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Logging Duel & PIC


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Where in the FAR/AIM does it talk about this? I have looked under 61.51 with no luck. Am I missing something.

 

I received my PPL(H) in the R-22 helicopter in December of last year. I regularly go on commercial flights with my CFI, ferrying a R-44 helicopter to the operation and back free of charge. He told me to log the time as Duel & PIC since I was a rated helicopter pilot, and was the sole manipulator of the controls. I am positive he is right, I simply want to know where the regs state this.

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If you're the "sole manipulator of the controls" as a rated pilot you don't have to log it as dual.

 

I suspect he wants you to log it as dual so that he can also log the time as your instructor. This is how the boatpix thing works. However, since you're not paying for those ferry flights it may be hard for him to justify it as instruction given?

 

You should only log dual time if you are recieving instruction! When asked how can I log both pic and dual, claiming that I am the sole manipulator the entire "training" flight? My cfi responded that although he never touched the controls, I am still recieving "verbal" instruction.

 

Where is this in the regs,...I can't find it either!

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If you're the "sole manipulator of the controls" as a rated pilot you don't have to log it as dual.

 

I suspect he wants you to log it as dual so that he can also log the time as your instructor. This is how the boatpix thing works. However, since you're not paying for those ferry flights it may be hard for him to justify it as instruction given?

 

You should only log dual time if you are recieving instruction! When asked how can I log both pic and dual, claiming that I am the sole manipulator the entire "training" flight? My cfi responded that although he never touched the controls, I am still recieving "verbal" instruction.

 

Where is this in the regs,...I can't find it either!

 

I was not checked out in the R-44 at this time, so I was unable to log it purely as PIC. Now that I have been endorsed I log it all as PIC.

 

61.51 seems to cover it somewhat, just not as straight forward as I would expect. Then again can you ever expect the FARs to be clear?

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Kind of on the same topic I have been scouring 61.51 regarding logging PIC as a safety pilot for simulated instrument flights. This happened to be in an airplane (which I am rated in) but never the less would still pertain to helicopters. So some people say that a safety pilot is a required crew member during a simulated instrument flight and can therefor log the time the other pilot is under the hood as PIC. Others say that this wouldnt be PIC and that it would be SIC. I think PIC makes the most sense to me since 91.3 states that the PIC is Directly responsible for and is the final authority as to the operation of the aircraft. Which while acting as a safety pilot you are. Any thoughts?

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Actually those first 5hrs in the 44 cannot even be logged as dual pic, they can only be "purely" dual!

 

If this is true, I have a new question. I had 14.9 (ok 15 Nearly Retired) hours before I was endorsed in the R-44 helicopter, most of it was doing commercial ferrying etc. Does this mean I cannot log any of that as PIC? Mikemv would you mind chiming in on this.

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If this is true, I have a new question. I had 14.9 (ok 15 Nearly Retired) hours before I was endorsed in the R-44 helicopter, most of it was doing commercial ferrying etc. Does this mean I cannot log any of that as PIC? Mikemv would you mind chiming in on this.

 

If you look at SFAR 73 you'll find that in order to act as pic in the 44 (presuming you already have enough time in the 22, (which you do)), you need 5hrs dual AND an endorsement! Therefore if you got that endorsement after 14.9hrs, then no, those 14.9hrs are not pic!

 

For technical advice like this, iChris is usually the expert!

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If this is true, I have a new question. I had 14.9 (ok 15 Nearly Retired) hours before I was endorsed in the R-44 helicopter, most of it was doing commercial ferrying etc. Does this mean I cannot log any of that as PIC? Mikemv would you mind chiming in on this.

 

As mentioned in a different thread, this bit me in the ass once too, and now I have 25hrs in the R44 that are non-PIC!

 

Look at SFAR 73, 2 b (2)(ii),...which sucks balls!

Edited by eagle5
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I was not checked out in the R-44 at this time, so I was unable to log it purely as PIC. Now that I have been endorsed I log it all as PIC.

 

61.51 seems to cover it somewhat, just not as straight forward as I would expect. Then again can you ever expect the FARs to be clear?

 

 

Remember logging PIC and "acting as PIC" are two different things when with an Instructor. Once you are endorsed to "act as PIC on the R44 then you can "act as PIC" without an instructor aboard, because you are the Final Authority. With your instructor aboard you are not the final authority/the one "acting as PIC". So why not log R44 time if you have a private license or higher and its a dual flight, why wouldn't it be logged as PIC- SFARs only talk about "ACTING AS PIC".

Edited by HeliFun
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Remember logging PIC and "acting as PIC" are two different things when with an Instructor. Once you are endorsed to "act as PIC on the R44 then you can "act as PIC" without an instructor aboard, because you are the Final Authority. With your instructor aboard you are not the final authority/the one "acting as PIC". So why not log R44 time if you have a private license or higher and its a dual flight, why wouldn't it be logged as PIC- SFARs only talk about "ACTING AS PIC".

 

This is exactly what I was thinking of, do you know where the regs state this? I am going to talk with my instructor in a few days about this.

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This is exactly what I thought, do you know where the regs state this? I am going to talk with my instructor in a few days about this.

 

I don't know of any regulation that read specifically what your trying for but take another approach with me here. Thinking about logging PIC vs Acting as PIC with a safety pilot aboard an aircraft. I'll copy and paste the link reference and the text from the page of a Q&A Rod Machado. Then go read the words carefully in the SFAR 73 and you should read "act as pilot in command"

 

SFAR 73 Link

http://ecfr.gpoacces...0.1.1.2.0.1.1.7

 

QUESTION # 1

Dear Mr. Machado:

Could you help clear up the confusion regarding the logging of PIC by a pilot acting as a safety pilot? Several of our local flight instructors are having a difficult time making heads or tails out of the regulations about logging time.

Thanks,

ANSWER #1

Greetings Jim:

There are only three conditions in which a private or commercial pilot can log PIC time.

You may log pilot-in-command flight time when:

1. You are the sole manipulator of the controls of an aircraft for which you are rated (if you are flying a Cessna 172 and you have an airplane, single engine land rating, then you can log this time as PIC. Of course, some folks want to know if this still applies when the airplane is being flown by the autopilot. The answer to this question is: Don't ask that question and don't brag about using the autopilot, either. Just log the time as PIC and be happy.);[/font]

2. You are the sole occupant of the aircraft (if you are the only one in the airplane then there's a very good chance that you're the only one flying it, so log the time as PIC. How do you log this if you have a split personality? I suppose you'll need to get a twin rating);[/font]

3.You are acting as pilot in command on an aircraft on which more than one pilot is required under the type certification or the regulations under which the flight is conducted (this one needs a bit of explanation)

To understand item #3 you must understand the difference between logging PIC and acting as the PIC. Keep in mind that FAR 91.109(b)1 wisely requires that a safety pilot be on board if the person flying is operating under simulated instrument conditions. Yes, I think this is a good rule, too:). The regulations also require that one person on board the aircraft always act as PIC. This will be the person who is legally responsible for the operation of that aircraft. The person acting as the pilot in command can obviously log this time as PIC. On the other hand, the regulations also allow an additional person to log PIC if that person does something that generates experience of sufficient value. Here's an example.

Suppose you and a friend both have private pilot certificates with airplane, single-engine-land ratings. Let's also say that each of you is legally qualified to act as the legal PIC (meaning that you are both current, have current medicals, etc., etc.). Both of you hop into a Cessna 172 for a flight. Your friend wears a view-limiting device and is the sole manipulator of the flight controls while you act as the safety pilot.

In this instance, if your friend elects to act as the legal PIC as well as be the sole manipulator of the flight controls, then he alone logs the flight time as PIC while you log the time as second in command (SIC). [This is also the example where, if the airplane is either complex or high performance, and if you don't have a complex or high performance endorsement, then you can still act as safety pilot and log it as SIC since you're not acting as (the legal) PIC.]

On the other hand, you may elect to act as the safety pilot as well as the legal PIC while your friend is the sole manipulator of the controls. If so, then you can log the time as PIC and your friend can also log the time as PIC. Do you see why this is? Being the safety pilot doesn't mean you can automatically log the time as PIC. You must be willing to act as the legal PIC (as well as the safety pilot) to log this time as PIC. Since your friend is the sole manipulator of the controls, he gets to log PIC time as well. If anything goes wrong in this scenario, you're the one whose ticket will be on the line.

Here's another commonly asked question regarding the information above. Suppose you and the same friend go flying in that same Cessna 172 and no one wears a view-limiting device. Is there any situation where both of you log the time as PIC?

Sorry, but there's absolutely no way this can happen.

Yes, I realize that some folks suggest it's possible for both pilots to simultaneously log all the flight time as PIC here but the FAA doesn't seem to think so (and they are the folks who count in this instance). The only condition where these two pilots can log PIC is when one pilot is operating under simulated conditions as stated above. Under this condition the regulations require that two pilots be on board the airplane. There's no type certificate (or any condition, for that matter) that requires that two private or commercial pilots be on board a Cessna 172. When two private or commercial pilots are on board an aircraft and neither wears a view limiting device, only one pilot can log PIC at a time. This will be the pilot who is the sole manipulator of the flight controls.

 

http://www.rodmachad...flight_time.php

 

Unfortunately the regulations are not clear and come out and spell things out for us. You have to pay attention to detail of word use and some enlightening from some web searches regarding acting and logging PIC led me to this conclusion that I was accurate to log R22 or R44 time after which I had obtained my ratings. I took the robinson safety factory course as a 200 hour pilot with 3 hours in the R22 several years ago and after talking with the instructor I flew with there I started logging PIC and went back and made the adjustment to my log book. I still have no endorsement to take any of the robinson aircraft solo since I can't still "Act as PIC" but I can still log PIC with an Instructor that is Legal to Act as PIC- now 2000 hours later is the little beast another animal sure but I shouldn't have to not log it as PIC. Something to research would be also look into our airplane counterparts that can't act or log? not sure what the regs say when they don't have 5 hours or something like that in a high performance aircraft? One of our hybrid pilots might be able to enlighten us on that. Please if I am mistaken and leading anyone astray please share with us your resources and justification.

 

(on the web article it appears the same with complex/high performance airplanes)

Edited by HeliFun
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Let me explain a different fixed wing scenario and see if it also mirrors your situation. I think it does, and if that's the case, you log it as PIC.

 

As one mentioned above, don't muddle the waters between logging PIC and acting PIC, two completely diffferent things.

 

I was a rated private pilot at the time in fixed wing, Private-Single Engine Land. In order to ACT as PIC in a tailwheel aircraft, I must receive and log flight instruction in a tailwheel, blah blah blah. That was in order to ACT as PIC. To log PIC....you may log PIC any time you are the sole manipulator of the controls of an aircraft you are rated for. [61.51(e)(1)(i)] "Rated" means the category and class (which I was rated for Category-Airplane, Class-Single Engine Land) that is listed on the back of your pilot certificate. Nothing else matters. Not instrument ratings. Not endorsements for high performance, complex, or tailwheel aircraft. Not medical currency. Not flight reviews. Not night currency. I was fully legal to log PIC in a tailwheel aircraft because I was rated for Airplane-Single Engine Land, which it was.

 

if you are at least hold a Private-Rotorcraft Helicopter, you are rated for the aircraft, in which you can log PIC. You may not ACT as PIC without the SFAR 73 endorsement. In this situation, you're logging PIC, but you aren't acting PIC.

 

Take a look at this website. It goes a little more in depth between logging and acting. It was wrote with fixed wing in mind, but the category/class stuff applies to this discussion.

http://www.midlifefl...faq/faq.php?s=1

Edited by air_1
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This is exactly what I was thinking of, do you know where the regs state this? I am going to talk with my instructor in a few days about this.

 

I don't know how anyone could log PIC time if the regs state that they cannot act as the PIC? Since the regs require "dual instruction" the cfi is not a "safety pilot", he's your instructor, instructing you!

 

This question is probably best answered by someone at Robinson. I'll write it down for the next time I'm there!

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Unfortunately the regulations are not clear and come out and spell things out for us. You have to pay attention to detail of word use and some enlightening from some web searches regarding acting and logging PIC led me to this conclusion that I was accurate to log R22 or R44 time after which I had obtained my ratings. I took the robinson safety factory course as a 200 hour pilot with 3 hours in the R22 several years ago and after talking with the instructor I flew with there I started logging PIC and went back and made the adjustment to my log book. I still have no endorsement to take any of the robinson aircraft solo since I can't still "Act as PIC" but I can still log PIC with an Instructor that is Legal to Act as PIC- now 2000 hours later is the little beast another animal sure but I shouldn't have to not log it as PIC. Something to research would be also look into our airplane counterparts that can't act or log? not sure what the regs say when they don't have 5 hours or something like that in a high performance aircraft? One of our hybrid pilots might be able to enlighten us on that. Please if I am mistaken and leading anyone astray please share with us your resources and justification.

 

When I was at Robinson I had about 50hrs in the R44, but no endorsement. I remember specifically Tim saying that you need the endorsement, no matter how many hours you have (there was a guy there with 500hrs in one without it) so I got the endorsement.

 

Without the endorsement you can still log PIC time in an R44 once you have 200hrs total in helicopters 25hrs R44 (provided you have 25 in the R22, otherwise its 50hrs R44). At the time I started flying the R44 I had 200hrs all in the R22, which is why only my first 25hrs in the R44 are not PIC.

 

I would love to be wrong, but its probably going to have to be someone from Robinson, or the FAA telling me I am!

Edited by eagle5
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Wow! Now we're getting an whole new shade of grey. Acting vs Sole manipulator? It's up for interpretation but weren't you a sole manipulator during your private training for at least part of that dual?

 

As far as the safety pilot thing, I've heard both ways but I've always gone with the safety pilot is sic. Mainly because it gets a slight mention in part 61.55 which describes the sic requirements. The slight mention is 61.55(7)(f)(4). It's a slight mention and you have to read most of the req to get the whole context. It's also up for interpretation.

 

My interpretation: A safety pilot is the sic and you need the hours and pic endorsement per sfar 73 to either act or be pic.

 

A solution to you folks who forgot to get your endorsement. Are you still in touch with those instructors who flew the 1st 5 hours in the 44? If they're comfortable and you did the required training manouvers prior to the 5th hour, you can always ask if they'll pre-date your endoresment in your logbook. If the instructor or you are not comfortable then it is what it is.

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2 more things:

 

1) HeliFun: with over 200 hrs r/w you're ok without an endorsement once you have 50 hours of Robbie products.

 

2) Just having interpretation fun. Isn't being the sole manipulator of the controls (flying the aircraft) part of "acting as pic?"

 

I was "sole manipulator of the controls" many times during my ppl training while the cfi was sitting next to me, but I don't think I can log any of it as pic (aside from my 10hrs of solo).

 

As for your safety pilot interpretation, there's nothing in SFAR 73 about safety pilots or sic. It states "dual instruction"! Safety pilots and second in comands do not "teach"!

 

...and as for calling that cfi who forgot to give me the endorsement. I'd say asking him to "pre-date" an endorsement for me sounds a bit dishonest, (since those hours have already been flown without the endorsement) and there's already another thread dedicated to that stuff.

Edited by eagle5
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I was "sole manipulator of the controls" many times during my ppl training while the cfi was sitting next to me, but I don't think I can log any of it as pic (aside from my 10hrs of solo).

 

 

Why not? Personally I would apply the same logic to being the sole manipulator of a robbie without the hours and pic endorsement as one would to being the sole manipulator of the aircraft during dual training for a ppl.

 

 

As for your safety pilot interpretation, there's nothing in SFAR 73 about safety pilots or sic. It states "dual instruction"! Safety pilots and second in comands do not "teach"!

 

My reference to safety pilot was for Helifun's referance to Rod Machado stating a saftey pilot and a pilot with foggles could both log pic of an aircraft provided they were both rated/current/etc in that aircraft. I wasn't refering to the sfar73 regarding safety pilot. On that note though, to be the safety pilot for somone with foggles in a Robbie, one would need the pic endorsement and be current in the Robbie per the sfar and 61.

 

 

...and as for calling that cfi who forgot to give me the endorsement. I'd say asking him to "pre-date" an endorsement for me sounds a bit dishonest, (since those hours have already been flown without the endorsement) and there's already another thread dedicated to that stuff.

 

I don't think it would be dishonest if you did the required training during the 1st 5 hours. The sfar lists the 5 thing that need to be taught in the aircraft in order to get the endorsement. If it was to long ago to remember whether you did or not then it's probebly not a good idea to predate.

 

Sorry for any spelling errors. I'm on the iphone.

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"I was "sole manipulator of the controls" many times during my ppl training while the cfi was sitting next to me, but I don't think I can log any of it as pic (aside from my 10hrs of solo)."

 

 

"Why not? Personally I would apply the same logic to being the sole manipulator of a robbie without the hours and pic endorsement as one would to being the sole manipulator of the aircraft during dual training for a ppl."

 

 

I've been under the impression that I can only log pic time in an aircraft for which I am rated. During ppl training I was not yet rated, so I would not log any of that time as pic (other than the solo time for which I was endorsed) even if I was the "sole manipulator of the controls"!

 

So, in my case, I am applying the same logic, and thus not logging it as pic!

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