Understanding the Federal Aviation Regulations is important for every pilot, especially those planning a career in aviation. For flight instructors and budding professional pilots, the complex rules on logging pilot-in-command (PIC) time are often stumbling blocks; I've helped several of our members when their careers were endangered by improperly logged time.
Quite often, questions on logging time are straightforward and I can provide the correct answer from memory. There are some questions, however, that make me dig into not only the FARs, but also preambles to the FAA rules, FAA orders, official FAA letters of interpretation, and National Transportation Safety Board case law. In rare cases, I'll have to request a ruling from the FAA General Counsel to answer such questions.
Why so much confusion over logging time, particularly PIC time? Often it's because pilots don't realize that there are actually two types of PIC time: time acting as PIC and time loggable as PIC even though you may not be acting as PIC. The difference is crucial.
Obviously, every flight needs one pilot to take responsibility for the flight. In FAR Part 1 (definitions), it's about as clear as it can get: the PIC is the pilot responsible for the operation and safety of an aircraft during flight. There can be only one "acting" PIC at a time and, of course, that pilot may log PIC, even if he or she is not touching the controls. Examples include flight instructors giving dual instruction, or a flight where you allow a passenger to experience the joy of flying the airplane.
But in FAR 61.51(2)(i), there's another definition. That paragraph allows logging of PIC time by the person handling the controls, if that person is rated in that aircraft. Under this provision, it's entirely possible for two pilots to log PIC time on a single flight: one because he or she is serving as the actual PIC responsible for the flight, the other as "sole manipulator of the controls."
Let's take some real-life examples. Almost every day, we get a question regarding a private pilot with an airplane, single-engine land rating (ASEL) flying a Cessna 172 while receiving instrument flight instruction from a CFII, in actual instrument weather. Of course, the private pilot does not yet hold an instrument rating, although he or she is actually manipulating the controls. Questions:
Who is "acting" PIC? The CFII, because the private pilot is not instrument rated and therefore cannot act as PIC in instrument conditions.
Who can log PIC time? Both. The CFII can log PIC as the person responsible for the safety of the aircraft in flight. For flight instructors, this is spelled out in FAR 61.51(c)(2)(iii). The private pilot can also log PIC time, as the sole manipulator of the controls in an aircraft in which he or she is rated (ASEL). In addition, the private pilot can also log IFR time, since the flight took place in actual instrument meteorological conditions.
Suppose a private pilot, ASEL, is taking multiengine instruction and has been signed off for solo practice by his flight instructor. He or she is alone in the airplane.
Can the private pilot log PIC? The private pilot is obviously acting as PIC, since there is no one else in the airplane who could take responsibility for the flight. That time is loggable as PIC under FAR 61.51(2)(i). That provision is often taken to mean that student pilots should log solo flight time as PIC, but that's not true: student pilots aren't yet certificated pilots. They must log solo time simply as "solo."
One more scenario: a private pilot, ASEL, is receiving flight instruction in a Beech A36 Bonanza in order to receive the high performance endorsement required by FAR 61.31(e).
Can the private pilot log the A36 instruction time as PIC? The private pilot is manipulating the controls of an aircraft for which he or she is rated (ASEL), and the A36 is definitely an airplane, single-engine land. The high performance restriction under 61.31(e) is a requirement for someone to be acting PIC in high performance aircraft only, not logging time in it.
As I write this, the new FAR Part 61 has not been issued, and it's possible that the new Part 61 will change some of the existing rules on logging time. Any time logged prior to the effective date of the new rules, however, will still be valid under the old rules.
Some of the most commonly asked questions about logging PIC time are answered on AOPA Online.
Miguel Vasconcelos, 29, joined AOPA Aviation Services in August 1995. His talents include fluency in five languages, and he is often called upon to solve problems for non-English speaking members of the association. He stays in touch with aviation as an active part-time CFI and corporate pilot in a Piper Cheyenne. Vasconcelos recently accepted a position in AOPA's Government and Technical Affairs Division.
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