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Answers for Pilots: Logging timeAnswers for Pilots: Logging time

Logging timeLogbooks mean many things to pilots—sentimental diaries of cherished time in the sky; reminders of people from years past who shared the cockpit with us; fond memories of aircraft we flew and destinations we enjoyed; journals of lessons learned. Logbooks, of course, have a practical use which includes keeping a record of time and training toward currency, and to be used for eligibility for additional certificates and ratings. It is important that airmen are aware of and comply with regulations related to logbook records to avoid problems, fines, or even certificate suspension.

For example, keeping track of takeoffs and landings is important because pilots must make three takeoffs and landings within the preceding 90 days to carry passengers. Additional currency requirements exist for night flight and tailwheel aircraft, so it's important to record night flight and time in tailwheel aircraft in separate columns. Though currency may be an obvious reason to keep flight logs, there are others. Logs should be kept for quick reference when applying for a flying job, as all aviation industry employers will require a certain amount of flight time to even be considered.

Logging time is usually straightforward. But occasionally, there are unique circumstances. Consider this scenario: 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-limiting 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).

How about this one—clarified in a recent FAA Letter of Interpretation signed by Rebecca B. MacPherson, Assistant Chief Counsel for Regulations, FAA Office of Chief Counsel.

This responds to your request for a legal interpretation that was faxed to this office on February 25, 2009. Your letter requests clarification concerning the logging of pilot-in command (PIC) flight time under 14 C.F .R. § 61.51 (e) and the logging of cross-country time to meet the aeronautical experience requirements for an instrument rating under 14 C.F.R. §61.65( d).

Your letter presents an example to illustrate your questions. In the example, Pilot A and Pilot B, who both are rated in the aircraft, take a flight between two airports that are separated by 187 nautical miles. As agreed to prior to the flight, Pilot A flies the aircraft and Pilot B acts as the PIC. Although the flight is conducted in visual meteorological conditions, Pilot A operates the aircraft in simulated instrument flight with Pilot B acting as a safety pilot. The total flight time is 2.2 hours and the total simulated instrument time is 2.0 hours. Your letter asks how much PIC flight time and cross-country flight time can be logged by Pilots A and B.

Section 61.51(e) governs the logging of PIC time and states, in relevant part, that a sport, recreational, private, or commercial pilot may log PIC time for the time during which that pilot is "the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges" or "acting as pilot in command of an aircraft on which more than one pilot is required under… the regulations under which the flight is conducted."

In your example, Pilot A may log the entire flight (2.2 hours) of PIC flight time because that pilot was the sole manipulator of the controls for the entire flight. Pilot B may log the portion of the flight during which Pilot A operated in simulated instrument flight and Pilot B acted as the safety pilot (2.0 hours) because Pilot B was a required flight crewmember for that portion of the flight under 14 C.F.R. § 91.109(b).

Section 61.65 requires, in relevant part, that an applicant for an instrument rating log 50 hours of cross-country flight time as pilot in command. Cross-country time is defined in 14 C.F .R. § 61.1 (b)(3)(ii) as time acquired during a flight conducted in an appropriate aircraft that "includes a point oflanding that was at least a straight-line distance of more than 50 nautical miles from the original point of departure" and that "involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point."

A safety pilot provides a visual reference to the ground and other aircraft during the portion of the flight when the pilot manipulating the controls is flying with a view-limiting device. As discussed above, the safety pilot is a required flight crewmember for only a portion of the flight. Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time. Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight. In your example, Pilot A may log the entire flight (2.2 hours) of cross-country flight time because that pilot conducted the entire flight. However, Pilot B may not log any cross-country flight time because that pilot was a required flight crewmember for only a portion of the flight.

Questions? Read more in AOPA subject report on Logbooks and Logging Time or call AOPA’s Pilot Information Center, 800/USA-AOPA (872-2672) Monday through Friday, 8:30—6 Eastern Time.

Kathy Dondzila

Kathleen Dondzila King

Manager, Technical Communications, Pilot Information Center
Technical Communications Manager, Kathleen Dondzila King, joined AOPA in 1990 and is an instrument-rated private pilot.
Topics: Cross Country, Safety and Education, Instrument Rating

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