For a planned ferry flight under FAA Part 91, this is the scenario:

  • Two of us, let's call us A and B (rated pilots for that airplane), want to sit in front and do the flying.
  • A highly experienced pilot, C, will accompany and supervise the flight, sitting in the back seat.
    • Insurance insists that C be acting PIC throughout the flight.
    • At the same time, insurance has explicitly said that C can sit in the back while doing so.

This doesn't accord with C's own understanding of what is legal in an airplane that only requires one crew member. My own reading of who can be PIC doesn't say anything about where in the plane they have to sit.

So the question is: Can someone act as PIC while sitting in the back seat in a single-pilot airplane?

Relatedly, if the answer to the above is Yes:

  • Suppose B is a CFI
  • A manipulates the controls.
  • Can all 3 pilots log PIC time?
    • A is sole manipulator of the controls;
    • B provides instruction;
    • C is acting PIC?
  • $\begingroup$ Is C comfortable with being in command while in the backseat? (seems implied by the question, but you don't mention it) $\endgroup$
    – Jeffrey
    Commented Jun 22, 2020 at 13:55
  • $\begingroup$ If A&B are rated pilots for the aircraft, why is the insurance company requiring C be the PIC? That sounds really odd to me, unless this is a ferry flight with some strange requirements (like flying across the Atlantic or to Hawaii)... $\endgroup$
    – Ron Beyer
    Commented Jun 22, 2020 at 14:01
  • $\begingroup$ @RonBeyer It's not that uncommon. Let's say A has a multi-engine commercial rating, and B is a CFI with multi-engine. But while A and B may both have time in piston twins, this aircraft may be a turboprop. A is the new owner, B is A's preferred instructor and C is a rated pilot with sufficient turbine time/time-in-type to keep the insurance company happy. The insurer will typically require new-owner A to fly with someone like pilot C for some number of hours before operating solo. $\endgroup$ Commented Jul 1, 2020 at 17:13

1 Answer 1


Can the acting PIC sit in the rear seat?

There's no regulation or FAA interpretation I can find that requires the acting PIC to sit in a seat with access to the controls. For flight instruction specifically, 14 CFR 91.109(a) requires dual controls (usually) and the instructor must be at a "pilot station" (14 CFR 61.195(g)(2) and Williams interpretation, 2018). So no instructing from the rear seat.

Of course there's also 91.13 (careless and reckless operation). That's a deliberately broad regulation and I have no idea how risky your operation might be considered. If A and B already have experience in the aircraft and they'd be fine to fly it without C anyway (from the FAA's point of view), then arguably there's nothing careless or reckless happening. On the other hand, if something goes wrong and lawyers get involved to determine liability then it's anyone's guess what could happen.

Can all three pilots log PIC time?

  • A: yes, as sole manipulator of the controls (61.51(e)(1)(i))
  • B: yes, if they're giving instruction (61.51(e)(4)). That means A and B need to log it as instruction time in their respective logbooks (61.51(h)); they can't just say "let's call this instruction so we can both log PIC".
  • C: no, acting as PIC doesn't automatically allow you to log PIC time. 61.51(e)(1)(iii) doesn't seem to apply here because in your scenario neither the aircraft type nor the operation require a second pilot

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