ATP PIC requirements
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Joined: Jul 2019
Posts: 18
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From: London
ATP PIC requirements
Hi all, I am currently an FO flying the A320 around Europe. I'm looking to move to the US soon (yes I can get the right to work). But I'm having difficulty understanding the FAR documentation.
To my understanding, under 14 CFR 61.51(e), I am able to count time as pilot flying on the airbus towards the PIC requirement for the ATP.
Could anyone please let me know if I'm hopefully understanding this correctly or if I'm going to have to spend hundreds of grueling hours doing traffic patterns to fulfil this requirement.
Thanks.
To my understanding, under 14 CFR 61.51(e), I am able to count time as pilot flying on the airbus towards the PIC requirement for the ATP.
Could anyone please let me know if I'm hopefully understanding this correctly or if I'm going to have to spend hundreds of grueling hours doing traffic patterns to fulfil this requirement.
Thanks.

Joined: Dec 2005
Aviation Qualifications: ATPL
Posts: 4,993
Likes: 339
From: Hong Kong
Read part 61. If you have a rating and you are the sole manipulator of the controls then you can log that as PIC. Sounds crazy but it's true. You can even count your ME-IR training.
Last edited by rudestuff; 21st February 2026 at 15:07.

Joined: Feb 2004
Aviation Qualifications: ATPL
Posts: 3,689
Likes: 118
From: USA
I see that while I was fizzing around trying to compose an answer, Rudestuff stepped in to comment. But I'll post what I had written as it gives some documentation to the answer.
Crusherrr,
I'm going to play jailhouse lawyer here and say you can user your time as "sole manipulator" of the controls as an F/O toward the PIC requirements for an FAA ATPL.
Here are a few FAA letters of interpretation addressing this issue. You'll find it addressed in part of each of these letters:
https://www.faa.gov/media/15551
https://www.faa.gov/media/14521
https://www.faa.gov/media/11911
I had a better one which I now can't find. But the gist of it was that the FAA realized a long time ago that for a person entering a Part 121 operation as a person with minimal PIC time, it was hard to get the required PIC time for an ATPL so they allowed "sole manipulator" time or PICUS to count for purposes of getting an ATPL.
Don't bet the grocery money on my version of this. Rudestuff or B2N2 will come along and concur or set the question right.
In any even, good luck.
Crusherrr,
I'm going to play jailhouse lawyer here and say you can user your time as "sole manipulator" of the controls as an F/O toward the PIC requirements for an FAA ATPL.
Here are a few FAA letters of interpretation addressing this issue. You'll find it addressed in part of each of these letters:
https://www.faa.gov/media/15551
https://www.faa.gov/media/14521
https://www.faa.gov/media/11911
I had a better one which I now can't find. But the gist of it was that the FAA realized a long time ago that for a person entering a Part 121 operation as a person with minimal PIC time, it was hard to get the required PIC time for an ATPL so they allowed "sole manipulator" time or PICUS to count for purposes of getting an ATPL.
Don't bet the grocery money on my version of this. Rudestuff or B2N2 will come along and concur or set the question right.
In any even, good luck.

Joined: Feb 2004
Aviation Qualifications: ATPL
Posts: 3,689
Likes: 118
From: USA
Crusherrr,
Found the letter of interpretation I was thinking of:
https://www.faa.gov/about/office_org...rpretation.pdf
Found the letter of interpretation I was thinking of:
https://www.faa.gov/about/office_org...rpretation.pdf
Last edited by bafanguy; 21st February 2026 at 16:57.




