tgrayson
New Member
If a type rating is required, and the pilot has a SIC limitation on his rating, then he cannot log PIC for sole manipulator time. Here's a clip from FAA notice 8000.351 (Procedures for the Second-In-Command Pilot Type Rating). Although it's now expired, it listed a variety of Q&As when the SIC ratings were first announced.
I agree that this order is more in line with regulation than the LOI that I posted. The only quibble is that the answer said "pilot is not qualified as a PIC in the Boeing 737". That itself isn't the important criterion, but rather that the pilot doesn't have the type rating. If he does, then and only then should he be able to log the PIC time. There may be other reasons he isn't qualified to ACT as PIC, but that's not relevant.
As I said, I don't like the interpretation and it seems to contradict the regulation and the order you posted. But there it is.