
 

Yes, a safety pilot needs only be rated in category and class but that does not solve the logging issue. A safety pilot may log either PIC time or SIC time, if you read 61.51, a safety pilot may log PIC time 

"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; "

the key is that a safety pilot may log PIC when acting' as PIC.  Nothing in the rules about safety pilots removes the requirements for acting as PIC, which include category and class, ratings, applicable endorsements, current flight review, etc.

[midlifeflyer]

3 hours ago, RobertGary1 said:

That’s not correct though. You can’t put anything in your logbook for acting as pic unless you also meet one of the unusual conditions of 61.51e. Logging pic is very clearly spelled out in the fars with a list of very specific ways to log pic.

Yes but we don't log "acting PIC."

https://www.ifr-magazine.com/system/logging-vs-being-pic/

a separate one I wrote specifically about safety pilots is, unfortunately only available to subscribers.

[RobertGary1]

9 minutes ago, midlifeflyer said:

Yes but we don't log "acting PIC."

https://www.ifr-magazine.com/system/logging-vs-being-pic/

a separate one I wrote specifically about safety pilots is, unfortunately only available to subscribers.

Exactly there is no way to log pic only because you are acting as pic. 
61.51e tells all and has some specific situations where acting as pic allows you to also log pic but it’s limited to very specific scenarios. 
 

-Robert 

[midlifeflyer]

15 minutes ago, RobertGary1 said:

Exactly there is no way to log pic only because you are acting as pic. 
61.51e tells all and has some specific situations where acting as pic allows you to also log pic but it’s limited to very specific scenarios. 
 

-Robert 

True.  Once we can get past the weird concept that the FAA treats "acting as PIC" and "logging PIC flight time" under two separate sets of rules which only intersect when 61.51 says so, it becomes easy. If you fit in a 61.51(e) box, you can log PIC, regardless of whether anyone else can also. If you don't, you can't. I guess the good news is that although the rules haven't changed in almost 40 years, the FAA has made 61.51(e) clearer. There simply is no 61.51(e) box which says, "anyone who is acting as PIC may log as PIC flight time."

The private pilot doing the flying, rated in category and class logs PIC because 61.51(e)(1)(i) says so.

The private pilot who is acting as safety pilot and  PIC (there's one place they intersect) - which means (a) the two pilots agree the safety pilot is in charge and (b) the safety pilot meets all of the  qualifications to act as PIC on that flight - logs PIC because the FAA says that 91.109 makes the safety pilot a required pilot and 61.51(e)(1)(iii) says so.

The private pilot who is not acting as safety pilot but not as PIC - there can be reasons in addition to lack of FAA PIC qualification ma log  SIC flight because 65.51(f)(2) says so.

[PT20J]

1 hour ago, gsxrpilot said:

That is not how I read 61.51. All it says is rated for Category and Class. So as long as my safety pilot is rated for Airplane Single Engine Land.. he can log the PIC time while I'm under the hood. There is nothing about HP/Complex endorsement or any other endorsements.

Paul, in this case it is 61.31 (e) that applies.

Additional training required for operating complex airplanes. (1) Except as provided in paragraph (e)(2) of this section, no person may act as pilot in command of a complex airplane, unless the person has—

(i) Received and logged ground and flight training from an authorized instructor in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane, and has been found proficient in the operation and systems of the airplane; and

(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane.

(2) The training and endorsement required by paragraph (e)(1) of this section is not required if—

(i) The person has logged flight time as pilot in command of a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane prior to August 4, 1997; or

(ii) The person has received ground and flight training under an approved training program and has satisfactorily completed a competency check under §135.293 of this chapter in a complex airplane, or in a full flight simulator or flight training device that is representative of a complex airplane which must be documented in the pilot's logbook or training record.

[RobertGary1]

2 hours ago, gsxrpilot said:

That is not how I read 61.51. All it says is rated for Category and Class. So as long as my safety pilot is rated for Airplane Single Engine Land.. he can log the PIC time while I'm under the hood. There is nothing about HP/Complex endorsement or any other endorsements.

The only way I’m aware a safety pilot can log pic under 61.51e is if he’s serving as pilot in command at the same time and that requires complex endorsement. 
So the safety pilot meet all the serving as pic requirements  

(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  aircraftor the regulations under which the flight is conducted; or

-Robert 

[Hank]

When I was working on my instrument rating a decade ago, the local DPE (also Commander of WV ANG) came to our local pilots association meeting, and I specifically asked this question in regard to who could act as my safety pilot. He said anyone with PPL, ASEL. Complex Endorsement not required. Instrument Rating for safety pilot not required. (But no Actual Instrument Conditions allowed!). Only category (aircraft) and class (single engine and land) required, and both could log the time. But the Safety Pilot couldn't log takeoff/landings, which were VFR and not under the hood, meaning safety pilot could log Mooney hours only for the time I was under the hood.

This was critical for me, as there were few pilots around with Complex Endorsement and fewer with any Mooney time.

[RobertGary1]

11 minutes ago, Hank said:

When I was working on my instrument rating a decade ago, the local DPE (also Commander of WV ANG) came to our local pilots association meeting, and I specifically asked this question in regard to who could act as my safety pilot. He said anyone with PPL, ASEL. Complex Endorsement not required. Instrument Rating for safety pilot not required. (But no Actual Instrument Conditions allowed!). Only category (aircraft) and class (single engine and land) required, and both could log the time. But the Safety Pilot couldn't log takeoff/landings, which were VFR and not under the hood, meaning safety pilot could log Mooney hours only for the time I was under the hood.

This was critical for me, as there were few pilots around with Complex Endorsement and fewer with any Mooney time.

That’s very true. The safety pilot just can’t serve as pic without the complex endorsement and in that case could log sic but of course not pic. 
 

-Robert