PIC time

Hi, can regional airline FO’s build PIC time without upgrading to Captain? I noticed that many Major’s want to see PIC time in their hiring…but wasn’t sure if upgrading to captain was a requirement.
Thanks!

Ravi,

PIC = Pilot in Command = Captain. Hence when you see turbine PIC that means they want to see turbine Capt time.

Adam

Ravi,

Negative, only the captain can log PIC time. A First Officer is never in command of the airplane, thus no PIC time.

Chris

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Hi Chris, so I assume as an FO in a company looking to upgrade to Captain within that same company, PIC time is not one of the requirements? I have been confused about this for a while. I assumed that the FO could log PIC as sole manipulator of the controls.

Taylor,

No, there should not be any PIC requirement to upgrade to Captain, at least on the airline side of things.

Chris

Okay, thanks Chris.

Taylor,

The FARs state the following:

121.533 Responsibility for operational control: Domestic operations.
(a) Each certificate holder conducting domestic operations is responsible for operational control.
(b) The pilot in command and the aircraft dispatcher are jointly responsible for the preflight planning, delay, and dispatch release of a flight in compliance with this chapter and operations specifications.
(c) The aircraft dispatcher is responsible for -
(1) Monitoring the progress of each flight;
(2) Issuing necessary information for the safety of the flight; and
(3) Cancelling or redispatching a flight if, in his opinion or the opinion of the pilot in command, the flight cannot operate or continue to operate safely as planned or released.
(d) Each pilot in command of an aircraft is, during flight time, in command of the aircraft and crew and is responsible for the safety of the passengers, crewmembers, cargo, and airplane.
(e) Each pilot in command has full control and authority in the operation of the aircraft, without limitation, over other crewmembers and their duties during flight time, whether or not he holds valid certificates authorizing him to perform the duties of those crewmembers.

If you notice there’s no reference made to who’s manipulating the controls as that has nothing to do with being PIC.

Adam

Hi Adam, okay got it. I guess I was thinking of 61.51e where it says,

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command [flight time] for flights-

(i) Except when logging [flight time] under [§ 61.159(c)] 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;

Hence why I was a little confused…

Taylor,
No worries. The FARs can be hard to interpret early on. Think of it as a book of rules. There are different rules for different kinds of flying. Some of the layers of rules can overlap. So what you posted Part 61 outlines requirements for getting licenses at flight schools. What Adam posted is Part 121 rules for scheduled air carriers (ie. regional and major airlines). So logging PIC time is valid under different conditions based on what kind of flying it is. Since we’re talking logging PIC in the 121 environment, you have to follow the guidance of Part 121. If an airline pilot wants to fly a Cessna on his/her day off, then you can log your flight time based on part 61 and you’d be flying under Part 91 flight rules.
-Hannah

Thanks Hannah. Makes perfect sense! Guess I have something new to tell my flight students lol

The correct answer is yes, a type rated SIC may log PIC time for which he/she was the sole manipulator of the flight controls. FAA chief legal counsel issued a letter of interpretation regarding the issue in 1992. You can look up FAA Butler letter, legal interpretation #92-40. I’ve copied and pasted it for you below. Hope this clarifies any misconceptions mentioned previously.

Legal Interpretation # 92-40

  June 5, 1992

  Dear Mr. Butler:

  Thank you for your letter of March 14, 1992, in which you ask
  questions about logging pilot-in-command (PIC) and
  second-in-command (SIC) time when operating under Part 121 of the
  Federal Aviation Regulations (FAR).

  Your letter presents the following scenario:  under a Part 121
  operation, the air carrier has designated a pilot and a co-pilot.
  The pilot is the authorized PIC and the co-pilot is the
  authorized SIC.  During the course of the flight, the SIC is the
  sole manipulator of the controls for one or more legs.

  You ask two questions.  The first asks whether the pilot
  designated as PIC by the employer, as required by FAR 121.385,
  can log PIC time while the SIC is actually flying the airplane.
  The answer is yes.

  FAR 1.1 defines pilot in command:

       (1) Pilot in command means the pilot responsible for the
       operation and safety of an aircraft during flight time.

  FAR 91.3 describes the pilot in command:

       (a) The pilot in command of an aircraft is directly
       responsible for, and is the final authority as to, the
       operation of that aircraft.

  There is a difference between serving as PIC and logging PIC
  time.  Part 61 deals with logging flight time, and it is
  important to note that section 61.51, Pilot logbooks, only
  regulates the recording of:

       (a) The aeronautical training and experience used to meet
       the requirements for a certificate or rating, or the recent
       flight experience requirements of this part.

  Your second question asks if the SIC is flying the airplane, can
  he log PIC time in accordance with FAR 61.51(c)(2)(i) because he
  is appropriately rated and current, and is the sole manipulator
  of the controls.  Additionally, he has passed the competency
  checks required for Part 121 operations, at least as SIC.  The
  answer is yes.

  FAR 61.51(c) addresses logging of pilot time:

       (2) Pilot-in-command flight time.

            (i) A recreational, private, or commercial pilot may
            log pilot-in-command time only that flight time during
            which that pilot is the sole manipulator of the
            controls of an aircraft for which the pilot is rated,
            or when the pilot is the sole occupant of the aircraft,
            or, except for a recreational pilot, when acting as
            pilot-in-command of an aircraft on which more than one
            pilot is required under the type certification or the
            aircraft or the regulations under which the flight is
            conducted.

            (ii) An airline transport pilot may log as pilot in
            command time all of the flight time during which he
            acts as pilot in command.

            (iii) Second-in-command flight time.  A pilot may log
            as second in command time all flight time during which
            he acts as second 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.

  As you can see, there are two ways to log pilot-in-command flight
  time that are pertinent to both your questions.  The first is as
  the pilot responsible for the safety and operation of an aircraft
  during flight time.  If a pilot is designated as PIC for a flight
  by the certificate holder, as required by FAR 121.385, that
  person is pilot in command for the entire flight, no matter who
  is actually manipulating the controls of the aircraft, because
  that pilot is responsible for the safety and operation of the
  aircraft.

  The second way to log PIC flight time that is pertinent to your
  question is to be the sole manipulator of the controls of an
  aircraft for which the pilot is rated, as you mention in your
  letter.  Thus, under a 121 operation you can have both pilots
  logging time as pilot in command when the appropriately rated
  second in command is manipulating the controls.

  We stress, however, that here we are discussing logging of flight
  time for purposes of FAR 61.51, where you are keeping a record to
  show recent flight experience or to show that you meet the
  requirements for a higher rating.  Your question does not say if
  the second pilot in your example is fully qualified as a PIC, or
  only as an SIC.  This is important, because even though an SIC
  can log PIC time, that pilot may not be qualified to serve as PIC
  under Part 121.

  An example of this difference is FAR 121.652(a), which raises IFR
  landing minimums for pilots in command of airplanes flown under
  Part 121 who have not served at least 100 hours as PIC in that
  type of airplane.  Served and logged are not the same in this
  context, and no matter how the SIC logs his time, he has not
  served as a PIC until he has completed the training and check
  rides necessary for certification as a Part 121 PIC.

  We hope this satisfactorily answers your questions.

      Sincerely,

  /s/ Donald P. Byrne
      Assistant Chief Counsel
      Regulations and Enforcement Division

Robert,

We are all well aware of the FAA interpretation that you mention. The thing is that many, if not most, airlines do not feel the way you and the FAA do because we all can clearly see that a First Officer is never the PIC of an airplane, regardless of who is actually manipulating the controls. Most airlines will specifically discount this time in their hiring application process because it is not true PIC time (at least not by most people’s definition).

Chris

Robert,

I came across this on Southwest’s hiring website today:

  • Note: PIC time is defined as Captain or Aircraft Commander of record or pilot signing for the aircraft (not sole manipulator of the controls)