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8 Answers

Logging PIC time as MEI

Asked by: 2590 views Flight Instructor

Is it defendable to log PIC time and dual given as a MEI (Right seat) on a multi-engine aircraft, when the logbook of the left seat pilot (logging PIC as well) was not endorsed or signed for dual flight given by the MEI?

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8 Answers

  1. Wes Beard on Jan 08, 2013

    Reference 61.189. If u don’t sign the logbook then you haven’t given instruction you can include in your logbook… in my opinion.

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  2. Anonymous on Jan 08, 2013

    Thanks for the confirmation, I do share the same opinion.
    In a case where the FAA or an employer would look at both loogbooks, this case will not be defendable.

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  3. Sam Dawson on Jan 08, 2013

    There are several NTSB cases where this resulted in “issues”. In one case a CFI refused to sign a logbook even after being told to do so by the FSDO. CFI had her certificate suspended.
    In the second case two CFIs were flying together and both logging PIC time, one as student the per as CFI. FAA said great, show us the required signatures. They could not do so and their certificates were revoked. Some have interpreted this as stating that two CFIs can’t log PIC, but that was not the intent of the FAA. The NTSB judge pretty much said if they show SOME kind of record they would have been good.

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  4. Nathan Parker on Jan 08, 2013

    14 CFR 61.189 merely says that you have to sign the logbook of someone you instruct. Failure to do so means that you’ve violated 61.189; it doesn’t mean that you haven’t instructed them. It’s mere speculation that you can’t log the time. I can’t think of any regulations that kick in when you’re violating other regulations.

    The case cited by Sam doesn’t really apply, IMO. In that situation, there was some suggestion of fraud going on, with two instructors teaching each other. It smelled, and I know that it goes on all the time in a ME.

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  5. Sam Dawson on Jan 08, 2013

    Yes, there was obviously fraud going on but the judge indicated that one of things things that sealed their fate was:
    “Under FAR § 61.189(a), a certified flight instructor must
    sign the logbook of the person who received instruction and must
    include the date and amount of time of instruction. Section
    61.51(b) requires that, for each flight or lesson logged, the
    pilot must include “[f]light instruction received from an
    authorized flight instructor” and “[i]nstrument flight
    instruction from an authorized flight instructor.”

    This was not done.

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  6. Nathan Parker on Jan 09, 2013

    “This was not done”

    As everyone agrees, but the judges were using the lack of signatures to conclude that instruction wasn’t occurring (which it probably wasn’t). Take a different context: you have a private student that just completed a checkride and went back to college; you realize you forgot to sign the last few training flights. Can you log the time? It would be crazy not to, since there is no regulatory requirement that you sign his logbook in order for YOU to log the time. No one viewing the logbook would reasonably conclude that instruction wasn’t occurring.

    I guarantee it: every one of us has student logbooks out there without our sigs on some flights, yet we still logged the time. Do you really think the FAA was hunting down these instructors for that?

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  7. Mark Kolber on Jan 09, 2013

    >>I guarantee it: every one of us has student logbooks out there without our sigs on some flights,

    I don’t; at least not on flights where I logged it as giving instruction. But I appreciate your point about the difference in the regs, agree with you on the limitations in the language of those two cases if read tightly, and have, in the past, agreed with your overall take.

    What ultimately led me to a different conclusion was that we have three regs involved. One requires an instructor to endorse instruction. Another requires instruction be endorsed in order for it to be counted toward instructional requirements. A third permits a CFI giving instruction to log the time as PIC.

    If asked, would the FAA say that the three need to be read together? That in order for a CFI to get the special benefit of building PIC time through giving instruction, he or she has to at least make it documented, countable instruction by taking the tiny step of endorsing it in a student’s records?

    My FAA crystal ball (which is hardly foolproof) says the answer to that would be yes.

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  8. Lucas on Jan 12, 2013

    Well there is one way around it all.
    People who are building multi time will eventually go for an ATP certificate. So as long as you are providing instruction to the other pilot towards his ATP rating it would justify the dual given and although the instructor would have to sign the applicants logbook for the dual given, this would not be seen as a negative by eventual employers nor would it be something that the FAA could criticize or find illegal.


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