Once you get a new pilot certificate, the next step is to spread your wings and explore the grand new world you’re now a part of. While being out of the initial training environment allows you to have some great new freedoms, it also means some new responsibilities. One of those new responsibilities is managing your logbook. In this article, we will focus on answering common questions about logging Pilot in Command (PIC) time, an area that can be confusing for some new pilots to master. Let’s start by defining PIC.
The FAA defines PIC in Title 14 of the Code of Federal Regulations (14 CFR) section (§) 1.1 as the person who:
(1) Has final authority and responsibility for the operation and safety of the flight,
(2) Has been designated as pilot in command before or during the flight, and
(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.
Acting as PIC vs. Logging as PIC
In both a practical and legal sense, only one pilot may act as PIC for any given flight. However, there are situations where a pilot can log PIC time while not acting as pilot in command. “One of the biggest issues when considering PIC time is that in order to understand it, you have to look across multiple regulations in 14 CFR parts 1, 61, and 91,” explains Allan Kash, an Aviation Safety Inspector (ASI) with the Flight Standards General Aviation and Commercial Division. To understand when you can log PIC time, you also need to understand how and why the FAA requires pilots to log flight time. For FAA purposes, a pilot is required to log certain flight time primarily to qualify for or maintain an airman certificate or rating.
Inspector Kash elaborated, “The next big issue is that the requirements to act as PIC and to log PIC time are different. There is a legal distinction. You could very well have a situation where you have both pilots legally logging PIC time, even though the regulations only allow for one pilot to act as PIC. ”
The FAA lists the requirements to serve as a required pilot flight crewmember in 14 CFR § 61.3(a) and (c). These requirements include holding a pilot certificate, photo ID, and a medical certificate (or the ability to meet sport pilot medical requirements). Additionally, § 61.3(e) requires a person acting as PIC under IFR or in IMC conditions to hold an instrument rating. Furthermore, § 61.31 requires a person acting as PIC to hold the appropriate ratings and endorsements for the aircraft type to be flown and § 61.56 requires a pilot to have a current flight review to act as PIC. So far it seems pretty straightforward, right? Here’s where the questions arise. The FAA’s standards for logging PIC time are found in § 61.51(e):
(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights November/December 2016 FAA Safety Briefing 15 Your friend asks if you want to fly one of the legs. Are you legally allowed to fly? Are you able to act as PIC? Are you able to log as PIC? (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate, (ii) When the pilot is the sole occupant in the aircraft, (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted. …
Note: There are other conditions under which a pilot can log PIC in §61.51 (e)(1)(iv). These regulations don’t quite appear to match up: the rule for logging PIC time has fewer restrictions than the rule to act as PIC. So there are circumstances where you can log PIC while not acting as PIC, but you can also be acting as PIC and not be able to log PIC. Stay with me — the details and examples below will help.
Solo vs. Sole Manipulator
Let’s look at § 61.51(e)(1)(ii) first, since that’s probably the simplest to define and contains what you may be most familiar with from your initial training as a solo student pilot. Under § 61.51(e) (1)(ii), you may log PIC flight time when you’re the only person on board the aircraft. In the most basic sense, all solo time is PIC, but not all PIC time is solo. For such a flight, you would also have to meet the requirements of § 61.3 (including holding a medical certificate), § 61.56 (flight review requirements), and § 61.31 (appropriate ratings and any endorsements required by the aircraft, such as high performance or complex).
Once you’ve been certificated as a pilot, if you take a non-pilot friend along on your solo cross country trip, you’re no longer the sole occupant. Accordingly, you may not log PIC under § 61.51(e) (1)(ii), but you may log PIC under § 61.51(e)(1)(i) as the sole manipulator of the controls of an aircraft for which you are rated. You would still have to meet the requirements in § 61.3, 61.31, and 61.56 just as you did for a solo flight. To further complicate matters, if you take a fellow pilot along on your cross-country trip, so long as you are the sole manipulator of the controls, you may log PIC under § 61.51(e) 1)(i) regardless of who is acting as PIC. However, the fellow pilot may not simultaneously log PIC time for the portion of the flight that you are logging PIC time as the sole manipulator of the controls, even if the fellow pilot is acting as PIC, unless the requirements of § 61.51(e)(1)(iii) are met, namely more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.
PF vs. PIC
The next quirk is that the Pilot Flying (PF) may not always be the PIC. The PF and PIC are definitely not synonymous. The clearest example is in an airline cockpit where crews will generally swap legs. The captain and first officer will switch between the PF and Pilot Monitoring (PM) roles. Regardless of who is actually flying the airplane, the captain is always the PIC. This situation could also occur in GA. Therefore, the question here is: When may a GA pilot log PIC under § 61.51(e), when not acting as PIC? One example is when a certificated flight instructor (CFI) is providing flight instruction to a student who holds at least a private pilot certificate and who is qualified to act as PIC. A CFI providing instruction to a person who is qualified to act as PIC need not be the acting PIC, yet still may legally log PIC under § 61.51(e)(3), regardless of who is manipulating the controls.
Let’s examine another common example in the GA world. Let’s say and a pilot friend are going for a $100 hamburger. Your friend suggests taking her Piper Saratoga (a complex high performance airplane). You both have private pilot certificates with an airplane single engine land (ASEL) rating. Your friend has both high performance and complex endorsements, but you do not. You do, however, have a lot of experience with similar airplanes and even some time in a Saratoga. For the purposes of this example, you both have current medicals and flight reviews. Your friend asks if you want to fly one of the legs. Are you legally allowed to fly? Are you able to act as PIC? Are you able to log as PIC?
The answers are yes, no, and yes. You may be the PF, but you may not act as PIC because you do not hold the complex and high performance endorsements required by § 61.31(e) and (f ). In this circumstance, your friend is acting as PIC while you fly. You may, however, log PIC time under § 61.51(e) (1)(i) as the sole manipulator of the controls because § 61.51(e)(1)(i) requires only that you are rated for the aircraft. In this situation, you would be flying and logging as PIC while your friend is acting as PIC but not able to log PIC per § 61.51(e)(1)(iii). This is 16 FAA Safety Briefing November/December 2016 further explained by a legal interpretation in 2009 (Speranza) http://go.usa.gov/xk4TM.
PIC vs. Safety Pilot
As we discussed earlier, the devil really is in the details when it comes to logging of PIC time. Nowhere is this truer than in § 61.51(e)(1)(iii). “The most common mistake I see with logging PIC is with safety pilots when required by § 91.109(c),” Kash said. He explained, “people don’t really understand the implications in § 61.51(e)(1)(iii).” Section 61.51(e)(1)(iii) reads:
“When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted”.
GA pilots often overlook this point because for the most part, our aircraft don’t require more than one pilot. However, in the case of simulated instrument flight, the regulations do require more than one pilot. Per 14 CFR § 91.109(c)(1), a safety pilot is required to operate in simulated conditions. This makes the safety pilot a required pilot flight crewmember under the regulations for the simulated instrument portion of the flight. The safety pilot is required to hold at least a private pilot certificate, be rated for the category and class of airplane to be flown, and hold a current medical as required by § 61.3(c). If the safety pilot is acting as PIC for the simulated instrument portion of the flight, the safety pilot may log that time as PIC time under § 61.51(e)(1)(iii) because he is acting as PIC of an aircraft for which more than one pilot is required under the regulations. The PF may also log the time as PIC time under § 61.51(e)(1)(i) as the sole manipulator of the controls of an aircraft for which the pilot is rated. Additionally, the pilot flying under simulated instruments log simulated instrument time.
However, if the PF is acting as PIC and is the sole manipulator of the controls during the simulated instrument portion of the flight, then the safety pilot may log that time as second in command (SIC) time because he or she holds the appropriate category and class ratings for the aircraft being flown and more than one pilot is required under the regulations under which the flight is being conducted in accordance with § 61.51(f)(2). This is further explained by a legal interpretation in 2012 (Trussell) http://go.usa.gov/xk4bB.
Let’s look at an example. You want to do some practice approaches to get ready for a big trip coming up next month, but your medical has lapsed and your appointment at the aviation medical examiner (AME) isn’t until next week. Your friend volunteers to be your safety pilot. Both of you are instrument-rated private pilots with all appropriate endorsements for the airplane. Your friend has a current medical. Can you fly? Can you act as PIC? Can you log PIC? Can you log simulated instrument time?
The answers are: Yes, no, yes, and yes. For the purposes of this flight, your friend meets the requirements for a safety pilot and the operation requires more than one pilot by regulation. You may not act as PIC because you do not have a current medical. Therefore, your friend would be acting as PIC and may log PIC under § 61.51(e)(1)(iii), but you could also log PIC time as sole manipulator of the controls when operating by sole reference to instruments and using a view-limiting device under § 61.51(e)(1)(i).
Now let’s say you have a medical and your friend does not. Does this change the answers? It does, because your friend no longer meets the requirements for a safety pilot as a required pilot flight crewmember directed by § 61.3(c). In that case, you couldn’t fly simulated instruments
per § 91.109(c).
Let’s look at another example. You own a Cessna 182RG and need to do some practice approaches. Your friend volunteers to be your safety pilot. You both have private pilot certificates with ASEL ratings, with current medicals and flight reviews. You have a complex endorsement, but your friend does not. Can you fly under simulated instruments? Can you log PIC? What does your friend log?
The answers are: Yes, yes, and your friend may log SIC. You may operate the aircraft in simulated instrument flight because your friend meets the requirements to serve as a safety pilot. Your friend has a current medical, which is required by § 61.3(c), and § 91.109(c) requires only category and class ratings appropriate to the aircraft being flown. In this case, you would be the only one eligible to act as PIC since your friend doesn’t hold a complex endorsement, which is required by § 61.31(e) to act as PIC. You may therefore log PIC under § 61.51(e)(1) (i) as the sole manipulator of the controls or under § 61.51(e)(1)(iii) because you are acting as PIC of an aircraft for which more than one pilot is required under the regulations under which the flight is conducted. Your friend may log SIC under § 61.51(f)(2) because he or she holds the appropriate category and class ratings for the aircraft being flown and more than one pilot is required under the regulations under which the flight is being conducted.
PIC vs. Dual Received
As we hinted at earlier, another common question is whether it is acceptable to log PIC and dual received at the same time. The answer is, under the right circumstances, yes. You may simultaneously log PIC and dual received if you are rated in the aircraft (category and class), are the sole manipulator of the controls, and are receiving flight instruction.
That means that once you earn your private pilot certificate (ASEL), you can log PIC during training in a single-engine land aircraft. You can log any commercial or instrument training, even in a complex airplane, as PIC for that time that you are the sole manipulator of the controls under § 61.51(e)(1)(i). This would also apply to training toward an endorsement like tailwheel, complex, or high performance. However, it would not apply to training toward a rotorcraft, glider, balloon, or airship since those are different categories. It would also not apply toward any training in a multiengine or seaplane, because those are different classes.
“I’ve seen lots of really smart people miss the mark when it comes to PIC,” Kash explained. “The bottom line is the need to look at § 61.51(e) in light of multiple pertinent regulations and use that as the guide to whether you can still log PIC.” He continued, “But just meeting the requirements to act as PIC might not mean you can log PIC because only one pilot can log PIC when the operation doesn’t require, or the aircraft type certification does not require, two pilots.”
Have a question about a specific circumstance? Let us know.
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6 thoughts on “Who’s In Charge? Logging/Acting PIC”
great article. I had a lot of discussion concerning this topic while taking my cfi this summer.
I though have a question you might be able to answere.
When you (multi commercial ifr, not typed) fly in the right seat of a single pilot jet (citation Mustang) with a single pilot rated pilot. What flight time can you log? Does it matter whether you’re in or outside of the US (in the US sic doesn’t need a tr)
I am not a lawyer but I think that pretty clearly comes under “not loggable” since you are not sole manipulator nor required crew (sorry, I bet you are one of many wishing it was otherwise!). You would have to be rated in the jet to act as a safety pilot (or CFI) and log any of this time.
Great article! One case you didn’t mention is actual IMC under an IFR flight plan with two pilots, only one instrument rated. IR Pilot is obviously acting as PIC, but non-rated pilot can still log PIC, actual, etc. if they are PF. You can’t both log though because only one is required. And yes, there is an FAA legal interpretation letter on this to Keith Walker: https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf
Yes, a fascinating “loophole” hinging on FAA interpretation of “rated”. I became aware of this exception while running a flying club (but did not spread this too far; amateur IFR with no “safety net”?
Yes good point. As a private pilot with an instrument rating, I would only consent to this with someone else who was far along in their instrument training and we were flying together anyway. I would still want to be left seat. It would be a convenience for the PIC akin to an autopilot that must be monitored closely. The good news is there is not an incentive for private pilots with IR to do this anyway, because they can’t log the time or be paid for it.