I hear this question fairly often when a student (who already has their private pilot certificate earned in an R22) starts training in an R44: “When can I start logging PIC time in the R44?“. The question arises because of SFAR 73 and it’s requirement for time in an R44 before you can act as PIC in the R44. The specifics of the requirements are explained (along with other parts of SFAR 73) in our SFAR 73 Explained article.
The Question
When can I start logging PIC time in the R44?
Confused R22 Private Pilot
The confusion often arises because the rated pilot usually* needs at least 5 hours of training in the R44 before they can get an SFAR 73 R44 PIC endorsement to act as PIC.
*Usually, but there is another pathway if the pilot has 200 hours total helicopter time, see here.
…No person may act as pilot in command of a Robinson R-44 unless…10 hours dual instruction in a Robinson helicopter, at least 5 hours in the R-44 and received an endorsement…
SFAR 73
The Answer
In this scenario, if you are a rated helicopter pilot, as soon as you start receiving flight instruction in the R44 you can log PIC time, even if you don’t have the SFAR 73 R44 PIC endorsement to act as PIC in the R44. The FAA regulations make a distinction between acting PIC and logging PIC and there are lots of possible scenarios where logging and acting are not the same thing. For this situation, refer to 61.51(e):
…private, or commercial pilot may log PIC time for the time during which that pilot is “the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges.”
61.51(e)
There is a 2009 FAA legal interpretation regarding a rated pilot being able to log PIC, even if they do not have the required PIC endorsement. In that interpretation the FAA is specifically answering a question about a rated airplane pilot logging PIC time while receiving training for complex or high performance airplanes before they receive an endorsement to act PIC in those aircraft.
…the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC
Herman 2009 FAA Legal Interpretation
DISCLAIMER – make sure you are fully informed on the latest regulations and their application.
For official guidance on laws and regulations, refer to your Certified Flight Instructor (CFI) or local Flight Standards District Office (FSDO) . Helicopter Training Videos aims to promote aviation knowledge and safety but makes no guarantees regarding accuracy or legal applications.
References
More Info
- Watch our SFAR 73 Awareness Training video
- Check your knowledge with our SFAR 73 Awareness Training Quiz
- Read our SFAR 73 Explained article
- See our How to Mark-Up SFAR 73 in the FAR/AIM video
- Robinson SFAR 73 Website
- SFAR 73 regulation in full
Feedback
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