Logging PIC time while working on R22 endorsement

[psehorne]

Hey Guys and Galls. I have a question about the FARs and SFAR 73.

Regarding LOGGING PIC time:
61.51(e)(1)(i) states that "A ... private...pilot may log pilot in command flight timefor flights ... when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated..."

Regarding ACTING as PIC
SFAR 73(2)(b)(1)(ii) states "No person may act as pilot in command of a Robinson model R-22 unless that person... Has had at least 10 hours dual instruction in the Robinson R-22 and has received an endorsement from a certified flight instructor"

THE QUESTION:
If a pilot has a rotorcraft/helicopter rating [satisfies 61.51(e)(1)(i)] can that pilot log PIC time the hours during which he/she is working on the Robinson R22 endorsement?

Note the the FARs do not prefix SFAR 73(2)(b)(1)(ii) with "Nothwithstanding 61.51(e)(1)(i)" and SFAR 73 applies only to ACTING as PIC, not LOGGING PIC time. The FAA makes a definite distinction between ACTING as PIC and LOGGING PIC time.

Interested in your views.

[psehorne]

Let's add a little twist to this.
If a pilot has ASEL certificate, can the time spent working on a tailwheel endorsement be logged as PIC time?

[Ascend Charlie]

Are you REALLY that desperate for the hours?

If an instructor is teaching you, it is Dual. If you are solo, it is PIC / Command / however your country names it. If two pre-wings students are flying, one of you is the captain and logs it all as Command, and the other one can log PIC for only the time they are on the controls.

The PIC time will come once you know how to fly it and have been ticked in the book.

[340drvr]

In the strict legal sense, under FAA rules, both the OP's examples may be logged as PIC, completely legal under 61.51(e)(1)(i).

[psehorne]

Are you REALLY that desperate for the hours?

DESPERATE? No. I just want my logbook accurate.

[psehorne]

340drvr

Thanks for your input.

[psehorne]

I emailed the FAA here is their answer:
Yes, the airman is allowed to log PIC time in a Robinson R-22 as long as the airman meets the requirements of § 61.51(e)(1)(i) provided the airman holds the required category and class ratings to do so. However, the airman may not act as PIC until the airman has received 10 hours of instruction from a qualified flight instructor and received a logbook endorsement in accordance with SFAR 73 2.(b)(1)(ii).

[psehorne]

This would apply also to a high performance endorsement, a tailwheel endorsement, a flight review, etc.