AC 61-65E–Change 1—Certification: Pilots and Flight and Ground Instructors

FAA has updated AC 61-65E: Certification: Pilots and Flight and Ground Instructors with Change 1. This AC “Provides guidance for pilots and flight instructors on the certification standards, written test procedures, and other requirements contained in FAR Part 61.” It also includes recommended logbook endorsements that CFIs should use when logging instructional flights, endorsing students for solo and cross-country flights, and preparing customers for practical tests.

FAA published AC 61-65F on February 25, 2016, which includes changes to the procedure for obtaining a student pilot certificate.

The update, published January 6, 2014, includes important changes to the requirements for the ATP certificate and other revisions, which are outlined in the record of changes.

Logging Flight Time

Arguments about who can log what type of flying time generate more discussion and misinformation than any other topic in aviation.

If you wonder about who can log pilot-in-command time (PIC) and second-in-command time (SIC), and if you don’t understand the key distinction between acting as PIC as logging PIC time, I strongly recommend visiting Logbooks and Logging Time at AOPA (you may need to be an AOPA member to access the page).

That page includes a discussion of the FARs, many common scenarios that spark debate, and links to additional resources that can help pilots and CFIs fill out their logbooks correctly and ensure that they meet the requirements for certificates and ratings and recent experience.

For more information about how flight instructors can log instrument approaches in IMC, see
Logging Instrument Approaches as a Flight Instructor here at BruceAir.

It’s important to understand that you can log PIC time whenever you are the sole manipulator of the controls of an aircraft for which you are rated (e.g., airplane single-engine land). The high-performance and complex endorsements aren’t required, for example, to log PIC time in a Bonanza if you hold at least a private pilot certificate with a SEL rating. You don’t even need a current medical or meet currency requirements to log PIC time as described above. Even if you haven’t flown in decades and don’t have a medical, provided you still have a pilot certificate, you can log PIC time in an aircraft for which you still rated. Of course, in that case, someone who is legal to act as PIC must be on board.

(A student pilot, properly endorsed for solo by a CFI, can also log PIC time while flying solo, but that’s variation on the theme.)

Acting as PIC is another matter. To act as PIC (i.e., be legally responsible for the flight) you must have the appropriate certificates, ratings, and logbook endorsements; and you must hold a current medical/basic med, have a current flight review, and have logged the requisite takeoffs and landings, etc.

Note that in an airplane certified for one pilot, you usually cannot log PIC or SIC time you spend acting as PIC while someone else is manipulating the controls. As AOPA explains, there are exceptions, such as acting as safety pilot or providing flight instruction as a CFI.

If these rules seem convoluted, there is logic and a benefit to the way they are written.

For example, a VFR-only private pilot who holds a SEL rating can log PIC time while receiving instruction (or even flying with a properly qualified and current safety pilot) in any SEL airplane (that doesn’t require a type rating) during training for the instrument rating, even when a flight is conducted under IFR in IMC. This distinction helps IFR students earn PIC and cross-country hours required for the rating and for other pilot certificates, such as the commercial and ATP.

A pilot without a complex, tailwheel, or high-performance endorsement can also log PIC time while receiving instruction in an such an airplane to earn those endorsements.

To read the FAA’s interpretations on the relevant regulations, visit and read the letters of interpretation on this topic from the office of the chief counsel, here.

Good examples of these letters include:

By the way, the AOPA page also discusses electronic logbooks. The FAA has issued an advisory circular (AC 120-78: Acceptance and Use of Electronic Signatures, Electronic Recordkeeping Systems, and Electronic Manuals) that provides guidance for pilots, maintenance technicians, and others who must keep records required by the FARs.