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4 Answers

Time Logging Complications

Asked by: 1632 views FAA Regulations

I am a Private Pilot who has the opportunity to fly with a Commercial Pilot for the sake of logging time (Pt. 91). The airplane is Amphibious and we have been doing operations under VFR and IFR. I am instrument Rated but not current, and I do not have 3 t/o's and landings within the last 90 days. Can I log PIC when I am sole manipulator since I am rated in the aircraft and trying to regain currency?

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4 Answers



  1. Mark Kolber on Jul 01, 2019

    What’s the complication? Here’s what FAR 61.51 says.

    “A … private pilot may log pilot in command flight time for flights—

    …when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated,”

    Are you searching for an exception which is not there?

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  2. KDS on Jul 01, 2019

    I was hoping Mark would see that question and provide an answer because there is nobody more qualified to answer. However, allow me to expand on what Mark wrote.

    You wrote, “Pt 91”, but if your commercial friend is engaged in a Part 135 operation at that time, he or she cannot allow you to touch the controls.

    If you are landing that amphibious aircraft in the water and you hold an ASEL certificate, you may log the time and the landings, but the landings (and takeoffs) do not count towards your 90 day landing (and takeoff) currency because they are not made in the same class. (I kept throwing in “and takeoff” because people forget to include takeoffs as part of the requirement.)

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  3. Student__Pilot on Jul 01, 2019

    It is all pt. 91. I suppose where I was tripping myself up was the PIC requirements of the previous 90 days. So what the decision comes down to is who is legal PIC as opposed to sole manipulator of controls PIC?

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  4. Mark Kolber on Jul 01, 2019

    >>So what the decision comes down to is who is legal PIC as opposed to sole manipulator of controls PIC?

    It does. The FAA decided at some point to separate the concept of logging pilot in command flight time from the concept of acting as pilot in command.

    So, for example, in the context of your question, since you are not PIC passenger current, you cannot *act* as PIC with your friend on board. Assuming he is PIC passenger current, he may *act* as PIC for the flight and, as PIC, allow you to fly the airplane and get your passenger currency landing in.

    BTW, notice, I am using the phrase “PIC passenger currency” rather than “landing currency.” I do that on purpose because 61.57(a) and (b) are not about being current to land. The 90 day currency is only about being current to carry passengers while acting as PIC. For example, if you have not landed at night for the past 8 years, there is noting gin the regulations to prevent you from going up at night all alone and fling as much as you want.

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