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Legal Interpretations

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Morris 2006

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Summary

The Question

May a military KC-135 copilot who has completed pilot proficiency checks log PIC time as sole manipulator of the controls under 14 CFR 61.51(e)(1)(i)?

Background

A rated military pilot serving as a copilot on a U.S. Air Force KC-135, who has completed pilot proficiency checks in the aircraft, asked whether time as sole manipulator of the controls could be logged as PIC time.

The FAA’s Interpretation

Yes. Under 14 CFR 61.51(e)(1)(i), a sport, recreational, private, or commercial pilot may log PIC time while sole manipulator of the controls of an aircraft for which the pilot is rated. The FAA considered the pilot rated in the KC-135, whose civilian version (Boeing 707) requires a type rating, by virtue of the completed pilot proficiency check, so the time would be treated as PIC time.

Requester
Morris
Issued
March 9, 2006
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.51

Page 1

0U.S. Department
of Transportation
Federal Aviation
Administration
Tom MoITis
Dear Mr. MoITis:
800 Independence Ave , SW.
Washington, D.C. 20591

In a letter dated March 9, 2006, you inquired whether you could record as pilot-in-command (PIC) time, the periods during which you were the 'sole manipulator of the controls' of a United States Air Force (USAF) KC-135 pursuant to Title 14, Code of Federal Regulations. (14 CFR) section 61.51(e)(1)(i). The pertinent facts you provided are that you are a rated militaiy pilot that serves as a co-pilot and that you have completed pilot proficiency checks in the KC-135. 14 CFR § 61.51(e)(1)(i) states in relevant pait:

A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person- is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges; We would consider you rated in the aircraft, which in the civilian version (Boeing 707) requires a type rating, by viitue of having completed the pilot proficiency check. Thus, in evaluating your militaiy flight time, we would treat the time as PIC time under section 61.51(e)(1)(i). Thank you for your inquiry. If you have any questions please feel free to contact Naveen Rao of my staff at (202) 267-3073.

Sincerely,

Rebecca MacPherson

Assistant Chief Counsel for Regulations

Regulations Referenced

14 CFR 61.51

Snapshot retrieved August 6, 2026.

Summary

The Question

May a military KC-135 copilot who has completed pilot proficiency checks log PIC time as sole manipulator of the controls under 14 CFR 61.51(e)(1)(i)?

Background

A rated military pilot serving as a copilot on a U.S. Air Force KC-135, who has completed pilot proficiency checks in the aircraft, asked whether time as sole manipulator of the controls could be logged as PIC time.

The FAA’s Interpretation

Yes. Under 14 CFR 61.51(e)(1)(i), a sport, recreational, private, or commercial pilot may log PIC time while sole manipulator of the controls of an aircraft for which the pilot is rated. The FAA considered the pilot rated in the KC-135, whose civilian version (Boeing 707) requires a type rating, by virtue of the completed pilot proficiency check, so the time would be treated as PIC time.

Requester
Morris
Issued
March 9, 2006
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.51