logging PIC times on an AOC listed helicopter?

[Reely340]

A company operates an EC120B, for commercial passenger transport. Therefore it is an "AOC" that has a register of "ready for service" aircraft, I'd guess.

Currently I'm paying a relatively tiny unofficial fee to be allowed to sit in the copilot's seat, all unofficially. I help with loading and unloading of passengers and their cargo and am a very happy camper, mostly watching the pro CPL show his proficiency, among other things covering up forgetting to release the rotor brake ;) Needless to say I don't log anything.

Here comes the question:

Should I someday have acquired a TR for EC120B may I operate as PIC and log PIC time when a company registered CPL is with me, who "doesn't need any more hours logged"?

That way I could accumulate PIC hours at minimal cost, albeit when and how this happens is out of my control, naturally.

The AC logbook would have "him/me" as pilot, and only I would log PIC time.
This would be okay with the AC insurance company as a mulit hour CPL enlisted in the AOC would oversee the whole flight.

Rumor has it, letting a PPL operate an AOC aircraft requires the company to do a "ready for service" check thereafter, every time, kinda cleaning the PPL residues off the commercial machine.
Put more bluntly one guy told me "a PPL never can log PIC time on an AOC listed AC, w/o the AOC having to do a documented ready-of-service check after such flight, regardless of a security CPL presents"

So, guys,
a) can a PPL piggy back commercial passenger flights to log PIC time
if the accompanying CPL is ok with that?

b) can a PPL log PIC time on commerical passenger flights for parts of a flight where passengers are not yet/no more present?

Sorry for my wording, having been awarded LPE-level6 not necessarily means being fluent in juridical terminology.

[Bravo73]

Essentially, no you can't.

You gave the reason yourself:
as a mulit hour CPL enlisted in the AOC would oversee the whole flight.

Although you might be doing the flying, it is still the CPL who is 'in command', hence PIC.

[gulliBell]

Logically there can be only one PIC of an aircraft, and that's the person appointed by the operator for that purpose.

[Reely340]

but could a holder (AOC) appoint a PPL as PIC of an AOC aircraft w/o breaking the law?

Maybe only for that portions of the flight where no passengers are on board? (like ferrying the a/c to the destination or back home)

The accompanying 2nd/security-pilot would be necessary to fulfill insurance terms only. (after 150h PIC time the insurance company would be ok with me as PIC w/o backup)

[Captino]

Well I think on the ferry flight its fairly easy just hop on the right seat than PIC time is all legal! The CPL will perform his safety pilot duty from the right, here is the tricky bit I don't know if the safety pilot needs to be an FI, I guess not. He just needs to be appointed by the boss. If he his a FI though you can log PIC time even without a Type Rating, but that's just legal if you complete the TR within 6 month otherwise you might get in trouble if somebody starts asking questions!

So I think if you get your TR and do the ferry from the right seat with your safety on the left, the time is totally legal!

Cheers
Captino

[Reely340]

@captino
That sounds very reasonable for me. I can see that only the "non commercial" ferry part is PPL PIC-able, the "real passenger/cargo" part, which requires a CPL as PIC , is sightseeing fun only.
The great thing is, the flight last time would be > 50% ferrying, e.g. of the total 2h08 flying time 1h10 were w/o passenger, hence eligible for me as PIC.
(1h10 @ 400€ in an EC120B is hard to beat, methinks)

Next questions:
1) Do you know if the insurance "typically" might not cover me PPL as PIC, even when security pilot is accompanying?

2) any reason why AOC rules might object to PPL PICS in AOCed machines?

TIA
Peter

[GoodGrief]

You're opening a can of worms here.
PPL as PIC with passengers - No.
PPL as PIC without pax (ferry) - Yes,as self fly hire for example.But then again some voices say no, because the flight is paid for by the customer, i.e. the empty return leg.
CPL as safety can't log PIC.

In some countries AOC work is exempt from fuel tax and only applicable to pilots listed in that AOC.
A PPL as PIC in the techlog would levy a fuel tax on the PPLs flight time.
Techlogs are checked every year by the taxman...
Flight instruction (TR) on an AOC only for employed CPLs, PPL can only train in a TRTO / FTO or whatever the new EASA slang is.
And you can't log copilot time on the little birds.

[Helinut]

Just a word of caution here. The rules do vary with the aviation authority. I remember a pre_JAA discussion where the USA pilots suggested 3 pilota might be able to log PIC time, in the right circumstances. So the answer may vary depending upon whose rules you fly.

[GoodGrief]

I forgot:
What do the country regs or the ops manual say about the dual controls and passengers in the left seat?
That's what you are, a non commercial non rated pilot, hence a passenger.
It doesn't matter whether you have the ability to control a helicopter or not.

Some regs/manuals say the duals have to be removed.

Currently I'm paying a relatively tiny unofficial fee to be allowed to sit in the copilot's seat, all unofficially
Promoting tax evasion publicly isn't a good idea, either.

[Captino]

@reely340

With insurance none is like the other... So that's something you need to ask the operator of your 120. Insurances normally get cheaper if the PIC has a TT of 1000 hrs. Hence most operators will employ mostly pilots who meet that requirment, but there are exceptions from that common phenomenon... So the only thing you need to do is to ask you operator!

Captino

[gulliBell]

Well I think on the ferry flight its fairly easy just hop on the right seat than PIC time is all legal!

If you're sitting in the right seat as PF, and the "for insurance purposes only" pilot is in the other seat as PNF, and the donk quits enroute, or some other malfunction happens to the aircraft, who gets the deciding vote as to what to do? If it's you, as PIC sitting in the right seat, log PIC time. If it's the other guy, he's the PIC all the time. That's the way I think of it.

[idle stop]

In the UK, (and, I presume the rest of EASA-land), for any Commercial Air Transport flight, the ‘second pilot’ in:
• A helicopter certificated for single pilot operations
• And, if configured for 9 or fewer passenger seats, and not additionally required by the AOC to operate with two pilots
• (and in this case the Operations Manual must also specify procedures for 2-pilot ops)

….has no status, and may not be part of the operating crew unless:
• a CPL (H) or higher qualification, and
• Type rated, and
• Current OPC on type/class, and
• Current Line Check on type, unless:
o undergoing line training (if and where permitted) on a revenue Commercial Air Transport flight, in which case Pu/t or P2, or
o If he is undergoing a Line Check as if the Commander, which, if successful, may be logged as PiCu/s.

The UK CAA produced a circular (FODCOM, probably now in CAP 789, ‘Guidance to Operators’) a few years back reminding AOC operators that a so-called ‘Pilot’s Assistant’ (ie not meeting the above requirements) must not in any way be involved in the operation of the aircraft on a CAT flight. I guess opening and closing the pax doors on the ground is allowable though!

In general, at any time only the Commander of an aircraft may log PiC time; a second pilot may be able to log PiCu/s or P1 for the time he/she actually is in charge of the flying controls, otherwise P2 (but only if it is a 2-pilot certificated aircraft) or Pu/t (Dual) if undergoing instruction.

A ‘safety pilot’ for insurance or lookout purposes cannot log flight time. He/she is just an extra well-qualified pair of eyes. (However, for safety reasons the how and why of any intervention by the SP should be pre-briefed by the Commander!)

Perhaps others can add to this or correct any of my errors in the above, doodled in a hotel room….

[Reely340]

@GoodGrief
Correct, today I'm a pax. My question was aimed at finding out what a TR for EC120 would do me good if I keep getting "invited" to be PIC on the ferry portions of said AOC machine.

If I as a TRed PPL cannot legally log PIC time on an EC120 other than dry leasing the whole machine myself (~1100€) plus paying a multi hour CPL to sit beside me for insurance reasons, then the TR ain't worth acquiring.

If I as a TRed PPL can legally log PIC time on ferry legs on an AOC machine that would be the cheapest way to accumulate PIC time on an "normally prohibitively expensive" (rel. to Hu269) aircraft.

Currently I can fly on my own a HU269 @~500€/h all inclusive, when ever I want where ever I want

Or I can sit in the "CoPilot"-seat of an EC120B or B206B3 paying 200€/h or 300€/h resp. and get to experience cool off-airport landings, beautiful Alps crossing etc. when the operator wants to fly, to/from where the operator wants to fly. I don't have any problem being thrid-party driven, my schedule permitting, doing off-airfield landings is de facto off limits to PPLs over here.

But as I learn here, there's no simple way to log PIC time on these turbine extravaganzas even after acquiring the TR. I'm increasingly curious where the CPLs get their impressive PIC times from, actually more hoe they paid for them.

[Reely340]

@idle stop
That's totally ok with the CPL accompanying the TRed me on the ferry portions of the flights. He/She "doesn't need an more hours, You can log them and be PIC".

My concer is if that combo PPL_PIC + CPL_2nd_set_of_eyes is legally possible in an AOCed aircraft on ferry legs (w/o Pax)

[GoodGrief]

No offence, I know how hard it is to come by the hours, but now you pay a lot of money and you get nothing.
You'd be better of saving up a little and head over to the east coast of the USofA.
Currently you get an R22/HU269 for under €240 per hour including an instructor.
You learn much more doing that than just looking out the window of a 120.

Might as well get your night rating and IFR that way.
Roundtrip flights from Vienna to Orlando are cheap, the equivalent of about two flight hours...

[idle stop]

Reely:
The EC120 is a single pilot helicopter. Unless you are under instruction for a check or qualification by an appropriately qualified Commander, or you are the actual aircraft Commander, you cannot log time on the dead-leg or ferry flights.
Sorry, that's just how it is: in Europe at least.

[gulliBell]

Understand that being PIC is not about being the person driving from A to B, it's about being the person who is legally conferred with the responsibility and sole authority to make the command decision about the final disposition of the aircraft. If you're flying solo, that's you. Otherwise if there are any other number of pilots on-board, somebody has to be the sole authority. There can't be any ambiguity who gets the deciding vote in any decision...whoever that is, he's the PIC.

(I know our friends in the US have a different perspective on this, so the previous advice from GG is good...go to the US and get your PIC time there, cheaper and legal within that jurisdiction).

[Bravo73]

Understand that being PIC is not about being the person driving from A to B, it's about being the person who is legally conferred with the responsibility and sole authority to make the command decision about the final disposition of the aircraft. If you're flying solo, that's you. Otherwise if there are any other number of pilots on-board, somebody has to be the sole authority. There can't be any ambiguity who gets the deciding vote in any decision...whoever that is, he's the PIC.

And added to all of that, who signs the tech log? That ultimately decides who is responsible for the aircraft, hence 'in command'.

[gulliBell]

In those operations which I am familiar with either member of the operating crew can sign the tech log, no problem at all...I have flown as PIC countless times without signing the tech log, but I always check it prior to the first flight of the day to double check that everything is in order (and will sign if the co-pilot hasn't already done so).

[Bravo73]

In those operations which I am familiar with either member of the operating crew can sign the tech log, no problem at all...I have flown as PIC countless times without signing the tech log, but I always check it prior to the first flight of the day to double check that everything is in order (and will sign if the co-pilot hasn't already done so).

That's different to the way that we operate. Only the P1/PIC signs for the aircraft. After all, it is ultimately his/her responsibility.

[Reely340]

I hereby summarize:

- as PPL with TR
- being officially assigned PIC by the operator for the ferry portions of a flight
- assuming all duties of a PIC while ferrying
- signing the tech log as PIC afterwards for that portion of the flight

you guys don't see any problems even if the machine ist listed in an AOC.

What remains to be checked is the eligibility of the AOC for tax reduced fuel if a not AOC listed PPL is doing the ferrying as PIC.

To please the insurance it doesn't hurt to have a pax termed "safety pilot" in the left seat.

Is that correct so far?


Peter

[gulliBell]

Yep, a tick in all those boxes should qualify you for the time (from my angle the important ones are TR, assigned PIC by the operator, and carry out PIC duty).

[pilot and apprentice]

I think 'not for hire or reward' might come into play if the customer is paying the operator for the ferry hours.

The litmus test I would use is....would the operator go through with this if the duals were not installed?