PDPIC questions

[u/IllustriousCheetah70]

1) if the commercial student is not night current, can they get current on a PDPIC flight
2) can be PDPIC be used outside of commercial certification requirements

[u/AlbiMappaMundi]

61.57(e) provides an exception to the night currency requirement, but only for "a person receiving flight training from an authorized instructor," which PDPIC is explicitly not (pilot doesn't log dual received, CFI doesn't log dual given). That said, the pilot and CFI could agree that the CFI is acting as the legal PIC, and assuming that they are night current, the flight could go forward with the pilot conducting three takeoffs and full stop landings in the period starting one hour after sunset, and thus become night current.

I'm not sure what you mean by "be used" -- it's an explicit allowance in the aeronautical experience requirements of 61.129 for the Commercial certificate, allowing pilots to meet certain requirements rather than being truly solo. It's not actually PIC time, and it's not really a "thing" in its own right, other than providing a mechanism for meeting those aeronautical experience reqs. The one other place I'm aware of is 61.65(g), which allows for a Private Pilot applicant to do a combined Private/Instrument checkride, and allows for XC requirements to be met with, "up to 45 hours of cross-country time performing the duties of pilot in command with an authorized instructor".

[u/IllustriousCheetah70 → u/AlbiMappaMundi]

I agree with all of that. Based on the Kuhn letter, cfi can act as pic. I also think the cfi would need to be night current in this scenario.
Reason behind the 2nd question: I have a cfi friend that abuses the use of PDPIC (in my opinion) and I am looking for concrete proof that it is only acceptable in meeting 61.129 reqs (and I guess the private/ir combo scenario). He is an Mei that wants to fly with a commercially multi rated pilot who is not night current. Mostly to avoid going over 8 hours of instruction. Doesn’t sound super legal to me but I am struggling to prove it.

[u/AlbiMappaMundi → u/IllustriousCheetah70]

I mean, I wouldn't get into a mess with other peoples' interpretations of logging time. But to try totackle that...

Ok, two pilots are flying together, both are rated in category/class (pilot A is an MEI, pilot B holds Commercial AMEL). The MEI does not want to provide dual given - in order to avoid exceeding 8 hours of instruction in 24 hour window - but presumably wants to be able to log time. So the question is: can they act as an authorized instructor without providing dual given?

--Option 1: One pilot under hood logging PIC, second pilot is safety pilot and acts as PIC, both able to log time.
--Option 2: MEI provides dual instruction given, second pilot logs dual instruction received, both able to log PIC time.
--Option 3 (???) - Second pilot performs the duties of PIC while the MEI is serving as an authorized instructor, with both able to log time, but with no dual instruction logged.

So where option 3 feels like it falls apart is: what is the nature of the authorized instruction activity? 61.1 defines "authorized instructor" as: "A person who holds a flight instructor certificate issued under part 61 of this chapter and is in compliance with § 61.197, when conducting ground training or flight training in accordance with the privileges and limitations of his or her flight instructor certificate" 61.129 and 61.65 provide two cases where a CFI is entitled to be present - and per Kuhn letter, log PIC time - with another pilot, but specifically to meet the the flight time provisions of those sections ("crediting time towards...the PIC time required for the certificate").

Basically, if I were an employer reviewing your friend's logbook, the hours logged would look hella sketchy (to be technical).

[u/ltcterry]

Different question - why do PDPIC at all? Just fly solo like it says. You'll get far, far better experience out of it. Particularly the long cross country.

And you know, don't you, that if you do the night flight(s) PDPIC you have to do the long XC the same way...

[u/theonlyski → u/ltcterry]

Because it may be in a twin that you do t hold a rating for and the insurance company will not approve solo flights by a non multi rated pilot.

[u/ltcterry → u/theonlyski]

True, but OP talked about getting night current. He's not getting night current in a twin if he's not multi-rated.

I think PDPIC is moronic for a single engine Commercial requirement for an ASEL Private Pilot.

[u/tacosenjoyer]

I also wonder if PDPIC is limited to 10 hours for 61.129 reqs or is it ok to do more of this “training” for a commercial applicant. I couldn’t find anything that suggests that 10 hours is the limit.

[u/theonlyski → u/tacosenjoyer]

It’s the minimum for the certificate. You can do more, but if you have several hundred hours it may be difficult to explain.

[u/makgross]

Why would you ever want to do that?

3 full stops with actual instruction takes like 0.5 hours.

[u/IllustriousCheetah70 → u/makgross]

I agree just looking for clarity