PIC: Who Is It? Who Can Log It?
Occasionally I receive e-mails with (occasionally) interesting questions. A while back this one arrived: Is it true that both the safety pilot and the “sole manipulator of the controls” may both log pic time simultaneously? This is a great thing if true, because it not only reduces the expense of getting one's 50 x-country hours for instrument rating by one half, but we can also get hood time without paying an instructor.
I've heard differing opinions. Per 61.51, pilots may log pic when they’re the sole manipulator of the controls of an aircraft for which they are rated, or when acting as pic in an aircraft requiring more than one pilot by the type certificate or the regulations under which the flight is conducted. In simulated instrument conditions, 91.109 (b) requires a safety pilot. Many people interpret this to mean that the pilot flying (sole manipulator of the controls) and the safety pilot each can log pic for the same flight time (if conducted under simulated instrument conditions). Do you know the FAA's position on this?
Well, it’s true that both the person under the hood and the safety pilot may log pic at the same time, on the same flight, but it depends on both the flight conditions and what the pilots agree to do beforehand. Anyway, the rationale goes something like this:
14 cfr 61.51(e)(1) says “... a recreational, private, or commercial pilot may log pilot in command time only for that flight time during which that person is —
(i) The sole manipulator of the controls of an aircraft for which the pilot is rated; or
(ii) Except for a recreational pilot, when acting as a 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.”
14 cfr 61.51 (f) (2) says that a person may log second-in-command flight time only for that flight time for which that person “... holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under ... the regulations under which the flight is being conducted.”
14 cfr 91.3(a) says, “The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.”
14 cfr 91.109(b) (1) says, “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.” Please note: these sections have nothing at all to say about whether a flight is in IMC or not, under IFR or not, or even whether either pilot is instrument rated. These have (almost) no bearing on who can log pic. Also note there is a difference between VFR and VMC (Visual Flight Rules and Visual Meteorological Conditions), and IFR and IMC (Instrument Flight Rules, etc.). Got all that? However, they do have something to say about who is the pic: “acting as” and “logging” pic are not the same thing.
The person under the hood may log pic if s/he's rated in the aircraft; i.e., it's a single engine land airplane and that's what his/her pilot certificate says. S/he also may log pic if the flight is under IFR, and if the flight is in IMC as well ... but if s/he is not instrument-rated and current, then there must be someone qualified to be pilot in command aboard the aircraft.
So this takes care of which one has his or her hands on the handlebars, is under the hood, whatever, right?
What about the safety pilot, then? This is where the “it depends” comes into play; consider a couple of scenarios. [Incidentally, a safety pilot must be rated and current in the aircraft, with a valid medical, too; see 14 cfr 61.55(a)].
First scenario: you do the flight under VFR in VMC — the person in the left seat is just practicing to keep the shiny side up under the hood.
In this case, the safety pilot may log either pic [14 cfr 61.51(e)(1)(ii)] or sic [14 cfr 61.51(f)(2)], depending upon what you two agreed to before the flight. If the safety pilot agrees to be responsible for the safety of the flight, then s/he may log pic (I suggest you and your safety pilot write this down and leave it with someone before you go). Otherwise, if the safety pilot is only going to look for traffic, etc., then s/he would log sic.
Second scenario: if you do the flight under IFR (whether in IMC or not), and you are not instrument-rated, there must be someone aboard who is rated, current, qualified, etc., to be the real pic, so the safety pilot will log pic (whether they actually fly or not), and so can you [cuz you have your hands on the handlebars, per 14 cfr 61.51(e)(1)(i)].
So, there you are. Sufficiently confused? Just remember that logging pic is not the same as being pic: there always is someone responsible for the flight (the actual pic) but more than one person may log pic time under the regs.
This is similar to the fact that you can log pic when you're receiving training as well, as long as you're rated in the aircraft ... your logbook would have entries both in the “pic” and “Dual Received” columns.
A final thought: be very careful of getting lots of instrument time without a CFII along. You can pick up many bad habits that actually get in the way of earning an instrument rating ... and you may end up spending more in the long run than if you paid an instructor. A CFII will tell you when you're on the right track and when you're going astray … that's their job, after all. If you have a CFII who doesn't keep you on the narrow path of improving all the time, get another one. Gaining an instrument rating isn't just about getting the flight time … it's the new knowledge areas and skill sets you need, too. An instrument rating probably is the most difficult pilot rating you will earn; the skills you learn during your training will keep you healthy as you move through your flying career (whatever that career may be, weekend warrior to airline captain).
You really have two goals when you work on any pilot certificate or rating: (1) to use whatever the certificate or rating is safely and wisely and (2) to get through the practical test. Taking shortcuts often results in getting lost along the way and actually taking much longer to reach your goal (that means it costs more, not necessarily in terms of money). There is absolutely no substitute for good instruction. Your examiner will find out on your practical test (believe me, examiners can tell), but even more than that, your real practical test is life.
Ask a simple question and you get a pageant, right? I hope this answers your question. Good luck! (And thanks, R.C.) |
