Thread: Envoy 2019
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Old 04-17-2019 | 03:06 PM
  #919  
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DBono
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From: Whole lotta sitting
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Originally Posted by DBono
Bumping that thread
That one's closed.


Short answer - technically legal but certainly not advisable, except maybe for insurance purposes.

I didn't contact the FAA, but I found a legal interpretation (Butler 92-40) in which the FAA legal counsel responds that it is legal for a type rated Pt 121 SIC to log PIC time when acting as "sole manipulator" (and it confirms the concept of the PF being "sole manipulator" even in an aircraft certificated for a min crew of 2).
It's here http://www.offhand.org/amb/pic-time.txt
and then search for "92-40" - it's about 1/5 of the way into the document . The FAA legal interpretation list on their web site does not go back that far. Here's the relevant quote.

Your second question asks if the SIC is flying the airplane, can
he log PIC time in accordance with FAR 61.51(c)(2)(i) because he
is appropriately rated and current, and is the sole manipulator
of the controls. Additionally, he has passed the competency
checks required for Part 121 operations, at least as SIC. The
answer is yes.

So legal, apparently, but clearly not advisable based on all the responses to this subject. Clearly meaningless in a 121 environment, but not widely acceptable for Pt 91 either, apparently. So clearly unwise to show up at a 91/135 interview claiming such time as PIC.

But for insurance purposes...…..it IS legal to log it as PIC.
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