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2 Answers

Supervised Pilot in Command in Part 61

Asked by: 709 views Commercial Pilot, FAA Regulations

I am a Flight Instructor in a Part 61 and 141 school. We commonly use the term Supervised Pilot in Command (SPIC). SPIC is typically used when we need a student to solo an airplane for aeronautical experience requirements, but still have a CFI on board just in case to catch any critical mistakes. Example: Commercial student on a long cross-country in a complex airplane.

Recently, a student has approached the school. He holds a Private certificate with Instrument Rating in a Airplane Single Engine Land.  

The student is requesting to do training for a Part 61 Multiengine Commercial Initial check ride. He does not currently hold either a commercial certificate or have any multiengine time. 

This student has requested that as many hours logged as possible be as SPIC for future employment opportunities.

I have reviewed 61.51(e)(iv)(B). It states that pilots may log time when " The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training."


My question is thus: Is a student allowed to log SPIC time under this Part 61 training scenarios? Does the reg cited above mean that SPIC time can only be given out during approved Part 141 training operations?


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2 Answers

  1. Mark Kolber on Sep 16, 2017

    Read the very first requirement in (e)(iv):

    (iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided

    (A) The pilot performing the duties of pilot in command holds a commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;

    Between C and D, you will see the small but meaningful word, “and”. All of the conditions, A through D must exist to take advantage of this rule.

    It’s not well explained, but an “approved pilot in command training program” is an FAA-approved type rating program for pilots who already hold a commercial or ATP in the category and class of aircraft. Think in terms of an airline program.

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  2. Kris Kortokrax on Sep 17, 2017

    I think you have a misunderstanding concerning PIC time. The only way your applicant can log PIC time is if he is in the airplane by himself, or is manipulating the controls of an aircraft for which he is rated. Neither of those two options will be the case while he is training for the ME Commercial certificate, unless he is already rated for ME at the Private level.

    Your use of the term Supervised PIC in reference to time logged under 61.129(b)(4) is problematic. While the regulation allows an applicant to substitute time spent “performing the duties of a PIC” for solo time, that does not mean that he can log PIC time. See the Kuhn legal interpretation:


    Further, the regulation allows the 10 hours done for 61.129(b)(4) to count toward the PIC requirement in 61.129(b)(2). That does not mean that it can be logged as PIC time. There is no provision in the regulations for an applicant to log as many hours as possible as “SPIC” to count toward PIC requirements for either regulatory requirements or future employment.

    Also, there is no requirement that the long cross country for a Commercial certificate be done in a complex airplane. That appears to be a method for an instructor to log cross country PIC time at a student’s expense.

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