I hold a PPL/SEL and I'm training for a helicopter addon. I'm training in a Robison R22 which is subject to SFAR 73. Can I log my solo training hours as PIC time? FOr student pilots, with solo endorsement, I believe the answer is yes.

However, SFAR 73 2.b.1.ii says, "no person may act as PIC of an R22 unless that person ii) Has had at least 10 hours of dual instruction and has received an endorsement from a CFI..."

Is this a different endorsement from the solo endorsement, which I obviously have to fly my solo flights?

The reason I ask - I want to know if my time flying solo counts as PIC time toward my commercial requirements.

  • $\begingroup$ Your quote says “act as PIC”. Since you definitely do that when flying solo, it means exactly the solo endorsement. $\endgroup$ – Jan Hudec Feb 24 '18 at 18:40

Solo time is always PIC time. You're alone in the aircraft, so who else could be PIC?

14 CFR 61.51(e)(ii):

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-


(ii) When the pilot is the sole occupant in the aircraft;

  • $\begingroup$ You would think so, I'm unclear if there is a difference between who is PIC in terms of responsibility for the aircraft and logging PIC time for the purpose of additional certification. $\endgroup$ – user28642 Feb 24 '18 at 18:26
  • 2
    $\begingroup$ Acting and logging PIC are indeed different things, but if you're the only pilot on board then you're doing both. $\endgroup$ – Pondlife Feb 24 '18 at 18:37

The solo time counts as PIC as the answer above states, since you are the sole occupant of the aircraft, however ..., the legality of you flying solo before getting the training required by SFAR 73 is more than questionable. In other words your instructor should have provided the training (and the 10 hours of dual) prior to signing you off for a solo. Additionally, while not relevant to the question, since you have a PPL/SEL, you are not a student pilot (for example you do not need a cross country signoff to fly a cross country, although you still cannot carry passengers because you are not rated in the aircraft). You are simply working on an additional rating.

Finally, SFAR 73 is a different endorsement from your solo and really does provide some important information, as R22 is rather tricky to fly (less so after the blade and the governor were redesigned a few years ago) and has a few gotchas (like the tendency of the rotor mast to snap after too vigorous maneuvering). Get it before your solo, it is worth it.

  • $\begingroup$ Thanks, Just to be clear, I never flew solo prior to having the SFAR73 awareness endorsement, the SFAR73 solo endorsement and the 61.31d2 endorsement. My question was simply about logging the solo time as PIC time towards the commercial ticket aeronautical experience. The answer is clearly yes. $\endgroup$ – user28642 Mar 24 '18 at 21:04

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