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3 Answers

Does FAR 61.3 Apply to Students During Flight Training?

Asked by: 1908 views FAA Regulations, Private Pilot

Hello all, I had a question regarding who FAR 61.3 applies to when it comes to flight training. I'm currently training in a 141 curriculum towards an instrument rating, and already have my private pilot certificate. My question is, since I'm not PIC during my flights, but am logging dual received, am I required to have my certificate/medical/photo ID with me? I remember hearing something about the student being a required crew-member during flight instruction, so as I interpret the regulations, I'm still required to have my certificates readily available. Is this correct? I was always hounded with "what documents must you carry with you as a private pilot," but never specifically knew if this only applied to a private pilot acting as PIC/required crew-member. Thanks

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3 Answers



  1. Wes Beard on Nov 06, 2013

    Whenever you are a required crewmember you would be required to have your pilot and medical certificates.

    You are a required crew member on training flights per the Kortokrax interpretation. This interpretation states a CFI doesn’t have to be landing current because the student was a required crewmember.

    If the aircraft requires two crewmembers or the regulation you will need to have your pilot and medical certificates. I.e. To act as pilot in command or act as a safety pilot.

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  2. Mark Kolber on Nov 07, 2013

    Wes, I think you go way too far in interpreting the Kortokrax landing currency letter (student pilot not considered a passenger for currency purposes) to make student pilot a required crewmember. A student pilot is specifically prohibited from being a required crewmwmber on any aircraft other than an airship by 61.89(b)

    No, LAX, just like before you ever had a student and medical certificate, you don’t have to have it with you when receiving dual instruction as a student pilot. But it is a good habit to get into.

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  3. Mark Kolber on Nov 07, 2013

    Ah, sorry… I noticed, that you are not a student pilot but an instrument student.

    Same thing. You still don’t have to have it with you when receiving instruction unless you are acting as PIC on the flight.

    What you probably have heard is that on a simulated instrument flight, both the pilot flying and the safety pilot may log flight time – PIC for both if the safety pilot is also acting as PIC. The FAA’s analysis of the rules is that 91.109 makes the safety pilot a required crewmember and therefore the safety pilot logs PIC under 61.51(e)(1)(iii) [PIC when the operation required two pilots] while the flying pilot logs PIC under 61.51(e)(1)(i).

    Despite that analysis, the flying pilot in situations where the safety pilot (CFI in your question) is also acting as PIC is not really a required crewmember. For example, a private pilot-required crewmember must have a current medical.

    But there’s no doubt that, if I have no medical, I may go up with a CFI and he can certainly let me fly under the hood. And, to continue the “student pilot” situation, if the flying pilot were really a required crewmember, hood training for student pilots would be prohibited by 61.89(b).

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