For all those who've wanted to know something about logging flight time, here are my answers to pilot's questions on the subject. These are not official FAA answers but they do comport with the FAA's knowledge on the subject. To find the official FAA answers to these and other questions, you'll need to look at the FAA's list of Frequently Asked Questions. Unfortunately, the FAA has since suspended the FAQ site for reasons that are only known to them. Nevertheless, I have the FAA's 2004 FAQs that are still relevant and can be found by clicking here. This is the original source of the information that follows.

For your convenience, I've excerpted many of the FAA's FAQs that pertain to logging PIC/SIC and they can be found by clicking here.

In addition, if you're an AOPA member, click here for additional information on logging PIC and SIC.

QUESTION # 1
Dear Mr. Machado:
Could you help clear up the confusion regarding the logging of PIC by a pilot acting as a safety pilot? Several of our local flight instructors are having a difficult time making heads or tails out of the regulations about logging time.

Thanks,
Jim

ANSWER #1
Greetings Jim:
There are only three conditions in which a private or commercial pilot can log PIC time.

You may log pilot-in-command flight time when:

1. You are the sole manipulator of the controls of an aircraft for which you are rated (if you are flying a Cessna 172 and you have an airplane, single engine land rating, then you can log this time as PIC. Of course, some folks want to know if this still applies when the airplane is being flown by the autopilot. The answer to this question is: Don't ask that question and don't brag about using the autopilot, either. Just log the time as PIC and be happy.);

2. You are the sole occupant of the aircraft (if you are the only one in the airplane then there's a very good chance that you're the only one flying it, so log the time as PIC. How do you log this if you have a split personality? I suppose you'll need to get a twin rating);

3.You are acting as pilot in command on an aircraft on which more than one pilot is required under the type certification or the regulations under which the flight is conducted (this one needs a bit of explanation)

To understand item #3 you must understand the difference between logging PIC and acting as the PIC. Keep in mind that FAR 91.109(b)1 wisely requires that a safety pilot be on board if the person flying is operating under simulated instrument conditions. Yes, I think this is a good rule, too:). The regulations also require that one person on board the aircraft always act as PIC. This will be the person who is legally responsible for the operation of that aircraft. The person acting as the pilot in command can obviously log this time as PIC. On the other hand, the regulations also allow an additional person to log PIC if that person does something that generates experience of sufficient value. Here's an example.

Suppose you and a friend both have private pilot certificates with airplane, single-engine-land ratings. Let's also say that each of you is legally qualified to act as the legal PIC (meaning that you are both current, have current medicals, etc., etc.). Both of you hop into a Cessna 172 for a flight. Your friend wears a view-limiting device and is the sole manipulator of the flight controls while you act as the safety pilot.

In this instance, if your friend elects to act as the legal PIC as well as be the sole manipulator of the flight controls, then he alone logs the flight time as PIC while you log the time as second in command (SIC). [This is also the example where, if the airplane is either complex or high performance, and if you don't have a complex or high performance endorsement, then you can still act as safety pilot and log it as SIC since you're not acting as (the legal) PIC.]

On the other hand, you may elect to act as the safety pilot as well as the legal PIC while your friend is the sole manipulator of the controls. If so, then you can log the time as PIC and your friend can also log the time as PIC. Do you see why this is? Being the safety pilot doesn't mean you can automatically log the time as PIC. You must be willing to act as the legal PIC (as well as the safety pilot) to log this time as PIC. Since your friend is the sole manipulator of the controls, he gets to log PIC time as well. If anything goes wrong in this scenario, you're the one whose ticket will be on the line.

Here's another commonly asked question regarding the information above. Suppose you and the same friend go flying in that same Cessna 172 and no one wears a view-limiting device. Is there any situation where both of you log the time as PIC?

Sorry, but there's absolutely no way this can happen.

Yes, I realize that some folks suggest it's possible for both pilots to simultaneously log all the flight time as PIC here but the FAA doesn't seem to think so (and they are the folks who count in this instance). The only condition where these two pilots can log PIC is when one pilot is operating under simulated conditions as stated above. Under this condition the regulations require that two pilots be on board the airplane. There's no type certificate (or any condition, for that matter) that requires that two private or commercial pilots be on board a Cessna 172. When two private or commercial pilots are on board an aircraft and neither wears a view limiting device, only one pilot can log PIC at a time. This will be the pilot who is the sole manipulator of the flight controls.

QUESTION #2
Dear Mr. Machado,
I am a student pilot. My CFI, a much younger man, has been filling in my log using the Hobbs meter time for the time of flight. Isn't the flight time that I log in my book the time between where I enter the runway for takeoff and the time I exited the runway after landing? What is the proper time for logging flight?

Thank you,
Sally

ANSWER #2
Greetings Sally:
Flight time is technically the time the aircraft begins to move under its own power for the purposes of flight. It ends when the aircraft comes to rest after landing. Hobbs meter time is considered a perfectly acceptable means of recording flight time, even though there may be a few minutes after an engine starts before you start moving. If this prevents you from sleeping well at night, then let the airplane move just a few inches immediately after engine start. My recommendation is to log all your Hobbs meter time since this is what nearly everyone else on the planet does.

QUESTION #3
Dear Flight Training:
A friend of mine wants me to act as a safety pilot for him in his Mooney while he obtains the instrument experience necessary to be instrument current. I am private pilot single-engine land rated. Most of my experience is in a Cessna 172. I don't have any high performance or complex airplane time. Am I wrong in thinking that I need a high performance and complex airplane endorsement in my logbook to act as a safety pilot? If I don't, would you consider this to be a safe thing to do?

Thank you for your time,
(No name provided)

ANSWER #3
Dear Man With Good Question:
No, you're not wrong in thinking that you can act as a safety pilot in a Mooney without a high performance and complex endorsement. It's perfectly legal to do so. In this instance, you'll be acting as a safety pilot (or second in command) and won't be acting as pilot in command. You only need the high performance and complex endorsements to act as PIC. The regulations say that the safety pilot must possess at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown. Since the Mooney is a single-engine-land airplane, you meet those requirements.

Not having a high performance or complex endorsement doesn't mean you can't perform the duties of a safety pilot in a Mooney. There's nothing necessarily unsafe about being a safety pilot in this airplane. Obviously the same couldn't be said if you elected to act as a safety pilot in a helicopter (since you're not rated in a helicopter). In this instance, you wouldn't know which chopper stick to move to maneuver that machine. This is the reason the FAA requires a safety pilot to be rated in the same category and class of airplane being used.

QUESTION #4
Hi Rod,
Here's a quick question about logging IFR time and approaches. I'm on an IFR flight plan and part of it in true IMC (instrument meteorological conditions). I break out at 4,000 feet in VMC (visual meteorological conditions) flew the ILS approach in VMC conditions. Is that a loggable approach for instrument currency?

Thanks,
Terrance

ANSWER #4
Greetings Terrance :
In the May-June 1982 issue of Flight Forum , the FAA said, "...In order to log approaches toward IFR currency, the approaches must be carried at least through the so-called critical elements. This could include conducting the approach to a landing, to the minimum altitude and\or missed approach point, or through the approved missed approach procedure."

In regard to breaking out from IMC to VMC on the approach, here's what the FAA had to say in their July-August 1990 issue of Flight Forum . "...Once you have been cleared for and have initiated an instrument approach in IMC, you may log that approach for instrument currency, regardless of the altitude at which you break out of the clouds. When doing a simulated IFR approach you should fly the prescribed instrument approach procedure to DH or MDA to maximize the training benefit."

Since you didn't begin your approach in IMC, you can't log that approach towards meeting the instrument currency (recent flight experience) requirements.

QUESTION # 5
Dear Mr. Machado:
I am a newly minted pilot and I decided to get my complex endorsement. Can I log the flight time needed to receive this endorsement as PIC time since I am a certificated pilot? If I can, what FAR covers this entitlement?

Thank you for your time.
David.

ANSWER #5
Greetings David:
Yes, if you are taking the training to obtain your complex or high performance endorsement, you can log that time as pilot-in-command time. The difference here is between logging PIC time and acting as the required PIC. Your instructor is the legal PIC on that flight since he or she is the only one with a complex or high performance endorsement. You can log the time as PIC since you're the sole manipulator of the controls on an aircraft for which you are rated. This is covered in CFAR 61.51(e).

QUESTION # 6
Dear Rod:
Yesterday I was flying an Instrument training flight on an IFR flight plan at 5000 feet. We were in between layers at 4800 and 5500 feet.  We could see ahead clearly but we could not see anything in the layers above and below.  VFR condition call for 1000 above and 500 below; since our conditions did not meet that test, then is that time considered actual instrument time for training purposes?  And secondly, if ATC asks me to say my conditions, do I report them as IMC or VMC? 

Thank you,
B.T.

ANSWER #6
Greetings David:
The FAA provided an excellent answer to this question many moons ago. The answer basically says that if you have to control your airplane solely by reference to the instruments, then you should log the time as actual instrument conditions. If you are in a situation such as the one you described (between layers) and you "can" control the airplane by outside references, then you're not in actual conditions, regardless of your distance from the clouds. Of course, it's entirely possible to be between layers where the layers slope creating a false horizontal horizon. If this is the case, you probably "can't" control the airplane by outside references and would, therefore be required to fly on instruments (a false, cloud top sloping horizon is very discombobulating). Thus you should consider yourself in actual conditions and log it as such.

Regarding the other question about IMC or VMC, if you can't control the airplane by outside references then you should tell the controller that you're in IMC. This should make sense since you're probably spending most of your time (if not all of it) looking at your instruments. More than likely, the controller isn't asking for a weather report here. He's simply checking to see if you're capable of honoring any request that he might make if you were in VMC (such as visually identifying a nearby target). If you can (and are) flying by outside references only, then you're in VMC. VMC has nothing to do with whether you have the legal cloud clearance and visibility requirements to fly VFR as stated in the regulations.

Given your situation of being between layers and flying by outside references, you should report your conditions as VMC.

There is one other point that's very important to consider. There is also no specific regulation stating that a pilot must have a definable, identifiable horizon when flying VFR, either. If there were such a requirement, then most VFR flights in desert areas on a moonless night would be illegal, given that an identifiable horizon under these conditions isn’t likely. On the other hand, if you are unable to determine your attitude by some outside reference (city lights or moonlit foreground, for example), you’ll often be forced to rely on flight instruments for attitude control. If so, in my opinion you should be instrument rated, current on instruments and in an appropriately equipped airplane when flying in these conditions.

The only requirements for VFR flight are a minimum visibility and a specific cloud clearance (and a minimum cloud height for departure in surface based controlled airspace). Technically, you are not in violation of any regulation when flying without a definable horizon. On the other hand, the question of safety here is an important one.

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