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4 Answers

Yet another question on logging PIC!

Asked by: 2895 views , ,
FAA Regulations

How do I log time in the following circumstances:

Me: Comm. Inst. SE & ME (no type ratings)

A/C: DHC-8 

Operation: Part 91

How do I log this time?  The time that I'm in actually manipulating the controls - PIC?  Or since I don't hold a DHC-8 type rating is it all SIC as long as I maintain the 3 bounces in the last 90? (FAR 61.57)

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4 Answers



  1. keith on Oct 24, 2011

    Great question! There are many people in this kind of circumstance flying king airs and other large aircraft. The bottom line is if it requires a type rating you must have one to log pic. Unfortunately that is the only way. If the airplane itself was certified requiring two pilots than you can log sic if you have the required and documented training. If your insurance requires two pilots it is still not totally legal to log the flight time as sic since insurance is not the FAA. In reality you can log whatever you want, its your logbook, you just cannot use that flight time to apply for any future rating (meaning if you have 500tt before logging any and you acquire 500 in that airplane then when you go up for your next rating whatever it is, you still only have the 500tt not 1000). I know its frustrating, we’ve had this discussing many times with the FAA at my 135 operation.

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  2. Wes Beard on Oct 24, 2011

    The type certificate data sheet (TCDS) requires two pilots for the DHC-8.  Since you do not have a type rating you cannot log PIC time as Keith stated above.  You are referring to §61.51(e)(1)(i) when you are manipulating the controls and that regulation states “for which the pilot is rated”.
     
    You can log SIC time (the whole flight) per §61.55, instrument time as well as cross country time, turbine jet time and multi-engine time; just not PIC time. 
     
    In reference to §61.57, a SIC is not required to have landings within the preceeding 90 days according to the FAA.  The regulation is specific to the pilot in command (which is not necessarily the pilot logging PIC time).

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  3. jeff on Jan 30, 2015

    Related question: during a type rating checkride for a student that has comm/multi/instrument for. CE500 series citation, the examiner insisted that my student was PIC for the flight. It is my understaning of the regs (and i have searched for chief counsil opinions too) that since the student does not have his type rating during the actual check ride that he can not act as PIC nor log PIC time, unlike many other types of check rides. Am i missing something or am i correct. Thanks

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  4. Mark Kolber on Feb 01, 2015

    Jeff, 61.47(b). Even a student pilot on his very first checkride is considered to be PIC simply because the Examiner is not.

    You say “unlike many other check rides”. What do you see being different about the type rating one? What are the different rules you see applying?

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