LOGGING PIC TIME

LOGGING PILOT-IN-COMMAND TIME

One of the most frequent questions arising on internet discussion forums relates to the conditions under which a pilot can log Pilot In Command time. This discussion will consider only situations pertaining to airplanes.

Before we launch into a discussion of the issue, let’s look at the pertinent FAR section:

§61.51 Pilot logbooks.

(e) Logging pilot-in-command flight time. (1) A recreational, private, or commercial pilot may log pilot-in- command time only for that flight time during which that person --

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated;

(ii) Is the sole occupant of the aircraft; or

(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate.

(3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor.

(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 current solo flight endorsement as required under §61.87 of this part; and

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

Student pilots are addressed in (e)(4). The student pilot must be the sole occupant of the airplane, and that means exactly that, no other pilot, no instructor, no girlfriend, etc. There is no way for a student pilot to log PIC time in an airplane other than solo flight (well, there is one exception, and that is when you take your checkride).

The provisions that cause the most trouble are (e)(1)(i) and (e)(1)(iii).

Subparagraph (e)(1)(i) says you must be the sole manipulator of the controls and you must be rated for the aircraft. What does “rated” mean? It means you have the appropriate category, class, and, if required, type rating on your pilot certificate. Except for type ratings, which I will not discuss further, ratings do not extend to make and model, they are just category (airplane, rotorcraft, lighter-than-air, etc.) and class (single-engine, multi-engine, land, sea, helicopter, gyroplane, etc.). Further definition of categories and classes of aircraft, for the purpose of the certification of airmen, can be found in FAR 61.5(b).

Say your friend owns a high-performance complex single-engine airplane, such as a Saratoga or Bonanza. You and friend go flying in the plane, and he lets you do the flying. Your private pilot certificate carries a rating for airplane, single engine, land. But you do not have the endorsements required by FAR 61.31(e) and (f) required to act as PIC in complex and high-performance airplanes. Can you log PIC time for the flight? Sure you can, for the time you were the sole manipulator of the controls. You are rated for the airplane (ASEL), and that is all that is required by the regulation. The airplane is ASEL, your pilot certificate carries a rating for ASEL. Lacking the endorsements, you cannot act as PIC in those airplanes, but you can log the time as PIC. Your friend, who has the endorsements, would have to act as PIC. It is an interesting quirk that your friend is the actual PIC but he cannot log the time as PIC because he was not sole manipulator of the controls.

The same applies to tailwheel airplanes and pressurized airplanes.

Note the distinction between acting as PIC and logging PIC time. That is the central issue in these discussions. They are two separate things and are treated separately in the regulations. If you are acting as PIC, then you are the person legally responsible for the conduct of the flight, you are the final authority as to the operation of the aircraft, and you are the person empowered to exercise the PIC’s emergency authority. See FAR 91.3. And you must be fully qualified to operate the aircraft and serve as PIC under the conditions of the flight. Logging PIC time is just bookkeeping, although with rules that result in frequent misunderstanding, and under the rules you don’t necessarily have to be acting as PIC in order to log PIC time.

Subparagraph (e)(1)(iii) says that another pilot on board, who is acting as PIC but is not manipulating the controls, can log PIC time if more than one crewmember is required, either by the type certification of the airplane, or by the regulations under which the flight is conducted. This subparagraph comes into play most commonly regarding a flight conducted for instrument training or practice, during which the pilot flying (sole manipulator of the controls) is using a view-limiting device to simulate instrument flight conditions, and another pilot (pilot not flying) is on board acting as safety pilot. In this case, the regulations under which the flight is conducted is FAR 91.109, set forth below in pertinent part:

§91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(b) No person may operate a civil aircraft in simulated instrument flight unless --

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot; and

(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when --

(i) The safety pilot has determined that the flight can be conducted safely; and

(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.

You can see (3)(ii) prohibits student pilots (and recreational pilots) from participating in this kind of flight without an instructor.

On this flight, you as sole manipulator of the controls can log PIC time. If the safety pilot acts as PIC for the flight, then he can also log PIC time, since he is a required crewmember under 91.109(b).

Note that FAR 61 governs the certification of airmen but does not govern the conduct of flights. The phrase regulations under which the flight is conducted refers to Part 91, 121, 125, 135, 137, or some other part of the FAR that governs conduct of flights.

For logging PIC time, there is no requirement that a pilot be current or have a current medical. You could have not flown in twenty years, go up with a pilot friend tomorrow (one who is current), and log PIC time. To act as PIC, though, you must be current.

There is one more little detail about this PIC business. The FAA makes a distinction between (a) logging PIC time, (b) acting as PIC (meaning that you are the PIC), and (c) performing the duties of PIC. This last situation, where you are kind of pretending to be PIC but really aren’t, arises in multiengine training flights at the commercial and airline transport pilot certificate levels. As an example,

61.129(b)(4) 10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor (either of which may be credited towards the flight time requirement in paragraph (b)(2) of this section), on the areas of operation listed in §61.127(b)(2) of this part that includes at least -- blah blah blah

This exists because of limitations of insurance contracts.

Refer to the Part 61 FAQ for more information on these topics.