61.31 (D)(2) and logging PIC

[CFI A&P]

Hey everyone,

During some couch flying, someone was stating that an endorsement under 61.31 (D)(2) would allow someone to log PIC & dual received in a new category/ class prior to being rated in the new category/ class.

For example: John the rated rotorcraft-helicopter pilot wants to add airplane single engine land to his certificate. He proceeds to train with a CFI-A in a C152 and solos. At the time in which he goes solo, he also receives the endorsment above. According to a DPE and a few instructors, from that point on, John can now log PIC ASEL when solo AND during any flight when an appropriately rated CFI is conducting training it is also DUAL received AMD and PICksjcbgsdjfhsdvihsdv & PIC &..

This DPE states that this allows the pilot to log more PIC time towards other ratings. I'm not familiar with this, and the DPE says this changed in the last year. The 2011 FAR/AIM shows a change in this area.

Anyone else run in to this yet?

 

[CoffeeIcePapers]

61.51 is where you need to look.

 

[nosehair]

the DPE says this changed in the last year. The 2011 FAR/AIM shows a change in this area.

Where? Ask him where?

 

[MidlifeFlyer]

I'm familiar with the concept and have seen it argued but don't think it applies any more if it ever did.

Here's the concept: 61.51(e)(1)(i) permitted a pilot (other than a student pilot) to log PIC when the sole manipulator of the control of an aircraft for which the pilot is rated "or has privileges. Although the "privileges" part was part of the sport pilot rules and was intended to cover them (sport pilots don't have ratings), a number of folks argued that since the 61.31(d) solo endorsement was a "privilege." I always thought it was just and argument under the law of unintended consequences (you make a rle change for one purpose and people try to wedge it into another).

But the 2009 revision changed 61.51(e)(1)(i) to specifically mention "sport pilot privileges" which took that argument out of the mix.

So I don't know whether the people who are saying it now are rehashing old discredited arguments or coming up with a new one.

So I'll repeat nosehar's question:

Where? Ask him where?

 

[Rotor2Wing]

Well I've been dealing with this as of late. I have been adding my SEL to Helicopter. The cut and dry PIC endorsement says for "SOLO" operation. I have had more than a few people tell me to log it as PIC but is 10-15 hours really worth the grief it could cause down the road at a interview. I decided to not put PIC in my logbook for dual until I get the add-on. It looks like its only going to be about 14hrs anyways.

 

[CFI A&P]

I'm familiar with the concept and have seen it argued but don't think it applies any more if it ever did.

Here's the concept: 61.51(e)(1)(i) permitted a pilot (other than a student pilot) to log PIC when the sole manipulator of the control of an aircraft for which the pilot is rated "or has privileges. Although the "privileges" part was part of the sport pilot rules and was intended to cover them (sport pilots don't have ratings), a number of folks argued that since the 61.31(d) solo endorsement was a "privilege." I always thought it was just and argument under the law of unintended consequences (you make a rle change for one purpose and people try to wedge it into another).

But the 2009 revision changed 61.51(e)(1)(i) to specifically mention "sport pilot privileges" which took that argument out of the mix.

So I don't know whether the people who are saying it now are rehashing old discredited arguments or coming up with a new one.

So I'll repeat nosehar's question:

With Sport pilot in there, that makes sense. Not sure when I'll see that DPE again, but I will ask him.

There is a revision bar next to this area in the FAR/ AIM so it has changed, I don't have an old FAR/ AIM to see how it changed.

 

[MidlifeFlyer]

With Sport pilot in there, that makes sense. Not sure when I'll see that DPE again, but I will ask him.

There is a revision bar next to this area in the FAR/ AIM so it has changed, I don't have an old FAR/ AIM to see how it changed.

Old:
==============================
(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) ...​

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

New:
==============================
(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
(ii)..​

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

btw, be careful of citing a publishers' written compilation of the federal aviation regulations and Aeronautical Information Manual, commonly called a FAR/AIM or and AIM/FAR. They are (a) not official and (b) tend to be obsolete before they ever hit the stands.