Logging Pilot-in-Command Time

There is one, and only one, section in the regulations that controls the way pilots log their experience, and that's in 14 CFR 61.51, Pilot logbooks. If you look anywhere else in the regulations, you will come away with incorrect or hopelessly confused notions. The paragraph that pertains to logging pilot-in-command time is in paragraph (e):

(e) Logging pilot-in-command flight time.

(1) A sport, recreational, private, or commercial pilot may log pilot-incommand 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; or
(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-incommand of an operation requiring an airline transport pilot certificate.
(3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor.
(4) A student pilot may log pilot-incommand time only when the student pilot—

(i) Is the sole occupant of the aircraft or is performing the duties of pilot of command of an airship requiring more than one pilot flight crewmember;
(ii) Has a current solo flight endorsement as required under § 61.87 of this part; and
(iii) Is undergoing training for a pilot certificate or rating.

Logging vs Acting

Before taking a closer look at the practical application of this section, I need to point out a significant distinction that isn't at all obvious when reading Part 61 regulations:

Important Concept

Logging PIC is not the same thing as acting as PIC.

The regulations we will be discussing here are only related to logging of PIC time. There are a wide variety of other regulations which determine a pilot's ability to act as PIC, but generally don't have anything to do with a pilot's ability to log the time as PIC. There are many common situations in which you can log PIC time, but cannot act as PIC, and, strangely, there are a few unusual circumstances when you can act as PIC, yet not be able to log it as such.

To make sure you accept this fundamental idea, check out this except from one of many legal interpretations FAA's General Counsel's Office:

There is a distinction between acting as pilot in command and logging of pilot in command time. "Pilot in command," as defined in FAR 1.1, "means the pilot responsible for the operation and safety of an aircraft during flight time." FAR 61.51(e) is a flight-time logging regulation, which only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience...

Since the only paragraph that really confuses people is paragraph (a)(1), we'll focus on that. Let me repeat it here, with the important phrases highlighted:

(e) Logging pilot-in-command flight time.

(1) A sport, recreational, private, or commercial pilot may log pilot-in command time only for that flight time during which that person—

Note that this paragraph applies to sport, recreational, private and commercial pilots. The only pilot certificates missing are student and ATP, which are addressed in other paragraphs. The Flight Instructor certificate is also in a separate paragraph.

The second thing to note is that the three subparagraphs are connected with an "or"; any of the three is sufficient to log the time as PIC. The subparagraph that applies in most situations is paragraph (i). Let me paraphrase it below:

Primary Rule

A pilot can log PIC flight time when he is the sole manipulator of the controls of an aircraft for which he is rated.

Although that seems simple enough, most pilots completely ignore it when the time comes to actually decide how to log their flight time. Here's a common scenario:

Question:	I'm undergoing instrument training and my instructor takes me into IMC. Can I log the flight time as PIC?
Answer:	Apply the Primary Rule. Are you the sole manipulator of the controls? Yes. Are you rated in the aircraft? Assuming it's a single-engine land, and you have a single-engine land on your pilot certificate, then, yes, you're rated and yes you can log the time as PIC.
Wrong answer:	Most people want to say "no", the pilot isn't instrument rated and thus can't act as PIC while in IMC. While this is true, it's also irrelevant, according to the Important Concept. The instrument student is not qualified to act as PIC while in IMC, but he can log the time according to the Primary Rule.

Show Letter

April 6, 1983

Harlan V. Elliott

Dear Mr. Elliott:

This is in reply to your December 10, 1982, letter questioning the accuracy of an interpretation appearing in the September/October 1982 issue of FAA General Aviation News (GA News) (found on page 15). GA News addressed the following question:

When I am taking instruction for an instrument rating, can I log it as pilot in command time in actual instrument conditions when I am the sole manipulator of the controls in IFR conditions?

This question was answered as follows:

No. A pilot receiving instrument instruction in actual instrument conditions must be rated and current in the aircraft and already possess an instrument rating, in order to log pilot in command time for such conditions.

You note that the Federal Aviation Regulations (FAR) do not specifically permit a pilot to log pilot in command (PIC) tine in actual instrument conditions without an instrument rating, but neither do they specifically prohibit logging this time.

As you indicated in your letter, there are a number of FARs which bear on this. Section 61.51(c)(2) provides in part that a private or commercial pilot may log as pilot in command time flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated. Section 61.51(c)(4) provides in part that a pilot may log as instrument flight time only that time during which he operates the aircraft solely by reference to instruments, under actual or simulated instrument flight conditions. Section 61.65(e)(2) requires that an applicant for an instrument rating must have at least 40 hours of simulated or actual instrument time as a pilot, and Section 61.65(e)(3) requires the applicant to have at least 15 hours of instrument flight instruction by an authorized flight instructor. You offer your opinion that the remaining 25 hours required in Section 61.65(e)(2) which is not "dual" instruction under Section 61.65(e)(3), could be flown with a "watch pilot" and must be pilot in command time under Section 61.51(c)(2) and instrument time under Section 61.51(c)(4).

The only limitations on the PIC time which may be logged by a private or commercial pilot are those found in Section 61.51(c)(2), including the provision that PIC time may be logged when the pilot is the sole manipulator of the controls of an aircraft for which he or she is rated.

Please note that Section 61.51(c)(2) and the other sections cited above are only provisions for logging flight time. Section 61.3(e)(1) provides in part that no person may act as pilot in command of a civil aircraft under instrument flight rules, or in weather conditions less than VFR minimums unless that person holds an instrument rating. A non-instrument rated pilot who is taking instrument instruction in IFR conditions may log that as PIC time, but may not actually serve as the PIC. The other pilot must be the PIC, and is not merely a "watch pilot." We are informing GA News of our interpretation. I hope this answers your questions.

Sincerely,

John H. Cassady
Assistant Chief Counsel
Regulations and Enforcement Division

Question:	I'm undergoing training in a complex aircraft; can I log the time as PIC prior to getting my complex endorsement?
Answer:	Apply the Primary Rule. Are you the sole manipulator of the controls? Yes. Are you rated in the aircraft? Assuming it's a single-engine land, and you have a single-engine land on your pilot certificate, then, yes, you're rated and yes you can log the time as PIC.
Wrong answer:	Most people want to say "no", the pilot doesn't have the proper endorsement and thus can't act as PIC of a complex aircraft. While this is true, it's also irrelevant, according to the Important Concept. The instrument student is not qualified to act as PIC of a complex aircraft, but he can log the time according to the Primary Rule. An endorsement is not a rating. The same logic applies to the high performance, tailwheel, and pressurized aircraft endorsements.

Question:	I have lapsed Flight Review. While I'm undergoing profiency training, can I log the time as PIC?
Answer:	Apply the Primary Rule. Are you the sole manipulator of the controls? Yes. Are you rated in the aircraft? Assuming it's a single-engine land, and you have a single-engine land on your pilot certificate, then, yes, you're rated and yes you can log the time as PIC.
Wrong answer:	Most people want to say "no", the pilot doesn't have a current Flight Review and thus can't act as PIC of any aircraft. While this is true, it's also irrelevant, according to the Important Concept. The Flight Review candidate is not qualified to act as PIC of an aircraft, but he can log the time according to the Primary Rule.

Show Letter

WINSTON SCOTT JONES

Dear Mr. Jones:

This is in response to your letter in which you request an interpretation of Section 61.51(2)(c) of the Federal Aviation Regulations, regarding logging of pilot-in-command (PIC) flight time.

Specifically, you ask what time may be logged as PIC time when the pilot in the right seat is a certificated flight instructor (CFI) along for the purpose of instruction and is not a required crewmember, and the pilot in the left seat holds either a private or commercial certificate in an aircraft for which he is rated.

Section 61.51 is a flight-time logging regulation, under which PIC time may be logged by one who is not actually the pilot in command (i.e., not "ultimately" responsible for the aircraft) during that time. This is consistent with the purpose of Section 61.51, which as stated in 61.51(a) is to record aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of Section 61. Section 61.51(c)(2)(i) provides that a private or commercial pilot may log as pilot-in-command time only that flight time during which the pilot--

1. Is the sole manipulator of the controls of an aircraft for which he is rated; or
2. Is the sole occupant of the aircraft; or
3. Acts as pilot-in-command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted.

Under Section 61.51(c)(2)(iii) a certificated flight instructor may log as pilot-in-command time all flight time during which he or she acts as a flight instructor. Sections 61.51(b)(2)(iii) and (iv) provide for logging of flight instruction and instrument flight instruction received. Accordingly, two or more pilots may each log PIC time for the same flight time. For example, a pilot who is the sole manipulator of the controls of an aircraft for which he or she is rated may log that time as PIC time under 61.51(c)(2)(i) while receiving instruction, and the instructor may log that same time as PIC time under 61.51(c)(2)(iii).

There is no provision in the FAR's for logging of "dual" flight time; however, we assume that you are referring to logging time as instruction received. Section 61.51(b)(2)(iii) and (iv) allow flight instruction and instrument instruction received time to be recorded. There is nothing in the FAR's which prevents a pilot from logging the same time as both instruction received and PIC time, as long as each requirement is met. The pilot may also log the same time as instrument instruction. Note, though, that one hour of flight logged both as one hour of PIC and one hour of instruction received still adds up to only one hour total flight time.

You request interpretations of these regulations for situations in which:

1. The purpose of the flight is instruction in advanced maneuvers.
2. The purpose of the flight is simulated instrument instruction in actual VFR conditions.
3. The purpose of the flight is instrument instruction actual IFR conditions.
4. The pilot in the left seat is not current in the aircraft or in the conditions of flight.
5. The purpose of the flight is transition from tricycle to conventional landing gear.
6. The purpose of the flight is obtaining logbook endorsement authorizing operation of a high performance aircraft, as required by FAR 61.31(e).
7. The purpose of the flight is transition to a different type aircraft of the same category and class for which the left seat pilot is rated and a type rating is not required.

In each situation, the CFI may log PIC time for all flight time during which she or he acts as flight instructor. The pilot receiving instruction may also log PIC time in each of these situations, as the pilot is the sole manipulator of the controls of an aircraft for which she or he is rated. Specifically, neither the currency requirements of situation 4 nor the log book endorsement of situation 6 are ratings within the meaning of Section 61.51. "Rating" as used in that section refers to the rating in categories, classes, and types, as listed in Section 61.5, which are placed on pilot certificates. We trust that this discussion answers your questions.

Sincerely,
EDWARD P. FABERMAN
Acting Assistant Chief Counsel
Regulations and Enforcement Division

Question:	I'm flying as First Officer under Part 135 in a King Air 200. Can I log the time when I'm flying as PIC
Answer:	Apply the Primary Rule. Are you the sole manipulator of the controls? Yes. Are you rated in the aircraft? Since you must have a Commercial multiengine rating on your pilot certificate in order to serve as a First Officer of a Part 135 operation, and no type rating is required for the King Air 200, then yes, you're rated and yes, you can log the time as PIC.
Wrong answer:	Most people want to say "no", the pilot isn't acting as PIC of the flight, since he's only a First Officer. While this is true, it's also irrelevant, according to the Important Concept. the Primary Rule doesn't require that the pilot be acting as PIC to log the fight time.

Show Letter

August 3, 1992
Mr. William Clay Cunningham

Dear Mr. Cunningham:

Thank you for your letter of September 28, 1991, in which you ask a question about the logging of pilot in command (PIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR).

Before addressing your question, I would like to first apologize for the delay in responding to your letter. In recent months, a large number of priority projects have been assigned to this division that have prevented us from responding in a more timely manner to the many requests for interpretations. Mr. Irshad A. Haqq of my staff recently discussed this situation and the question raised in your letter with you via telephone. This letter constitutes our formal reply.

In your letter, you pose the following scenario: under a part 135 operation, the flight crew of a 19 seat deHaviland Twin Otter (DHC-6-300) consists of a captain and first officer, neither of whom is required to possess a type rating to act as a flight crewmember. You then ask whether the first officer may log PIC time for the period during which he is the sole manipulator of the controls of the aircraft. You also explain that you have received conflicting answers from local FAA personnel to whom you have posed this question.

The answer to your question is yes. Under Sec. 61.51(c)(2) of the FAR, the first officer may log as PIC time that time during which he is the sole manipulator of the controls of the aircraft. In fact, both the captain, assuming he is the designated PIC required under Sec. 135.109, and the first officer may simultaneously log as PIC time that time during which the first officer is the sole manipulator of the controls.

We recently rendered an interpretation encompassing the issue you raise as well as other questions related to the logging of PIC time under the FAR. A copy of that June 25, interpretation addressed to Mr. Dallas Butler is enclosed for your reference and convenience. The sections of the FAR that are pertinent to this issue are cited in that letter.

We hope this satisfactorily answers your question.

Sincerely,
Donald P. Byrne
Assistant Chief Counsel
Regulations Division

When Acting as PIC Matters

There are only two situations in which acting as PIC is relevant to logging of PIC time. The first is

(e) Logging pilot-in-command flight time.
...

(2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-incommand of an operation requiring an airline transport pilot certificate.

So an ATP can log PIC time when acting as PIC of a flight that requires an ATP. The second is part of the same paragraph that applies to non-ATP pilots:

(e) Logging pilot-in-command flight time.

(1) A sport, recreational, private, or commercial pilot may log pilot-in command time only for that flight time during which that person—

...
(iii) Except for a recreational pilot, is acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

Note the two possibilities: type certification of the aircraft or the regulations under which the flight is conducted. The first instance might occur in a Citation X, for example. Whoever is acting as PIC can log the entire time as PIC, since he is acting as PIC in an airplane that requires two pilots. The second possibility is typical with safety pilots, the "regulation under which the flight is conducted" being

§ 91.109 Flight instruction; Simulated instrument flight and certain flight tests.
...
(b) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

If a safety pilot chooses to act as PIC, then he can log the flight time as PIC. He can only take this route, however, if he is qualified to act as PIC, and all the other regulations within Part 61 that deal with the requirements to act as PIC suddenly become relevant.

Summary

A pilot can always log flight time as PIC when he meets the conditions of the Primary Rule, end of story. There are small number of other situations in which the pilot may be able to log PIC time when the Primary Rule doesn't apply, such as when the pilot is acting as a safety pilot and assumes the role of PIC. Only in the latter situation must the pilot actually meet all the Part 61 requirements to be pilot-in-command.