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PIC Question

rileyspoon

Active Member
Question for you CFI folks out there. I'm licensed as a Sport Pilot but I recently decided to pay for a couple of hours in an Archer just to get the exposure to a low wing aircraft that was not an LSA. To date all my training and flying has been in a high wing LSA and I'm now building an RV-12iS.

The CFI for that flight said I should log the time as PIC. Seems like the requirements for PIC say something to the effect that I'm supposed to be endorsed for that class and type of aircraft. The Archer is not one that a SP is allowed to fly solo so wouldn't this time really be logged as "dual". Not sure how much difference it makes but I want my logbook to be correct.
 
Question for you CFI folks out there. I'm licensed as a Sport Pilot but I recently decided to pay for a couple of hours in an Archer just to get the exposure to a low wing aircraft that was not an LSA. To date all my training and flying has been in a high wing LSA and I'm now building an RV-12iS.

The CFI for that flight said I should log the time as PIC. Seems like the requirements for PIC say something to the effect that I'm supposed to be endorsed for that class and type of aircraft. The Archer is not one that a SP is allowed to fly solo so wouldn't this time really be logged as "dual". Not sure how much difference it makes but I want my logbook to be correct.

Fun area of discussion. You don't have to BE PIC to be able to LOG PIC. There's a couple of good FAA Letters of Interpretation on this - look up the Herman and the Speranza interpretations.

Short version: your sport pilot certificate allows you to LOG PIC under 61.51e while you are sole manipulator of the controls, even though the CFI is the ACTING PIC.

A lot of private pilots keep a separate column in the logbook for "61.51 time" where they can't actually BE the PIC but still log it.

This is one of those things that I strongly encourage my students to look up, read and understand. It's easy to source a CFI's opinion on the internet, but, now that you're pointed in the right direction, read up on 61.5, 61.51 and the concept of logging vs. acting as PIC. It yields some interesting scenarios.
 
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Can you provide a link to this? My reading of part 61.51 makes me think he cannot log pic time.
Herman and Speranza involve both pilots being rated Private pilots. ..
 
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Can you provide a link to this? My reading of part 61.51 makes me think he cannot log pic time.
Herman and Speranza involve both pilots being rated Private pilots. ..

His sport pilot certificate applies to category and class - in this case, ASEL.

Both letters of interpretation involve pilots logging PIC where they hold category and class but lack ability to ACT as PIC. Both letters point out that he can LOG PIC per 61.51 but cannot ACT as PIC. Notice the wording of 61.51(e)(1)(i) relative to sport pilot.

I've also bounced this off a local DPE whom I know well. If he's ambivalent, I'll also confirm it with the FSDO, but I'm reasonably certain on this.
 
Thanks for all the responses. I read several places before posting the question and nothing seemed to address this specific situation so I thought I'd ask. Be interested to hear what the DPE thinks.
 
Bill Hutchinson fundamentally has it correct.

However in this case a Light Sport (only) pilot is NOT rated in an Archer (not an LSA). So he can not log PIC, only dual.

If the pilot has a Private certificate, but is operating without a medical (so limited to Light Sport operations), then he can still log PIC, but obviously can not be the acting PIC.

Been through this many times. :cool:
 
I’m a CFII and I agree with Dennis. A sport pilot cannot log PIC time in an aircraft that does not meet the definition of a light sport aircraft (2 seats, max gross, fixed gear, etc.). The SP can log the time as dual if the CFI is not rated as a CFI with light sport privileges as opposed to a CFI not limited to light sport. In addition if the CFI that trained the SP for the SP license is not limited to light sport the dual time logged for SP can be credited against a PPL and higher rating.
 
In addition if the CFI that trained the SP for the SP license is not limited to light sport the dual time logged for SP can be credited against a PPL and higher rating.

It can if his CFI was a SFI-S, also. That changed several years ago.
 
Bill Hutchinson fundamentally has it correct.

However in this case a Light Sport (only) pilot is NOT rated in an Archer (not an LSA). So he can not log PIC, only dual.

His certificate applies to category and class - there is nothing that specifies LSA in the certificate issuance nor in 61.51. Logging PIC is pretty explicit that it's category and class, and LSAs aren't a separate category or class...there's no rating for a make/model in this case.

I am not disputing that he cannot act as PIC, but I believe he can log PIC under 61.51.

EDIT: The Speranza letters seem to be the closest on this, but now I'm really curious and I'm contacting someone I work with who also works for the FSDO. Happy to admit I'm wrong if I am.
 
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Further update - I heard back from the DPE this morning, who is also with the local FAAST group and he concurs that the sport pilot in this scenario can log PIC.

Waiting to hear from the FSDO guy.
 
Further update - I heard back from the DPE this morning, who is also with the local FAAST group and he concurs that the sport pilot in this scenario can log PIC.

Waiting to hear from the FSDO guy.

I would love to see his explanation to HOW. The sport pilot cannot fly this plane solo, cannot take non pilots flying in it, and therefore can't ACT as PIC, in the spirit of the regs, I don't see how he can justify logging PIC.
 
I would love to see his explanation to HOW. The sport pilot cannot fly this plane solo, cannot take non pilots flying in it, and therefore can't ACT as PIC, in the spirit of the regs, I don't see how he can justify logging PIC.

Because, as the FAA has repeatedly pointed out in multiple letters of interpretation, that one does not have to be eligible to BE PIC (final authority for the operation of the aircraft) to be able to LOG PIC.

You gotta look at 14 CFR 61.51(e)(1), then look at sub (iv)(A) which is applicable to this situation. The OP is not the ACTING PIC. He is under the supervision of an ACTING PIC - the instructor.

This all applies to category and class. An LSA is still an ASEL.

He just can't ACT as PIC, but he can LOG it under 61.51.

This is the same reg that allows for CFIs to log all PIC time, allows safety pilots to log PIC time with other pilots under the hood, and a few other bizarre edge cases that I would never try to log because I'd have to explain to an employer.

That's the thing about logging under 61.51 when you're not ACTING PIC - it's time with an asterisk, so to speak. If you're not the ACTING PIC (final authority) then some employers look askance at that time. Doubtful that that scenario applies here - don't know the OP's career aspirations - but it's probably not a big deal either way.
 
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Because, as the FAA has repeatedly pointed out in multiple letters of interpretation, that one does not have to be eligible to BE PIC (final authority for the operation of the aircraft) to be able to LOG PIC.

You gotta look at 14 CFR 61.51(e)(1), then look at sub (iv)(A) which is applicable to this situation. The OP is not the ACTING PIC. He is under the supervision of an ACTING PIC - the instructor.

This all applies to category and class. An LSA is still an ASEL.

He just can't ACT as PIC, but he can LOG it under 61.51.

This is the same reg that allows for CFIs to log all PIC time, allows safety pilots to log PIC time with other pilots under the hood, and a few other bizarre edge cases that I would never try to log because I'd have to explain to an employer.

Sort of doesn't make sense to me, as a PPL requires having had a 3rd class medical at some point in time, which can then go to a Basic Med, to fly with a PPL.

The Sport Pilot License only requires a current Drivers License, and a self assessment. It then limits you to Light Sport Aircraft as Pilot in Charge, nothing else.

Convoluted? So it seems. Hard to act as PIC when you're not medically rated to do so? A PPL is held to a higher medical standard, therefore can fly a higher weight or performance rated plane, is my line of thinking, but I'm not the FAA.
 
Interesting Discussion

I am a CFII and also a licensed attorney (although by way of full confession not in practice, having attended law school, passed the bar exam, and practiced only as a way to pass time decades ago waiting for airline hiring to resume).

There is something that specifies LSA in the Sport Pilot certificate issuance. The applicable FARs themselves specify exactly that.

I will happily change it if definitive and official information is promulgated (which I have not seen to date), but my personal view is that the OP, with only a Sport Pilot license, cannot LOG PIC time in the Archer, or anything other than an LSA.

My reasoning is that the Sport Pilot is not “rated” in anything other than ASEL LSA’s, as that term is used in FAR 61.51(e)(1)(i).

“Rating”, defined in FAR 1.1, “means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.”

A Sport Pilot license holder has an ASEL “rating” in LSA’s by a logbook endorsement only. The logbook ASEL endorsement is limited to LSA’s by FAR 61.303. FAR 61.303 states that a Sport Pilot license holder can operate only a “light sport aircraft for which you hold the endorsements required for its category and class.”

In other words, this is the “special condition, privilege, or limitation” placed on the Sport Pilot ASEL rating. A Sport Pilot is neither rated, nor does he/she have operating privileges in anything other than LSA’s, by express FAR language.

The Speranza and Herman letter rulings, while instructive on the distinction between acting as PIC and logging PIC time, are not applicable to this situation. As the earlier post pointed out, everyone involved in them was appropriately rated and had operating privileges in the airplane by virtue of holding a Private Pilot license with appropriate ratings for the aircraft.

In fact, the Speranza legal interpretation specifically states that an “appropriate aircraft rating” is required to log PIC time. A Sport Pilot ASEL rating specifically limited by FAR to LSA’s only is not an “appropriate” rating for anything other than an LSA.

These are always interesting discussions, best held over a cool one in a relaxing environment among friends after a good day of flying. But without something official from the FAA itself, all of this amounts to little more than what we Navy veterans used to call “sea lawyering.”

In this case the OP has a legitimate question on which there are reasonable arguments for both sides. And in any case it is mostly an academic discussion.

But express FAR language defines what a Sport Pilot is “rated” in and does actually put express LSA limitations on the Sport Pilot certificate issuance. And the “rating” is what controls on the issue of whether PIC time can be logged.
 
Further update - I heard back from the DPE this morning, who is also with the local FAAST group and he concurs that the sport pilot in this scenario can log PIC.

Waiting to hear from the FSDO guy.

And then poll 20 different “FSDO guys” and then after you have 10 that say you can log it and 10 others that say “no”, you will be back where you started and will end up logging it how YOU want! :) The answer is going to be based on interpretation of FAR’s that don’t specifically address the issue. Different people always have and always will interpret things differently.
 
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Convoluted? So it seems. Hard to act as PIC when you're not medically rated to do so? A PPL is held to a higher medical standard, therefore can fly a higher weight or performance rated plane, is my line of thinking, but I'm not the FAA.

As Bill has said repeatedly, the part 61 logging rules are for the experience required for additional ratings - and, confusingly, not the same as the rules for acting as THE PIC. I believe historically, this goes back many years, to a time when it was common for an airline copilot to hold only a commercial license. They complained that even though they flew everyday, they could never log any PIC time towards their ATP, because the captain was always the PIC. So the logging rules were changed.
Part 61 uses the word ‘rating’. For private pilots that has been held to mean what is printed on their license, e.g. category and class, e.g., single engine land. So a private pilot who does not hold a high performance endorsement can nevertheless log PIC time as the sole manipulator of the controls of a 182 while receiving instruction from a cfi because he is ‘rated’ (category and class) in the plane, even though he may not act as the pic. Now the tricky part here is, Sport pilots have no category and class on their license. It’s all done by endorsement. So are they rated in zero airplanes, or all? My interpretation would be zero, but it is a fine legal point best determined by lawyers.
 
You gotta look at 14 CFR 61.51(e)(1), then look at sub (iv)(A) which is applicable to this situation. The OP is not the ACTING PIC. He is under the supervision of an ACTING PIC - the instructor.

FAR 61.51(e)(1)(iv) is not applicable to this situation.

That particular subpart applies to a “pilot performing the duties of pilot in command” who is authorized to log PIC time while someone else acts as PIC. But it sets additional specific conditions about when that is allowed.

The same FAR section further specifies in the next sub paragraph, FAR 61.51(e)(1)(iv)(A) that the “pilot performing the duties of the pilot in command” who is authorized to log PIC time while someone else acts as PIC, must “hold a commercial or airline transport pilot certificate”.

A Sport Pilot certificate holder cannot qualify to log PIC time under the express language of this part of FAR 61.51 either.

All of this stuff is mind numbing and in the case of this particular thread, of little practical significance. The earlier post about finding 10 FSDO’s on either side of the question is probably the most instructive.
 
I am a CFII and also a licensed attorney (although by way of full confession not in practice, having attended law school, passed the bar exam, and practiced only as a way to pass time decades ago waiting for airline hiring to resume).

There is something that specifies LSA in the Sport Pilot certificate issuance. The applicable FARs themselves specify exactly that.

I will happily change it if definitive and official information is promulgated (which I have not seen to date), but my personal view is that the OP, with only a Sport Pilot license, cannot LOG PIC time in the Archer, or anything other than an LSA.

My reasoning is that the Sport Pilot is not “rated” in anything other than ASEL LSA’s, as that term is used in FAR 61.51(e)(1)(i).

“Rating”, defined in FAR 1.1, “means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.”

A Sport Pilot license holder has an ASEL “rating” in LSA’s by a logbook endorsement only. The logbook ASEL endorsement is limited to LSA’s by FAR 61.303. FAR 61.303 states that a Sport Pilot license holder can operate only a “light sport aircraft for which you hold the endorsements required for its category and class.”

In other words, this is the “special condition, privilege, or limitation” placed on the Sport Pilot ASEL rating. A Sport Pilot is neither rated, nor does he/she have operating privileges in anything other than LSA’s, by express FAR language.



These are always interesting discussions, best held over a cool one in a relaxing environment among friends after a good day of flying. But without something official from the FAA itself, all of this amounts to little more than what we Navy veterans used to call “sea lawyering.”

In this case the OP has a legitimate question on which there are reasonable arguments for both sides. And in any case it is mostly an academic discussion.

But express FAR language defines what a Sport Pilot is “rated” in and does actually put express LSA limitations on the Sport Pilot certificate issuance. And the “rating” is what controls on the issue of whether PIC time can be logged.

Thank you. The more I think about this, the more I am inclined to agree with you and revise some of my previous understanding. I am wondering about the procedure for asking for an LOI, because other discussions I’ve seen on this specific topic have been less conclusive than the points you have been making. So I appreciate you taking the time.

Appreciate the input.
 
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I am a CFII and also a licensed attorney (although by way of full confession not in practice, having attended law school, passed the bar exam, and practiced only as a way to pass time decades ago waiting for airline hiring to resume).

There is something that specifies LSA in the Sport Pilot certificate issuance. The applicable FARs themselves specify exactly that.

I will happily change it if definitive and official information is promulgated (which I have not seen to date), but my personal view is that the OP, with only a Sport Pilot license, cannot LOG PIC time in the Archer, or anything other than an LSA.

My reasoning is that the Sport Pilot is not “rated” in anything other than ASEL LSA’s, as that term is used in FAR 61.51(e)(1)(i).

“Rating”, defined in FAR 1.1, “means a statement that, as a part of a certificate, sets forth special conditions, privileges, or limitations.”

A Sport Pilot license holder has an ASEL “rating” in LSA’s by a logbook endorsement only. The logbook ASEL endorsement is limited to LSA’s by FAR 61.303. FAR 61.303 states that a Sport Pilot license holder can operate only a “light sport aircraft for which you hold the endorsements required for its category and class.”

In other words, this is the “special condition, privilege, or limitation” placed on the Sport Pilot ASEL rating. A Sport Pilot is neither rated, nor does he/she have operating privileges in anything other than LSA’s, by express FAR language.

The Speranza and Herman letter rulings, while instructive on the distinction between acting as PIC and logging PIC time, are not applicable to this situation. As the earlier post pointed out, everyone involved in them was appropriately rated and had operating privileges in the airplane by virtue of holding a Private Pilot license with appropriate ratings for the aircraft.

In fact, the Speranza legal interpretation specifically states that an “appropriate aircraft rating” is required to log PIC time. A Sport Pilot ASEL rating specifically limited by FAR to LSA’s only is not an “appropriate” rating for anything other than an LSA.

These are always interesting discussions, best held over a cool one in a relaxing environment among friends after a good day of flying. But without something official from the FAA itself, all of this amounts to little more than what we Navy veterans used to call “sea lawyering.”

In this case the OP has a legitimate question on which there are reasonable arguments for both sides. And in any case it is mostly an academic discussion.

But express FAR language defines what a Sport Pilot is “rated” in and does actually put express LSA limitations on the Sport Pilot certificate issuance. And the “rating” is what controls on the issue of whether PIC time can be logged.


I also believe that with a Sport Pilot license, your license requires you get checked out even in other model LSA that you fly, before you can fly PIC, by a CFI.

Although I am close to getting my PPL instead of a LSA, it was due to this restriction, since I wanted it covered in the event I wanted to fly something else or wanted to step up to a RV-9A and sell my RV-12, that I went forward with the minor additional standards and lessons required to get the PPL over retesting to get from a LSA to a PPL.

In short, just do it right, the first time, and get the 3rd class medical and instruction and testing by a DPE out of the way, rather that spend a bunch more money retesting and another DPE exam oral and written going from SPL to PPL.

Once you have your PPL, Insurance might require you get instruction to fly another single engine piston aircraft before you get coverage, but, while not wise, you would have the option to self insure until you do get the hours to meet insurance requirements.
 
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Where have you seen that written?

It's not.

Ninerbikes appears to be confusing “model” with “category and class.”

In the case of a Sport Pilot certificate, FAR 61.321 only requires an authorized instructor check-out and logbook endorsement to operate an “additional category or class” of LSA’s. Examples of additional “categories” of LSA’s would be airplanes, gliders, rotorcraft, lighter than air, powered parachute or weight shift control. Examples of LSA “class” ratings which are added to a category rating are airplane category with single engine land class rating or single engine sea class rating, rotorcraft category with a gyroplane class rating, lighter than air category with an airship class rating or balloon class rating.

A Sport Pilot certificate with an ASEL-Land endorsement in the logbook allows the holder to operate any LSA single engine land airplane without obtaining another authorized instructor logbook endorsement for each make and model of LSA land airplane.

It is only if they want to operate for example, an LSA glider or trike, or an LSA single engine sea airplane, that additional training and a new logbook endorsement from an authorized instructor would be required, because those are a different category or class of aircraft.

Insurance, rental airplane requirements, and good judgment may dictate training and a checkout in a different model of LSA airplane, but not the FAR’s.
 
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It's not.

Ninerbikes appears to be confusing “model” with “category and class.”

In the case of a Sport Pilot certificate, FAR 61.321 only requires an authorized instructor check-out and logbook endorsement to operate an “additional category or class” of LSA’s. Examples of additional “categories” of LSA’s would be airplanes, gliders, rotorcraft, lighter than air, powered parachute or weight shift control. Examples of LSA “class” ratings which are added to a category rating are airplane category with single engine land class rating or single engine sea class rating, rotorcraft category with a gyroplane class rating, lighter than air category with an airship class rating or balloon class rating.

A Sport Pilot certificate with an ASEL-Land endorsement in the logbook allows the holder to operate any LSA single engine land airplane without obtaining another authorized instructor logbook endorsement for each make and model of LSA land airplane.

It is only if they want to operate for example, an LSA glider or trike, or an LSA single engine sea airplane, that additional training and a new logbook endorsement from an authorized instructor would be required, because those are a different category or class of aircraft.

Insurance, rental airplane requirements, and good judgment may dictate training and a checkout in a different model of LSA airplane, but not the FAR’s.

That's the way I understood it.. thus the question... Thanks!
 
The fact that so many experienced aviators can’t come to a consensus in this discussion seems to indicate the regulators need to do a better job of specifying the requirements.
 
The fact that so many experienced aviators can’t come to a consensus in this discussion seems to indicate the regulators need to do a better job of specifying the requirements.

This.

I will say right now - as an ardent supporter of the OP being able to log this, and believing the regulations supported it - I was wrong. He cannot log the time as PIC.


I consulted with a very experienced DPE who had come to the same initial conclusion I had. When I brought the rest of the discussion to him, he frowned and said, "I'll get back to you" and I suspect he'll get here as well. My other contact at the FSDO said, basically, this is a humdinger of a reading on the regs, and he's still confirming, but he also believes the answer is no.

I do wish the regs were a little clearer to the non-lawyer.

But alas, they say a good CFI is always learning, so I'm chalking this one up to a learning experience.
 
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