Student Pilot Logging PIC 61.51(e)(4)

[MajorTom]

I have a question about logging PIC time as a student.

The FAR in question is 61.51(e)(4) which states:

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(e) Logging pilot-in-command flight time.​

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(4) A student pilot may log pilot-in-command time only when the student pilot—​

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;​

(ii) Has a solo flight endorsement as required under §61.87 of this part; and​

(iii) Is undergoing training for a pilot certificate or rating.​

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Specifically I have a question about line (iii) stating, "Is undergoing training for a pilot certificate or rating."​

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The Scenario: I am a CFI/II now and I am transferring my records to an electronic logbook. When I worked on my Private Pilot back in the day, I logged over the required solo time for Part 61 Private Pilot. For the time that was beyond the requirement still considered as time "undergoing training."​

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If Yes, Then when are you not undergoing training towards a rating as a student pilot? Is this just supposed to be a "good faith" type statement, where If I know I wasn't working towards a rating that I shouldn't log it as PIC? Anyone know what the idea behind this stipulation might be?​

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I understand I may be splitting hairs here but I find this stuff interesting.​

 

[Maurus]

Going over minimums doesn't mean you still aren't training. I think the last item is for the people that just keep getting 90 day endorsements and never actually finish their training. I knew a guy like that. Kept getting his endorsement renewed but never seemed to finish his private certificate. He even owned his own aircraft.

 

[MajorTom]

That's how I saw it.But playing devils advocate here, I could say he is still training, right? I guess I might be looking for a specific answer where there is none.

 

[Houston]

This doesn't throw a lot of light on your second question, but it is somewhat related. This comes from the old John Lynch FAQs:

The intent of the phrase “undergoing training” in §§ 61.51(e)(4)(iii) or the phrase “receiving training” in § 61.31(d)(3) merely means receiving training for the purpose of a certificate or additional rating. The training may be dual training received from an authorized instructor while the instructor is on board the aircraft. Or the training may be a part of the training process where the person is solo aboard the aircraft after being given an appropriate solo privilege endorsement per subpart C for student pilots or § 61.31(d)(3) for recreational and higher level certificated pilots.

{Q&A-479}