logging PIC in R22

[mattpilot]

Q....

I got a RH rating, but all my time is in a Bell 47.

I started doing some flying in the R-22 (gawd, its like half the size of the -47 ), and i was wondering if i could log that time as PIC, before i even get the SFAR sign-off.

Now, i realize the SFAR specifies you must have 10 hours & a signoff in the -22 to be PIC. What i'm wondering is, since i'm rated in category and class, could i log PIC under the stipulation that i'm the sole manipulator (receiving flight instruction)?

What i'm getting at is kinda similar to Airplanes & the Complex/High perf endorsement. YOu need to have the endorsement to be PIC, but while you are flying it with a flight instructor, you can log PIC because you are rated in Category/Class (according to the local DPE's here).

The instructor doing the SFAR R-22 training says i can't log PIC... so i'm just wondering what you guys think.

 

[nosehair]

The instructor doing the SFAR R-22 training says i can't log PIC... so i'm just wondering what you guys think.

He's just as confused as I used to be. I used to think you had to be able to ACT as PIC to LOG PIC. That ain't true. 61.51(e) applies to all aircraft - not just airplanes. Yes, the word rated in that FAR means the rating on your pilot certificate. If you have Rotorcraft-Helicopter on your pilot certificate, you can log PIC anytime you are the sole manipulator of the controls of any helecopter You don't need the endorsement to log it, you only need the endorsement to act it.
I don't like it, I think it is a complete oversight by the FAR makers, but it is the FAR.

 

[mattpilot]

Thx for the reply - was worried for a sec that no one would answer . I guess the word "act" is the keyword and i'll present the case as such the next time i'll see him.

I don't like it, I think it is a complete oversight by the FAR makers, but it is the FAR

I like it! Will save me roughly 1000$ getting the 35hours PIC required for the CPL.

 

[mattpilot]

Unfortunately the instructor doesnt' like that explanation for various reasons. I even showed him something from the FAA's Part 61 FAQ authored by John Lynch, which IMO is pretty clear. It doens't name the R22 by name, but it mentiones other endoresments (like complex/ high perf) where John says you can LOG pic because you are properly rated (e.g. you got the category & class) - an endorsement is not a rating, thus doesn't apply. The instructor in question can't seperate 61.31, acting PIC, and 61.51, logging PIC.



He wants something close to a certified letter from the FAA that mentiones the R22 by name. I don't suppose anyone of you guys could help out with that?

Thanks in advance.

 

[Sim Sweat]

Garbage

That's absurd. How about spending your hard-earned money with a different CFI?

If you're rated in category and class, you can log PIC. Have him call Robinson and talk to Tim Tucker. They wrote the d4mned SFAR.

 

[mattpilot]

Have him call Robinson and talk to Tim Tucker. They wrote the d4mned SFAR.

ah... thanks for a name

He did call various people, but he is getting different responses from different people, thats why he isn't sure what to do. I understand his concerns, because he has been doing it a certain way for a period of time, and i suddenly come along and confuse everything.

I do believe he called Robinson earlier this week, but i didn't hear the conversation or what exactly was discussed. Thanks for the contact name at robinson - i'll pass that on.

 

[Sim Sweat]

Hope it helps.
They should get a good laugh out of it.

 

[Pilot_Ryan]

Unfortunately the instructor doesnt' like that explanation for various reasons. I even showed him something from the FAA's Part 61 FAQ authored by John Lynch, which IMO is pretty clear. It doens't name the R22 by name, but it mentiones other endoresments (like complex/ high perf) where John says you can LOG pic because you are properly rated (e.g. you got the category & class) - an endorsement is not a rating, thus doesn't apply. The instructor in question can't seperate 61.31, acting PIC, and 61.51, logging PIC.

He wants something close to a certified letter from the FAA that mentiones the R22 by name. I don't suppose anyone of you guys could help out with that?

Thanks in advance.

That really is ridiculous. Sorry, I'm sure he means well, but it sounds like he has a comprehension problem and/or an unwillingness to admit he is wrong. The SFAR does not cancel out your right to log PIC under 61.51, it simply prevents you from ACTING as PIC without meeting the requirements specified therein. Once you're rated in category and class, you're golden... log away.

At one time I was a tailwheel instructor at my old flight school. I routinely came up against pilots who received tailwheel endorsements that were led to believe by their instructors that the tailwheel training they received, AS PRIVATE PILOTS or above, could not be logged as PIC. I have no idea how this sort of misinformation perpetuates. This is not hard to confirm via the regs.

The same sort of instructors who got it wrong with the tailwheel endorsement had a hard time understanding add-on rating helicopter students. Seems many never really grasped that a certificated pilot taking dual instruction in a helicopter is NOT a student pilot, he's an "airman seeking additional category/class rating." As such, many of the endorsements required for student pilots are not necessary for add-on students. In fact, it's possible to use one and only one endorsement for their entire solo training segment.

By the way, it really doesn't matter what your instructor thinks. It's your logbook, not his. His only obligation is to sign your logbook with his name, CFI #, date and description of training. Let him know that if he's really hot and bothered with how you log the time, for some reason, to simply leave that column blank when he endorses your logbook; and you'll fill it in, instead of him. He does not have the authority to demand you not log that time as PIC.

Best,

-Ryan

 

[nosehair]

....uh, yeah, you're going to get different answers from different people, because we all are confused by words and concepts of Pilot in Command. I'm one of the old die hards who, until just a few recent years ago insisted that 61.31 requirements, as well as SFAR 73 about the Robbie had to be done to be "rated" in the machine. And you do to ACT as PIC. That's where it takes lots of head bangin'. All thos regs say "To act as PIC, you must..."

61.51 doesn't say ACT, it says LOG. "To LOG PIC, you must..."

And you don't have to do what your instructor says as far as the logbook goes.
It is legal, and everybody logs dual & PIC in an aircraft for which you have the rating on your certificate, ie. 61.31. That's fine for meeting PIC requirements for other certs & ratings.

Just do it.

 

[KigAir]

I have a friend who didn't log any of his instrument training time as PIC, only dual. I asked him why, he was rated for the aircraft. His instructor told him that it wasn't possible to log dual time as PIC, even though he was rated for the aircraft .