Multi-engine time logging
 

I got my multi-engine rating recently in a Twin Comanchee. After couple flights when I was getting relatively proficient flying the plane my flight instructor started logging my time as both PIC and dual received. He gave me a "solo" endorsement (even though the flight school doesn't allow solo in a twin) and said it was legal to log the time as PIC now. When I took my checkride, DPE didn't say anything about that either (but I didn't ask). My question is: is it legal to log PIC time while receiving dual instruction without being rated in a twin? At the time of training I only had commercial ASEL.

Yes. If you look under the requirements to obtain a commercial pilot multi license you need to have so much PIC time. You were technically logging "supervised PIC" time. The solo endorsement was to take the check ride with the examiner as you were not yet rated in the airplane.

This is not correct. Dual and supervised PIC can not be logged at the same time. Once you get the PIC endorsement for an aircraft your not rated you can log PIC while solo or while meeting the solo requirements while being supervised. It doesn't work for dual instruction. If your CFI gave you a solo endorsement you technically weren't legal to fly solo or act as PIC because its the wrong endorsement. The solo endorsement is only for a student pilot. Once you become a certificated pilot you have to have a PIC endoresement for aircraft your not rated to fly while doing the training to fly it solo or for the checkride.

I would bet that if the training was not endorsed or logged properly the DPE just didn't catch it.

exactly... not sure why he would give you a "solo endorsement" when you are already a certified pilot and this is an add-on rating. Many insurance companies flat out will not insure a flight school if they let students solo multi/complex aircraft. So they came up with "supervised solo" time to get around the insurance companies. You should not of logged that as PIC until you were a certified multi-engine pilot.

I have seen this happen multiple times when a student needed a solo endorsement to fly a multi engine airplane even though he was already certificated to do a check ride with a DPE. In fact the DPE has come out and made the instructor endorse the student perhaps we are missing something here. Can't someone choose to log or not log dual instruction? I know at ATP now that they started doing combine PPL/IRA check rides they have supervised solo and XC time. I am not sure how they log it but I think it's strictly a loop hole to obtain the license as you would never solo a multi engine aircraft and the FAA knows this.

You are right. I made a mistake in my original post. It was a PIC endorsement that I got from my CFI, not solo. Does that make it legal to log both PIC and dual time? Is there a Letter of Interpretation from FAA on this subject?

Which makes sense. The examiner is not the PIC during a check ride so therefore for you to act as PIC you would need to have an endorsement although I don't remember having an endorsement for my private multi add on.

Look up solo endorsements in Part 61. A "solo endorsement" is only for a non rated student pilot. It doesn't matter if you have a private airship certificate and working on your helicopter rating you do not ever get a solo endorsement again once you get a certificate. You get the endorsement from 61.31 (d) for acting as PIC when not rated. This endorsement is even pre-printed in the back of Jeppesen Pro Pilot Logbooks.

As for the supervised PIC (solo) vs Dual. Think about it this way. Can you log solo and dual at the same time? No. So how could you log supervised PIC and dual at the same time?

No you still can't log PIC until you are rated except for solo and supervised PIC, not dual. If you read 61.31 (d) it only allows you to log PIC when solo.

I've re-read 61.31 (d) and it talks about serving (or acting) as a PIC. I'm talking about logging PIC time though. The CFI would ACT as a PIC during a training flight. But I'd be the sole manipulator of the controls. Which I think makes it leagal to log this time as a PIC. Am I wrong agian?

What your instructor was probably trying to get at is called PDPIC time. Performing the duties of pilot in command. THIS IS NOT PIC TIME! It is simply an endorsement to satisfy the FAA requirements of "Solo" cross country or "solo" time in a multi. However, your instructor is always going to be with you. I usually make an column labeled PDPIC or have an asterisk next to every PIC time logged.

On the 8710 you log it as PIC and solo time, however your log book should not match this. Because in the FAA's eyes this is technically "solo" time.

You can not log PIC in the aircraft unless you are rated or sole occupant. Which in your case, is neither of those.

THIS^

all of my "solo ME PIC" time without a rating was specifically labeled as such in my logbook.

Yes, If I understand correctly, you're wrong. If you are not the sole occupant of the aircraft, you need to be rated to log PIC as the sole manipulator of the controls.

But I think I may understand where the CFI is coming from. Until a recent change, 61.51(e)(1)(i)'s sole manipulator clause referred to "rated or has privileges." A number of folks (not the FAA) took the position that the 61.31(d) solo endorsement was a "privilege" that counted. I'm not aware of a Chief Counsel interpretation on it but the FAA ended up amending 61.51(e)(1)(i) to make it clear that it was referring to "rated or has sport pilot privileges" which, AFAIK, was always the intent.

Thanks everyone for your resonses, they were very helpful! I hoped I could log that time as PIC, which would help toward 15 hrs of PIC time required for MEI rating. But I had a feeling that I couldn't, so I asked here. Now, what do I do with that time in my logbook, cross it out or just leave it as is?

Depends on how you want to log it. Some prefer different methods.

If you want to log it as PDPIC, then I suggest making a new column and making a new entry today. Put your total PIC mistake in parentheses to signal a subtraction, then add that time into your new PDPIC column. Put in the remarks section the reasoning and dates effected.
or..

You can do the strike-through method and adjust your totals beneath. Both are accepted as reasonable entries. Don't use whiteout it usually looks unprofessional, or you are trying to hide something.

Explain in future interviews that your instructor decided to log it this way. As a "Student pilot" you did not know better. But now that you have evolved into a "professional mature" pilot you have corrected the time accordingly.

I did my commercial initial in a multi and I had to do the supervised PIC thing too. My CFI wrote it into my logbook under both the "PIC" and "Dual Received" columns. I now understand that to be incorrect, but the two different DPE's I used for my multi initial and single addon didn't say a word about it.

I don't think it supposed to count, but it depends on the FSDO. I know at least one that will count it towards the 15 hours of PIC (or at least as of two years ago allowed it).