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Logging PIC if not type rated?


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OK, here's the question I've been asked...

 

If you fly as SIC in a heavy that requires two crew, is there a way to log any flight time as PIC when you are flying? For example, the command pilot is an ATP, CFI, or a Check Airmen for the company etc...

 

I have not been able to find the answer.

 

Thanks for all the replies in advance.

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OK, here's the question I've been asked...

 

If you fly as SIC in a heavy that requires two crew, is there a way to log any flight time as PIC when you are flying? For example, the command pilot is an ATP, CFI, or a Check Airmen for the company etc...

 

I have not been able to find the answer.

 

Thanks for all the replies in advance.

Nope you can't log PIC in a heavy without a type rating. You can log all the SIC time you want. It should be in 61.55 ish.

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I have already read that section and it only pertains to receiving the SIC endorsement. It does not specify about logging PIC. I know anything less than 12,500lbs I can log PIC, anything over that you need to be typed for that aircraft. 61.51(f) also refers to SIC only not PIC. Thanks though.

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If you are not rated on it, how can you be "in command"?? Nobody could believe your logbook to see that all your training is in R22 but you have 20 hrs command of a CH53.

 

With an instructor, it could be logged as Dual, but you are just playing with yourself by wanting to call it PIC.

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After further research, I believe I found what I was looking for in Part 61.51(e)(1)(i-iv)©(1)(2)(4)(i). If I understood it correctly this is what I got out of it. An ATP or a CFI that is typed for that aircraft and is authorized to act as PIC in that aircraft and is supervising the SIC pilot while performing the duties of PIC, then the SIC pilot may log the flight time as PIC in an aircraft requiring more than one pilot flight crew-member. Thanks again Helipilotm.

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I totally agree Eric. I however did not see anything in that reg that stated it should be logged as dual. If you are the sole manipulator of the controls and under supervision of the ATP, or CFI then you may log it as PIC.

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Actually, you need to read a little more. You must be undergoing an approved PIC training program. This rule, as I was told, was put into place for the airlines. If your company has an approved training program and puts you into it, then you can log it. It is usually only the difference of 20 hours or so so that you can meet the minimum PIC requirements of part 121 or 135. If your job is SIC, then no, you can't log it as PIC.

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Here is the full text of the rule ... You must comply with A, B, C, and D:

 

(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided

 

(A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

 

(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation

 

( 1 ) Preflight preparation;

 

( 2 ) Preflight procedures;

 

( 3 ) Takeoff and departure;

 

( 4 ) In-flight maneuvers;

 

( 5 ) Instrument procedures;

 

( 6 ) Landings and approaches to landings;

 

( 7 ) Normal and abnormal procedures;

 

( 8 ) Emergency procedures; and

 

( 9 ) Postflight procedures;

 

( C ) The supervising pilot in command holds

 

( 1 ) A commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or

 

( 2 ) An airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and

 

(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook and attests to that certification with his or her signature, and flight instructor certificate number.

Edited by HeliUtah
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Actually, you need to read a little more. You must be undergoing an approved PIC training program. This rule, as I was told, was put into place for the airlines. If your company has an approved training program and puts you into it, then you can log it.

 

Yes sir, that's all correct.

 

The only way currently (new rule Oct/2009) for a SIC to log PIC time without a type rating is under 61.51[e][1][iv], which requires an approved training program be setup and the supervising pilot hold a flight instructors certificate or ATP. That's something your company should setup with your FSDO. 

The FAA made clarification in their Final Rules Notice, effective April 4, 1997. This made clear that the SIC needs a type rating in the aircraft to log PIC time. However, the FAA did state in the notice that those SIC pilots who logged PIC without a type rating did not have to revisit past loggings. In effect a type of grandfathering.

 

From the Federal Register/ vol. 62 No. 65 / April 4, 1997 pg. 16249 - 16251

“The FAA has determined that clarity is necessary to preserve the value of pilot-in-command time. In light of the inconsistent policy opinions issued by the FAA, however, this clarification is meant to be prospective and not to require pilots to “revisit” past logging. The FAA’s position regarding the proper logging of pilot-in-command time for a recreational, private, or commercial pilot applicable after the effective date of this final rule is set forth in this response”

 

Legal Interpretations & Chief Counsel's Opinions

 

See line #26: 61.51(e)(1)(iv) Background.pdf

Edited by iChris
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This rule, as I was told, was put into place for the airlines.

 

 

Initially petitioned for by Saudi Aramco. Saudi Aramco wanted permission to allow new hires' training in their Bell 214 helicopter to eventually become PICs in the company and allow logging PIC flight time while under the supervision of more experienced and senior PICs.

 

REF:

See line #26: 61.51(e)(1)(iv) Background.pdf

Edited by iChris
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HeliUtah, I did read the full text of Part 61.51 (e), that's how I got my information that I posted earlier. I also understood you need an approved training course. I was just simply asking if you could log PIC without being typed and the short answer is YES, but with stipulations! Thanks for post it though. I appreciate your help.

 

iChris, I was hoping you would chime in with your knowledge as you usually have very good refs and details. Again thanks to all that have replied. This is why I like this forum. I have already relayed the information to those that have been asking me and I have directed them to part 61.51(e)

 

Thanks again

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HeliUtah, I did read the full text of Part 61.51 (e), that's how I got my information that I posted earlier. I also understood you need an approved training course. I was just simply asking if you could log PIC without being typed and the short answer is YES, but with stipulations! Thanks for post it though. I appreciate your help.

 

iChris, I was hoping you would chime in with your knowledge as you usually have very good refs and details. Again thanks to all that have replied. This is why I like this forum. I have already relayed the information to those that have been asking me and I have directed them to part 61.51(e)

 

Thanks again

In this case I'm a glass half empty guy. The short answer is no. The long answer is there is one tiny exception.

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  • 6 months later...

Ok, I know this post is a few months old, but I'm hoping someone can help. I think I know the answer to this, however I need confirmation.

 

I am a former Navy Aviator, who was fully qualified as a HAC (Helicopter Aircraft Commander) which is the Navy equivalent of a Captain. I was qualified in both the Boeing V-107 (H-46 Sea Knight), and the Sikorsky 61 (H-3 Sea King). Of the two helicopters, I flew the H-3 last in the service. I then got out of the service, and took a contract job with a company Helicopter Transport Services, flying the S-61. I never got a type rating from the FAA, but given I was fully qualified, (and I have paperwork to prove it) can I log PIC time while the sole manipulator? My gut says no, but of course, I'm hoping for a yes.

 

Thank you for any and all replies, I'm just trying to figure out if I need to correct my log book as I'm looking to apply for a few pilot positions.

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Ok, I know this post is a few months old, but I'm hoping someone can help. I think I know the answer to this, however I need confirmation.

 

I am a former Navy Aviator, who was fully qualified as a HAC (Helicopter Aircraft Commander) which is the Navy equivalent of a Captain. I was qualified in both the Boeing V-107 (H-46 Sea Knight), and the Sikorsky 61 (H-3 Sea King). Of the two helicopters, I flew the H-3 last in the service. I then got out of the service, and took a contract job with a company Helicopter Transport Services, flying the S-61. I never got a type rating from the FAA, but given I was fully qualified, (and I have paperwork to prove it) can I log PIC time while the sole manipulator? My gut says no, but of course, I'm hoping for a yes.

 

Thank you for any and all replies, I'm just trying to figure out if I need to correct my log book as I'm looking to apply for a few pilot positions.

Without looking, A military PIC designation suffices for a type rating for the purposes of logging PIC on that aircraft.

 

I think I found what applies to your question...

 

 

§61.73 Military pilots or former military pilots: Special rules.

(a) General. Except for a person who has been removed from flying status for lack of proficiency or because of a disciplinary action involving aircraft operations, a U.S. military pilot or former military pilot who meets the requirements of this section may apply, on the basis of his or her military pilot qualifications, for:

(1) A commercial pilot certificate with the appropriate aircraft category and class rating.

(2) An instrument rating with the appropriate aircraft rating.

(3) A type rating.

 

I don't know if you have to apply for the type rating, but for the purposes of an aircraft requiring a type rating, that a military pilot is PIC qualified in, then yes you may log PIC.

 

 

edit our

 

Edited by aeroscout
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Considering nothing in the military carries over directly, I would say you need to apply for it and get the FAA equivalent type rating. Here's why...

 

61.31 says you need the type rating/endorsement to act as PIC.

61.73(e) says you can apply for the type rating

61.51 says you can log PIC if "sole manipulator of the controls for which the pilot is rated"

 

That pesky little word "rated" is the one that bites you. While you might be "rated" as per the military, in the FAA's eyes, you aren't, since you don't have the 61.31 type rating endorsement.

 

It's also important to know that 61.73 doesn't give you authorization to act or log anything. It only tells you what you can apply for with the training and hours you have received, as well as how to go about it and what documentation you need.

 

Thinking about it, though, if you get hired by someone to fly that aircraft, they're going to put you through their training anyways. Why not just have them give you the type rating while they are at it? It's nothing more than an endorsement anyways.

 

 

Also, feel free to correct me if I'm wrong with any of this. It's late. I'm tired. And let's face it... It's the FAR's we're talking about here. They can get confusing...

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Thank you both for responding, I was afraid I wouldn't be able to log PIC and it looks like I cannot, simply because I didn't get the FAA endorsement. However, I'm wondering since he was a CFI that changes anything? Although if I dig in my mind I believe he would have had to sign my logbook each flight...does that sound right?

 

I only flew with them a few months, before I became a foreman in a factory. The job was a contract job and the company went under, so getting the signature now is going to prove futile.

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Thank you both for responding, I was afraid I wouldn't be able to log PIC and it looks like I cannot, simply because I didn't get the FAA endorsement. However, I'm wondering since he was a CFI that changes anything? Although if I dig in my mind I believe he would have had to sign my logbook each flight...does that sound right?

 

I only flew with them a few months, before I became a foreman in a factory. The job was a contract job and the company went under, so getting the signature now is going to prove futile.

 

He would have had to sign your logbook for the training flight(s) leading up to getting the type rating, yes.

 

It would be worth it to call/visit your FSDO and bring in the proof that you have the training and military documents that back up the type rating, if you still want. It couldn't hurt anything. The worst they could do is say "no, I won't give you the type rating." That just leaves you right where you already are, though.

 

 

Sorry to hear about the job. Like they say though... when one door closes, another one opens.

Edited by ridethisbike
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Ok, I know this post is a few months old, but I'm hoping someone can help. I think I know the answer to this, however I need confirmation.

 

I am a former Navy Aviator, who was fully qualified as a HAC (Helicopter Aircraft Commander) which is the Navy equivalent of a Captain. I was qualified in both the Boeing V-107 (H-46 Sea Knight), and the Sikorsky 61 (H-3 Sea King). Of the two helicopters, I flew the H-3 last in the service. I then got out of the service, and took a contract job with a company Helicopter Transport Services, flying the S-61. I never got a type rating from the FAA, but given I was fully qualified, (and I have paperwork to prove it) can I log PIC time while the sole manipulator? My gut says no, but of course, I'm hoping for a yes.

 

Thank you for any and all replies, I'm just trying to figure out if I need to correct my log book as I'm looking to apply for a few pilot positions.

 

I asked a similar question to a DPE once about logging PIC in the R44 without having the PIC endorsement. I was told as long as I was "sole manipulator" I could log it as PIC, even though the instructor was the one "acting" as PIC.

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I asked a similar question to a DPE once about logging PIC in the R44 without having the PIC endorsement. I was told as long as I was "sole manipulator" I could log it as PIC, even though the instructor was the one "acting" as PIC.

 

That's different. That isn't a type rating.

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Ok, I know this post is a few months old, but I'm hoping someone can help. I think I know the answer to this, however I need confirmation.

 

I am a former Navy Aviator, who was fully qualified as a HAC (Helicopter Aircraft Commander) which is the Navy equivalent of a Captain. I was qualified in both the Boeing V-107 (H-46 Sea Knight), and the Sikorsky 61 (H-3 Sea King). Of the two helicopters, I flew the H-3 last in the service. I then got out of the service, and took a contract job with a company Helicopter Transport Services, flying the S-61. I never got a type rating from the FAA, but given I was fully qualified, (and I have paperwork to prove it) can I log PIC time while the sole manipulator? My gut says no, but of course, I'm hoping for a yes.

 

Thank you for any and all replies, I'm just trying to figure out if I need to correct my log book as I'm looking to apply for a few pilot positions.

 

Yes, You can log PIC time under §61.51[e][iii] as SIC without a type rating. This applies if the SIC is required and the SIC meets §61.55 Second-in-command qualifications.

 

Within the context of your question there are only 4 ways that would allow you (under §61.51) to log PIC.

 

In your case, if you’re serving as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember (SK-61) and you meet §61.55 Second-in-command qualifications.

 

§61.51[e]

 

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;

 

[ii] When the pilot is the sole occupant in the aircraft;

 

[iii] When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

 

[iv] When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

 

[A] The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

 

The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

 

**** UPDATE ****

§61.51[e][iii] as SIC only applies if the SIC hold a type rating for the aircraft. The only way a SIC can log PIC time without a type rating is under §61.51[e][iv].

Edited by iChris
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Yes, You can log PIC time under §61.51[e][iii] as SIC without a type rating. This applies if the SIC is required and the SIC meets §61.55 Second-in-command qualifications.

 

Within the context of your question there are only 4 ways that would allow you (under §61.51) to log PIC.

 

In your case, if you’re serving as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember (SK-61) and you meet §61.55 Second-in-command qualifications.

 

§61.51[e]

 

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;

 

[ii] When the pilot is the sole occupant in the aircraft;

 

[iii] When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

 

[iv] When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

 

[A] The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

 

The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

So what do you do with S-58 time? It's over 12,500 but it does not require a second pilot....like the H3/S61 does....If you are not in an approved program where do you put it? I know it's not PIC time, but how can it even be SIC time?

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OK, here's the question I've been asked...

 

If you fly as SIC in a heavy that requires two crew, is there a way to log any flight time as PIC when you are flying? For example, the command pilot is an ATP, CFI, or a Check Airmen for the company etc...

 

I have not been able to find the answer.

 

Thanks for all the replies in advance.

 

Missed that the first time, requires two crew

Yes, You too can log PIC time under §61.51[e][iii] as SIC without a type rating. This applies if the SIC is required and the SIC meets §61.55 Second-in-command qualifications.

In your case, if you’re serving as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember and you meet §61.55 Second-in-command qualifications.

Sometimes the term SIC is used in reference to non-required second pilots.

**** UPDATE ****

Yes, You too can log PIC time under §61.51[e][iii] as SIC; however, you as SIC must still hold a type rating.

Edited by iChris
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Even as SIC, wouldn't he be unable to ACT as PIC without the type rating? Thus making him unable to log PIC time. Or is the SIC type rating under 61.55 (d) or (e) enough to satisfy the requirements of 61.31 © ?? Which would make him eligible to log PIC as per 61.51 (e)(iii)?

 

edit: Which is what aeroscout just said... lol

 

My head is starting to spin. Hopefully, I'm understanding this correctly...

Edited by ridethisbike
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So what do you do with S-58 time? It's over 12,500 but it does not require a second pilot....like the H3/S61 does....If you are not in an approved program where do you put it? I know it's not PIC time, but how can it even be SIC time?

 

The S-58T is an excellent example. Some are over 12,500 so 61.51[e][iv] would apply.

 

§61.51[e][iv] was setup for aircraft like the S-58T and the Bell 214 that were over 12,500 but required only one pilot. Before [e][iv] there was no way for a non-required SIC to log PIC without a type rating.

 

[iv] When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

 

[A] The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

 

The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation—

 

However, since only one pilot is required, they just do the training with a type rated pilot and document the time as training. That’s all that is required to get a new pilot setup to take type ride.

 

They can also play the S58JT (12,500 GTW) vs. S58ET (13,000 GTW) game. They would limit GTW to 12,500 and keep external gross at 13,000.

 

Owners would file a change of registration or airworthiness from ET to JT, therefore a type rating was not required. That was based on the S-58 TCDS 1H11. Lots of those S-58Ts are JTs, FTs, or HTs (12,500 GTW - 13,000 external)

 

Note 9: Except for a difference in Maximum Weight, the following models are identical to each other including all limits:

 

S-58F identical to S-58B

S-58G identical to S-58C

S-58FT identical to S-58BT

S-58H identical to S-58D

S-58HT identical to S-58DT

S-58J identical to S-58E

S-58JT identical to S-58ET

 

Maximum weight

 

13000 lb. for S-58BT, S-58DT, S58ET

12500 lb. for S-58FT, S-58HT, S-58JT

Edited by iChris
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