by James Williams, FAA Safety Briefing
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-
(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.
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?
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 you 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 further explained by a legal interpretation in 2009 (Speranza) http://go.usa.gov/xk4TM.