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Hi,

What is the difference bewteen acting as PIC and loggind PIC? are there times when one may not act as PIC but still be able to log PIC time or vice versa?

Also, if during flight training or BFR the student's/pilot's medical certificate is expired, may they still log PIC time?

Sincerely,

Oren.

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6 Answers



  1. RM on May 06, 2011

    Flight instructor can log pic even though he is not acting pic. technically you need a medical to log pic if ur by yourself or you r violating smith far. If ur up with an instructor and your medical is expired and you r sole manipulator of the controls then u can log pic. When given bfr or training or flying with another pilot decide before u go who is pic. This way if something goes wrong they will b asking who pic was.

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  2. Jon on May 06, 2011

    Logging PIC is well-defined in FAR 61.51(e) (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=14:2.0.1.1.2.1.1.31&idno=14).  For most Part 91 operations, it basically boils down to 1) if you’re the sole manipulator of the controls in an airplane for which you’re rated, OR 2) if you’re the only person on the aircraft.
     
    Acting as PIC is also well defined in Part 1.1 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div8&view=text&node=14:1.0.1.1.1.0.1.1&idno=14), but there are a whole bunch of limitations scattered through the regs as to when you may not act as PIC.
     
    For your first question, examples would be a private pilot getting instrument training or getting a complex signoff.  You can’t act as pilot in command because you’re not yet qualified to do so, but you can log PIC because you’re the sole manipulator of the controls.  As for acting as PIC while not being able to log, I think that’s a less common situation, but let’s go back to the complex example.  If you’re sitting next to a private pilot who’s qualifed to act as PIC in a complex aircraft and you’re not, but you’re flying the plane – he is acting as PIC (because he’s the only one qualified to do so), but he can’t log PIC because you’re the sole manipulator of the controls.  Sorry for the reach – I’m having a hard time thinking of examples this morning.
     
    As for your last question, you don’t need a valid medical to log PIC, only to act as PIC.  There are a lot of instructors out there who who haven’t had a valid medical in a long time, but can still instruct as long as their student is qualified to act as PIC (i.e. they already have a license – think instrument or commercial training).  Bottom line: as long as you’re rated (licensed) in the plane and you’re the sole manipulator of the controls, you can log PIC.  The last two paragraphs of 61.51(e) give some other situations where you can log PIC, but I’ll leave that as an exercise to the reader.
     
    Jon

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  3. Micah on May 06, 2011

    There is plenty of discussion here and elsewhere on this topic, but it can be confusing until (and even after) you figure it out.
     
    It helps me to think this way: Acting PIC (1.1) means you are the PIC. Logging PIC does not make any direct representation that you are acting as PIC. Start from there and work your way out (read up on the links above)
     
    You are always allowed to log PIC when you are acting PIC if (a) you are the sole manipulator or (b) you are a required crewmember. But don’t misinterpret or be too liberal with “required crewmember.” Look that up and understand what that means. (ie, if you take up your buddy, who is not a pilot, and he manipulates the controls while you watch–which is perfectly legal–you may not log that portion of the flight during which he is the manipulator.)
     
    You are allowed to log PIC in certain cases when you are (a) not the PIC (acting) but are the sole manipulator or (b) when you are the PIC (acting) but not the sole manipulator. This is the case during certain types of flight instruction or flight with a safety pilot. 

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  4. Matthew Waugh on May 06, 2011

    Here is my treatise on the subject:
     
    http://www.mwaugh.com/Aviation/Articles/loggingtime.htm

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  5. Kent Shook on May 06, 2011

    The key to understanding all this is that acting as PIC and logging PIC are two different things. There is ALWAYS one, and only one, acting Pilot In Command. However, there are scenarios where anywhere from zero to three people may *log* PIC.
     
    Zero: You are the acting PIC, but are letting a non-rated passenger fly the plane so you are not sole manipulator of the controls. (Note: I’ve heard that there’s an FAA interpretation which now allows you to log PIC in this situation despite the fact that it doesn’t strictly meet the definitions in 61.51(e))
     
    One: The fairly common situation where you’re rated and you’re flying.
     
    Two: A couple of examples here. One would be a flight instructor giving instruction to an already-rated pilot. For example, you’ve got your PP-ASEL and you’re working on your complex endorsement. You cannot act as PIC because you lack the necessary 61.31(e) endorsement, but you are *rated* in the airplane (complex is an endorsement, not a rating – See FAR 1.1 for the definition of “rating”) and thus you can log PIC as the sole manipulator of the flight controls under 61.51(e)(1)(i) while your CFI can log PIC as an instructor under 61.51(e)(3). Another example is one pilot under the hood and a safety pilot who is acting as PIC (which isn’t a given in this scenario – hash it out before you take off who the actual PIC is!). The hooded pilot who is flying logs PIC under 61.51(e)(1)(i), and since the regulations for this operation require a second pilot (91.109(b)(1)) the safety pilot can log the time that the flying pilot is under the hood under 61.51(e)(1)(iii).
     
    Three: Fairly unusual, but still possible. For this to happen, we need to have an airplane that requires two pilots, and three pilots who are all rated to act as PIC. We’ll call the three pilots the Pilot Flying (PF), the Pilot Acting (PA), and the Pilot Instructing (PI). Let’s say the PF is in the left seat, the PA is in the right seat, and the PI is in the jumpseat. It’s a training flight, and the PI is giving instruction to one or both of the pilots in the front seats. The PA is the acting PIC and the PF is the sole manipulator of the controls. In this case, PF can log PIC under 61.51(e)(1)(i), PA can log PIC under 61.51(e)(1)(iii) and PI can log PIC under 61.51(e)(3). But the PA is still the one and only acting PIC and is the “sole authority…” who is in charge of the flight and its outcome (91.3). 
     
    Confused yet? Well, you’re in good company – This has got to be THE most frequently-asked regulation question in aviation.

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  6. Oren on May 06, 2011

    Thanks guys! can’t get much clearer than that..(:

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