Maintaining Instrument Currency During Medical Deferral
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Answered By AOPA

My medical was deferred by my AME back in April and I am “patiently“ waiting for the FAA to issue its determination (I  responded to the CAMI letter in June).

Meanwhile…can I legally log my 6 approaches and/or complete an IPC provided a CFII is on board acting as PIC, or I complete the approaches in an ATD?

7 Replies
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AOPA Staff Answer

Hi Camden,

All the medical issue is doing is preventing you from acting as PIC. You can do exactly what you propose without holding a current medical, no issues.

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Thank you!

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And by regulation 61.51, you can log all of the time you are the sole manipulator of the controls as PIC time even though you are not the acting pilot-in-command.

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Regarding my logging PIC with another pilot as sole manipulator - Don't you have to be Commercial and (or at least) CFI rated to be supervising PIC if both you and the sole manipulator log PIC and there's no foggles used? 

I don't believe that I, as a private instrument pilot can log PIC in the left seat of my own plane while a private pilot in the right seat is sole manipulator and logs PIC himself 61.51.e.iv.C etc? Please clarify? I guess we are assuming the medical issue situation  above was using foggles, which is of course needed for currency?

Is anything different if I am “helping control the aircraft” while he learns how to fly this plane? Who logs then. It would be great if we both can log PIC but I believe that's only OK if one is under foggles or if CFI (while training).

Last - How about when a non-pilot. non-student is at the controls? Can I still log PIC?

I have found these questions difficult to answer and somewhat ambiguous. Thanks in advance.

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Hi Dave, 

I'll try to answer these in the order you asked them:

 

Regarding my logging PIC with another pilot as sole manipulator - Don't you have to be Commercial and (or at least) CFI rated to be supervising PIC if both you and the sole manipulator log PIC and there's no foggles used? 

 

In that circumstance (without you being a CFI) only one pilot is required for that flight therefore only one of you can log PIC. When foggles are used its a different story, where both can log PIC, but for different reasons. Hicks 1993 legal interpretation

 

I don't believe that I, as a private instrument pilot can log PIC in the left seat of my own plane while a private pilot in the right seat is sole manipulator and logs PIC himself 61.51.e.iv.C etc? Please clarify? 

 

You are correct, because the pilot in the right seat would be logging the time not as sole manipulator, but rather as acting PIC. 

 

Is anything different if I am “helping control the aircraft” while he learns how to fly this plane? Who logs then. It would be great if we both can log PIC but I believe that's only OK if one is under foggles or if CFI (while training).

 

No, nothing is different. Unless you're authorized instructor you couldn't log PIC time under the provision provided for CFIs under 61.51(e)(iv)(D)(3). There is still only one pilot required for this flight, therefore only one of you can log the time.  

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The Jason Herman letter of interpretation from 2009 addresses the distinction between logging PIC and acting as PIC.