Should I be logging solo time as a private pilot?
Votes
Joined 02/13/2020 - 1 Posts
Answered By AOPA
There isn't a separate column in my logbook for solo time (as differentiated from PIC time with a passenger). Should I add one and keep track of it? Are there any ratings or certifications that require solo time? Or am I fine just logging solo time and time with a passenger as the same kind of time (PIC)?
11 Replies
Votes
Joined 01/30/2020 - 38 Posts
AOPA Staff Answer
Hi Alex,

There has been some good information in the replies, and some very, very bad information in the replies (I will let the up and down votes and other posters hash that out). I would absolutely recommend that you keep track of your solo time, especially if you plan on going for further ratings, or plan on getting insurance.

Find a way that works for you to denote solo time and PIC time (new column, circling, notes, etc.). Yes there are other ratings that require solo time for aeronautical experience. The commercial rating for example requires at least 10 hours of solo time (FAR 61.129(a)(4)):



You'll notice that it calls out FAR 61.127(b)(1) for the areas of operation (commercial), which would prevent someone from carrying forward solo time from their private training towards these specific requirements.

Rest assured:
  • Solo flight time is NOT just for student pilots or pilots transitioning from other categories or classes
  • Solo flight time IS PIC time, because if you're the sole occupant of an aircraft who else could be PIC?
  • Flight time as a rated pilot can be both solo and PIC, or just PIC (when you're not the sole occupant)
  • Logging PIC time and Solo time is absolutely fine, and is NOT a fraudulent logbook entry when you're sole occupant. 
If you have any specific scenarios you wanted to go through, post them here or give us a call at the Pilot Information Center 1-800-USA-AOPA (872-2672).
Votes
Joined 06/11/2017 - 702 Posts
Yes, you should log in a "Solo" column all flights which are made where you are the sole, living, human occupant (no babies, but dogs are OK, and so are corpses [BTDT]).  If you ever go for the Commercial-Airplane certificate/rating, you will need documentation of a number of solo flight requirements.  See 14 CFR 61.129(a) for details.
Votes
Joined 02/15/2020 - 3 Posts
You only need 10 hours or more of solo time that includes the required cross country and night flights.  So you can just record solo in the remarks section.  It is easy enough to circle the solo flights with a pencil if you need to show that you have the required solo time.  If an examiner wants to see if you meet the requirements they'll need to see the conditions of flight and not just a column total for solo.
Votes
Joined 06/11/2017 - 702 Posts
You can try it John's way if you want, but you're making it harder for the examiner to determine your eligibility than if you do it the way I suggested.  My experience as an instructor suggests making it as easy as possible for the examiner has significant benefits.
Votes
Joined 02/15/2020 - 3 Posts
I was assuming you have a standard logbook and not an electronic one.  If your logbook has a blank column under "type of piloting time" then why not use it for solo time?  Some have that blank column, mine doesn't and it would be very messy for me to try to create one.
Votes
Joined 06/11/2017 - 702 Posts
John Yurkon:
If your logbook has a blank column under "type of piloting time" then why not use it for solo time?

Excellent suggestion.

Votes
Joined 06/11/2017 - 702 Posts
Mr. Gallaher, who I gather is not a CFI, is incorrect on all counts.  Read 61.51 for the details, especially paragraph (e) on PIC time and paragraph (d) on solo time.  The two are not mutually exclusive, and solo time is not only time "under the control of your instructor".  Keep in mind that the OP is already a rated Private Pilot, not a Student Pilot.  Also, while all Solo time is PIC time (see 61.51(d) and (e)(1(II)), not all PIC time is solo time.
Votes
Joined 01/14/2018 - 40 Posts
Not that it matters, Hoss works at AOPA, I worked for the FAA. I'm retired now. 
Don't take the word of anyone except the ones that have the power to judge your actions. Here I would advise not getting the answer from an online chat.
AOPA is a fine institution that can help you if you get in trouble with the FAA. AOPA does have lawyers that will argue this issue with the FAA or in front of a Federal Administrative Judge.
You don't want to go there. Lawyers always want to get paid. $$$$$ I think before a lawyer does anything they first send out a bill. I've even seen a lawyer that charged to write and send a bill.
Here I also wouldn't ask your 'local' FSDO for the answer, unless you get the answer in writing and keep it for as long as you keep your log book.
You are asking a legal question that will follow you as long as you fly, and since Hoss mentioned insurance, your insurance company can void your claim with improper log entries questioning the validity of all entries.
(this is why I have kept every reciept for any logged flight time over the last 40 years)
Here is what I believe the court will use as a legal definition of logged solo flight should there ever be a question as to your log entries.

§ 61.87 Solo requirements for student pilots.

(a) General. A student pilot may not operate an aircraft in solo flight unless that student has met the requirements of this section. The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft or that flight time during which the student performs the duties of a pilot in command of a gas balloon or an airship requiring more than one pilot flight crewmember.

Note - the student can perform the duties of PIC, but the flight time is not logged as PIC, because the pilot is a student and not rated in that aircraft.
Once rated the pilot can log PIC time. Your lawyer could argue that you are now a student pilot studying for your commercial.
I doubt that would Fly. Now go look at the definition of 'Student Pilot' for this law.

In your life as a pilot you only ever need 10 solo hours in the type of aircraft you whish a certificate from private to ATP for example single engine land aircraft.
So why would you want log more?
You should log when you are flying with other pilots, however that could whack you too if that person is not a CFI or CFII.
They will likely question, who was really flying the plane. Did both log the flight time? Was the aircraft certificated for two pilot operation? 
Or was this other pilot the safety pilot during an instrument proficiency flight? (in this case you must log the other pilot)

Commercial / ATP rotorcraft pilots do move from rotorcraft to fixed wing, and they do require solo time as a student in the aircraft which a certificate is sought.
Even an ATP multi engine land pilot needs to log 10 hours of solo time in a single engine land aircraft for a private or commercial addition of the Private, Commercial, or ATP Privilege's in a Single Engine Land aircraft.. That is where the perceived discrepancy is in the Commercial and ATP single engine land additions to a certificate.
Remember, they are not rated to fly the single engine land aircraft on their certificate. They are 'a student pilot' able to act as Pilot in Command but not without a CFI rated in that aircraft and as such require an endorsement by a CFI to fly a single engine land aircraft 'solo' as a student pilot.
Note - they are specific for the time that may be logged as 'solo' with an instructor in FAR 61.129(a)(4) This modifies the legal definition of the subpart 61 only slightly.
They clarify in this subpart that 'The person logging solo time is Not PIC', only performing the duties of PIC with an instructor. It is this exception that permits a student to log the required 10 hours solo required in the aircraft which a certificate or endorsement is sought.

Don't take my word for it... I'm just a pilot, but we know everything.
 

Votes
Joined 02/15/2020 - 3 Posts
Here is one FSDO's opinion on students logging PIC time. Scottsdale FSDO
Votes
Joined 06/11/2017 - 702 Posts
Richard Gallaher:
Not that it matters, Hoss works at AOPA, I worked for the FAA. I'm retired now. 
Don't take the word of anyone except the ones that have the power to judge your actions. Here I would advise not getting the answer from an online chat.
AOPA is a fine institution that can help you if you get in trouble with the FAA. AOPA does have lawyers that will argue this issue with the FAA or in front of a Federal Administrative Judge.
You don't want to go there. Lawyers always want to get paid. $$$$$ I think before a lawyer does anything they first send out a bill. I've even seen a lawyer that charged to write and send a bill.
Here I also wouldn't ask your 'local' FSDO for the answer, unless you get the answer in writing and keep it for as long as you keep your log book.
You are asking a legal question that will follow you as long as you fly, and since Hoss mentioned insurance, your insurance company can void your claim with improper log entries questioning the validity of all entries.
(this is why I have kept every reciept for any logged flight time over the last 40 years)
Here is what I believe the court will use as a legal definition of logged solo flight should there ever be a question as to your log entries.

§ 61.87 Solo requirements for student pilots.

(a) General. A student pilot may not operate an aircraft in solo flight unless that student has met the requirements of this section. The term “solo flight” as used in this subpart means that flight time during which a student pilot is the sole occupant of the aircraft or that flight time during which the student performs the duties of a pilot in command of a gas balloon or an airship requiring more than one pilot flight crewmember.

Note - the student can perform the duties of PIC, but the flight time is not logged as PIC, because the pilot is a student and not rated in that aircraft.
Once rated the pilot can log PIC time. Your lawyer could argue that you are now a student pilot studying for your commercial.
I doubt that would Fly. Now go look at the definition of 'Student Pilot' for this law.

In your life as a pilot you only ever need 10 solo hours in the type of aircraft you whish a certificate from private to ATP for example single engine land aircraft.
So why would you want log more?
You should log when you are flying with other pilots, however that could whack you too if that person is not a CFI or CFII.
They will likely question, who was really flying the plane. Did both log the flight time? Was the aircraft certificated for two pilot operation? 
Or was this other pilot the safety pilot during an instrument proficiency flight? (in this case you must log the other pilot)

Commercial / ATP rotorcraft pilots do move from rotorcraft to fixed wing, and they do require solo time as a student in the aircraft which a certificate is sought.
Even an ATP multi engine land pilot needs to log 10 hours of solo time in a single engine land aircraft for a private or commercial addition of the Private, Commercial, or ATP Privilege's in a Single Engine Land aircraft.. That is where the perceived discrepancy is in the Commercial and ATP single engine land additions to a certificate.
Remember, they are not rated to fly the single engine land aircraft on their certificate. They are 'a student pilot' able to act as Pilot in Command but not without a CFI rated in that aircraft and as such require an endorsement by a CFI to fly a single engine land aircraft 'solo' as a student pilot.
Note - they are specific for the time that may be logged as 'solo' with an instructor in FAR 61.129(a)(4) This modifies the legal definition of the subpart 61 only slightly.
They clarify in this subpart that 'The person logging solo time is Not PIC', only performing the duties of PIC with an instructor. It is this exception that permits a student to log the required 10 hours solo required in the aircraft which a certificate or endorsement is sought.

Don't take my word for it... I'm just a pilot, but we know everything.
 

I'd like to know in what capacity Mr. Gallaher worked at the FAA because I'm pretty sure it wasn't Flight Standards or Legal.  In particular, he is misinterpreting the language from 61.87 about Student Pilots logging solo time because that section clearly says it only applies to "this Subpart", i.e., Subpart C Student Pilots.  It does NOT apply to anyone else.  For those like the OP Private and up, the definition of what gets logged as "Solo" is in 61.51(d).

(d) Logging of solo flight time. Except for a student pilot performing the duties of pilot in command of an airship requiring more than one pilot flight crewmember, a pilot may log as solo flight time only that flight time when the pilot is the sole occupant of the aircraft.

And that means you CANNOT log Solo time when flying with another pilot.  Even when you are doing the "simulated solo" training for 61.129(a), you log it as PIC, but not Solo -- the instructor notes in the remarks block that it was "flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor on board" and signs that.  And as long as the trainee has the ASEL rating on his/her Private ticket, that is certainly PIC time per 61.51(e)(1)(i) even though the instructor is still the actual PIC.  This issue has been discussed repeatedly by the FAA Chief Counsel.

As for Student Pilots, Hoss clearly stated above the regulations and FAA legal position on that -- Student Pilots flying solo log it as both Solo and PIC time, per 61.87 and 61.51(d).

Anyone who needs official confirmation of everything I've said (and official denial of Mr. Gallaher's statements) should contact an Operations Inspector at their local FSDO.  They can provide written guidance on all points.