The Hangar Myth That Messes Up Pilot Logbooks
Walk into almost any flight school or aviation forum and ask this question: “I’m a Private Pilot working on my complex endorsement. Can I log PIC time while receiving instruction from my CFI if I’m the sole manipulator of the controls?”
Chances are, your hangar session will split right down the middle. Half the instructors will tell you absolutely not—because you aren’t legally endorsed to fly the plane yet. The other half will tell you that you can.
As a Designated Pilot Examiner (DPE), I see this confusion translate directly into applicant logbooks on checkride day. The good news is that you don’t have to rely on tribal flight school rumors. The FAA has a definitive, black-and-white answer.
Yes, you can legally log PIC time in this scenario.
The Golden Rule: Acting vs. Logging
To understand why this is legal, you have to master a fundamental concept that trips up applicants on almost every Commercial and CFI oral exam: the difference between acting as Pilot in Command and logging Pilot in Command time.
- Acting as PIC (14 CFR §61.3): To act as the PIC, you are the final authority and hold ultimate responsibility for the safety and operation of the flight. To act as PIC in a complex aircraft, you must hold the appropriate category, class, and specific type ratings (if required), which includes having the complex endorsement signed off in your logbook.
- Logging PIC (14 CFR §61.51): To log PIC time, the rules are entirely different. Under §61.51(e), a sport, recreational, private, commercial, or airline transport pilot may log pilot-in-command time for any flight during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated. Being “rated” means you need to hold the basic underlying rating of the aircraft being flown—for example, Airplane Single Engine Land (ASEL) for a Cessna 172.
Because you already hold an Airplane Single Engine Land rating, and the complex aircraft you are training in is a single-engine land airplane, you are properly rated. Because you are the one physically flying the airplane (sole manipulator of the controls), you meet the explicit FAA criteria to log that time as PIC—even though your CFI is the one acting as the legal PIC.
The Official Proof: The Herman 2009 Legal Interpretation
When a DPE asks you a regulatory question during an oral exam, pointing to a blog post or quoting your primary instructor won’t cut it. You need to show official legal precedence.
The definitive authority for this scenario is the Herman 2009 FAA Chief Counsel Letter of Interpretation. The FAA Chief Counsel was asked this exact question regarding a pilot flying a high-performance or complex aircraft without the proper endorsements. Here is the relevant conclusion from that official document:
“Accordingly, in your examples, the pilot may log PIC time if that pilot is properly rated for the aircraft flown, even though that pilot does not have the required endorsements to act as a PIC.”
The interpretation makes clear that §61.31(e) and (f) establish additional training and endorsement requirements specifically for acting as PIC of a complex or high-performance airplane. Those endorsements are not required to log PIC time, provided the pilot is properly rated in the aircraft and is the sole manipulator of the controls.
Never Second-Guess the Regulations Again
Trying to track down, download, and read through dozens of individual FAA Letters of Interpretation while preparing for a checkride is a massive headache. That’s exactly why I built the VSL ACE Guide.
Walk Into Your Checkride with Confidence
The ACE Guide puts a curated library of over 30 critical FAA Legal Interpretations—including the Herman 2009 LOI—right at your fingertips. Each one includes a clean, simplified breakdown alongside the actual source document. No cheat sheets. No guesswork. Just the real regulatory framework your DPE will test you on, organized and ready to go—with free lifetime updates as new interpretations are added.
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