When may I log 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 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 certificates.
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.
May a Safety Pilot Log PIC Time?
It depends. If the safety pilot is also acting as PIC (in charge of the flight), then the safety pilot may log PIC time while the flying pilot is under the hood. If not, the safety pilot is permitted to log second-in-command time. To understand the answer, make sure that you first understand the “golden key” to logging mentioned in the general logging PIC FAQ – the FAA treats “acting as pilot in command” and “logging pilot in command time” under FAR 61.51 as completely different concepts. 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.
Logging PIC time as a safety pilot is one of those times that 61.51 tells you to look somewhere else. As usual, let’s start with 61.51. 61.51(e)(1)(iii) tells us that 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 by the regulations. More than one pilot may be required because the aircraft is not certified for single-pilot operations. But there are other situations as well. One is set up for us by 91.109(b):
No person may operate a civil aircraft in simulated instrument flight unless … 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.
So, a second “safety pilot” is required by the regulations while the “manipulator” is under the hood. 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. Think it’s a little sneaky? Trying to get around the rules by looking for technicalities? Here’s what the FAA Chief Legal Counsel said about it decades ago in a 1993 interpretation letter sent to Steve Hicks:
In your second question you ask “how shall two Private Pilots log their flight time when one pilot is under the hood for simulated instrument time and the other pilot acts as safety pilot?” The answer is the pilot who is under the hood may log PIC time for that flight time in which he is the sole manipulator of the controls of the aircraft, provided he is rated for that aircraft. The appropriately rated safety pilot may concurrently log as second in command (SIC) that time during which he is acting as safety pilot.
The two pilots may, however, agree prior to initiating the flight that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i). Enclosed please find a prior FAA interpretation concerning the logging of flight time under simulated instrument flight conditions. We hope that this interpretation will be of further assistance to you.
That was back in 1993. The specific FAR 61.51 subparagraph has changed but the substance has not. As with most logging questions, the FAA has been incredibly consistent since then, applying the same rules to a series of safety pilot scenarios almost 20 years later in an interpretive letter to William Trussell.
When may I log cross country time?
This is one of those FAA definitions that change depending on what you’re using the time for. Cross-countries fall into four groups. The first three groups are all contained in 61.1(b)(3).
Group 1: General Definition: A cross country flight is one in which you land at another airport that you didn’t accidentally bump into. There are no distance requirements.
Group 2: In order to “Count” for Most Certificates or Ratings: Same as the general definition, except at least one of the places where you land has to be more than 50 NM from where you started the flight. This applies to the private and commercial certificates, and the instrument rating.
Group 3: In order to “Count” for ATP: Same as for Most Certificates or Ratings, except you don’t have to land anywhere
Group 4: Apart from there are the “special cross countries” that are part of the experience requirement for certain certificates and ratings. One example is the private pilot certificate requirement for 150 total distance solo cross country with at least one 50 NM leg (61.109(a)(5)).
So, they’re all cross country. And they all can be logged from the time that you are a student pilot. The problem is keeping track of them so you can total the ones that “count” in any given situation. Most new pilots tend to log only Group 2 since those are the ones that they will have to total up in the near future. Some set up two columns right away (Group 1 counts for 135 experience purposes). The lack of a landing in Group 3 is a well-deserved tip of the hat to military pilots who will often fly some distance without landing.
May more than one pilot log cross country time?
Since 61.51 allows more than one pilot to log PIC time at the same time, it’s tempting to think that the same holds true for logging cross country time. If. for example, a rated flying pilot and a non-flying safety pilot who is acting as PIC may both log PIC time, can’t they both log cross country time as well?
For the most part, the answer is no. The FAA Chief Counsel has given an unequivocal thumbs down to more than one plain vanilla Part 91 pilot logging cross country time on the same cross country flight (there is probably an exception for CFIs during dual cross country training flights but even that is not completely clear at this point). The various opinion letters cite different rationales, but ultimately, it comes down to this:
only the pilot who performs the takeoff , en route portion, and the landing
on a cross country flight may log the cross country time
at least when the flight is not a “true” 2-pilot operation (see the Glenn Opinion below).
So, for example:
- A safety pilot may not log cross country time because he or she is not a required crewmember for the entire flight. 2009 Gebhart Opinion.
- When pilots switch sole manipulator duties in the air, neither may log the cross country time. 2009 Hilliard Opinion.
Other opinion letters in the series include the 2009 Glenn Opinion, which reviews multiple similar scenarios. It is Glenn which allows both pilots in aircraft or Part 135 ops required more than one pilot to log cross country time because both are required crewmembers for the entire flight.
May I Log Sim Time as “Total Time”?
A Simulator or FTD session is not a “flight”. The confusion that leads to this frequently asked question comes about because there are a number of different definitions here. And “total time” is not one of them. “Total Time” isn’t defined anywhere in the FAR. When the term is used, it’s not alone. For example, 61.109(a) requires 40 hours of “flight time” for the private certificate. On the other hand, the 61.159 aeronautical experience requirements for the ATP include “at least 1,500 hours of total time as a pilot” So there’s really no such thing as “TT” standing by itself. It’s usually combined with either “pilot time” or “flight time”. And there is a definite difference between these two terms.
“Pilot time” is defined in 61.1(b)(12) and specifically includes simulator time.
that time in which a person – (i) Serves as a required pilot flight crewmember; (ii) Receives training from an authorized instructor in an aircraft, flight simulator, or flight training device; or (iii) Gives training as an authorized instructor in an aircraft, flight simulator, or flight training device.
On the other hand, “flight time” is defined in FAR 1 as
Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing…
That does not include simulators. Even the best of them are still not “aircraft” The logbooks I’ve seen don’t have a column for “total time” or “total pilot time”. They do have a column for total “flight” time or “Total duration of flight” and sim or FTD time doesn’t belong there. Want to track total pilot time? Add a column and go ahead. It counts for something.
When May I Log “Night” Flight?
The trouble with “night” is that the way the FAA treats what we consider night changes. It’s used a bit different for position light requirements, “night” landing currency, and general use. We sometimes talk about “night” having multiple FAA definitions. In reality there is only one FAA definition of the word, which appears in FAR 1. Night means the time between the end of evening civil twilight and the beginning of morning civil twilight, as published in the American Air Almanac, converted to local time. So, when the word “night” is used in a regulation, this is what it means unless the regulation says something different. So, for general logging of night flight time for certificate requirements, including the landings, I would use this definition. I would also use this definition for all FAR purposes, like night VFR visibility requirements, fuel reserves, etc.
For “night” passenger-carrying currency purposes, we’re talking about the regulation saying “something else”, in this case 1 hour after sunset to one hour before sunrise (61.57). But that time frame limitation describes a certain part of the “night.” It doesn’t have any effect on the overall definition of “night”. And it only applies to currency requirements for carrying passengers as PIC during a certain part of the “night”. It doesn’t apply to anything else. Finally, there’s the aircraft lights rules from 91.208, requiring lighted position lights “during the period from sunset to sunrise” (different in Alaska). That regulation doesn’t use the word “night” at all.
Oh, one more thing. Most of us don’t carry around the American Air Almanac (in fact, I don’t even know anyone who has seen one!). The next best choice is the U.S. Naval Observatory web site