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Student and instructor both logging PIC

I’ve always seen and done it this way: PPL students log dual, while I log PIC + instructor, except for solo’s where the student logs PIC and the instructor sips coffee on the ground And then the same for the IR, student logs dual + IFR time, and the instructor logs PIC + IFR + instructor time.

In the US it’s typical for the student to log PIC time during training after they get the license, so during IR they usually log PIC. I think nobody does that in EASA, but I was reading Part-FCL for something else and saw this in AMC1 FCL.050 (b) (1) (iii):

the holder of an instructor certificate may log as PIC all flight time during which he or she acts as an instructor in an aircraft;

And (iv) specifies the same for examiners. That got me searching, but nowhere does it say the instructor must also be PIC of the flight. So if you’re doing IR training in a SEP, on a VFR plan (student wearing IFR goggles), most students would be qualified to be PIC of that flight and log it as PIC time, while the instructor still logs it as PIC/instructor as usual due to FCL specifying that any time instructing can be logged as PIC.

What did I miss? As far as I’ve seen nobody does it this way, but it seems like Part-FCL allows doing things very similar to how the US does it?

Netherlands

Could mean that during an IR instruction flight under VFR, the student (eg PPL VFR) can log PIC/DUAL RECEIVED and the instructor PIC/DUAL GIVEN.

On the other hand „may log as PIC time“ could also mean the instructor can elect to „override“ the student’s eligibility for PIC and simply say „I’ll be acting PIC, you log it as dual received only!“ So who of the two is PIC is subject to the instructor‘s choice.

To further complicate it:

Quoting the knowledgeable @Qalupalik

The relevant implementing rules in Part-FCL, and the
associated essential requirements for aircrew in annex IV to the Basic
Regulation, only require the instructor to be ENTITLED to act as PIC.
This means the person being instructed could be acting as PIC. Just
search for the string “entitled to act” within the Aircrew Regulation
or see FCL.915(b)(4)

always learning
LO__, Austria

Ah, thanks for adding that one. I think the wording of FCL 915 is in line with the interpretation that IR students could log PIC:

(b) Applicants for the issue of or holders of an instructor certificate with privileges to conduct flight
instruction in an aircraft shall:
[..]
(4) be entitled to act as PIC in the aircraft during such flight instruction.

If they wanted the instructor to be PIC they would have written that, not shall be entitled to. That implies you only have to have the privileges.

I’m still thinking there is something I miss, otherwise why wouldn’t all modular CPL/ATPL students get these 40 to 50 extra PIC hours during IR?

Netherlands

At my recent IR PC, the examiner told me to log the flight as dual. I asked why as he had always told me to log PIC before (7 previous PCs with the same guy). He said that he had been wrong before… I can’t find anything in the IR PC regs (Appendix 9 to part-FCL) that says the FE should be PIC, so I think he’s wrong – but it’s really not a big deal.

ESKC (Uppsala/Sundbro), Sweden

There is too much of this “wisdom” being passed along from examiners, instructors and flying clubs. The problem is that if as an examiner (or like me, an instructor) you say something like that, the student will remember it and spread it as the one and only truth, because their examiner said so.

That’s also partially why I was searching something in Part-FCL, it’s best if you say these kinds of things to show the student where they could have found it themselves. Both so you are sure it’s correct, and so they attach that feeling of authority to an EASA document instead of “my instructor said so”. Even more so because a lot of instructors say a lot of wrong things

Netherlands

I agree it should be defined by EASA; but isn’t the reality that the competent authority decides who EXACTLY the logging shall be done in such cases?
At least, that’s the case in Germany, where the LBA has always been very prescriptive about logging rules, leaving no doubt they think THEY decide how exactly the logging is to be done. Germany says that an examiner (acting as such) is always the PIC. Does Sweden not have any regulation on this matter?

To be honest, it’s ok for me. I fly so much…. any flight where I am not PIC is fine for me… whatever happens on that flight, I am not to be blamed…

Last Edited by boscomantico at 15 Jul 09:06
Mainz (EDFZ) & Egelsbach (EDFE), Germany

We have done this before a few times and I don’t think anybody ever found anything clear.

I think the answer is simply that in Europe it is a convention in schools that in ab initio training the instructor is always PIC even if the student does have papers sufficient to make him legally PIC on that particular flight.

Later, e.g. proficiency checks, with freelance instructors/examiners, the candidate usually logs “PIC” unless this would be clearly illegal (e.g. an IMCR/IR reval flight, or an FAA IPC, in IMC).

I reckon every “instructor” I have ever flown with logged it as “PIC”

Ultimately, you (as an FI) don’t own the candidate’s logbook so they can put what they like in there, as far as you are concerned. It is only a matter of whether such entries are acceptable to some inspecting authority later on.

Administrator
Shoreham EGKA, United Kingdom

My 2 cents
In my pilot logbook (Belgian,JAA) ,the explanations tell exactly what to mention
Column 10 :Enter flight time as pilot in command (PIC),student pilot in command (SPIC) and pilot in command under supervision (PICUS) as PIC
all time recorded as PICUS or as SPIC must be countersigned by the aircraft commander/flight instructor in the Remarks (colomn 12)
instructor time should be recorded as appropriate and also entered as PIC.

LFDU, Belgium

boscomantico wrote:

I agree it should be defined by EASA; but isn’t the reality that the competent authority decides who EXACTLY the logging shall be done in such cases?

The logging is not the issue here. That, at least, is clear from part-FCL. The issue is who should be PIC (which of course determines what to log).

At least, that’s the case in Germany, where the LBA has always been very prescriptive about logging rules, leaving no doubt they think THEY decide how exactly the logging is to be done. Germany says that an examiner (acting as such) is always the PIC. Does Sweden not have any regulation on this matter?

I can’t find any Swedish regulation on the matter, but there is an “Examiner handbook”. EASA also has an examiner handbook.

Both say basically the same thing.

EASA: “Normally, the Examiner shall be the pilot-in-command, except in circumstances agreed by the Examiner with the Candidate.”
Swedish CAA (in my translation): "…the Examiner shall be the pilot-in-command unless otherwise agreed prior to the test.

To be honest, it’s ok for me. I fly so much…. any flight where I am not PIC is fine for me… whatever happens on that flight, I am not to be blamed…

Same for me.

ESKC (Uppsala/Sundbro), Sweden

In the US, logging PIC is totally different from being the Pilot In Command. Logging is what you are entitled to record in your log book and governed by 61.51. More than one pilot may be entitled to record the same flight time as PIC. Acting as PIC is a defined term:

Pilot in command means the person who:
(1) Has final authority and responsibility for the operation and safety of the flight;
(2) Has been designated as pilot in command before or during the flight; and
(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

There are at least a dozen or more regulations that limit who may act as Pilot in Command, for example 61.56 Flight Review, 61.57 Recent Experience, 61.75 FAA certificated based on Foreign License, endorsements, and all the pilot privileges for various pilot certificates and ratings. There is only one regulation that specifies who may log Pilot in Command and such pilot does not have to be the one who is “Acting as Pilot in Command”. Any pilot who holds a pilot certificate for category and class of the aircraft they are flying and are the sole manipulator of the controls may log the time as pilot in command. Such pilot does not need to hold a medical, be current in any way, or have endorsements required to act as pilot in command. There are instances where the pilot acting as PIC may not log PIC because they don’t meet any of the requirements in 61.51 for logging PIC.

KUZA, United States
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