Morris 2006

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 pe1tinent 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 spo1t, 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 inqui1y. 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