Originally Posted by
rudestuff
I can't believe this has gone on so long - the FAA allow a pilot to "log" PIC any time they are sole manipulator of the controls of an aircraft for which they are rated. PICUS on an EASA aircraft obviously satisfies that.
The only grey area is if the EASA type rating has a "no pic" endorsement, which could be construed as you can't log PIC. A bit of logical reasoning will conclude that's bollocks: it simply means you can't sit on the left. EASA specifically allow you to log PICUS from the right seat to get the hours for an ATPL so that you CAN sit on the left - which is exactly what the issue is here.
Actually, it's not a grey area. FAA Interpretation to Glenn Counsil dated Apr 13, 2012 specifically outlines that a type rating limited to SIC privileges only is not a "rating" for the purposes of 61.51(e)(1). Thus the only avenue for logging time when the SIC does not hold a full PIC type rating is under 61.159(a)(5)
for the purposes of earning an ATP.
The FAA has answered all the questions in the past regarding the "performing the duties of PIC while under the supervision..." in their now discontinued FAQ. The SIC who is "performing the duties of PIC" does not have to be in the left seat, nor does he have to be undergoing any kind of PIC training at the time. He does not have to have a PIC type rating under this provision. The FAA does recommend that the actual PIC sign the logbook of the SIC performing the duties of PIC, but this particular provision does not require such an endorsement. He DOES have to be serving as a REQUIRED second-in-command in order to qualify under this provision.
Mine is a little more than an amateur opinion. I am a former airline Aircrew Program Designee (examiner) responsible for scouring through logbooks and making sure airline pilot trainees met the requirements of the FARs before conducting an ATP/Type Rating check ride and (if all went well!) issuing them a certificate. While we did not see a lot of candidates with foreign experience, there were a few.