Legal Interpretations
Dick 2 2017
Summary
The Question
Must a pilot meet all four conditions of 14 CFR 61.51(e)(1)(iv)(A) through (D) to log PIC time while performing PIC duties under supervision?
Background
A requester twice asked the FAA to reconsider its September 20, 2016 interpretation of 14 CFR 61.51(e)(1)(iv) on logging pilot-in-command time, disagreeing with the FAA's reading.
The FAA’s Interpretation
Yes. The FAA reaffirmed its earlier reading: the em dash, the semicolons, and the "and" before (D) mean all four conditions apply. A pilot performing PIC duties under a qualified PIC's supervision may log PIC time only if the pilot holds a commercial or ATP certificate with the appropriate category rating, is in an approved PIC training program, the supervising PIC is qualified, and the supervising PIC logs and certifies the time.
- Requester
- Dick
- Issued
- January 12, 2017
- Subject
- Pilot Certification & Privileges
Regulations Cited
Unreadable text from the scan (such as a barcode or stamp) is left out of the text below; the original letter shows it exactly.
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
JAN 1 22011
Charles Allan Dick
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington , O.C. 20591
Re: Second and third request for interpretation of 14 CFR 61.51(e)(l)(iv) - logging time as
pilot in command
Dear Mr. Dick:
We have received your two requests for reconsideration of our legal interpretation, dated September 20 ~ 2016, regarding logging of pilot in command (PIC) flight time under 14 C.F.R. § 61.S l (e)( l )(iv).
We have reconsidered the issue and disagree with your interpretation of the regulation. From a grammatical standpoint, we note that the introductory language to§ 61.5 l(e)(l)(iv) uses an em dash leading into the subsequent subparagraphs (A) through (D). Consistent wjth the Government Printing Office Style Manual, an em dash is used after an introductory phrase reading into the following lines and indicating repetition of such phrase for each those subsequent lines. Subparagraphs (A) through (D) arc separated by the use of semicolons with the use of the word "and" immediately preceding paragraph (D), meaning that a person must satisfy all four requirements to log PIC flight time under that provision. Additionally, there is no punctuation or language (i.e. the word "or") preceding paragraph (B) that suggests the FAA intended a pilot could log PIC time by satisfying subparagraph (A) alone. Accordingly, the FAA interprets§ 61.S l (e)(l)(iv) to mean that a pilot may log PIC flight time when he or she performs the duties of PIC while under the supervision of a quaUfied PIC provided: (A) the pilot holds either a commercial pi lot certificate or airline transport pilot (ATP) certificate with the appropriate category rating, (B) the pilot is undergoing an approved PIC training program that includes the appropriate ground and flight training, (C) the supervising PIC meets the listed qualifications, and (D) the supervi sing PIC logs and certifies the time in the pilot's logbook and attests to the certification with his or her signature and flight instructor certificate number. As noted in our earlier letter, th is position is supported by the 2009 preamble to the final rule. 74 FR 42500, 42514 (Aug. 21 , 2009).
Based on the above, we consider your request addressed. This response was prepared by Anne Moore, an attorney in the Regulations Division. If you have any additional questions regarding this matter, please contact my office at (202) 267-3073 .
Sincerely,
~~Lorelei Peter
Assistant Chief Counsel for Regulations
Regulations Referenced
Snapshot retrieved August 6, 2026.