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Logging Instrument SIC 121

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HS-125,

First, I don't have a lot tied up in this debate, as I have plenty of instrument time for any certifcate I need, and I generally only log instrument time when I'm PF. I am, however inclined to beleive that I could legally log Instrument time when I am PNF (I fly as SIC in a 3 crew aircrft)

OK, so at some time in the past, 61.51 referred to "manipulating the controls", instead of "operating" regarding logging of instrument time.

Can you post the exact wording, or at least verify that what you posted above is a verbatim quote, and not a paraphrasing?

Like In Hot, I wonder if the change from "manipulating the controls" to "operating" is indicative of a change in the intent of the FAA. Certainly, there are cases where the SIC is held to be "operating" the plane when he is not manipulating the controls.

Regarding your link to the AFS 640 document: I would be extremely careful relying too heavily on this document. It is not a product of the FAA's Office of Chief Counsel. They are the only entity which may issue a binding interpretation of the regulations (them, and a judge, is suppose)

There have been times in the past when the Chief Counsel has disagreed with such a publication. I recall one instance where they issued an interpretaiton which directly contradicted a statment made in a similar FAQ sheet. If I recall correctly, it was on the AFS-840 webpages and was by John Lynch, the author of the Part 61 rewrite.
The chief counsel essentially said that the information on that site was not official, merely advisory, even though it was published on the official FAA website (by the guy who wrote the regulation, no less). I can't come up with the actual opinion letter at the moment, but I'll try to find it.

Anyway, unless an opinion, is issued from the Office of Chief Counsel, it isn't binding in any way.

Regards
 
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Disclaimer

A Squared:

Here's the diclaimer from the FAQ Site:

http://av-info.faa.gov/data/640otherfaq/pt61-16.pdf

Disclaimer Statement: The answers provided to the questions in this website are not legal interpretations. Only the FAA's Office of Chief Counsel and Regional Chief Counsel can provide legal interpretations. The FAA's Office of Chief Counsel does not review this website nor does it disseminate legal interpretations through it. However, there are some answers provided in this website where the FAA Office of Chief Counsel's legal interpretations have been reprinted.
However, the answers in this website address Frequently Asked Questions on 14 CFR part 61 and represents FAA Flight Standards Service policy as it relates to this regulation. The answers are provided for standardization purposes only.

Bottom line, we're not going to definitvely decide this issue.

Thank God.

Can't wait til I have a job again and don't have time to read and create this stuff.


:)
 

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