Logging of landings and cross-country flight with a non-pilot
Votes
Joined 03/18/2020 - 3 Posts
Answered By AOPA
My son is a student pilot, not quite ready to solo (but darned close).  I went flying with him on Sunday (I am fully rated and thus was the legal PIC for the entire flight), and we flew KPAE-KBLI (a little over 50nm).  I sat in the right seat, essentially on my hands – he did every last bit of the flying.

When we were done, we didn’t bother putting anything in his logbook because (despite the great experience he gained), I can’t give dual and he can’t log PIC time.

I logged 1.8 hours of total time and 1.8 hours of PIC time.  I also logged 1.8 hours of cross-country time, and despite the fact that we did 4 landings, I did *not* log any landings. 

My rationale on the cross-country time by 61.1 is that I “conducted” the flight (I’m not sure the FAA's definition of “conducted”, but I assume my son did not and could not “conduct” it) and it included a landing at a point other than the point of departure (happened to also meet the 50nm+ threshold too, but that’s only relevant if I'm using it for training, which I'm not).

My rationale for not logging the landings is that since my son was manipulating the controls, I can’t count them towards 61.57(a) - which explicitly requires me to be the sole manipulator, so I didn’t want to pollute my logbook and its currency computations.

Another pilot disagrees with me, saying that since I didn’t perform the landings (and arguably, since my son conducted the flight), I missed two of the 61.1 requirements for cross-country time.  Further, he claims that I should have logged the landings because my son was not qualified to do so but somebody needs to log them.

Thoughts as to what was the correct way to enter this in my logbook?
8 Replies
Votes
Joined 01/30/2020 - 25 Posts
AOPA Staff Answer
You are free to log what ever you want, however you will only be able to use that logged time and/or event (landings) for the purpose of meeting training time and aeronautical experience requirements if it meets the specific regulation. In your case, your interpretations are correct. So you can log the landings in your Son's logbook as he was the sole manipulator of the controls, but he will not be able to use them in any aeronautical experience requirements. So, as a CFII I would recommend logging them in the remarks section. Or, if you want, make a new column titled appropriately.
Votes
Joined 06/11/2017 - 699 Posts
First of all, you are correct about the 61.57(a) landings issue -- the FAA has repeatedly stated in legal interpretations that you must be the sole manipulator during the landing in order to log the landing for passenger-carrying currency.  This distinction from other logging considerations is made clear in the next-to-last paragraph of the Collins interpretation.  That's why I, as an instructor, cannot log the landings made by my trainees even though I am talking them through it.

The cross-country time issue is murkier.  61.1 does not say "sole manipulator", just that the flight "include a point of landing".  There are several legal interpretations on this issue:
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2009/louis glenn - (2009) legal interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2009/gebhart - (2009) legal interpretation.pdf
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Hilliard - (2009) Legal Interpretation.pdf

Per the Gebhart interpretation, a safety pilot can't log XC time because the safety pilot isn't a "required pilot crewmember" for the entire flight, and the hood comes off before landing (one hopes).  However, per the Glenn interpretation, "Any required flight crewmember for the operation could meet the entire definition of cross-country time provided that flight met the definition."  As the only rated pilot aboard a flight which "met that definition", you were required for the entire flight even if you weren't the sole manipulator of the controls at any time.  By that standard, you should be able to log XC time for this flight.

And finally (though you did not ask), even though you didn't explicitly meet any of the standards for logging PIC time in 61.51(e), you were correct by the 1977 Beane interpretation (which isn't on the FAA website because it predates all this electronic stuff) to log PIC time for yourself because you were the only rated pilot aboard.
 
Also, a pilot, rated in category and class (e.g. airplane single-engine) could, as the pilot who "Has final authority and responsibility for the operation and safety of the flight" log PIC time if another pilot, not appropriately rated, was actually manipulating the controls of the aircraft.

Essentially, the FAA held that someone always has to be the PIC, and someone always has to be able to log the time on a legally-conducted flight, so if nobody else can log the time, the PIC can.

 
Votes
Joined 03/18/2020 - 3 Posts
Perfect - thanks, Ronald!  Indeed, I didn't see any ambiguity about logging of PIC.  The only ambiguity was around XC and landings.  Those references do seem to make clear that I can log the XC and, while I suppose I can log the landings for my own records, I can't use them for 61.57(a) currency, so I think omitting them was the right call.
Votes
Joined 06/11/2017 - 699 Posts
Prometheus At AOPA:
You are free to log what ever you want, however you will only be able to use that logged time and/or event (landings) for the purpose of meeting training time and aeronautical experience requirements if it meets the specific regulation. In your case, your interpretations are correct. So you can log the landings in your Son's logbook as he was the sole manipulator of the controls, but he will not be able to use them in any aeronautical experience requirements. So, as a CFII I would recommend logging them in the remarks section. Or, if you want, make a new column titled appropriately.

I'd be very cautious about putting in one's official pilot logbook anything which doesn't meet the FAA's standards for logging.  I think it carries a substantial risk of being charged with violating 14 CFR 61.59, which carries the FAA equivalent of the death penalty -- revocation of all airman certificates, ratings, and authorizations (the penalty almost uniformly applied in such cases).  If you want to keep a separate aviation journal where you put things that don't meet FAA standards for recording an your "pilot logbook", mighty fine, but otherwise you raise in the mind of anyone reviewing your pilot logbook questions you may be unable to answer satisfactorily.  If you still want to do this anyway, I suggest marking the entries in a way which clearly shows they are not to be used for any FAA purpose, although that will complicate your logbook and make it harder for a DPE or Inspector or future aviation employer to figure out what your legitimate aeronautical experience actually is.

Votes
Joined 01/30/2020 - 25 Posts
Ron, I couldn't agree more. However, 61.59 specifically states " fraudulent or intentionally false statement". To reiterate, your logbook is your logbook and although you can log anything you want, what you log should be clear, which is why I suggested logging in remarks section or create a separate column.
Votes
Joined 03/18/2020 - 3 Posts
After this conversation, I decided that my son should add an entry with details of the flight all in the remarks section, but with NO time or landings.  I.e., not claiming any quantitative experience, but describing the (undoubtedly valuable nevertheless) experience he gained.  That is both truthful and, by definition, not contributing towards any requirements that he needs to demonstrate but is unable to claim due to my lack of CFI certificate.  Right?
Votes
Joined 06/11/2017 - 699 Posts
Eric Berman:
After this conversation, I decided that my son should add an entry with details of the flight all in the remarks section, but with NO time or landings.  I.e., not claiming any quantitative experience, but describing the (undoubtedly valuable nevertheless) experience he gained.  That is both truthful and, by definition, not contributing towards any requirements that he needs to demonstrate but is unable to claim due to my lack of CFI certificate.  Right?

That probably meets the letter of the law, but I would not have done that with my son if I hadn't held a valid CFI ticket at the time we were doing this sort of thing 25 years ago.  I sure don't see any need to demonstrate the "experience he gained" by cluttering up his pilot logbook with unnecessary information -- he can do that better with his performance during training and the practical test.  I'm always impressed when one of my trainees demonstrates performance beyond my expectations based on their logbook.  OTOH, it always worries me when one isn't as good as their logbook suggests they should be.

Choose wisely. 

Votes
Joined 01/30/2020 - 25 Posts
I would agree. After all, it was your son who landed the airplane and he should be credited for that, even though the FAA will not.