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6 Answers

Logging PIC time

Asked by: 493 views FAA Regulations, Flight Instructor

My CFI certificate expired 6 years ago and I am currently working on a renewal. I have been logging my flight time as PIC. Can I technically do this since I have not received the 1 hour ground training required by 61.56(a)? 61.56(g) offers an exception for student pilots. But does "student" refer to the holder of a student certificate or to anyone receiving training?

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6 Answers



  1. Ken White on Aug 06, 2017

    Logging and acting as PIC are two different things. If you are are the sole manipulator of the controls of an aircraft you are rated for then you can log that time as PIC irregardless of your ability to act as PIC. If you are not able to act as PIC you would obviously need to be flying with someone who can. Whether or not they can log the time depends on if they are a CFI giving you instruction, or if you are under the hood but that’s another discussion. 61.51(e) is your reference for this one.

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  2. Mark 2 on Aug 06, 2017

    It seems like 61.56(c) defines who is eligible to log PIC time (those who have completed a flight review) and 61.51(e) defines what PIC time actually is (sole manipulator, sole occupant). So if I’m not eligible by 61.56(c) then I can’t log time defined in 61.51(e). Or am I just reading this stuff wrong?

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  3. Ken White on Aug 06, 2017

    You’re really just reading this stuff wrong. 61.56(c) specifically uses the word “act” and never uses the word “log” so it can not be giving direction on how to log something. 61.51(e) clearly uses the word “log” and never tries to define what pilot-in-command means. Be careful not to read into the regulations something that is not there.

    Go to the FAA Legal Counsel’s website and search for the word “logging”. You will find plenty of interpretations that deal with the difference between acting and logging PIC, each of which will reference 61.51(e) in some way. Don’t worry it is a widely misunderstood subject.

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  4. KDS on Aug 06, 2017

    Mark, what you’re doing is “reinstating” your CFI, not renewing it. It’s a small point, but it would be better to use the word “reinstate” when talking with your examiner.

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  5. Mark Kolber on Aug 09, 2017

    You are looking at the wrong rule. 61.56 defines who is eligible to act as pilot in command in certain situations. It does not define who is eligible to log PIC time.

    61.51, on the other had, does. I like to refer to it as “the Universal Rule of Logging Flight Time.” If you have been out of the loop for a while, you probably have not seen the numerous discussions in recent years on this topic. But the essence is, logging flight time is a concept created by the FAA to record time toward certificates, ratings, and currency. It has almost no relation at all to the requirements for acting as the PIC or as a required crewmember.

    You might want to take a look at the summary of the rules on my website at http://midlifeflight.com/question/when-may-i-log-pic-time/

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  6. Mark Kolber on Aug 09, 2017

    BTW, the rules aren’t new, just the discussions. There are consistent official FAA Chief Counsel interpretations on the subject going back to at least 1980.

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