Pilot PIC Time Logging

Key Conclusion

The FAA interprets that acting as PIC and logging PIC time are separate concepts. Under certain conditions, both the safety pilot and the pilot flying under the hood may log PIC time simultaneously.

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Primary Legal Issue

Whether a safety pilot may log PIC time during simulated instrument flight conducted under VFR.

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Rule (CFR)

Pilot in Command

• FAR 1.1: Defines PIC as the pilot responsible for the operation and safety of the aircraft.

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Logging PIC Time

• FAR 61.51: A pilot may log PIC time under specific circumstances, including when acting as:
  • the sole manipulator of the controls of an aircraft for which the pilot is rated; or
  • the PIC of an aircraft requiring more than one pilot by regulation.

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FAA Interpretation

1. Acting as PIC is different from logging PIC

The FAA explains that:

• Only one pilot may act as PIC during a flight.
• However, more than one pilot may be able to log PIC time, depending on the applicable logging provision.

This distinction is the central issue of the interpretation.

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2. Pilot under the hood

The pilot flying solely by reference to instruments may log PIC time:

• while acting as the sole manipulator of the controls; and
• provided the pilot is rated for the aircraft.

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3. Safety pilot by default

If no prior agreement exists making the safety pilot the acting PIC:

• the safety pilot is a required crewmember;
• the FAA interprets that the safety pilot may log SIC, not PIC.

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4. Safety pilot designated as PIC

If, before the flight:

• both pilots agree that the safety pilot will act as PIC,

then the FAA interprets that:

• the safety pilot may log PIC as the acting PIC under FAR 1.1; and
• the pilot under the hood may simultaneously log PIC as the sole manipulator of the controls.

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Implication (Limited)

This interpretation applies specifically to:

• simulated instrument flight under VFR;
• an appropriately rated safety pilot; and
• the logging provisions discussed in FAR 61.51.

It should not be read as establishing that two pilots may act as PIC simultaneously.

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Common Misunderstandings

• ❌ Acting as PIC and logging PIC are the same.
• ❌ A safety pilot always logs PIC.
• ❌ Two pilots may both act as PIC during the same flight.

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One-Sentence Summary

The FAA interprets that only one pilot may act as PIC, but under the appropriate logging provisions, both the acting PIC and the sole manipulator may be able to log PIC time simultaneously.

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Reference

• Legal Interpretations - Hicks_1993_Legal_Interpretation