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Logging PIC time

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Commercial Pilot, FAA Regulations, Flight Instructor, Instrument Rating

I just took my MCE and have completed my simulator training for C-130Js. Previous to that I flew T-44C and T-6B Texan IIs. Total I have around 300 hrs. My question is regarding what I can count as PIC time in my training to apply toward a single and multi-engine commercial instrument rating? I am not a designated Aircraft Commander yet, but I have been the "sole manipulator" of the controls, including around 12 hrs of solo flight. Can simulator time count if it is a full motion, full visual (the C-130J sim is where we do all out Fleet Replacement Squadron training)? In a logbook, does "First Pilot" time equate to PIC time?

2 Answers



  1. Mark Kolber on Aug 09, 2015

    Sine you haven’t received a response, and I haven’t had any experience with the issue directly, some ideas for you to research:

    1. The starting point is FAR 61.73 which deals directly with the application of military flight time toward private and commercial certificates and instrument ratings.

    2. There is a recent (2015) FAA Chief Counsel opinion dealing with 61.73 – http://bit.ly/2015Walker It deals with the transfer of flight instructor privileges but may have some helpful thoughts.

    3. I did a brief search and couldn’t find any, but I recall a few websites that claimed to hep with the conversion, including an electronic logbook that would allow entry of flight time based on various certificating authorities. I did find this pdf, though, which discusses a number of the issues (including your “First Pilot” as 61.51 PIC time question): http://www.aptap.org/logging%20pic.pdf

    4. If you don’t the qualifications for 61.73, you are stuck with what I think is the general rule that when applying for a certificate or rating, you need to meet the qualifications as defined by the certificating authority. IOW, time spent by you as the sole manipulator of the controls of a military aircraft you had the military equivalent of FAA “ratings” for, would be countable toward FAA PIC requirements, whether or not you were the command pilot.

    Sorry I couldn’t be more help than that

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  2. Best Answer


    Kris Kortokrax on Aug 09, 2015

    The fact that you have taken the MCE suggests that you are aware that you may apply for and receive an FAA Commercial pilot certificate with Airplane Single and Multi-engine Land ratings and an Instrument Airplane rating based on your military experience.

    This presumes that you have the documentation outlined in 61.73(h).

    It boils down to having
    1. Orders assigning you as a pilot in the military,
    2. A graduation certificate from the pilot training course.
    3. Copies of pilot proficiency checks for single and/or multi-engine airplanes and an instrument proficiency check.

    If you will be rated in the C-130, you should also receive an L-382J type rating as well.

    You do not need to worry about counting any time towards ratings which you can receive based on your military qualifications. If you did need to use your military time, 61.41(a) allows you to credit your military time toward the experience requirements for a certificate or rating.

    Don’t waste your money on a flight school for training you don’t need.

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