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Logging PIC flight time in Army vs. Civilian logbooks

Asked by: 7902 views FAA Regulations, Helicopter, Student Pilot

After reading some Q&A from others on this site, I have to say I got a very good impression of the knowledge and experience many people have on this site.  I hope gain your knowledge and experience in due time. As for my question, I am an Army student pilot and currently filling out a logbook to track my hours separately from the Army.  Can anyone clarify for me what CFR Part 61 says about logging pilot-in-command flight time as a student pilot?  This is the only reference I could find relevant. (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; (ii) When the pilot is the sole occupant in the aircraft; (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or (iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided— 4) A student pilot may log pilot-in-command time only when the student pilot— (i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember; (ii) Has a solo flight endorsement as required under §61.87 of this part; and (iii) Is undergoing training for a pilot certificate or rating.   As a student, about half the time I am the sole manipulator of the controls and directing assistance as a PIC would do.  Would this count toward PIC time even though I am not a rated military aviator yet?  

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3 Answers



  1. Kris Kortokrax on Jul 06, 2015

    61.51 (e) only allows logging PIC time when you are sole manipulator of the controls of an aircraft for which you are rated. Until you complete your military training and become “rated” for the aircraft, you would be limited to logging PIC time when you are alone in the aircraft.

    Having said that, the military has its own regulations concerning flight operations. You are operating under those.

    61.41 does allow counting military training time toward the requirements for a U.S. pilot certificate. Once you become a military rated pilot, the FAA will issue you a U.S. Commercial pilot certificate with an Instrument rating for the category/class military aircraft for which you are rated.

    As far as records go, you may certainly keep your own personal copy of a logbook for your military flights. However, the time logged for dual training flights would not be valid unless endorsed by your instructor. For that reason, you should probably keep a copy of your military training records to substantiate what you put in your personal logbook.

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  2. Kris Kortokrax on Jul 06, 2015

    Sorry, I had looked up this legal interpretation and forgot to mention it and post the link.

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2006/morris%20-%20%282006%29%20legal%20interpretation.pdf

    It states that once you are rated in the military, the FAA considers you rated in the aircraft and allows logging PIC time as sole manipulator of the controls of an aircraft for which you are rated, even though you hold no FAA rating for the aircraft.

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  3. Marcus on Dec 07, 2017

    Does anyone have a copy of that letter?

    The link to it is no longer valid.

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