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One topic that invariably pops up whenever there is a gathering of pilots is the logging of pilot-in-command (PIC) time. The much-coveted PIC time has been a controversial subject and can be very confusing. After reading this, you may be amazed to find that there are many different ways to log PIC!
Before we get started, we must define pilot in command. The PIC is, by Federal Aviation Regulations (FARs), responsible for the safe operation of the flight (FAR 1.1, 91.3). At any given time, there can only be one acting PIC on a flight, no matter how many pilots are on board the aircraft. To legally act as PIC, a private, commercial, and airline transport pilot must have a current medical certificate and have all required endorsements, ratings, and recency of experience for the type of aircraft being flown and the flight conditions under which the flight is conducted (FAR 61.3, 61.31, 61.56, 61.57). Sport pilots can act as PIC with a valid and current driver's license in lieu of the FAA medical (FAR 61.23). Before a flight is initiated, an agreement should be made to determine who is to be acting as PIC.
Unlike driving cars, the PIC may allow anyone, including a non-pilot, a pilot who may not legally act as pilot in command, or another fully qualified pilot fly the airplane, or be "sole manipulator of the controls" during the flight. The PIC is not required to sit in the left pilot seat. Regardless of where the PIC is sitting in the airplane or who is manipulating the controls, the PIC is ultimately responsible and accountable for the safety and operation of the flight.
A pilot may log PIC time when he/she is the sole occupant of the aircraft; is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges; or is acting as PIC where more than one pilot is required (FAR 1.1, 61.51 [e]). An airline transport pilot may log PIC time when he/she is acting as PIC of an operation requiring an ATP certificate. An authorized instructor may log PIC time while acting as an authorized instructor in flight. A student pilot may log PIC time only when he/she is the sole occupant of the aircraft (exception for airship category) while training for a pilot certificate and has a current solo flight endorsement. The FARs provide several situations (see scenarios listed below) where two or more pilots may log PIC time, even though there can only be one pilot acting as PIC.
Why do the FARs allow more than one pilot to log PIC time when there can only be one PIC on a given flight? To help pilots build PIC time toward the furtherance of other certificates and ratings. This is also helpful in fulfilling insurance requirements for PIC time.
A pilot, whether acting as PIC or not, may log PIC time anytime in which he/she is sole manipulator of the controls of an aircraft for which he/she is rated (FAR 61.51). This is true regardless of weather conditions, whether VFR or IFR, simulated or actual.
Rated, by FAA interpretation, means that the pilot has the appropriate category, class, and type (if required) privileges on his/her pilot certificate for the aircraft being operated. Period. Note that "rated" does not require the pilot to have an instrument rating, a current medical, recency of experience, flight review, or required endorsements (such as tailwheel or high performance). "Privileges" often refer to sport pilots because sport pilot certificates are not issued to pilots with category and class ratings. Rather, an endorsement for the category, class, and make and model of aircraft is placed in the sport pilot's logbook.
For example, if you are a non-instrument-rated, private pilot with airplane, single-engine land privileges, you would be considered appropriately "rated" to log PIC time anytime (in VFR or IFR conditions) you are sole manipulator of the controls of any (high-performance or tailwheel) single-engine airplane configured for takeoff and landing on land (unless, of course, the airplane required a specific type rating, which is required for jet aircraft and aircraft with gross weights over 12,500 pounds). Remember, although a pilot may log flight time as PIC under this provision, there must still be someone in the aircraft who is legally acting as PIC.
Let's say you want to get an endorsement to fly tailwheel airplanes or high-performance aircraft. If you are already rated for that aircraft, you may log PIC time for all instruction time that you are sole manipulator of the controls. To illustrate, if you have private pilot certificate, airplane single-engine land, and you wish to receive instruction for a tailwheel endorsement in a single-engine, tailwheel aircraft, you may log the instruction time in which you are sole manipulator of the controls as PIC time.
The same holds true for instrument instruction. If you are receiving instrument instruction in an aircraft for which you are rated, the time you spend as sole manipulator of the controls is loggable as PIC, whether you are in actual or simulated instrument conditions.
When practicing flying in simulated instrument conditions with a safety pilot, both the pilot flying the aircraft by reference to instruments and the safety pilot may log PIC time if the safety pilot is acting as PIC. As long as the pilot flying the aircraft is rated for the aircraft being flown, he/she may log this time as PIC because he/she is sole manipulator of the controls (FAR 61.51). Because the pilot flying will be wearing a view-limiting device, a safety pilot will be a required crewmember on board (FAR 91.109). The safety pilot may log as PIC any flight time for which he/she is acting PIC in an operation requiring more than one pilot crewmember (FAR 61.51).
A sport or recreational pilot may not act as safety pilot because a sport or recreational pilot may not act as a required pilot flight crewmember in an operation requiring more than one pilot (FAR 61.101).
To act as a safety pilot, a current medical certificate is required because a safety pilot will be acting as a required pilot crewmember, which requires a current medical certificate (FAR 61.3).
We have provided some scenarios to illustrate the logging of PIC time with regard to safety pilots; in both cases, Pilot A will be the pilot flying the aircraft by reference to instruments under the hood or in actual instrument conditions, and Pilot B will be the safety pilot and/or acting as PIC:
Pilot A wants to accompany Pilot B on a cross-country flight in a single-engine, high-performance aircraft. Pilot A is rated for the airplane but does not have a current medical, high-performance endorsement, or current flight review. Pilot A will be practicing simulated instrument flying, wearing a view-limited device, and will be sole manipulator of the controls during the en route portion of the flight. Pilot B meets all the requirements to be PIC and has agreed to be PIC and safety pilot during the flight.
Under these circumstances, Pilot A may log PIC time and simulated instrument time; Pilot B may log PIC time but not instrument time, because he/she is not operating the aircraft by reference to instruments (FAR 61.51).
Pilot A wishes to fly with Pilot B on a cross-country flight in a single-engine, high-performance aircraft. Pilot A is rated for the aircraft but is not instrument rated or endorsed to fly high-performance aircraft and does not have a current medical certificate or flight review. Pilot A will be flying by reference to instruments during actual instrument conditions. Pilot B is legal to act as PIC and has agreed to be the PIC. Under these circumstances, Pilot A may log PIC and actual instrument time (although Pilot A should be prepared to explain to an FAA inspector why PIC time was logged while in actual instrument conditions, when he/she was not instrument rated). Pilot B cannot log PIC as he/she is not the sole manipulator of the flight controls and cannot log instrument time because he/she was not flying the aircraft by reference to instruments (Far 61.51).
Pilot A wishes to fly with Pilot B for the purpose of practicing instrument flying in a high-performance aircraft. Pilot A may legally act as PIC and has agreed to act as PIC. Pilot A will be wearing a view-limiting device and will be flying by reference to instruments. Pilot B is rated in the aircraft and has a current medical certificate but is not instrument rated, endorsed to fly high-performance airplanes, or have a current flight review. Pilot B has agreed to be the safety pilot for the flight.
Pilot A may log PIC and simulated instrument time. Pilot B may log second-in-command (SIC) time. Pilot A is assuming PIC responsibilities and may log PIC. Pilot B is a crewmember where more than one pilot is required and may log SIC (FAR 61.51). Again, because Pilot B is a required crewmember, he/she will need a current medical certificate (FAR 61.3).
Flight instructors may log any flight time as PIC whenever they are providing flight instruction, whether or not they are acting as PIC (FAR 61.51). This mainly applies to FAR Part 91 operations! An instructor may not give flight instruction during a FAR 135 or 121 operation unless he/she is a designated flight instructor as stated in the carrier's approved operations manual.
Another popular question that arises in discussion is whether or not a student pilot may log PIC time. As per FAR 61.51 (e)(4), a student pilot may log PIC when they are the sole occupant of the aircraft and have a current solo flight endorsement. This is a part of the August 4, 1997, Part 61 rewrite and is a change from past regulations.
What happens when a student pilot is taking a checkride for his/her private, recreational, or sport pilot certificate, or a pilot is upgrading to a higher rating or privilege? By FAR 61.47, the examiner is not PIC. The student pilot or pilot at this time is now considered a flight test applicant and may log the flight evaluation as PIC, whether or not he/she passes.
A special note to "time builders": Although the FAA provides several means to log PIC time, PIC time represents flying or instructional experience and sound decision making ability. Commercial employers might not be impressed with hundreds of hours logged as PIC where the pilot was not actually flying.
This document has been prepared from various reference to FARs and letters of interpretation from the FAA.
AOPA thanks our members for their continued support in protecting the freedom to fly.