When Can I Log PIC Time?
by Mark Kolber, CFI

There is one question that repeatedly comes up in discussions and it is misunderstood more frequently than not. The question involves when pilots may, or may not, log flight time as PIC time.

The "golden key" to understanding the rules of logging PIC is to always keep in mind that the FAA treats "acting as pilot in command" and "logging pilot in command time" under FAR 61.51 as completely different concepts. It's the difference between (1) having final authority and responsibility for the operation and safety of a flight (commonly referred to as "acting as PIC") and (2) writing numbers in columns on a piece of paper while sitting at a desk with a beer in your hand. They never mean the same thing and they have completely different rules. A pilot can be responsible for a flight and not be permitted to write those numbers down. A pilot can be technically nothing but a passenger in the FAA's eyes and be permitted to write time in that PIC column. In some circumstances, two pilots may sit at that desk and write numbers in their logbooks, even though, quite obviously, only one can bear the ultimate responsibility for a flight.

The known universe of rules for logging flight time to show qualification for certificates, ratings and currency is contained in FAR 61.51. Unless 61.51 specifically directs you to it, answering a logging question by including the word "acting" or pointing to any other FAR is always a mistake. This is a simplified version of the rules of Part 61 PIC logging as they have been written in the FAR and repeatedly and consistently interpreted by the FAA Legal Counsel since at least 1980. It's limited to student, recreational, private, and commercial pilots. CFIs and ATPs can fend for themselves. If they don't know the rules, tough.

Rule 1. If you are a recreational, private or commercial pilot, you may log PIC any time you are the sole manipulator of the controls of an aircraft you are rated for. [61.51(e)(1)(i)] "Rated" means the category and class (and type, if a type rating is necessary for the aircraft) that is listed on the back of your pilot certificate. Nothing else matters. Not instrument ratings. Not endorsements for high performance, complex, or tailwheel aircraft. Not medical currency. Not flight reviews. Not night currency. Nothing. There are no known exceptions. Note that the rule is different for sport pilots who have endorsed "privileges" for aircraft in their logbooks insetad of ratings on their pilot certifciates.

Rule 2. If you are a student, recreational, private or commercial pilot, you may log PIC any time you are the only person in the aircraft. [61.51(e)(1)(ii) and 61.51(e)(4)] This means that even without category and class ratings, you may log PIC time if you are solo. In addition to the obvious (student solo), it also means, for example, that if you are rated ASEL and solo in an AMEL or ASES, you may log the time as PIC.

Rule 3. If you are a private or commercial pilot, you may log as PIC any time you are acting as PIC (in charge) of a flight on which more than one pilot is required [61.51(e)(1)(iii)] More than one pilot may be required because the aircraft is not certified for single-pilot operations. But more common for us, it covers simulated instrument flight where a second "safety pilot" is required by the regulations while the "manipulator" is under the hood. [91.109(b)] If the two pilots agree that the safety pilot is acting as PIC, the safety pilot can log the time as PIC. An important, but often misunderstood part of this rule is that in order to act as PIC in this context, the pilot must be qualified to do so. That means being current and having the appropriate endorsements in addition to ratings.

Rule 4. Based on a unpublished and (so far) unverifiable 1977 Chief Counsel opinion, you may log PIC if you are acting as PIC and you are the only person on board with the necessary aircraft ratings. In other words, if no one else on board may log PIC time, the person acting as PIC may. Note that there is nothing whatsoever in 61.51 to support this interpretation. Although I received a copy from a source that I trust (sort of), there is some reasonable disagreement on whether it's any good or even really exists. But it does answer the silly question: "Can I log PIC while I let my four year old niece fly the airplane?" Frankly, I can't imagine that the FAA gives a hoot about this one way or another.

Rule 5. If you are a student, recreational, private, or commercial pilot and don't fit into Rules 1-4, you may not log the time as PIC under FAR 61.51 even if you are acting as PIC. This is the bottom line that tells us how different the concepts of "acting as PIC" and "logging PIC time" can be. An example: An instrument rated and current private pilot files an instrument flight plan but lets her non-instrument rated friend do all of the flying. Let's go a step further. Most of the flight takes place in IMC. The instrument rated pilot, who is clearly acting as PIC and responsible for everything is entitled to log nothing in the PIC column of her logbook under 61.51.

Keep them straight. Acting As PIC means duty, authority, and responsibility. Logging Part 61 PIC Time means putting numbers in columns on a piece of paper. Different purposes, different concepts, different rules.

Copyright 2015 by Mark Kolber. All Rights Reserved.