According to my interpretations of the scenarios we discussed about Logging PIC Time, it appears that I am legally justified in logging PIC Time in the Lear: 1. When I am the sole manipulator of the controls, (After receiving my Type Rating and FAA 8410-3 designating me as PIC,) and 2. When I am giving instruction in the Lear to the company-designated PIC. The LEGAL requirements of acting as the PIC is addressed in § 1.1. 1.1 Definitions: Pilot in command means the person who: (1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight. Logging PIC time is provided for by § 61.51(e). (e) Logging pilot-in-command flight time. (1) A recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person - (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated; (ii) Is the sole occupant of the aircraft; or (iii) Except for a recreational pilot, is acting as 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. (2) An airline transport pilot may log as pilot-in-command time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport pilot certificate. (3) An authorized instructor may log as pilot-in-command time all flight time while acting as an authorized instructor. Per § 1.1: "Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time." QUESTION: Question regarding 61.51(e)(3) and 61.23(b)(5) -- Can a CFI who is exercising the privileges of a flight instructor certificate under 61.23(b)(5) log PIC even though he or she does not have a valid medical certificate. ANSWER: Ref. § 61.51(e)(3): Yes, the CFI may log it as PIC time. As I have stated in the past the rules are different between "logging PIC time" under § 1.1 vs "acting as the PIC" under § 61.51(e)(3). The CFI cannot "act as the PIC" without a medical certificate, but he or she can certainly "log it as PIC time." There is a difference between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 deals with logging PIC flight time, and it provides that a private or commercial pilot may log as PIC time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR 61.51 only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience. Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51. Enclosed please find two prior FAA interpretations concerning logging of PIC time. We hope that these will be of further assistance to you. 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.