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.