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SFAR 73 and PIC logging


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I've started to transition from the R22 to the R44. My CFI thinks that SFAR 73 (B)(2)(ii) trumps 61.51(e)(1)(i) -- in other words even though I'm rated in category and class, that I can't log my first 5 hours of dual as PIC time.

 

An informal question to the helicopter guy at the Philly FSDO came back that it's loggable at PIC time under 61.51.

 

Does anybody know of a definitive ruling on this issue?

 

SFAR 73 says I can't act as PIC until I do those 5 hours, but it doesn't say anything about loggine the time as PIC. Seems to me that this is like the fixed-wing cases of tailwheel, high performance, or complex, where the FARs say you can't act as PIC until you get the endorsement, but 61.51 allows you to log the time as PIC if you're rated PP-ASEL for example. Or am I missing something?

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I haven't had to deal with this yet myself, but I think I would log both, PIC and Dual. "Logging" PIC, and "Acting as" PIC are two totally different animals. If push came to shove, I would think that the FAA would only be concerned with the 5 hours of dual being logged, and you have the endorsement to act as PIC of an R44 as that is what is "required," the logging of PIC wouldn't matter to them. Just my opinion.

 

Clark B)

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Special Federal Aviation Regulation No. 73—Robinson R–22/R–44 Special Training and Experience Requirements

 

...(B) Aeronautical Experience:

 

(1) No person may act as pilot in command of a Robinson model R–22 unless that person:

 

(i) Has had at least 200 flight hours in helicopters, at least 50 flight hours of which were in the Robinson R–22; or

 

(ii) Has had at least 10 hours dual instruction in the Robinson R–22 and has received an endorsement from a certified flight instructor authorized under paragraph (B)(5) of this section that the individual has been given the training required by this paragraph and is proficient to act as pilot in command of an R–22. Beginning 12 calendar months after the date of the endorsement, the individual may not act as pilot in command unless the individual has completed a flight review in an R–22 within the preceding 12 calendar months and obtained an endorsement for that flight review. The dual instruction must include at least the following abnormal and emergency procedures flight training...

 

§ 61.51 Pilot logbooks.

 

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—

 

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;

 

(ii) Is the sole occupant of the aircraft

 

The way I see it, if you haven't had a robbie sign off, then you dont have privileges in that aircraft.

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I've posed the same question to three different FSDOs (Seattle, Portland, and Sacramento) and to John Lynch of AFS-800. All four answers were the same: §61.51(e)(1)(i) applies and the time may be logged as PIC. That's good enough for me.

 

Bob

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I've started to transition from the R22 to the R44. My CFI thinks that SFAR 73 (B)(2)(ii) trumps 61.51(e)(1)(i) -- in other words even though I'm rated in category and class, that I can't log my first 5 hours of dual as PIC time.
You are rated in helicopters. You can log PIC for all the time you are sole manipulator of the controls. It is the same as a fixed-winger doing a tailwheel transition. Once you are endorsed, you can then ACT as PIC (fly solo, carry pax).
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