Legal Interpretations
Lloyd 2007
Summary
The Question
May a helicopter pilot log as flight time periods on the ground with the engine running and rotors turning before moving for flight or after coming to rest?
Background
An individual asked about logging helicopter ground time toward part 61 certificates or 14 CFR 135.243(b)(2), including adding startup and cooldown time beyond the reading of a time-in-service meter actuated by the collective.
The FAA’s Interpretation
No to all three. Under 14 CFR 1.1, flight time begins when an aircraft moves under its own power for the purpose of flight, whether by lifting off or taxiing, and ends when it comes to rest after landing. Time running at the parking place before moving or after coming to rest cannot be logged, nor can added startup and cooldown time.
- Requester
- Lloyd
- Issued
- April 27, 2007
- Subjects
- Pilot Certification & Privileges · Air Carrier & Commercial Operations · Definitions
Regulations Cited
Page 1
U.S. Deportment
o f TronsportatiOn
Federal Aviation
Administration
APR 2 7 2007
Dear Mr. Lloyd,
This responds to your letter dated December 13, 2006, in which you ask three questions concerning the logging of flight time in a helicopter. The answers all flow from the definition of"flight time" found in section 1.1 ofTitle14 Code of Federal Regulations. Your three questions are:
l. May a pilot log as "flight time" to qualify for a certificate or rating under 14 CFR Part 61, or for purposes of qualifying under 14 CFR 135.243(b)(2), that time accrued in a helicopter when the aircraft is sitting on the ground with the engine running and rotor blades turning, but the aircraft has not moved from its parking place and flight has not yet commenced?
2. May a pilot log as "flight time" to qualify for.a certificate or rating under 14 CFR Part 61, or for purposes of qualifying tmder 14 CFR 135.243(b)(2), that time accrued in a helicopter after the end of a flight prior to shut down when the helicopter has set down and come to a rest at its parking place, flight has ceased, but the engine is still running and rotor blades are still iuming?
If a helicopter is equipped with a ''time in service" meter that is actuated only by the collective pitch control, may a pilot add a couple of tenths of an hour of "flight time" to their log book in excess of the aircraft "time in service" meter reading, to account for the time that the aircraft is starting and running up at the beginning of the training period prior to lift off, and that time the engine is idling and cooling down after the last landing, prior to the engine being shut off? The regulations in pertinent part define "flight time" as "[p]ilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to.rest after landing." 14 C.F.R. § 1.1. As with fixed-wing aircraft, flight time in a helicopter commences the moment that it moves under its own power away from its parking place for the purpose of flight- whether departure is commenced by lifting off or taxiing. (Helicopters can be equipped with different types oflanding gear; and those equipped with wheels or pontoons have the option of a vertical lift-off or taxiing before lift-off.) Flight . time ends for any helicopter operation when the helicopter comes to rest after landing. It follows from the plain words of the regulation that the circumstances you described could not be logged as flight time.
Page 2
The answer to all three questions is that flight time may not be logged. This response was prepared by Viola Pando, Attorney in the Regulations Division of the Chief Counsel and has been coordinated with General Aviation Division of Flight Standards Service. If you have additional questions regarding this matter, please contact us at your converiience at (202) 267-3073. ·
Sincerely,
~t:'J,/~
Assistant Chief Counsel
Regulations Division
Regulations Referenced
Snapshot retrieved August 6, 2026.