In this article I look to address some of the most commonly misunderstood issues when it comes to logging pilot in command time (PIC) during different flight conditions, aircraft and when serving as a safety pilot.

Logging PIC Time

There are some common misunderstandings when it comes to logging PIC flight time.  Many instructors, including my former self, thought that students need to be properly rated for the flight condition and endorsed properly for the aircraft in order to log PIC time.  This would restrict instrument students from logging PIC time while receiving instruction in IMC conditions.  It would also forbid students from logging PIC time while receiving training in an aircraft they are not properly endorsed to fly. Howevera close look at the regulations tell us differently. First, lets look what 61.65(e) says about logging PIC time.

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

[(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
(ii) When the pilot is the sole occupant in the aircraft;
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted; or…

Basically, a pilot can log PIC time whenever they are the sole manipulator of the controls while flying an aircraft for which the pilot is rated to fly, regardless of flight conditions or endorsements. This rule does excluded student pilots who are flying with their instructors.   What this means is that an airplane single engine land (ASEL) rated private pilot can in fact log PIC time when receiving training in a high performance, complex or high altitude aircraft such as a Pilatus PC-12.  In addition an instrument student can log PIC time for the duration of the flight, regardless of the flight condition since they are in fact the sole manipulator of the controls.

This works fine for supervised flights, however there is another  issue that is a bit more critical.  That is acting as PIC.  On a flight in IMC with a private rated instrument student the CFII is acting as the PIC even though he is not the ‘sole manipulator of the controls.’  What this means is that the CFII has final authority and responsibility for the operation and safety of the flight.   The acting PIC must not only be properly rated but also endorsed for the aircraft being flown.  This is stated in a FAA Letter of Interpretation dated May 21, 2009 and again on October 7, 2009;

For a pilot to act as a PIC (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a pilot must be properly rated in the aircraft and be properly rated and authorized to conduct the flight. In your example, being properly rated and authorized would include having the endorsements for complex and high-performance airplanes as required by sections 61.31 (e) and (t).

It is also worth noting that the FAA does not differentiate between IMC or simulated instrument time.  They count both as simply ‘instrument time’ regardless of the condition of flight.  The only time that IMC vs simulated time may become an issue is when applying for a pilot job.  Many companies do require a minimum amount of IMC time.

Safety Pilot Time

Many instrument students and instrument rated pilots take advantage of the values of safety pilot time.  What this allows for is that 2 pilots (neither of them being instructors) are able to fly together, and simultaneously log flight time in an aircraft that only requires on pilot.  To do so the pilot manipulating the controls wears a view limiting device and operates the aircraft by sole reference to the instruments.  Then, the non flying (safety) pilot is required to ensure the safety of the flight by looking out for traffic, mountains, airspace and the like.  During this time both pilots are able to log PIC time.  However there are a few catches to keep things legal.

  1. During any flight there is time required for taxi, takeoff and landing.  During these times the manipulator of the controls wont be wearing the view limiting device.  This time is not logable by the safety pilot since at this time he/she is not a required crew member.  The safety pilot is in fact just a passenger during this time.
  2. Only the manipulator of the controls may log cross country time if applicable because they are the pilot during the takeoff and landing phase of flight.  The safety pilot can only log PIC time, and nothing else.
  3. The flight must take place in VFR conditions.  If the flight were to continue into IMC then the safety pilot would not be required.

A quick summary:

The pilot who is the manipulator of the controls for the entire flight can log:

  • PIC time
  • Cross country time if applicable
  • Landings
  • Any instrument approaches or holds that are performed

The safety pilot can log:

  • Only PIC time for the flight time during which the manipulator of the controls is wearing the view limiting device.  From my personal experience I’ve found that this would account for the total time minus .3 at best.

More can be found in this FAA letter of interpretation regarding safety pilot time.  When properly done safety piloting time is a wonderful asset to pilots to gain proficiency, practice their skills, maximize their training  dollars, and maintain their IFR currency.