Estimating PIC with known Total Hours?

6 Answers

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   KDS on Aug 14, 2017

   Your fellow pilots are incorrect regarding that 85%. There is no percent conversion factor for military time. It’s a common misconception among military pilots. Where it usually is asked by them is related to the fact that civilian flight time is logged differently than military. That’s why the guys who understood the rules from the beginning would keep a civilian logbook as well as maintain their military records per those rules. I was one of the ones who didn’t understand the rules and I could never figure out why those other guys went to all that extra trouble. Later, I found out. However, in my case, it didn’t matter because I had more time than I needed even using the military numbers.

   I’m sure a great many military pilots have obtained certificates without valid records, but that follows the logic of “he got away with it, so it must be okay”.

   The FAA’s guidance on the subject is contained in FAA Order 8900.1 beginning at Paragraph 5-171. I’ll quote that section here:

   5-171 GENERAL. Aeronautical training and experience that is used by airmen to meet the requirements for a certificate or rating, or for recent flight experience, must be documented in a reliable record. This section provides guidance to operations inspectors on the requirement for airmen possession of logbook records and replacement of pilot flight experience records. A pilot logbook is the primary evidence of pilot experience; however, inspectors may accept operator records in lieu of a personal pilot logbook. Pilot logbooks or those company records used to meet the recordkeeping requirements of 14 CFR part 61, section (§) 61.51 may be inspected upon reasonable request by the Federal Aviation Administration (FAA) Administrator, an authorized representative of the National Transportation Safety Board (NTSB), or any state or local law enforcement officer.
   5-172 LOST LOGBOOKS OR FLIGHT RECORDS. Inspectors should advise airmen that they may reconstruct lost logbooks or flight records by providing a signed statement of previous flight time.
   A. Proof of Experience. Airmen may use the following items to substantiate flight time and experience:
   • Aircraft logbooks,
   • Receipts for aircraft rentals,
   • Operator records,
   • Copies of airman medical files, and
   • Copies of FAA Form 8710-1, Airman Certificate and/or Rating Application.
   B. Obtaining File Copies. Airmen who have lost their logbooks or flight records may request copies of their files from the FAA by writing to the following:
   FAA Airmen Certification Branch, AFS-760
   P.O. Box 25082
   Oklahoma City, OK 73125
   or
   FAA Aeromedical Certification
   P.O. Box 25082
   Oklahoma City, OK 73125

   Beyond what that section says, each inspector will put their own spin or emphasis on it. That isn’t to say they are operating in conflict with the order. They are just going with how they would like to see the documentation. The one I heard that I liked best was to take whatever documentation you CAN get and put a cover statement on it attesting to the amount of time you have and how you believe you earned it. Then, have your signature notarized. The logic behind adding a notary’s seal to it is that it proves with certainty that the document was signed on that particular day. The reason that can be important to the FAA is kind of long and complicated and it has to do with they can enforce any violation, no matter how old it is, as long as they have only learned of it recently. Having your document date stamped by a notary is proof you didn’t just put together some document and backdate it.

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   KDS on Aug 14, 2017

   P.S. ….. Thanks for your service. I’ve worked with and around you USCG guys and you all did a great job.

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   heloguy on Aug 14, 2017

   Thanks, KDS, but I think you misunderstood where the 85% came from…

   They all went through their logbooks, and totaled the hours that qualified for PIC for each flight. When they finished, they all had about 85% of the hours logged were PIC time. The Navy doesn’t log PIC specifically, but FP time meets that definition. So if they had a 2.0 flight and logged 1.7 FP and 0.3 CP, they counted the 1.7 as PIC.

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   KDS on Aug 14, 2017

   Each service records time differently. The Coast Guard record is OPNAVFORM 3710-31. If the time is recorded in there as first pilot, then that is the time. If you don’t have that form, for one reason or another, you cannot just take 85% of the time. There is no provision for doing that. However, as I wrote earlier, you can certify that you had X amount of time.

   Take a worst case scenario that a friend of mine had. He was a military pilot for another country. He escaped to the US. His former country wasn’t happy about it and they aren’t about to send his military records. All he came out with was the clothes he was wearing. He could make a letter certifying his flight time, and use that as the best available record. You have more records than he does, so your certification is easier.

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   heloguy on Aug 14, 2017

   Thanks again. I guess my question is when I write my letter certifying my time, what should I do to come up with my PIC time? All I know is I had about 120 hours total. Most of that would have been FP time; a small amount, CP time. Without my logbook to see what was specifically logged under each, the best I can do is take a swag at it. I obviously can’t claim all of it as I know that isn’t true, but I don’t want to short change myself either. I know there is no rule, but what would be a reasonable estimation?

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   KDS on Aug 14, 2017

   That gets into the area of each inspector puts their own spin on it. The how to go about it depends on how you will apply for your ATP rating and where. What I’m going to say is just personal advice and not policy. I’m just going by the way I’ve seen things work.

   I’d go to whoever is going to do your check and talk with them well in advance. As them what they need to see? For example, if it is a DPE, then they may want a letter from the FSDO saying you are qualified to take the test. (Incidentally, years ago, you HAD to go to the FSDO to get a statement that you were qualified to take the test.) On the other hand if it is a school, like Flight Safety, they will have their own requirements. If it is to be an inspector, see if one will be preassigned. If so talk to him or her. If not, ask if you could have an inspector look at what you do have and write you a statement that they feel you are qualified.

   I know all of that sounds like overkill, but what you want to avoid is doing a bunch of training and getting all ready for the check and then the examiner says he doesn’t feel comfortable giving you the check and your whole schedule gets messed up, time is wasted, etc.

   All of that just falls under the heading of how to work with people and unfortunately, there is no operating manual for humans. You just have to play it by ear and use your best judgment. But, just generally speaking, it’s better to be over-prepared well in advance.

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