Logging Duel & PIC

[iChris]

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.

 

It’s right there in FAR 61.51. Your CFI was correct, as a rated helicopter pilot, sole manipulator of the controls, and Awareness Training endorsed pilot you should have logged that time in the R44 as PIC.

 

FAR 61.51 [e] Logging pilot-in-command flight time. [1] A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

 

When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

 

“Rated” means holding category, class and type rating if appropriate. Since you already held your PPL [H] you’re within your rights to “Log PIC.”

 

But hold the phone, since we’re talking about an R44 we need to check the Applicability of SFAR 73:

 

SFAR 73 - Applicability. Under the procedures prescribed herein, this SFAR applies to all persons who seek to manipulate the controls or act as pilot in command of a Robinson model R–22 or R–44 helicopter. The requirements stated in this SFAR are in addition to the current requirements of part 61.

 

A reading of the SFAR reveals you don’t have the required Aeronautical Experience to “Act as PIC.” However, you do have the required Awareness Training endorsement as a R22 pilot per paragraph [a][3] of the SFAR to manipulate the controls of the R22/R44:

 

[a] Awareness Training:

 

[1] Except as provided in paragraph [a][2] of this section, no person may manipulate the controls of a Robinson model R–22 or R–44 helicopter after March 27, 1995, for the purpose of flight unless the awareness training specified in paragraph [a][3] of this section is completed and the person's logbook has been endorsed by a certified flight instructor authorized under paragraph [5] of this section.

 

[a][3] Awareness training must be conducted by a certified flight instructor who has been endorsed under paragraph [5] of this section and consists of instruction in the following general subject areas:

 

Energy management;

Mast bumping;

Low rotor RPM (blade stall);

Low G hazards; and

Rotor RPM decay..

 

NOTE: Awareness training is stated as general subject areas not aircraft specific.

 

REF (Logging PIC & Acting as PIC):

 

Legal Interpretations & Chief Counsel's Opinions - 2009/Herman

 

Legal Interpretations & Chief Counsel's Opinions - 2011/Walker

 

Legal Interpretations & Chief Counsel's Opinions - 2009/Speranza

Edited July 23, 2012 by iChris

[eagle5]

It’s right there in FAR 61.51. Your CFI was correct, as a rated helicopter pilot, sole manipulator of the controls, and Awareness Training endorsed pilot you should have logged that time in the R44 as PIC.

 

FAR 61.51 [e] Logging pilot-in-command flight time. [1] A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

 

When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

 

“Rated” means holding category, class and type rating if appropriate. Since you already held your PPL [H] you’re within your rights to “Log PIC.”

 

But hold the phone, since we’re talking about an R44 we need to check the Applicability of SFAR 73:

 

SFAR 73 - Applicability. Under the procedures prescribed herein, this SFAR applies to all persons who seek to manipulate the controls or act as pilot in command of a Robinson model R–22 or R–44 helicopter. The requirements stated in this SFAR are in addition to the current requirements of part 61.

 

A reading of the SFAR reveals you don’t have the required Aeronautical Experience to “Act as PIC.” However, you do have the required Awareness Training endorsement as a R22 pilot per paragraph [a][3] of the SFAR to manipulate the controls of the R22/R44:

 

[a] Awareness Training:

 

[1] Except as provided in paragraph [a][2] of this section, no person may manipulate the controls of a Robinson model R–22 or R–44 helicopter after March 27, 1995, for the purpose of flight unless the awareness training specified in paragraph [a][3] of this section is completed and the person's logbook has been endorsed by a certified flight instructor authorized under paragraph [5] of this section.

 

[a][3] Awareness training must be conducted by a certified flight instructor who has been endorsed under paragraph [5] of this section and consists of instruction in the following general subject areas:

 

Energy management;

Mast bumping;

Low rotor RPM (blade stall);

Low G hazards; and

Rotor RPM decay..

 

NOTE: Awareness training is stated as general subject areas not aircraft specific.

 

REF (Lodding PIC & Acting as PIC):

 

Legal Interpretations & Chief Counsel's Opinions - 2009/Herman

 

Legal Interpretations & Chief Counsel's Opinions - 2011/Walker

 

Legal Interpretations & Chief Counsel's Opinions - 2009/Speranza

 

The biggest confusion with the issue is the ability to log "pilot in command" time without being able to "act" as the "pilot in command". I just doesn't make sense!,...maybe its because I'm a college dropout?

 

The second confusion is the endorsement. I know its not a "type" rating, but it just seems like if you aren't endorsed for a particular helicopter then you're technically not "rated" to fly it! Again, maybe I'm just not smart enough to truley understand?

 

However, it has come to my attention that this R44 SFAR thing is the same as when you fly with a cfi (post PPL). As long as you are the "sole manipulator of the controls" you CAN log it as PIC, even without the endorsement! However I doubt you can fly solo without it, until you have the 200/50hr requirement!?

 

It would really help if the FAA was more clear with this issue of logging PIC vs. acting as PIC!,...but I'm not going to hold my breath!

Edited July 23, 2012 by eagle5

[iChris]

The biggest confusion with the issue is the ability to log "pilot in command" time without being able to "act" as the "pilot in command". I just doesn't make sense!,...maybe its because I'm a college dropout?

 

The second confusion is the endorsement. I know its not a "type" rating, but it just seems like if you aren't endorsed for a particular helicopter then you're technically not "rated" to fly it! Again, maybe I'm just not smart enough to truley understand?

 

 

There is a distinction between logging PIC time and acting as a PIC. For a pilot to log PIC time (i.e., the sole manipulator of the controls), a pilot must be properly rated in the aircraft by having the appropriate category, class, and type ratings. For a pilot to act as a PIC (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a pilot must be properly rated in the aircraft and be properly rated and authorized to conduct the flight.

 

As an example, being properly rated and authorized would include having the

endorsements required. However, the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC.

 

One of the reasons of this type wording (Acting vs. Logging) is to allow new pilots to gain needed flight experience while flying with more experience pilot and at the same time build PIC time.

 

Read over the above Legal Interpretations a few times.

Edited July 23, 2012 by iChris

[Helipilot PTK]

like always IChris, thank you for clearing this up for everyone. The legal interpretations were a very informative read also.

[cbl2799]

Hey guys, as a civil and military pilot, here is my take:

 

1. If you are appropriately rated (in this case, rotorcraft helicopter), by all means, log the time as PIC.

 

2. If you are actively receiving instruction, log it as dual time as well, and have the instructor pilot either sign the log entry, or annotate his name accordingly.

 

Make sense?

 

-Brian