(h) Logging training time.

  1. A person may log training time when that person receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device.

  2. The training time must be logged in a logbook and must:

    (i) Be endorsed in a legible manner by the authorized instructor; and

    (ii) Include a description of the training given, the length of the training lesson, and the authorized instructor's signature, certificate number, and certificate expiration date.

(14 CFR § 61.51)

Consider a 4-seat airplane with flight controls for the front seats only. If there are two students on one flight and they go up with a CFI and neither one touches the flight controls can they both log the instruction time? Assume the CFI takes off and shows the students how to conduct various maneuvers and how to track an ILS glide slope. Can the student in the back log training time since they received training from a CFI in an airplane? I sent off a request for legal interpretation but they said it could take up to four months to get a response.

  • $\begingroup$ What kind of training time do you mean? Do you mean flying hours? $\endgroup$
    – GdD
    Jun 10, 2022 at 16:46
  • $\begingroup$ If sitting in a passenger seat qualified as experience the world would be full of terrible pilots. $\endgroup$
    – GdD
    Jun 10, 2022 at 17:05
  • $\begingroup$ Would you add up the dual received column in your log book and count it as pilot time for the purpose of hitting the PPL hour minimums? $\endgroup$ Jun 10, 2022 at 19:01
  • $\begingroup$ 61.51 (c)Logging of pilot time. The pilot time described in this section may be used to: (1) Apply for a certificate or rating issued under this part or a privilege authorized under this part. So PIC, SIC, instrument time, training time, NVG. Some call training time dual received but that is wrong it is "training time". 61.51 (h) states that training time is time obtained from instruction in an aircraft. $\endgroup$
    – James
    Jun 10, 2022 at 19:48
  • 2
    $\begingroup$ If that worked, there would be an awful lot of people getting most of their dual instruction credit sitting in the back to save big bucks. You're just an observer, not a student when you sit in the back. $\endgroup$
    – John K
    Jun 10, 2022 at 20:37

1 Answer 1


In my opinion, the FAA Legal interpretation Williams 2018 Legal Interpretation, makes a compelling argument that a person receiving flight training must occupy a pilot station. The pertinent portion of this (multi-question) legal interpretation states that a Flight Instructor must occupy a pilot station and it also states that the other pilot station is for the student. Read in full context, it seems fairly clear to me that the pilot receiving the flight training must be in a pilot station to credit the flight time as instruction received.

However, getting a direct FAA legal interpretation for your specific point would provide an unambiguous answer to your question.

The image below is a pertinent portion of the linked Williams 2018 Legal Interpretation. Although the interpretation specifies the requirement that the instructor must occupy a pilot station, its corollary seems reasonably clear to also apply to the person receiving the flight instruction.

enter image description here

  • 2
    $\begingroup$ Which is pretty much what common sense would overwhelmingly suggest. $\endgroup$
    – John K
    Jun 10, 2022 at 17:36
  • $\begingroup$ I wonder if you could record it as “ground” instruction. $\endgroup$
    – Jim
    Jun 10, 2022 at 17:53
  • $\begingroup$ It would be funny to see a plane with more than two pilot stations. $\endgroup$
    – Joshua
    Jun 11, 2022 at 1:34
  • 2
    $\begingroup$ @Joshua - Yes some do look funny: images.app.goo.gl/5CGZ6y37karfNdEu6 $\endgroup$
    – Jim
    Jun 11, 2022 at 15:49

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