ATP Multi-Engine Hours
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Good evening -- first time posting with a hopefully not too tricky question. Currently a military pilot working through mil-comp rating and add ons. I was able to comp commercial SEL, R-H, IA, IH as well as my CFI SEA and IA. I've since added my MEL to my commercial, and through a part 141 program added ME to my CFI. Along with my CTP course, this has brought my multi-engine hours to 50.8, including the sims.

Strictly reading the FARs, I have the requisite class total for an ATP check ride. It breaks down to approximately 15 hours time as dual received, 25 hours PIC time (under instruction for my CFI check, plus the ride), and the 10 hours in the sim for my CTP (yes, it was all in the appropriate full fidelity sim). The FAR does not specify any of the class time need to be of a particular "flavor," i.e., not PIC.

Here's the rub: how do I document my time on an IACRA form? For specific class totals, the form only allows me to identify PIC and SIC time. Since I was not yet rated for MEL, I cannot log the time as PIC under the "sole manipulator" regulation. Nor does it seem like it would qualify as SIC time. Does anyone have any experience with this particular scenario? How does the dual received time count? How is it documented? And what is the legal precedence? References?

I've searched the pubs, the IACRA documentation, and the interwebs, but can't find anything specifically covering this situation. Thank you in advance for any insight!
6 Replies
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Ronald, thank you! I'll have to give them a call then. Appreciate the help!

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1169 Posts
This is beyond me.  Try calling IACRA help at 844-322-6948.
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Ronald, the screen shot indicated covers my actual flight time. The IACRA interface has another tab, slightly lower, simulator time. There's 10 hours FFS included in the calculation IACRA is running which has resulted in the error shown.

That still leaves no area for me to annotate the remaining 15 hours or so of “dual received” which are in my logbook. You can clearly see the class totals section includes a simple total time for helos and gyros, but breaks down any multi-engine time by PIC or SIC, which as you previously stated, doesn't cover the time gained as “instruction received” before I was MEL rated… but it does count towards the class requirement for ATP. So how to I get IACRA to see that?

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1169 Posts
Where is your simulator time?
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Ronald, thank you for taking the time to reply – I really appreciate it. As I've been dipping my toes in the GA/civilian world, I've sorted through pitfalls of actually logging the specified time. I'm happy to report all my hours are appropriately logged within my combined logbook, to include painstakingly translating military time to appropriately credited civilian time. Happy to say everything you stated jives with what I've achieved in that regards!

Which leaves one question… how do I get IACRA to see it that way? I've achieved the minimum “flight time” in class, as you've said, by including the training time I spent acquiring the rating. The problem is, IACRA doesn't provide a breakout for AMEL “training time” or “instruction received." Only for PIC or SIC, or in a later category FFS time, which leaves an error which IACRA won't even allow you to proceed with the application. Please see the attached to clarify.

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1169 Posts
When you are receiving flight training from an authorized instructor in an aircraft in which you are not rated, it counts as pilot time, flight time, training time, and instrument time (if in actual or simulated instrument conditions).  It does not count as either PIC or SIC time, so those columns are left blank.  As a result, your total flight time will be less than the sum of your PIC and SIC time, and that is recognized by the FAA.  For the sim time, it counts as pilot time (but not flight time, and the total time column in your log book is flight time -- nobody I know tracks pilot time, anyway), training time, simulated instrument time (as appropriate), and simulator time (the type of sim {FFS/FTD/AATD/BATD and class - ASEL, AMEL, etc} should be noted).  Ref: 14 CFR 61.51.  There are also some FAA Chief Counsel interpretations on point.

As to the 50-hour in-class requirement in 61.159(a)(3), that need not be PIC time, and would include your training time in AMEL even it wasn't PIC time.  You can also include up to 25 hours of training time in an AMEL full flight simulator.  And as I read the regs, SIC time in AMEL aircraft would also count, since it only says "flight time", and SIC time is "flight time".  Ref: 14 CFR 61.51, 61.1(b), and 1.1.

"Dual received" time is documented by including the time in the "Training Time" column of that line in the logbook, plus the signature/number/expiration date of the instructor on that line.  What other columns are used depends on the situation, i.e., they are independent of the fact that you are receiving training.  So, as regards PIC or instrument time, if you are rated in the type and the sole manipulator while receiving training, it is PIC time as well as training time.  If you're sole manipulator while receiving training in instrument conditions, it is instrument time as well as training time.  Could be either, neither, or both, depending on your rating and the conditions, and the inapplicable columns are left blank.

And welcome to the confusing world of logging time in the civilian world.