Posted 6 years 276 days ago ago by Randy Rowles
The subject of solo requirements for the addition of a helicopter rating to an existing commercial pilot certificate, when the applicant does not hold a helicopter rating at any level, is a question not easily answered. To get the correct answer, you must look at more than just the experience requirements as stated in 14 CFR Part 61.129(c). Additionally, the method in which a pilot would log the pilot in command (PIC) flight time is confusing. In this article, we’ll attempt to provide some clarity on these subjects.
An applicant for an added helicopter rating to an existing commercial pilot certificate will all too often arrive at their checkride and not have adequate experience to be eligible for the practical test. In these cases, the applicant may have spent thousands of dollars only to discover that they cannot use those hours toward the rating for which they are applying. This can be a devastating—and often career altering—revelation.
Within 14 CFR Part 61.129(c), guidance is provided regarding the solo requirements to meet the minimum experience for a helicopter rating. The part reads:
“Ten hours of solo flight time in a helicopter, or 10 hours of flight time performing the duties of pilot in command in a helicopter with an authorized instructor onboard.”
The question that often arises from this statement is: Should the pilot, when performing PIC duties with an instructor onboard, log this time as solo or as PIC? In this case, the pilot could not log solo because he or she was not the sole occupant of the aircraft (Ref. 14 CFR 61.51–Logging of Solo Flight Time). The correct method of logging this time would be as PIC, but it is important to provide clarity that these hours were logged PIC prior to obtaining the helicopter rating. A successful method for doing this would be to place an asterisk (*) next to each logged hour. At the bottom of the logbook page, note that the asterisk reflects PIC time earned in accordance with 14 CFR 61.129(c)(4). This simple effort provides clarity to the FAA inspector or pilot examiner, and validates the method of which a non-rated applicant may log PIC with an instructor onboard.
In this example, only 10 of the 35 PIC hours required for addition of a helicopter rating to an existing commercial pilot certificate is remedied. How do you handle the remaining 25 PIC hours required? They must be logged as solo flight time. Why? There are two reasons: Firstly, 14 CFR 61.51 (Logging of PIC Flight Time) states the requirement to log PIC time. Clearly this pilot does not meet those requirements, except for the 10 hours as described in 14 CFR Part 61.129(c)(4). Secondly, the opinion issued by FAA Legal Interpretation (Crowe-Palm Beach Helicopters/February 2013) addresses both issues in detail.
Truth be told, the intent when re-writing 14 CFR 61.129(c)(4) was to eliminate the solo requirement for the addition of a helicopter rating to an existing commercial pilot certificate. The selected wording did not make that happen. To summarize: Yes, a person adding a helicopter rating to an existing commercial pilot certificate must solo. Remember, the appropriate solo endorsement in this case would be 14 CFR Part 61.31(d)(2) … but that’s for another article.
Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award. Randy is currently Director of Training at Epic Helicopters in Ft. Worth, Texas.