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6 Answers

Who is logging the PIC time

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Commercial Pilot, FAA Regulations, Flight Instructor, General Aviation, Instrument Rating, Private Pilot, Student Pilot

I have come to the conclusion that the only time 2 pilots may log PIC at the same time is during "Simulated Conditions” or while acting as an appropriately rated flight instructor giving flight instruction toward certificate or rating.
From what I understand while in IMC the person who is sole manipulator of the controls is the person logging time as PIC.  In the following scenario, Pilot A, who is instrument rated takes Pilot B, who is NOT instrument rated into IMC conditions.  Pilot B (who is NOT instrument rated) is flying the airplane solely by instruments on an IFR flight plan in actual IMC conditions.  Even though Pilot A IS instrument rated, Pilot B (who is NOT instrument rated) is actually the only pilot at the airplane controls logging time as PIC.   And even though Pilot A who IS instrument rated and is the PIC for the flight is not allowed to log the time as PIC while in IMC conditions because he is not a required crew member as defined by FAR 91.109 (c).
Here is my summary of the 2 Chief Counsel interpretations concerning the subject.  Links to the interpretations are below.
Logging PIC during IMC with 1 pilot that is not Instrument Rated.  Can Pilot B who is not instrument rated log "PIC" and "Actual" time while in IMC?
  • Pilot Profile - Pilot A - Instrument rated / Pilot B - Not Instrument Rated.
  • Can Pilot B (not ints rated) log "PIC" and "Actual" time while in IMC?  YES - While in IMC if Pilot B is sole manipulator of the controls and PIC then Pilot B can Log PIC and Actual.
  • However Pilot A is not a required crew member or Safety Pilot (Safety Pilot is required during "simulated" instrument flight).   Pilot A can not log PIC time.
 
Logging PIC by 2 pilots that are both rated in the same category and class.  Can Pilot A and Pilot B both log PIC time while Pilot A wears view limiting devices?
  • Both pilots can log PIC time while in Simulated Conditions.
Pilot Profiles
  • Pilot A - Multi or Single and Instrument rated 
  • Pilot B - Multi or Single and Private Pilot
  • Both Pilots agree that Pilot B will serve as PIC during the flight
  • Pilot A wears view limiting devices and Pilot B serves as safety Pilot
  • Pilot A is sole manipulator of the controls - Logging PIC
  • Pilot B serves as a required crew member - Logging PIC
  • Pilot B’s Presence is required for the portion of flight under FAR 91.109 (c)
http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2013/creech - (2013) legal interpretation.pdfWalker - (2011) Legal Interpretation http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf

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6 Answers



  1. jeff on Jan 10, 2016

    In your senario, pilot A is absolutely a required crew member and must be the PIC the entire flight regardless who is operating the controls as you are on an instrument flight plan. So pilot B can log PIC time but can not act as PIC as he is not instrument rated.

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  2. tommytom on Jan 10, 2016

    This post poses the question in respect to logging time. Not who is acting as PIC for a flight. To log PIC time a pilot must be sole manipulator of the controls FAR 61.65 (e).

    Assuming that the airplane is single pilot certified, Pilot A is in fact PIC for the flight but according to the regulations and interpretations Pilot A cannot “log the time” in actual conditions as PIC while Pilot B is sole manipulator of the controls. Pilot A is just merely acting as PIC for the flight. If the airplane is certified requiring 2 pilots then the story is different and Pilot A would log the time differently.

    If both pilots agree that Pilot A will be PIC for the flight and Pilot A is also serving as Safety Pilot in “simulated” conditions then the outcome of logging the time is different for Pilot A. Pilot A then becomes a required crew member in simulated instrument conditions. Refer to FAR 91.109 (c). The difference is the conditions are simulated not in actual conditions.

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  3. tommytom on Jan 10, 2016

    Here are the links to the Chief Counsel Interpretations concerning the scenario.

    2013 Creech

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2013/creech%20-%20(2013)%20legal%20interpretation.pdf

    2011 Walker

    http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2011/walker%20-%20(2011)%20legal%20interpretation.pdf

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  4. John D Collins on Jan 10, 2016

    Tom,

    I am not sure I see a question in your post, but in essence I agree with your conclusion, but not all of your analysis. In your scenario where the flight is conducted in actual instrument conditions, Pilot A is a required crew member, pilot B is a passenger. The passenger, pilot B, is rated in the aircraft and may log PIC time and actual instrument time. Pilot A must act as PIC and is a required crew member, but may not log PIC time because he is not the sole manipulator of the controls. The PIC logging exception provided by 61.51(e)(1)(iii) does not apply because Pilot A is not acting as a safety pilot as required under 91.109(c) because it only applies when simulated instrument conditions for Pilot B who would then require Pilot A to be a safety pilot.

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  5. tommytom on Jan 10, 2016

    John and Jeff

    Yes I see what you two are pointing too. Thank you for pointing this out. What is posted are my own journal notes. I keep a journal with a summary of scenarios and the interpretations so that I can go back to them when needed. I have made corrections.

    I put “not a required crew member” because Pilot A is not acting as a safety pilot.

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  6. Mark Kolber on Jan 11, 2016

    “I have come to the conclusion that the only time 2 pilots may log PIC at the same time is during “Simulated Conditions” or while acting as an appropriately rated flight instructor giving flight instruction toward certificate or rating.”

    Unfortunate to start off with something not correct.

    Consider two pilots flying an aircraft that is type certificated for two pilots. One is designated PIC, the other SIC. When the SIC is doing the flying, the acting PIC may log PIC time under 61.51(e)(1)(iii), the same rule that allows a safety pilot acting as PIC to log PIC time. And, of course, the SIC gets to log PIC time as the sole manipulator under (e)(1)(i).

    It’s not a big error. But I generally think it is a mistake and a hindrance to understanding the logging rules to work from the scenarios backwards to divine the rules. It leads to the type of analytical errors John speaks of.

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