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Logging PIC Time

Logging of PIC time is important for currency, insurance, and for experience necessary for obtaining ratings. The rules are not necessarily the same in all instances.

FAR 61.51 covers what must be included in logbooks and gives guidance on how to log experience. To interpret the regulation correctly it is important to first understand the terms that are used.
Pilot in command means 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. FAR 1.1.

Implicit in this definition is the fact that only one person is able to act as PIC for any segment of the flight. It says nothing about who is manipulating the controls of the aircraft and who can log time as PIC.

Category and class are used to describe aircraft and to describe airman ratings. Categories are also used to describe aircraft based on intended use and operating limitations: transport, normal, aerobatic, etc. Category is also used in IFR flying in reference to approach speed and equipment. For purposes of this section category and class refer to the type of aircraft for which the airman holds a rating.

61.51 (e) A sport, 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 or has privileges;
(ii) Is the sole occupant of the aircraft;
(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required…

We see that there is distinction between who is legally responsible for the flight and who can log the time. The person who logs PIC time may not be the person who is legally PIC.

The question that comes up frequently is: can you log PIC time when training in an airplane that requires an endorsement—complex, high performance, taildragger?

A pilot may log PIC time if they are “ the sole manipulator of the controls of an aircraft for which the pilot is rated“. So suppose you are a private pilot who learned in a 152 or Cherokee and want to move up to an airplane for which an endorsement is required. You have a single-engine land rating so you can log PIC time in any single-engine land airplane when you are sole manipulator of the controls. You cannot log PIC time when learning to fly a twin or a seaplane because you are not rated in the category and class of aircraft in which you are training. You cannot log PIC time when learning to fly a jet or turbine powered airplane because a type rating is required and you do not have one.

Another question that comes up frequently is when can a student pilot fly and log time.

61.51 (e) (4) A student pilot may log pilot-in-command time only when the student-pilot—
(i) is the sole occupant of the aircraft or … airship…
(ii) Has a current solo flight endorsement…
(iii) Is undergoing training for a pilot certificate or rating.
So a student pilot may log PIC time when alone in the aircraft. They may not log PIC time when flying with someone else. A student pilot may fly with another pilot, who is not an instructor, if the other pilot agrees to act as PIC for the entire flight. Neither pilot can log the time as PIC. The student pilot can’t because they are not flying solo and the other pilot can’t because they aren’t the sole manipulator of the controls.

Another group of questions arises about acting versus logging time arises when one pilot is manipulation the controls but is not current. Suppose a pilot has not made the required number of takeoffs and landings to carry passengers. If the other pilot agrees to act as PIC then the pilot manipulating the controls may log the time and it will count toward currency. The same is true for flight in IMC conditions. As long as an instrument rated pilot agrees in advance to act as PIC, then the flight is legal and the manipulator of the controls can log the time as actual IMC. The pilot acting as PIC cannot log the time.

The final scenario arises when flying with an expired medical. Section 61.3 ( c) (1) provides that a person may not act as pilot in command…unless that person has a current and appropriate medical certificate…

As above, as long as an pilot who is rated in the aircraft (and current) agrees in advance to act as PIC, then the pilot may log time as PIC and that time will count for recency of experience. The pilot should record the details of the flight and who is acting as PIC in the logbook to avoid any questions in the future if the logbook is inspected and the flight with an expired medical is noted.

References

FAR’s explained page 61-63 Notice No. 95-11[FR] “Two recreational, private, or commercial pilots may not simultaneously log pilot in command flight time when one pilot is acting as pilot in command as defined in Part 1, and the other pilot is the sole manipulator of the controls, unless the aircraft type certification or the regulations under which the flight is conducted require more than one pilot.”

Rod Machado on logging flight time. “…if you are taking the training to obtain your complex or high performance endorsement, you can log that time as pilot-in-command time. The difference here is between logging PIC time and acting as the required PIC. Your instructor is the legal PIC on that flight since he or she is the only one with a complex or high performance endorsement. You can log the time as PIC since you’re the sole manipulator of the controls on an aircraft for which you are rated. This is covered in CFAR 61.51(e).”

AOPA e-Pilot Quiz Me 10/5/07
Question: I have a private pilot certificate for airplane single-engine land and typically fly a Cessna 172. I am interested in stepping up to the Cessna 182RG that is available for rent at my local flight school. Will I be able to log pilot-in-command (PIC) time while training for the necessary complex endorsement?
Answer: Yes, you are allowed to log PIC flight time during your training. The difference between logging PIC time and acting as PIC is subtle, but important. FAA regulation 61.51(e)(1)(i) allows you as an airman to log PIC flight time whenever you are the sole manipulator of the controls of an aircraft for which you are rated or have privileges (i.e. aircraft category, class and/or type rating). However, you cannot act as PIC of the training flights. Because the complex airplane endorsement outlined in FAR 61.31(e) is required in order to act as PIC, you would not be allowed to fly solo in an aircraft requiring the endorsement until you obtain it through dual instruction with an authorized instructor.

This AOPA article covers logging PIC time and this article covers logging time as a safety pilot.

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