Can I log PIC time: FAR 61.51

7 Answers

1. Best Answer
   
   

   
   

   Kris Kortokrax on Oct 05, 2017

   Yes, endorsements are not ratings.

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2. 
   

   
   

   KDS on Oct 08, 2017

   What Kris wrote is correct. Stated differently; if I can’t tell by looking at your pilot certificate alone that you were not qualified to act as the PIC, then you can indeed legally log PIC time for that time when you were the sole manipulator of the controls. Conventional gear is another example where you could log the time as PIC even though you didn’t have a corresponding endorsement.

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3. 
   

   
   

   Murryn5 on Oct 08, 2017

   Thanks! Just logged my first 1.8 complex/high performance in the Comanche!

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4. 
   

   
   

   Skyman100us on Oct 23, 2017

   No, you cannot act as PIC nor log PIC time in a high performance aircraft unless you have a one time endorsement in your log book or unless you logged PIC time in a high performance aircraft prior to Aug 4, 1997. The same goes for a complex aircraft. Familiarize yourself with FAR 61.31 (e) & (f).

   The responses from Kris and KDS are incorrect and taking their advice can get you in some trouble. For example, if you decide to pursue additional ratings, a FAA examiner may ask to see your logbook. Should he or she discover you logged PIC time without an endorsement, at best, you may be denied that endorsement as that time you logged will not be used to calculate flight time required for the rating being sought. At worst, your certificate may be suspended or revoked. Also, a tail-wheel endorsement is required for acting as PIC and logging PIC time in an aircraft with a conventional landing gear (tail-wheel) unless you logged PIC time in a tail-wheel aircraft prior to Apr 15, 1991. FAR 61.31 (i).

   Unfortunately, that 1.8 hrs you just logged as PIC may not be legal. See FAR 61.59.

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   John D Collins on Oct 25, 2017

   Skyman100US,

   I considered not approving your answer as gross misinformation, but decided to include it so your misunderstanding of the regulations could be pointed out. Although you would be correct to assert the pilot could not act as PIC without the endorsement, logging PIC only requires that the pilot be rated in the aircraft and be the sole amipulator of the controls. Kris is an expert on this and I am sure that any FAA examiner would know that he is 100% correct.

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6. 
   

   
   

   Skyman100us on Oct 27, 2017

   Mr. Collins,
   Thanks for your response. I would like to know how I am misinterpreting the regulations.
   I have read and re-read the FARs pertaining to this subject and think I found the misinterpretation so let me know your thoughts.
   FAR 1.1 defines a pilot in command as the person who;
   1. has final authority and responsibility for operation and safety.
   2. has been designated as pilot in command.
   3. holds the appropriate category, class, and rating for the conduct of the flight.

   This person could theoretically be someone sitting in the back seat and does not have access to the aircraft controls. In fact, there is nothing in the definition that says the PIC needs to actually be in the aircraft during the flight.

   Since FAR 61.51 only address logging of pilot in command time as being the sole manipulator of the controls except for a flight instructor then I would be incorrect in my previous post. My confusion is relating being a pilot in command with logging PIC time which in reality has no such relationship.

   One more point to make sure I have a grasp on this. If I am reading the regulations correctly, I would say that a CFI can log PIC time for a student pilot’s solo flight. Right or wrong?

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7. 
   

   
   

   John D Collins on Oct 28, 2017

   Skyman100us.

   Your statement “My confusion is relating being a pilot in command with logging PIC time which in reality has no such relationship” is the key. There are numerous FAA General Counsel opinions stressing this point. In the US, we use the terminology of Acting as Pilot in Command meaning the person responsible for the safety of the flight and Pilot in Command as a logging category. In other countries, they separate the two terms and call the person who is acting as PIC the Aircraft Commander. Sometimes I think it would be clearer if the US did the same.

   Here is a link to a FAA General Counsel Opinion on the OP topic.

   https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2009/herman%20-%20(2009)%20legal%20interpretation.pdf

   With respect to a CFI logging PIC time for a solo flight conducted by their student, that is not correct. The instructor complies with 61.87(p) and is not acting as PIC of the aircraft when the student is conducting solo flight.

   61.87 (p) Limitations on flight instructors authorizing solo flight. No instructor may authorize a student pilot to perform a solo flight unless that instructor has–
   (1) Given that student pilot training in the make and model of aircraft or a similar make and model of aircraft in which the solo flight is to be flown;
   (2) Determined the student pilot is proficient in the maneuvers and procedures prescribed in this section;
   (3) Determined the student pilot is proficient in the make and model of aircraft to be flown; and
   (4) Endorsed the student pilot’s logbook for the specific make and model aircraft to be flown, and that endorsement remains current for solo flight privileges, provided an authorized instructor updates the student’s logbook every 90 days thereafter.

   61.89 describes the general limitations of a student pilot and when they may not act as pilot in command. In a proper solo flight, they would not encounter any of these limitations and therefore would be acting as PIC. There can only be one person acting as PIC for any flight, so there is no way the instructor could also act as PIC or log the time when they are not an occupant of the aircraft and providing training, even if it was a supervised solo.

   §61.89 General limitations.
   (a) A student pilot may not act as pilot in command of an aircraft:
   (1) That is carrying a passenger;
   (2) That is carrying property for compensation or hire;
   (3) For compensation or hire;
   (4) In furtherance of a business;
   (5) On an international flight, except that a student pilot may make solo training flights from Haines, Gustavus, or Juneau, Alaska, to White Horse, Yukon, Canada, and return over the province of British Columbia;
   (6) With a flight or surface visibility of less than 3 statute miles during daylight hours or 5 statute miles at night;
   (7) When the flight cannot be made with visual reference to the surface; or
   (8) In a manner contrary to any limitations placed in the pilot’s logbook by an authorized instructor.

   Finally, you are anonymous and don’t use your name. That is fine. But Kris and I are willing to contribute to this forum without anonymity. It takes time and effort to answer these questions and for you to do a thumbs down on answers that you don’t understand or disagree with rather than just post your concerns is not warranted in my opinion. Like I said in my first post, I considered not approving your response because it was gross misinformation and only allowed it to clarify your understanding of the regulations.

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