Can dual after solo endorsement be logged PIC

[napalm]

Hey I got a question. I am a commercial (AMEL,ASEL) rated fixed wing pilot. After I get my solo endorsement in the R-44(end of this week prayerfully) can the dual instruction that I get be logged as PIC. Is it true that because of the instruction that I have received from my instructor and the endorsements I will have the "priveleges" of a rated helicopter pilot and can log dual as PIC? My intention is to use this interpretation to meet some of the requirements of 61.129©. For example it says that I need 10 hours PIC x-country and 35 hours PIC in helicopters. From this interpretation then the dual I get after I get my solo endorsement will count as PIC and will decrease the amount of flight time I need to meet these requirements. What do you folks think? If you think this is not a good idea please include FAR numbers and references so I can take a look. Thanks.

Edited December 12, 2006 by napalm

[Jeff]

Hey I got a question. My CFI says that because I am a commercial (AMEL,ASEL) rated fixed wing pilot that after I get my solo endorsement (end of this week) that the dual instruction that I get can be logged as PIC. He says that because of the instruction that I have received from him and my endorsements I will have the "priveleges" of a rated helicopter pilot and can log dual as PIC. His intention is to use his interpretation to meet some of the requirements of 61.129©. For example it says that I need 10 hours PIC x-country and 35 hours PIC in helicopters. From his interpretation then the dual I get after I get my solo endorsement will count as PIC and will decrease the amount of flight time I need to meet these requirements. What do you folks think? If you think this is not a good idea please include FAR numbers and references so I can take a look. I am going to call the FSDO but thought I would ask you all first. Thanks.

 

 

I went the exact same route as you, and here is my advice. Read FAR 61.51(e). "(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; "

 

The question is whether or not your endorsement constitutes a privilege. I'm thinking that you might be able to, but the FSDO might say no.

 

I recommend that you get your PPL Helicopter, then start training for your instrument rating. Then, all your time dual is also PIC. And you're building PIC for your CPL. Besides, you probably only need 15 hours for an instrument helicopter rating.

 

When I did my helicopter training a few years ago, that's what I did. I was under the impression then that I couldn't log the time PIC as you asked. But looking at the FAR's today, it looks as though you might. Let me know what you find out when you ask the FSDO.

 

Jeff

[Guest pokey]

all the regs can be interpreted different ways by different ppls,,,,, the thing to keep in mind tho is to cover every possible base. Does it really matter if its dual, pic?--only to satisfy the regs. HECK ! i even met some DPE's that didnt know if what they were doing was what the regs meant !

 

better to be safe than sorry,,, besides?---we can ALL use some dual

Edited December 10, 2006 by pokey

[Jeff]

I just did a bit of research and the word "privileges" was added to 61.51(e) in 2004. And since your endorsement most likely constitutes an operating privilege, you should be able to log dual time as PIC also before you are rated.

 

Jeff

[napalm]

I just did a bit of research and the word "privileges" was added to 61.51(e) in 2004. And since your endorsement most likely constitutes an operating privilege, you should be able to log dual time as PIC also before you are rated.

 

Jeff

 

 

Thanks for the input from all on this post. Hey jeff, where did you get your info on the word "priveleges". How did you research it?

[Jeff]

Thanks for the input from all on this post. Hey jeff, where did you get your info on the word "priveleges". How did you research it?

 

Just go on the FAA's website and look up historical CFI's. It requires a good deal of reading and searching through final rules and NPRM's, but it's doable.

 

Jeff

[Jeff]

CORRECTION:

 

In my last post, I meant to say "historical FAR's", not "historical CFI's."

[JDHelicopterPilot]

Hey there guys, I don't have much time but thought I'd put my $.02. Student pilots may not log PIC when on a dual flight. Per part 61 they must be the sole occupant of the aircraft. There are to parts which state this. Here they are as follows: Jason

 

§ 61.89 General limitations.

(a) A student pilot may not act as pilot in command of an aircraft:

 

(1) That is carrying a passenger;

 

(2) That is carrying property for compensation or hire;

 

(3) For compensation or hire;

 

(4) In furtherance of a business;

 

§61.51 (e) Logging pilot-in-command flight time.

4) A student pilot may log pilot-in-command time only when the student pilot—

 

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

 

(ii) Has a current solo flight endorsement as required under §61.87 of this part; and

 

(iii) Is undergoing training for a pilot certificate or rating.

[JDHelicopterPilot]

Ok, I have a few more minutes now that I am waiting around for the fuel truck. To clearifiy, student pilots must be the sole occupant unless they are acting as PIC for an aircraft that requires 2 crew members. (Reference: 61.51) Also student pilot limitations state they cannot carry PAX per 61.89. They of course must have a current solo endorsement per 61.87. It is true when CFI's give endorsements it is an operating privliage, but they cannot log PIC all the time after that. For your PPL students only need 10 hrs PIC. I am sure if students were able to log dual PIC then the FAA would have required a lot more hours as PIC for the PPL.

 

To me when the far states you can log PIC for the aircraft in which you are "rated or have privileges" means those who are rated in that aircraft or student pilots operating under their solo endorsement. They cannot operated under their solo endorsement if they are not acting as PIC for an aircraft that requires 2 crew members or are not rated in such aircraft.

[67november]

Hey there guys, I don't have much time but thought I'd put my $.02. Student pilots may not log PIC when on a dual flight. Per part 61 they must be the sole occupant of the aircraft. There are to parts which state this. Here they are as follows: Jason

 

§ 61.89 General limitations.

(a) A student pilot may not act as pilot in command of an aircraft:

 

(1) That is carrying a passenger;

 

(2) That is carrying property for compensation or hire;

 

(3) For compensation or hire;

 

(4) In furtherance of a business;

 

§61.51 (e) Logging pilot-in-command flight time.

4) A student pilot may log pilot-in-command time only when the student pilot—

 

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;

 

(ii) Has a current solo flight endorsement as required under §61.87 of this part; and

 

(iii) Is undergoing training for a pilot certificate or rating.

 

 

JD, have to disagree, you can act as PIC of the aircraft under the follow Regs.

 

61.31

(d) Aircraft category, class, and type ratings: Limitations on operating an aircraft as the pilot in command. To serve as the pilot in command of an aircraft, a person must—

 

(2) Be receiving training for the purpose of obtaining an additional pilot certificate and rating that are appropriate to that aircraft, and be under the supervision of an authorized instructor;

 

so there

[DebosDave]

JD,

 

You are correct when you state that a "student pilot" cannot log the time in question as PIC. HOWEVER, I personally don't believe that napalm is a student pilot. He is an airman in pursuit (not exactly sure the term here) of additional ratings or certificate. Therefore, I believe after he gets his solo endorsement, he will be able to log dual time as PIC. I would however call the FSDO to verify, just to cover the bases.

 

Dave

Edited December 11, 2006 by DebosDave

[Jeff]

Napalm is not a student pilot. He is a commercial pilot. The student pilot rules in the FAR do not apply to him. When the instructor signs him off to solo, he is giving him an operating privilege for solo, PIC operations in a helicopter. An example of this endorsement is in AC 61-65e.

[JDHelicopterPilot]

67november,

 

You are right about logging PIC when doing it as an "add-on". I didn't realize at first that that was the case with the original post. I was in a bit of a hurry this morning then ended up waiting an hour for the fuel truck. 67November is right on about being able to log PIC when training for an additional rating. JD

[Guest pokey]

i may be letting my ignorance show here now ( no biggie-i been there B4) PLUS i'm too lazy to look this up myself right now,,, but what is the difference between solo & PIC time,? in this situation. (PLUS i'm getting old & CRS is beginning to take it's toll more & more each day )

 

interesting discussion BTW

[DebosDave]

OK, I just got off the phone with my FSDO, and part 61.51(e) is reffering specifically to Sport Pilot category when it says "... or has privileges;", therefore it can not be interpreted such that a solo endorsement constitutes "privileges".

 

Sorry, that sucks, but it sucks for me too, as I am an airman in training for additional rating or certificate myself. But the word is, Part 61, you can't log PIC time in a helicopter until you are either rated, or the sole occupant of the aircraft...

 

Dave

 

P.S. I don't know or see where there is any evidence that this is different for a commercially rated pilot, but if there is something that states it, I would say that the above is for a private rating... However, I do think if your CFI is quoting 61.51(e) as his evidence, I would question it after talking to my FSDO

Edited December 11, 2006 by DebosDave

[Superman]

I also was a commercial rated fixed wing driver when I did my add-on. I wanted to just add the commercial helicopter also, the first school I went to said no problem, well, it ended up being a problem. I ended up doing the PPL add-on, then the commercial add-on (and switched schools) This was several years ago, but if memory serves me, the 35 hrs of PIC- helicopter had to be met with solo time if you weren't rated in helicopters. The reasoning was this: (1) You are a commercial pilot, but not rated in helicopters, so no way to act or log PIC there. (2) The only endorsement your Instructor can give you to act as PIC (AC61-65D, Appendix 1, 35) reads

To act as PIC of an aircraft in solo operations when the pilot does not hold an appropriate categoru/class rating 61.31 (d )(3)

 

I certify that ________________has received the training as required by 61.31 (d)(3) to serve as PIC in a ________________. I have determined that he/she is prepared to act as PIC in that _____________ aircraft.

 

Notice that this endorsement refers back to 61.31(d) which covers additional category and class ratings (3) Have received training required by this part that is appropriate to the aircraft category, class, and type rating for the aircraft to be flown, and have received the required endorsements from an instructor who is authorized to provide the required endorsements for solo flight in that aircraft.

 

(3) In regards to 61.31 (d )(2) Be receiving training for the purpose of obtaining an additional pilot certificate and rating that are appropriate to that aircraft, and under the supervision of an authorized instructor.

Well, the their take on "Supervision" was "solo" flight, being "supervised" by an instructor.

 

So, I guess I would recommend that you get with your DPE or local FISDO as they will be the ones that "Interpret" the requirements you need. I have personally never met anyone that has done a Commercial helicopter add-on without doing the PPL add-on first ...... anyone?

 

Please let us know how this works out, I would like to know

 

Fly Safe

Clark

[Jeff]

OK, I just got off the phone with my FSDO, and part 61.51(e) is reffering specifically to Sport Pilot category when it says "... or has privileges;", therefore it can not be interpreted such that a solo endorsement constitutes "privileges".

 

Sorry, that sucks, but it sucks for me too, as I am an airman in training for additional rating or certificate myself. But the word is, Part 61, you can't log PIC time in a helicopter until you are either rated, or the sole occupant of the aircraft...

 

Dave

 

P.S. I don't know or see where there is any evidence that this is different for a commercially rated pilot, but if there is something that states it, I would say that the above is for a private rating... However, I do think if your CFI is quoting 61.51(e) as his evidence, I would question it after talking to my FSDO

 

 

Your FSDO is right. As I stated earlier, the "or privileges" part of 61.51(e) was added in 2004 when the reg. was changed for sport pilots; so that is the intent. However, as written, it implies that with the PIC endorsement we're discussing here, one can log PIC and DUAL at the same time.

 

Jeff

[DebosDave]

Your FSDO is right. As I stated earlier, the "or privileges" part of 61.51(e) was added in 2004 when the reg. was changed for sport pilots; so that is the intent. However, as written, it implies that with the PIC endorsement we're discussing here, one can log PIC and DUAL at the same time.

 

Jeff

 

 

I agree as written it seems like you can achieve a "privilege" by getting a solo/PIC endorsement, HOWEVER, my local FSDO said no dice.. you can't log PIC and DUAL at the same time unless you are rated. I argued with him for a bit (probably not the best idea), but he was very specific that the "privileges" only were for Sports Pilots, and he referred me to the Sports Pilot section to support this. I now don't believe that under Part 61, a fixed wing pilot can log PIC time in a helicopter unless he/she is the sole occupant or until he/she is rated in helicopter. I went to a part 141 school that said I didn't need any solo time at all to achieve my Private Rotorcraft Helicopter License, and the FSDO supported this, saying as long as they meet Part 141 requirements, their syllabus may not require solo...

 

Maybe a part 141 is worth looking into??

 

Dave

Edited December 11, 2006 by DebosDave

[flingwing206]

This is from the Pt 61 FAQs:

 

==============

QUESTION: A commercial pilot with an airplane single-engine land rating is now seeking to add a helicopter rating onto his commercial pilot certificate. How can the applicant obtain and log the PIC flight time in a helicopter to show 35 hours of PIC flight time in helicopters as required per § 61.129©(2)(i)?

 

ANSWER: Ref. § 61.51(e) or § 61.31(d); The PIC flight time would have to be obtained:

 

• Already hold a helicopter rating at the private pilot level. Then PIC flight time can be logged while flying solo and / or while manipulating the control as per § 61.51(e)(1)(i) when the flight instructor is on board; or

 

• Be the sole occupant of the aircraft and have a current solo endorsement in accordance with § 61.31(d)(3).

 

QUESTION: I am private pilot with an airplane single-engine land rating. I am seeking to add a helicopter rating. Can I log the time as PIC while manipulating the controls with my instructor on board as in § 61.31(d)(2)?

 

ANSWER: Ref. § 61.51(e)(1)(i)No. You cannot log the time as PIC while his instructor is on board since you are not rated in the aircraft. § 61.31(d) deals with the requirements to “serve” as the pilot-in-command but does not authorize logging PIC. § 61.51 specifies proper pilot logbook entries. There has always been a difference between logging PIC flight time vs. acting/serving as PIC. § 61.31(d)(2) was written as a part of the original Notice of Proposed Rule Making (NPRM) in which the term “supervised PIC flight” was proposed. When this term was dropped with the revised NPRM in 1996, this subparagraph should have been removed but was overlooked.

{Q&A-146}

==============

 

I had an in-depth discussion with my FSDO (Minneapolis) about a year ago on this very subject. They were unequivical in their assertion that only a pilot rated in the aircraft could log PIC with an instructor on board.

[67november]

Bravo, Bravo, I knew you'd clear the mud on this situation. it make sense now. as long as i can remember that a year+ from now when doing my knowledge tests

[delorean]

Read FAR 61.51(e). "(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; "

 

Sorry, I'm getting into this a little late....Here's what the sentence means in this example:

 

I have COMMERCIAL PILOT certificate, on the back of which, my RATINGS are listed as:

-Commercial Pilot

----Rotorcraft-Helicopter; Instrument Helicopter

-Private Privileges

----Airplane Single Engine Land

 

You cannot have a Private and a Commercial certificate at the same time--you have one or the other. I am commercially RATED in helicopters, but NOT in airplanes. Therefore, since I'm not commercially RATED in airplanes, I can only exercise private PRIVILEGES under my commercial certificate.

 

And since I'm not a commercially rated pilot in airplanes, I log PIC time under the "privileges" clause.

 

Next, solo "sign-offs" are NOT in any way PRIVILEGES.....they are ENDORSEMENTS. Just like SFAR73, tailwheel, complex, high performance, spin training, etc.

 

The FARs are all about syntax. Just because a word sounds a like or almost means the same thing, it does not in the FARs. The most common is people calling it a pilot's license. The FAA does not, and will not license you for anything. It's a certificate.....they certify you. It's a liability thing for the federal government.

[napalm]

thanks everyone for your replies to this question. It was a great help.

[Helo-Pilot]

Ok. Heres a twist.

 

As a private rated helicopter pilot, working on building time towards my commercial, I was told that I could not take a friend up with me while on a night cross country flight. I was told that this would not be solo.

 

Ok, in the most basic interpretation, I can see this. But, as a rated pilot, would'nt we think that solo would mean, not having anyone else there that can operate the aircraft?

 

Is this an 'interpretation' of the regs?

[flyby_heli]

FAR 61.87 (a): ".......The term solo flight, as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft....."

 

That is at least for subpart C: student pilots.

I could not find anything similar for subpart E (private) or F (commercial), but my understanding is solo means by yourself (sole occupant)......

[67november]

Ok. Heres a twist.

 

As a private rated helicopter pilot, working on building time towards my commercial, I was told that I could not take a friend up with me while on a night cross country flight. I was told that this would not be solo.

 

Ok, in the most basic interpretation, I can see this. But, as a rated pilot, would'nt we think that solo would mean, not having anyone else there that can operate the aircraft?

 

Is this an 'interpretation' of the regs?

 

if your cross country flight is part of your night flight requirements per 61.131 then no you have to fly solo, alone, by yourself. the only person in the helo is me myself or I then your good to go

Edited December 15, 2006 by 67november