When can you log PIC time? FAA 14 CFR 61.51(e) explained

The three ways most pilots log PIC: 61.51(e)(1)

Paragraph (e)(1) lets "a sport, recreational, private, commercial, or airline transport pilot" log PIC time when the pilot is "the sole manipulator of the controls of an aircraft for which the pilot is rated", when the pilot "is the sole occupant in the aircraft", or when the pilot "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". Sport and recreational pilots are excluded from that third route.

"Rated" has a fixed meaning. In its 21 May 2009 letter to Jason Herman, the FAA Chief Counsel said it "refers to the pilot holding the appropriate aircraft ratings (category, class, and type, if a type rating is required)" as listed on the certificate. In the Speranza interpretation (4 December 2009), quoted again in the Walker letter, the FAA added that "a pilot must hold ratings for the aircraft rather than for the conditions of flight". A private pilot without an instrument rating who flies a leg in cloud while the instrument-rated PIC sits beside them logs that leg as PIC and as actual instrument time.

The autopilot does not stop the clock. The FAA's second interpretation to Daniel Murphy says "a pilot may log PIC flight time as the sole manipulator of the controls for the time in which he or she engages an autopilot".

Logging PIC time versus acting as PIC

14 CFR 1.1 defines the pilot in command as the person who "has final authority and responsibility for the operation and safety of the flight", designated before or during the flight and holding the category, class and type rating for it. Acting as PIC also brings in your flight review, currency, medical and any 61.31 endorsements. Logging PIC asks only whether a paragraph of 61.51(e) fits.

The Herman letter shows the gap. A private pilot without the complex and high-performance endorsements cannot act as PIC of that airplane, but "may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC", so the endorsement decides who may act as PIC and the rating decides who may log.

The gap also works against the acting PIC. In the Walker scenario two private pilots share a single-pilot airplane under IFR. Pilot B flies a half-hour leg. Pilot B logs PIC as sole manipulator, and Pilot A, the acting PIC, "may not log PIC time for the portion of the flight during which Pilot B is the sole manipulator", because only one pilot is required for that flight.

On a practical test the examiner is not PIC unless agreed in advance (61.47(b)). The FAA's 30 June 2009 letter to Daniel Murphy concluded that "a pilot may log PIC time for the practical test", and that a student pilot taking the private test may do the same.

Type-rated aircraft: SIC-only ratings, 61.51(e)(1)(iv) and the ATP rule

In an aircraft that needs a type rating, the sole-manipulator route needs the full type rating. The Counsil interpretation (April 2012) said a pilot "only qualified to serve as SIC of an aircraft would not be able to log PIC time" under 61.51(e)(1), and the Morris letter that followed applied it to a type rating carrying the "SIC Privileges Only" limitation and to a pilot with no type rating at all. A first officer who holds the unrestricted type rating logs PIC for the time they are sole manipulator.

Paragraph (e)(1)(iv) is the other way in. A commercial or ATP holder in an approved PIC training program may log PIC while performing the duties of PIC under a supervising PIC, who must log and certify that training in your logbook and sign it with a flight instructor certificate number.

Paragraph (e)(2) lets an ATP who is rated to act as PIC "log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate". Time logged as SIC under a Part 135 SIC professional development program is different: 61.159(c)(4) says it "may not be logged as pilot-in-command time even when the pilot is the sole manipulator of the controls".

Do not count one hour twice. When a type-rated SIC takes the controls, both 61.51(e) and (f) can fit, and the second Murphy letter answered that "a pilot may not 'double log' flight time in a manner that would misrepresent that pilot's total flight hours". The same hour can still count toward different requirements, such as night and cross-country.

Instructors and student pilots

Under 61.51(e)(3) a flight instructor "may log pilot in command flight time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft". The instructor logs PIC whether or not the trainee is on the controls.

A student pilot logs PIC only when they are the sole occupant (or performing PIC duties in an airship that needs more than one pilot), hold a 61.87 solo endorsement, and are training for a certificate or rating (61.51(e)(4)). A certificated pilot training for a new rating in an aircraft they are already rated for logs the lesson as dual received and, as sole manipulator, as PIC. The regulation and your operator's procedures decide each case; the FAA's interpretations show how it reads them.