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6 Answers

Instrument Student logging actual IFR time as PIC

Asked by: 11974 views , , , ,
Flight Instructor, Instrument Rating, Student Pilot

I am an instrument student.  On friday, my instructor and I took an IFR flight in actual conditions.  I was the sole manipulator of the controls but as a CFII he was responsible for the safety of the flight.  I know I can log the time as actual IFR time but can I also log the time as PIC?

I spoke to two people today and one said yes and one said no.

My interpretation of 61.51 leads me to think I can but I thought I would ask you here.  My instructor is calling the FSDO tomorrow to get their opinion as well.  Here is the (slightly simplified) text from the FAR.

Additionally, I wonder what they mean by an "approved" pilot in command training program.


§61.51 - Pilot logbooks

(e) Logging pilot-in-command flight time.

(1) A private pilot may log pilot in command flight time for flights
(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided
(B) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation-
( 1 ) Preflight preparation;
( 2 ) Preflight procedures;
( 3 ) Takeoff and departure;
( 4 ) In-flight maneuvers;
( 5 ) Instrument procedures;
( 6 ) Landings and approaches to landings;
( 7 ) Normal and abnormal procedures;
( 8 ) Emergency procedures; and
( 9 ) Postflight procedures;

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6 Answers

  1. Best Answer

    Kent Shook on Apr 10, 2011

    You are correct – But not for the reason you think you are. 61.51(e)(1)(i) states that you may log PIC time for any time which you are the sole manipulator of the controls for an aircraft in which you are rated. “Rated” means category, class, and type if applicable (highly unlikely considering you are just working on your instrument rating). So, if you’re a private pilot with an Airplane Single Engine Land rating, and the airplane you were flying was a single-engine land airplane, 61.51(e)(1)(i) says you can log it as PIC. There are numerous FAA legal interpretations supporting this, and I’m surprised your CFI doesn’t already know the answer.

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  2. Nathan Parker on Apr 10, 2011

    You can certainly log the time, but the pertinent regulation is 61.51(e)(1):
    (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
    (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

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  3. MaggotCFII on Apr 11, 2011

    Here is the link to the FAA Letter of Interpretation page, a/k/a
    Legal Interpretations & Chief Counsel’s Opinions
    One can search for specific topics, with or without a year sekected.  As noted above numerous interpretations exist.
    Good to read and see how FAA views their regs!

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  4. XJT on Apr 18, 2011

    If you do not have the instrument rating on your pilot certificate then no you would not be able to log it because in order to log PIC, you must be the sole manipulator of flight control but also need to be rated appropriately. Yes you may have the rating for the aircraft but you can not file IFR in the first place. So based on what you provided, you would not be able to log PIC. hope that helps.

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  5. Jon Anderson on Apr 29, 2011

    As mentioned in the Office of the Chief Counsel’s response to John Speranza letter on 4 Dec 2009
    The FAA previously has stated the term “rated,” as used in § 61.51(e), refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required), and these ratings are listed in 14 C.F.R. § 61.5 and are placed on the pilot certificate. […] for the purpose of logging PIC time under § 61.51 (e), a pilot must hold ratings for the aircraft rather than for the conditions of flight. Accordingly, Pilot B may log PIC time for the portion of the flight during which Pilot B was the sole manipulator of the controls [even though Pilot B didn’t have an instrument rating and was flying under instrument flight rules].


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