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How to log time in aircraft I’m not type rated in

Asked by: 1361 views FAA Regulations

I periodically perform aerial photography shoots.  The photographer flies in a Bonanza or a Seneca and the owner of the subject aircraft hires me to fly his/her plane in formation off the photo ship.  Many of the aircraft do not require type ratings but some of them do.  How do I log my time in these aircraft since I'm the sole manipulator of the controls during the formation work?

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2 Answers



  1. Kris Kortokrax on Dec 14, 2022

    Since you said you were sole manipulator during the formation work, I’m assuming that there is another pilot on board, who has the type rating and can act as PIC.

    61.51 deals with logging time.

    You cannot log solo time (61.51(d)), because you are not the sole occupant.

    You cannot log PIC time , because you are not solo (61.51(e)(1)(ii)), you are not sole manipulator of the controls of an aircraft for which you are rated (61.51(e)(1)(i)), you are not acting as PIC (because you can’t do that without the type rating) of an aircraft that requires more than one pilot (61.51(e)(1)(iii)), you are not getting training under an approved PIC training program (61.51(e)(1)(iv)), you are not rated to act as PIC (61.51(e)(2)), you are not instructing in the aircraft (61.51(e)(3)), you are not a student pilot (61.51(e)(4)) and you are not part of an SIC PDP (61.51(e)(5)).

    If you had undergone SIC training for the aircraft (61.55) and were current under 61.55 (b), you could log SIC time, if the aircraft requires two crewmembers. So yes, if you are in a G-IV, no, if you are in a Vision jet, Eclipse, CE-525 or any other aircraft that requires a type rating, but does not require two pilots. You would be flying under Part 91, so 135 requirements for two pilots would not apply.

    You would not log instrument time, because formation work would not be done in IMC.

    You would not log training time (dual) because you would not be receiving instruction during the time you were manipulating the controls (you already know how to fly S&L and do turns, climbs, descents), even if the other pilot were an instructor.

    You would not log cross country time, because you did not perform the takeoff, landing and were not manipulating the controls for the entire flight.

    You could certainly put a line in your logbook showing the date, make/model, departure, destination, remarks for the flight without recording the time (unless qualified as SIC).

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  2. Mark Kolber on Dec 17, 2022

    If the airplane doesn’t require a type rating, you can log your sole manipulator time as PIC if you have the appropriate category/class rating. ASEL for the Bonanza. AMEL for the Seneca,

    Based on your description (for example, you say nothing about receiving instruction from a CFI), if it requires a type rating, you have nothing that counts for anything loggable. Nice for a scrapbook, perhaps.

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