Logging flight time and instrument experience when the autopilot is engaged

Following the FAA’s latest clarification for logging instrument approaches, an airman posed a two-part question: “Does use of the autopilot prevent a pilot from logging PIC flight time as sole manipulator of the flight controls, and does a pilot using the autopilot during an instrument approach procedure (IAP) actually ‘perform’ the IAP as required by FAR 61.57(c)?”

The first part of this question stems from the requirements for logging flight time as PIC, as found in FAR 61.51, “Pilot Logbooks.”  The FAR provides several instances when a sport, recreational, private, commercial, or airline transport pilot may log PIC flight time for flights, one of which is “when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated…”

While the language of FAR 61.51 doesn’t address whether using an autopilot is sufficiently manipulating the aircraft’s flight controls within context of this regulation, the FAA issued a legal interpretation in March 2015 that squarely addresses this issue.

According to the legal interpretation, the FAA “considers a pilot's use and management of the autopilot to be the equivalent of manipulating the controls, just as one manages other flight control systems, such as trim or a yaw dampener. The autopilot system's sophistication does not affect a pilot's responsibility to manipulate and manage all control systems, including an autopilot, appropriately. Therefore, a pilot may log PIC flight time as the sole manipulator of the controls for the time in which he or she engages an autopilot.”

Although this legal interpretation is limited to FAR 61.51, the FAA’s reasoning that a pilot’s use and management of the autopilot system is equivalent to the use and management of other flight control systems allows us to determine how the FAA would likely answer the second part of our airman’s question. Specifically, an instrument rated pilot may use the autopilot during an IAP and be considered to have “performed” the IAP for the purpose of logging six IAPs every six months in order to maintain his or her IFR currency as required by FAR 61.57(c), “Instrument Experience.”

As a final note, remember that while an autopilot is a valuable resource that can greatly reduce the pilot’s workload, it is simply another aircraft system to be managed. The NTSB  has long held that pilots have a duty to monitor the autopilot at all times, even at cruise, but especially when a small course change or other adjustment is being made. And of course, even pilots with the most reliable autopilots may want to consider performing a few practice IAPs while hand-flying the aircraft to maintain proficiency.

Jared Allen
Mr. Allen is AOPA’s Legal Services Plan (LSP) senior staff attorney and is an instrument-rated private pilot. He provides initial consultations to pilots through the LSP when the FAA has contacted them about potential FAR violations. Jared has helped numerous pilots successfully navigate through compliance actions.

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