Legal Interpretations
Richards 2013
Summary
The Question
May a pilot without the complex or high-performance airplane endorsements log pilot-in-command time as sole manipulator of the controls while another pilot acts as PIC?
Background
An individual described a private pilot with an airplane single-engine land rating but no complex or high-performance endorsements flying such an airplane with an appropriately certificated pilot acting as pilot in command.
The FAA’s Interpretation
Yes. The endorsements in 14 CFR 61.31(e) and (f) are required to act as pilot in command of a complex or high-performance airplane, but not to log PIC time under 14 CFR 61.51(e) when the pilot is rated for the aircraft and is its sole manipulator of the controls, as the FAA explained in its Speranza and Herman interpretations.
- Requester
- Richards
- Issued
- December 23, 2013
- Subject
- Pilot Certification & Privileges
Regulations Cited
Page 1
U.S. Department
of Transportation
Federal Aviation
Administration
Office of the Chief Counsel
DEC 23 2013
Mr. Bryce Richards
Dear Mr. Richards:
Office of the Chief Counsel
800 Independence Ave., SW.
Washington, DC 20591
This is in response to your request for interpretation concerning the logging of Pilot-In-Command (PIC) time under 14 C.F.R. § 61.51(e) for flights conducted in a high-performance or complex airplane.
Your inquiry .involves a scenario where Pilot 1, holding a private pilot certificate with an airplane single-engine land rating, but no endorsements for complex or high-perfonnance airplanes as required by 14 C.F.R. §§ 61.31 (e)-(f) to act as PIC, is flying in a complex or high-perfonnance airplane. The other pilot, Pilot 2, who does hold the proper certificate and ratings, is acting as PIC for the flight. You ask whether Pilot l , who does not hold the proper endorsements may still log PIC time for the time he is sole manipulator of the controls and whether any time such pilot might spend flying in simulated instrument conditions, may be credited as instrument time in his logbook. In response to your inquiry, I refer you to the Legal Interpretation to John Speranza, December 4, 2009, and the Legal Interpretation to Jason HeITilan, May 21, 2009, both of which deal with the question of logging PIC time when a pilot is sole manipulator of the controls of an aircraft. Copies of both interpretations are enclosed. As explained more fully in those interpretations, although the endorsements requirement of Sections 61.13(e) and (f) must be met to act as PIC of a high-performance or complex airplane, those endorsements are not required to log PIC time if the pilot is rated for and is the sole manipulator of the controls of the aircraft.
We hope this response has been helpful to you. If you have additional questions, please contact my staff at (202) 267-3073. This response was prepared by Neal O'Hara, an Attorney in the Office of the Chief Counsel, and was coordinated with the Commercial and General Aviation Division of the Flight Standards Service. ark y Assistant Chief Counsel for International Law, Legislation and Regulations , AGC-200
Enclosures (2)
Regulations Referenced
Snapshot retrieved August 6, 2026.