Logging PIC as student pilot

[Jaybee]

You see...I like to read....should try it sometime.... Like the title of this post as an option for ya...

 

 

 

I knew you would say that. The pilot in the original posting is a Rated Pilot looking to do an add-on in a different category and class, not a Student Pilot and I'm not picking nits, it is a distinction that makes a difference.

 

Did you add-on a Rotorcraft-Helicopter category and class to your fixed wing license ?

 

Have you done an add-on for a student ?

[WolftalonID]

Touche'

 

Next question then, its been asked but the argument steered away from the direct answer. Being a rookie in the industry, I also am interested in the thoughts of others on the question.

 

Is a rated pilot in a different class and catagory(fixed wing as example) considered a student pilot while training in a new class and catagory(rotorcraft helicopter as the example)?

 

Or are they just a pilot in a training program restricted on logging as dual instruction received?

 

The first bit of knowledge I have is they dont need a student pilot certificate to do it.

The second is there are regs on add ons. FAR 61.63

 

Going back to FAR 61.51 on loggin time as PIC, being the add on is for a different catagory/class the time logged would be

1) dual instruction received ONLY,

2) until a solo endorsement is issued from which point you can log only your solo time also as PIC,

3) and after the practicle test is passed, Log that flight and further flight time as PIC when conducting flights in the new catagory/class as PIC.

 

Did I miss any basic concepts?

Edited February 21, 2014 by WolftalonID

[pilot#476398]

According to SFAR 73 if you don't have a rotorcraft catagory/helicopter class rating you must do the 20 hours of dual before you can solo.

 

So I would say that the regs do consider an airplane pilot doing a helicopter add-on a student, who cannot log PIC in the helicopter, with the exception of any solo requirement in which he would also be sole occupant under a solo endorsement (just like any other student pilot would,...except you Wolf ).

Edited February 21, 2014 by pilot#476398

[WolftalonID]

I'm special....momma always said I was special... 😳

[cburg]

Additional FAA Interpretations...the most recent on this subject is the first one listed below...in 2013...

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

 

http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2013/crowe-palmbeachhelicopters%20-%20%282013%29%20legal%20interpretation.pdf

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

May an applicant who has been endorsed for solo flight under § 61.31 credit or log a

portion of the flight training conducted in accordance with § 61.129©(3) as PIC time

after receiving such an endorsement?

Section 61.31 (d) sets forth the requirements for acting as pilot in command of an aircraft. An

endorsement for solo flight under that section does not alter the requirements for logging

1 Under 14 C.F .R. § 1.1, a pilot in command must hold the appropriate category, class, and type rating for the

conduct of the flight. Additionally, under § 61.31(d), to serve as pilot in command of an aircraft, a person must

hold the appropriate category, class, and type rating (if required) for the aircraft to be flown unless conducting

a solo flight under an instructor endorsement.3

pilot-in-command flight time under § 61.51(e). As such, notwithstanding the 10 hours of

flight time that may be credited under §61.129©( 4), a pilot who holds a § 61.31(d)

endorsement for solo flight may not log or credit flight training with an authorized instructor

as pilot-in-command flight time because the pilot is neither rated in the aircraft nor the sole

occupant of the aircraft.

This response was prepared by Anne Moore, an attorney in the International Law,

Legislation, and Regulations Division of the Office of the Chief Counsel, and has been

coordinated with the Airman Certification and Training Branch of Flight Standards Service.

If you have any additional questions regarding this matter, please contact us at your

convenience at (202) 267-3073.

 

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

[WolftalonID]

Cburg that is a nice find for sure....however.

 

FAR 61.31 is not related to student pilots as the discussion is focused on. This is a clarification of a pilot issued a solo endorsement for TYPE RATED aircraft. In helicopters thats more like helis weighing more than 12,500lbs or rated for such gross weight take off capabilities. There maybe a few other options that mandate a type rating.

 

My question as a rather rookie pilot here is.....how would a guy "solo" a type rated helicopter? Dont most require two crew?

[Jaybee]

To sum it up, Wolf, because I didn't come here to argue -

 

• It was not clear that you only meant yourself, not only to me but a few others on the thread as well as people that PMed me here and on Facebook. I had to go back and reread what you said a couple of times after you stated you were only talking about yourself.
• It was not clear what you meant by "transition" as you talked about doing an R44 "transition". That is what I was speaking to, an R44 transition. I know that several schools teach that you cannot log PIC in the 44 until you have your PIC endorsement. Not true, letters of interpretation from Chief Counsel cited.
• As talked about, you can log PIC in a 141 program where otherwise you would not.
• You stated several times, you did not understand the need to log PIC. Some people doing an "add-on" do it to save money. Since you need XXX PIC time to qualify for an FAA certificate logging PIC as much as and as soon as legally possible saves money. For the record - PP-ASEL, add on Private RH, Commercial RH and Instrument Helicopter - I was out the door for roughly $35,000.

As an aside, little known factoid - if you are scheduled to go to the Robinson Factory School soon after your CFI and/or CFII ride - then do not pay your school or DPE for the second additional ride. If you take the R44 out for a spin at the Factory school, the Factory Instructor Pilot will give you endorsements to teach in the R44 just by attending the Factory School.

[WolftalonID]

Went to the RHC factory school as a private/ intstrument pilot. Missed the boat on the free endorsement there.

 

Annnnd so now we cant read again......... Lets start in the Government publication with the title in big bold letters called...... Ready for it?????? FAR/AIM

Might look at what ever year you find important but the new shiny 2014 edition is out now.

 

SFAR 73 B (2) (ii). Its an endorsement required bro and its in my LOG book, received after having the needed (5) hrs and performing emergency procedures to standards depicted in the 141 syllabus of the school I went to which was drafted from requirements of SFAR 73.

 

 

I love this argument its exactly why I come back to this thread..... My instruction was a 141 level robinson based training program... My CFI rating means I earned it...by proving to an FAA DPE that I knew my stuff, my endorsements too! I have em all written out, not copied from my log book.

 

I even had to have one endorsement in my log book re-done after actually reading the regs.... They had put the wrong reference in it!!! Wowsers!!!!! Even my DPE was impressed because it was a sign I knew how to validate my work, and any work my signature would follow on.

 

I am a rookie pilot with years of flying ahead of me. I am 38 years old though, have learned alot in my years, taught alot of things, trades, etc in my years, and know from experience I don't know it all, but stand your ground when you do. Dont teach it till your certain, and if your not certain say so.

 

 

Explain how I didnt need that R44 transition now?

Edited February 24, 2014 by WolftalonID

[iChris]

Out of curiosity, what helicopter are pilots soloing that requires a type rating? What student pilot is flying a helicopter that requires a type?

 

My question as a rather rookie pilot here is.....how would a guy "solo" a type rated helicopter? Dont most require two crew?

 

Technically, you could conduct primary flight training in an old round motor Sikorsky S-58B, which would normally require a type rating, and solo the student under 61.31[d][2].

 

As side note, its been reported that a few cherry drying operations were hiring non-typed pilot and flying them in S-58’s that required type ratings. The FAA has not the manpower to follow-up.

 

Another game was to re-register without a change to the TC. Example, change the registration of a Bell 214B to a Bell 214B-1 or S-58ET to a S-58JT. This is done to bypass the type rating requirement.

 

With older aircraft it passes without much notice since no passengers are carried (Parts 133/137).

 

Single pilot type rating required

 

13,800 lbs. for Bell 214B (16,000 external cargo operations)

17,500 Bell 214ST (VFR – One helicopter pilot Single pilot operations)

12,700 lb. for Sikorsky S-58A, S-58B, S-58C

13,000 lb. for Sikorsky S-58D and S-58E

13,000 lb. for Sikorsky S-58BT, S-58DT, S58ET

 

Single pilot no type rating

 

12,500 lbs. for Bell 214B-1 (16,000 external cargo operations)

12,500 lb. for Sikorsky S-58F, S-58G, S-58H, S-58J

12,500 lb. for Sikorsky S-58FT, S-58HT, S-58JT S-58FT, S-58HT, S-58JT

Edited February 24, 2014 by iChris

[pilot#476398]

Instrument training was when I first got into a 44. The instructor said after my checkride (and 40 hours in the 44) he'd give me the PIC endorsement. Said it would last longer if we waited until the end (its only good for 12 months,...unless you get to 200/50 first).

 

Needless to say, he forgot!

 

...and I forgot too!

 

A couple of years later at RHC we were discussing the PIC endorsement (one guy had 500 hours in a 44 and didn't have one). The guy teaching the class said just go ahead and get it now, you don't really need it after 200/50 (or 200/25 for those of us who trained in the 22), but you may as well have it.

 

He also said my first 25 hours in the 44 (which I had recently gone back and edited as non-PIC) were in fact loggable as PIC as long as I was "sole manipulator" flying with a CFI who was in fact the acting PIC.

 

That guy had also been my DPE, so I trusted his judgement.

[WolftalonID]

Thanks iChris....makes sense now I guess....odd but I understand. Guess re registering is cheaper than rebuying!

 

Pilot, I get that...seems DPE's can vary on their enforcement about as much as regular pilots disagree on how its done or not done. I seem to put them on a pedestal though as they are supposed to be the almighty approver of good doers right? Lol. It is irritating when here is not much continuity amongst them though.

 

I recently did my biannual in the R44... After having passed the 200/50 mark...good to go now for a while in that ship.

[pilot#476398]

I wouldn't go with calling in "enforcement" that makes it sound like some are following the regs and others are just "letting it slip by".

 

I would go with their "understanding" of the regs instead.

 

Anyway, if the answer to a question regarding SFAR 73 comes from a teacher at Robinson, then its a safe bet its the correct one. Which is why I don't ask CFIs about it anymore. If I have a question about that damn thing I either right it down and save it for my next trip to the safety course, or I e-mail someone over there.

 

My first BFR was a month later than it should have been due to mine and my CFI's "understanding", or lack-there-of of SFAR 73!

 

Always go to the source!

[Retreating Brain Stall]

. Its up to the pilot to log how they see fit, and its up to me to make sure the log is legal and true before my signature is added to the entry.

Let me play the devils advocate here and stir it up on you Wolf- no offense. (I've been enjoying this post myself).

 

One should log in the logbook the PIC (that you choose not to by choice) why? Simple- Insurance. When you work for a company they want your PIC and other numbers (legal and loggable hours). Your only selling yourself short and if it was shady or gray the Feds would rewrite it, but that's not the intent as the Feds have pointed out in the explanation to the regulation.

 

Your making it a cut off your nose despite your face. If I were in a hiring position or in a manager position asking for PIC time for the insurance company- I wouldn't want the black sheep marching to his own beat.

 

I had a hard time wrapping my mind around some regulations before but as my knowledge and experience grows I make changes and accept it and embrace them.

 

This is all part of the CFI refining fire.

[WolftalonID]

Great point pilot# but the SFAR wasnt written by Robinson.

Your problem of that endorsement sucks...I see it often with CFI's not reading and not seeking the whole picture behind the SFAR.

 

The FAA FSDO's have even complicated the matter by one saying one thing and another office saying another.....then you have the age old CFI shoot out on who's on first syndrome, while students get shafted by rookie pilots!

 

RBS,thats a hilarious SN by the way.

 

If you as an employer were to look at my log book, you would see in my student pilot hrs, several catagories listed per flight as we are trained to do. One in particular for most of them was Dual received. There is a few night flights, mostly day, I added a column in the write in for R22 so as my time grew I could more redily split the hours from other ships.

When it came to my solo hours, I kept it simply solo, for a total of like 5.? Hrs. (Not illegal, and it shows as solo for two reasons). I know where they are to reference a DPE for a check ride( and yes thats over but it was helpfully fast as I highlighted them too), and it was under my student pilot certificate, and my CFI's signature not my own. Again my reason, and its only 5.? Hrs...( light blasphemy apparently )

 

Then as a rated pilot moving on to the R44, due to SFAR 73 and its very clear writting, I logged dual for the first 5 hrs of flight, received my endorsement stating I was good to go as PIC in that frame, and I logged PIC thence, and dual if my CFI was on board, solo when I was flying it myself.( I didnt solo under the hood here guys, I took my mom on a flight over Boise one evening).

 

Back into the R22 for Commercial, I logged PIC the whole time, and dual or solo as per the flight being conducted. CFI training was also PIC with Dual received, just flew left seat, and never solo( um, obviously not solo left seat here).

 

 

So RBS, a student pilot, non rated, is endorsed by me to fly solo, comes back and has that flight logged and also has it as PIC..... I will ask him why, if he cant show me, I will show him why he can, and sign it.

 

If that same or any other student pilot flies with me, has a solo endorsement, but we did dual instruction, and they try and log that as PIC, I again will ask why, if they cant show me, I will show them the regs, edit the log as Dual only and explain they were NOT the sole occupant as per regs require to log the PIC( assuming we are in robbies here ok ) and then sign it.

 

Now if that pilot logs his student solo hrs just as Solo.....I get it, will explain to him how soooooo valuable those 5 hrs are and the world will go flat again and certain pilots will sh*t themselves if they ever show their log books the light of day with that aweful blasphemy of those 5 hrs as solo and not PIC, and I will make them draw blood and press it next to that entry so even GOD knows of the deed.......... And then sign it......

 

All the same except for the blood letting on the R44 transition.... Rated pilots can have a touch of mercy once in a while.

Edited February 24, 2014 by WolftalonID

[Retreating Brain Stall]

Logging PIC:

 

Solo = PIC

 

Non-rated for category and/or solo endorsed for category + instructor = Dual

(anyone below private per category receiving dual)

 

Rated for category + instructor = Dual & PIC

(anyone after private per category)

 

Acting as PIC:

 

Solo = Acting as PIC

Non-rated for category and/or solo endorsed for category + instructor = Instructor Acting as PIC

Rated for category + instructor = Instructor Acting as PIC

[Jaybee]

Went to the RHC factory school as a private/ intstrument pilot. Missed the boat on the free endorsement there.

 

Annnnd so now we cant read again......... Lets start in the Government publication with the title in big bold letters called...... Ready for it?????? FAR/AIM

Might look at what ever year you find important but the new shiny 2014 edition is out now.

 

SFAR 73 B (2) (ii). Its an endorsement required bro and its in my LOG book, received after having the needed (5) hrs and performing emergency procedures to standards depicted in the 141 syllabus of the school I went to which was drafted from requirements of SFAR 73.

 

 

I love this argument its exactly why I come back to this thread..... My instruction was a 141 level robinson based training program... My CFI rating means I earned it...by proving to an FAA DPE that I knew my stuff, my endorsements too! I have em all written out, not copied from my log book.

 

I even had to have one endorsement in my log book re-done after actually reading the regs.... They had put the wrong reference in it!!! Wowsers!!!!! Even my DPE was impressed because it was a sign I knew how to validate my work, and any work my signature would follow on.

 

I am a rookie pilot with years of flying ahead of me. I am 38 years old though, have learned alot in my years, taught alot of things, trades, etc in my years, and know from experience I don't know it all, but stand your ground when you do. Dont teach it till your certain, and if your not certain say so.

 

 

Explain how I didnt need that R44 transition now?

 

You keep insinuating that people can't read... yet you are the worst offender.

 

When did I ever say not to comply with SFAR 73B (2)(ii) ?

 

ALL I said it that you can log R44 transition time as PIC and that the factory school can give you endorsements to teach in the R44 (if you have one already in the R22 obviously). You are truly showing your lack of knowledge if you don't know that endorsement can come from a factory instructor pilot instead of a DPE and that someone rated in category and class can log PIC.

 

Amazingly enough, I can say all this without resorting to calling names.

 

I've had enough of your childish bloviating. I'm done with you.

[Retreating Brain Stall]

And Wolf, let me get this straight- you choose not log PIC when you ARE NOT ACTING as PIC correct?
Perspective:

When you advance to the big stuff and get a type rating and are in a SIC job with a type rating and the company wants to upgrade you to captain- they are going to be scratching their heads wondering how you don't have enough PIC time in the machine to meet the insurance requirements.

[Jaybee]

Let me play the devils advocate here and stir it up on you Wolf- no offense. (I've been enjoying this post myself).

 

One should log in the logbook the PIC (that you choose not to by choice) why? Simple- Insurance. When you work for a company they want your PIC and other numbers (legal and loggable hours). Your only selling yourself short and if it was shady or gray the Feds would rewrite it, but that's not the intent as the Feds have pointed out in the explanation to the regulation.

 

Your making it a cut off your nose despite your face. If I were in a hiring position or in a manager position asking for PIC time for the insurance company- I wouldn't want the black sheep marching to his own beat.

 

I had a hard time wrapping my mind around some regulations before but as my knowledge and experience grows I make changes and accept it and embrace them.

 

This is all part of the CFI refining fire.

 

Aye. This guy has never even worked in the industry, let alone fill out an application for a place like PHI - I lost count but it asked for roughly 48 different kinds of flight time in the application.

[WolftalonID]

Jaybee,

I never once stated that the factory course does or does not count as an endorsement to teach in the frame you ride in. I went as a private pilot, still working on my commercial, so no such endorsement was going to be given me, as I did not have a CFI rating at the time I went to the RHC school.

 

Then you asked where you stated that the SFAR didn't matter? Right in the post above mine. You said you CAN log PIC in those first 5 hrs.... Yet the SFAR clearly states your not PIC until endorsed.

 

My total hrs not marked as PIC to me is 5.? Solo hrs. Still don't see how to log those transition hrs, the POH says 1 pilot as min crew and I wasn't endorsed to act(fly) as PIC for those first 5 hrs. I had an endorsed to teach in R44 CFI on board teaching me, training me, and dual instructing me on the proper techniques of flying the R44, who then after 5 hrs wrote out my SFAR PIC endorsement to then fly as a rated pilot and PIC.

 

Now as far as industry two pilot ships,SIC, transition, dual, etc in 135 or similar company training programs.... Cant answer that one. I have not read on regulations towards that, I am not 135 qualified...do not even have 1/2 the hrs towards it, so have to say don't know on that.

 

However....once I do head that direction, I will be busting my butt, driving people crazy with scenario questions, reading regs, and preparing for that.

 

Now at one time a few weeks back, I briefly dove into SIC and type rating training regs to see what I had to review for actually flying SIC. I found some cool stuff to read and still honestly need more time reviewing and cross referencing that to understand it.

 

However from my brief read, I am guessing once you receive training enough to be endorsed as SIC of say an S92 then as your PIC allows under further training the SIC to "take" command during the flight, that those hrs are loggable towards the PIC hrs needed further down the road for a PIC endorsement in that ship.

 

Again to clarify, it was not much more than a once over read, and I am sure there is way more to it than that and look forward to learning more.

 

My main frustrations here have been seeing people say a student certificated pilot can claim PIC hrs after solo endorsed but flying dual with the CFI. It appears to me that some here seem to say thats ok?

I don't agree, and in the school environment I trained in I cant find regulations that agree. In fact they say exactly what I showed they did.

 

As far as my R44 hrs, I am rated category and class to fly it, but then I read the SFAR, and have to consider its limitations because the SFAR supersedes part 61 rules regarding flight in Robinson Helicopters vs other helicopters in the same category/class.

 

I was taught(oops said it), that one can not take just a part of the regs as the law if another part is required for a full definition. Thus flying Robinsons means, SFAR 73 part 1 and paragraph 1 applies and parts 61 both are considered when coming to conclusion.

 

Read part 61 and come to the conclusion alone, and your only partly right on how to log PIC in training while flying robbies.

 

I know its not clear when people first come across it, it wasn't for me either. "Learn how to read!" Was an often said statement by my assistant chief pilot. Its a requirement of a US pilot to read english, he would say, so don't take FAR regs out of context.

 

I learned over and over to apply both SFAR 73 as superseded rules to part 61 for flying Robinson Helicopters.

 

Fly a different trainer.... Part 61 is all you need.

 

Again, RBS, cant answer in fact your questions to me on SIC training stuff....but someday soon I could. Good question though.

 

Jaybee, I am an ass sometimes, not all the time, just sometimes, but this thread fo sho!

Seems we both have been addicted to the drama it had brought, and it makes for great TV!( read forum entertainment) for those who just watch like voyeurs in the shadows.

 

Arguments are worth the efforts, its what gets us to see things we didn't before....sometimes....

Edited February 24, 2014 by WolftalonID

[WolftalonID]

Logging PIC:

 

Solo = PIC

 

Non-rated for category and/or solo endorsed for category + instructor = Dual

(anyone below private per category receiving dual)

 

Rated for category + instructor = Dual & PIC

(anyone after private per category)

 

Acting as PIC:

 

 

Solo = Acting as PIC

 

Non-rated for category and/or solo endorsed for category + instructor = Instructor Acting as PIC

 

 

Rated for category + instructor = Instructor Acting as PIC

 

My first of two added thoughts is towards acting PIC as solo...we are PIC when solo and of course endorsed, because we have a pilot certificate with solo authority albeit a student pilot certificate. No other person on board right? Its not just acting but our first actual doing.( so add my solo hrs to my PIC..its an easy math problem unlike some iChris will post...)

 

The second is more of how I perceived my CFI in regards to him, now myself as a CFI. Regs state we can log hrs as PIC while giving dual for the entire duration of the dual flight. Being my CFI had more hrs than I did...it wasn't a question regardless of who called the shots during training, I saw him as my senior and respected his calls. They often were different than my initial ideas because as a budding pilot, I often was behind the process while learning not ahead of it.

 

That position probably jaded my take on the separation of acting vs is.

 

Not really sure if instead, say I had more TT than the CFI if it would have made the same impression.....as it often is different in other life situations when a young low timer tries to sell their take on life differently than my experience has led me to take a stand.

 

I have two sons, one eight, one nine. The older one I am teaching to elk hunt so he will be ready as he gets of age at twelve.

Both are being taught archery by me, I have been behind a bow since I was six.

 

The older son takes it all in and tries his hardest to apply my senior level learning to his approach.....the younger one knows it all and tries to tell me how its done, had since he was able to talk.

 

I see myself in them both, and know as they grow and experience life, it will offer them lessons to learn, and some they will be prepared for by me, some they have to face alone.

 

I too have found I don't know everything, or maybe its a side effect of aging... Haha

I may spout off at times and be completely wrong....or completely right.....and it doesn't matter which.....someone will argue based on their own grasp of the situation!

Edited February 24, 2014 by WolftalonID

[Jaybee]

May God have mercy on my soul because I have no idea why I am responding -

 

since you persistently insist on superior reading skills, I'll quote you the appropriate part (see if you can read it this time)-

 

"(2) No person may act as pilot in command of a Robinson R-44 unless that person"

 

and I'll refer you to previous commentary upon the differences of logging PIC as sole manipulator vs. acting PIC

 

last but not least you keep on saying something about taking in the regulations as a whole - please show me in 61.5 where R44 is a rating.

 

"(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-

(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, "

You are confusing a R44 endorsement with a rating. Ratings are defined in 61.5

Again, FAA Chief Counsel opinion letters were cited on endorsement vs. rating.

 

[WolftalonID]

Ok touche' again. The FAA loves symantics....so should I

 

Maybe that is the defining difference and the balance point of my understanding.

 

Endorsement vs rating....let me look into that...give me time to read on my own and get back with you.

 

Seems logical and I like logic...

[Nick9er]

I personaly did not log hours as PIC in the R22 until my checkride. My DPE told me it was not dual and it was my first true rated pilot flight. My first 5 hours of R44 time even though I was a rated Pilot, were not logged as PIC, being it took having the 5 hours of transition training to gain that R44 PIC endorsement.

Students (ppl students) need to be aware that they are able to, and should, log the first 5hours in the 44 as PIC time, and subsequently apply it to SFAR & total PIC hours thereafter. You simply may not act as PIC (ex. having passengers aboard) during that time. I suggest you go back through your logbook and correct for the instructor's oversight.

[WolftalonID]

Thanks Nick, as stated I was presented above with the challenge of knowing the FAA difference of endorsement vs rating. One term I believe I do know well enough, which is rating, however the term endorsement is not as easily defined, nor is the relationship between them especially in consideration with and including SFAR 73.

 

Still researching more detailed information myself before making any further conclusive statements as that may be exactly as stated above by Jaybee, the hitch in my understanding.

 

Will post my findings as I can.

[WolftalonID]

I sat here for an hour....not sure what to say exactly..... Odd me at a loss for words exactly.

 

So first things first. --------- Jaybee, I believe you are right, I was wrong. -------------

 

It took me a while to do as I preach and read things that I didnt even knew existed on the FAA website until I was faced with this challenge. I was quickly able to find the definition of rating, it validated my understanding of what a rating was, and its limitations. I was not so quick to find a definition of endorsement outside of a regular dictionary, however, through several Chief Counsel letters on various subjects, several FAR's using the term, and clarification from a pilot I personally know vs just everyone here... I believe I do understand what an endorsement is.

 

An endorsement is an approval of performance, or a lifting of a restriction on a pilots rating.

My experience is very limited to a school environment, and specifically a Robinson Helicopter environment. This is something that at this time in my career has restricted my perspective and for which my own expression of knowledge was jaded.

 

I am now understanding that the SFAR restrictions are the reason a pilot is required to be endorsed to "act" as PIC,meaning, taking passengers, flying solo even once rated, and not needing a rated PIC on board to cover for them.

 

Knowing 61.51 vs 61.57 also helped clarify logging PIC, knowing my restrictions for "acting" PIC,( read by me as performing full function PIC duties ), and now why I am learning to see it differently.

 

Noone likes admitting being wrong, or being an ass while being wrong, but here I have to do both.

 

I will stand by my hours logged as a student, being SOLO hrs are the same in the eyes of the FAA as PIC that column still reads as such.

 

My transition hrs for the SFAR 73 endorsement were PIC loggable, but not PIC actable, and have been corrected to show that.

 

And.....

 

Any future airframe transitions I get training for that fall under my rating....will be logged as PIC/Dual received, not just DUAL.

 

Thanks guys for hammering the sh*t out of me.....its really thick upstairs sometimes and it takes a good beating to get a point across sometimes.

 

I am still smiling about it, wearing the dunce cap publicly about it, and improved because of it.

 

John