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Legal Interpretations

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Morgan 2013

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Summary

The Question

May a pilot whose type rating is limited to second-in-command privileges log pilot-in-command time under 14 CFR 61.51(e)(1)(i)?

Background

An individual asked whether a pilot holding an S-61 type rating limited to SIC privileges may log pilot-in-command time as sole manipulator of the controls. The FAA had answered the same question in a 2012 interpretation to Glenn Counsil.

The FAA’s Interpretation

No. 14 CFR 61.51(e)(1)(i) allows PIC time only when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is "rated," meaning holding the appropriate category, class, and type ratings. A type rating subject to a "SIC Privileges Only" limitation does not qualify.

Requester
Morgan
Issued
October 22, 2013
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.5
  • 14 CFR 61.51

Page 1

U.S. Department
of Transportation
Federal Aviation
Administration
OCT 22 2013
Jeff Morgan
Dear Mr. Morgan:
Office of the Chief Counsel 800 Independence Ave., SW.
Washington, D.C. 20591

This letter responds to yow request for a legal interpretation that was emailed to my office on September 4, 2013. Specifically, you have asked whether a pilot who holds a type rating limited to SIC privileges may log time as pilot in command (PIC) under§ 61.51(e)(l)(i). We previously answered this question in a legal interpretation to Glenn Counsil issued on April 13, 2012.

Section 61.51(e)(l)(i) permits a pilot to log PIC time for flight time as "the sole manipulator of the controls of an aircraft for which the pilot is rated." We have consistently stated that the term "rated," as used in § 61.Sl(e) refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required) on his or her pilot certificate. See Legal Interpretation to John Speranza (Dec. 4, 2009); Legal Interpretation to Jason E. Herman (May 21, 2009); Legal Interpretation to James R. Knight II (Jtllle 3, 1999). We stated in the Counsil Interpretation that, to log PIC time under§ 61.Sl(e)(l)(i), a pilot must hold a type rating that is not subject to a "SIC Privileges Only" lirnitation.1 Accordingly, in your scenario, a pilot who holds a type rating limited to SIC privileges for the S-61 may not log time as PIC under§ 61.51(e)(l)(i). We have attached the Cow1sil Interpretation for your consideration.

This response was prepared by Anne Moore, an attorney in the International Law, Legislation, and Regulations Division of the Office of the Chief Counsel. If you have any additional questions regarding this matter, please contact my office at (202) 267-3073. I temational Law,

Legislation, and Regulations ·vision 1 The requirement that a pilot who is the sole manipulator controls be rated in the aircraft in order to log PIC time dates back to the Civil Air Regulations. See CAR 43.405. As such, it predates the existence of the SIC type rating which was placed in the regulations in 2005.

Regulations Referenced

14 CFR 61.51

Snapshot retrieved August 6, 2026.

Summary

The Question

May a pilot whose type rating is limited to second-in-command privileges log pilot-in-command time under 14 CFR 61.51(e)(1)(i)?

Background

An individual asked whether a pilot holding an S-61 type rating limited to SIC privileges may log pilot-in-command time as sole manipulator of the controls. The FAA had answered the same question in a 2012 interpretation to Glenn Counsil.

The FAA’s Interpretation

No. 14 CFR 61.51(e)(1)(i) allows PIC time only when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is "rated," meaning holding the appropriate category, class, and type ratings. A type rating subject to a "SIC Privileges Only" limitation does not qualify.

Requester
Morgan
Issued
October 22, 2013
Subject
Pilot Certification & Privileges

Regulations Cited

  • 14 CFR 61.5
  • 14 CFR 61.51