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Here is the scenario. Could you please tell me if this pilot can log PIC time?

I am a private pilot and my medical is expired. I want to fly so I am trying to fly with another private pilot friend. My friend has a valid medical and flight review. The flight will be VFR, in VFR conditions.

I am going to fly so I will be the sole manipulator. Can I do so without a medical? Can my friend be acting PIC, with just me flying and logging PIC? My friend is going to watch me.

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  • $\begingroup$ What is preventing you from going an getting a medical or going through the BasicMed process? $\endgroup$ Jun 17, 2023 at 1:00
  • $\begingroup$ @SMSvonderTann Seems like rather private information to me. $\endgroup$
    – Chris
    Jun 17, 2023 at 3:23
  • $\begingroup$ Also irrelevant to the question, since the reasons have nothing to do with improving the questions or how we would frame an answer. $\endgroup$ Jun 17, 2023 at 15:41

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No. You need to dig into the regulations a bit to get at the answer:

§ 61.51(e):

Logging pilot-in-command flight time.

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) Except when logging flight time under § 61.159(c), when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

This seems to imply you can at first glance, but you need to dig into the definitions of the terms used. § 1.1 defines "flight time":

Pilot 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

and then § 61.1 defines "pilot time":

Pilot time means that time in which a person -

(i) Serves as a required pilot flight crewmember;

(ii) Receives training from an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device;

(iii) Gives training as an authorized instructor in an aircraft, full flight simulator, flight training device, or aviation training device; or

(iv) Serves as second in command in operations conducted in accordance with § 135.99(c) of this chapter when a second pilot is not required under the type certification of the aircraft or the regulations under which the flight is being conducted, provided the requirements in § 61.159(c) are satisfied.

The only one here that could possibly apply to you, assuming your friend is not a CFI, is the first. However, you cannot serve as a required flight crewmember without a medical, as stated in § 61.3(c)(1):

A person may serve as a required pilot flight crewmember of an aircraft only if that person holds the appropriate medical certificate issued under part 67 of this chapter, or other documentation acceptable to the FAA, that is in that person's physical possession or readily accessible in the aircraft. Paragraph (c)(2) of this section provides certain exceptions to the requirement to hold a medical certificate.

unless one of the exceptions in § 61.3(c)(2) applies to you.

In short, you can only log "flight time," which is a type of "pilot time," which only accrues if you are a "required flight crewmember." Since you are not allowed to be a required flight crewmember without a medical, you can't log time either.

You can log PIC time if you are receiving training from a CFI in a plane you are rated for. If your medical has lapsed and you don't have a medical condition that makes flying unsafe, picking up some training from a CFI is a safe and legal way to continue flying and logging time while you work on getting your medical in order.

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    $\begingroup$ Um... there are plenty of times that rated pilots swap controls, operate as "sole manipulator", yet are not both required crewmembers. Does that time not count? $\endgroup$ Jun 17, 2023 at 2:27
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    $\begingroup$ It is an interesting interpretation. I can see your logic. $\endgroup$
    – wbeard52
    Jun 17, 2023 at 7:32
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    $\begingroup$ I would stop at 61.51(e) and answer yes. If you try hard enough you can talk yourself out of almost anything. $\endgroup$ Jun 17, 2023 at 15:02
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    $\begingroup$ @MichaelHall It's in 61.1. $\endgroup$
    – Chris
    Jun 17, 2023 at 19:19
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    $\begingroup$ FWIW, the AOPA has written an article regarding the logging of pilot-in-command time. I've linked it HERE. Note Scenario 1 of the article agrees with Michael's answer. I'm not saying that this supersedes @Chris-RegenerateResponse position, just that it is probably worth a look. $\endgroup$
    – user22445
    Jun 17, 2023 at 19:32
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It is pretty simple. If your medical is not valid, you can not be pilot in command.

You can go flying with your friend, but he will be pilot in command, and he will log the time.

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    $\begingroup$ I agree you cannot act as PIC without a current medical, but sole manipulator? $\endgroup$ Jun 17, 2023 at 2:28
  • $\begingroup$ I keep forgetting about FAA “sole manipulator” since I am not FAA licenced. My guess is no to “sole manipulator” since his medical is not valid and he is not receiving training. $\endgroup$ Jun 17, 2023 at 5:11
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Yes.

Regarding logging PIC time, 14 CFR § 61.51(e) states in part:

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

(i) Except when logging flight time under § 61.159(c), when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;

(ii) When the pilot is the sole occupant in the aircraft;

(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or

You really don't need to go any further than that.

You cannot "perform the duties" or "act as PIC" without a current medical certificate, which is stated clearly in 61.23(a)(3)(ii). The FAA breaks PIC duties out separately from "sole manipulator" and your friend must be act as PIC. However, if you are a rated pilot flying the airplane you can log the time while you are sole manipulator per 61.51(e)(i).

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    $\begingroup$ Seems like poor legal advice to suggest one doesn't need to check the definitions of terms used, when "flight time" and "pilot time" are both clearly defined in the regs. I'd be open to an argument that my analysis is in some way flawed, but just ignoring the definitions seems rather cavalier. $\endgroup$
    – Chris
    Jun 17, 2023 at 18:37
  • $\begingroup$ @Chris-RegenerateResponse, I am not offering legal advice, and I'm not ignoring definitions, this one just happens to be self contained. In this context, PIC time is defined as "when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated". If a medical certificate was also required it would say that just like it does when describing requirements for "acting as PIC" in 61.23(a)(3)(ii). It is well established that acting as PIC and logging PIC as sole manipulator are distinctly different. $\endgroup$ Jun 17, 2023 at 18:52
  • $\begingroup$ ...and I am no more cavalier for seeking a permissive interpretation than you are irrational for seeking the most restrictive one. You are free to disagree, and I always welcome constructive feedback, but I'm not alone here. Let the votes be cast... $\endgroup$ Jun 17, 2023 at 18:53
  • $\begingroup$ Just stating my thoughts. The full sentence (chopping off the irrelevant parts that apply only to sport pilots and part 135 operators) is "A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated." I don't think that you can interpret this sentence without reference to the definition of "flight time." But as far as I can tell there is no FAA interpretation directly dealing with this, so we can agree to disagree. $\endgroup$
    – Chris
    Jun 17, 2023 at 19:05
  • $\begingroup$ FWIW, the AOPA has written an article regarding the logging of pilot-in-command time. I've linked it HERE. Note Scenario 1 of the article agrees with your answer. I'm not saying that this supersedes @Chris-RegenerateResponse position, just that it is probably worth a look $\endgroup$
    – user22445
    Jun 17, 2023 at 20:16

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