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8 Answers

A question on logging flight time

Asked by: 6032 views , , , , ,
Commercial Pilot, FAA Regulations, Helicopter

So here is my situation: I am a commercially licensed pilot (rotorcraft-helicopter).  I have been doing some work with a local tour company, mostly stuff on the ground, but also ferrying the R44 they use back and forth from where they store it to their helipad.  I know I can't log any of it as PIC time since the company pilot is acting PIC but can I still log it as total time as long as I am manipulating the controls?

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8 Answers



  1. Steven Porter on Oct 28, 2013

    It is my understanding that you can, because FAR 61.51e states you can because you are the sole manipulator of the controls and are rated. However, since the flight does not require more than one crew-member FAR 61.51eiii seems to state that the company pilot cannot log PIC at all.

    For reference.

    61.51…
    (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-

    (i) 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;

    (ii) When the pilot is the sole occupant in the aircraft;

    (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, 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; or

    (iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided—

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  2. Chris Caswell on Oct 28, 2013

    Thanks for the answer Steven,

    I had looked at 61.51 before posting but maybe I am not interpreting it correctly. I guess what I was really asking was whether it is possible for one of us to log PIC time and the other just log the time towards our total time, or if this is only possible when the operation requires more than one crewmember as in 61.51eiii (such as flying under the hood with a safety pilot).

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  3. Kris Kortokrax on Oct 28, 2013

    You didn’t provide enough information to adequately answer the question.

    1. Do you meet the requirements of SFAR 73 to manipulate the controls of the R-44?
    2. Is the other pilot an instructor?
    3. If so, does the other pilot meet the requirements of SFAR 73 to instruct in an R-44?

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  4. Chris Caswell on Oct 28, 2013

    Kris – Yes I have received the awareness training needed to manipulate the controls of the R-44, and the other pilot is not an instructor.

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  5. Kris Kortokrax on Oct 28, 2013

    OK, I’m guessing that you are probably trying to build time in the R-44 so as to be able to act as PIC in the R-44.

    What I would have said (had the other pilot been an instructor) is that he could be giving you instruction towards the time required to meet the SFAR requirements to act as PIC of the R-44. That would allow an instructor to log PIC time while acting as an instructor and you to log PIC time as sole manipulator.

    However, that is not the case. So, you may log PIC time and total time while you are the sole manipulator of the controls. The other pilot (even though he is acting as PIC; I’m assuming that you don’t have enough time to act as PIC of the R-44) may not log any time while you are manipulating. There’s no free lunch.

    Also, if the company is conducting sightseeing rides (air tours), you may not ride along on the air tour and manipulate the controls, unless you are in the operator’s drug testing program. I would also think that you would need to meet SFAR 73 PIC requirements to fly during the air tours.

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  6. Chris Caswell on Oct 28, 2013

    Well I have had the required dual instruction and the endorsement to act as PIC of the 44 but the plan was to build up my 44 time so I could meet the company’s insurance minimums to get me on staff.

    So basically there is no way for two rated pilots in an aircraft with dual controls to both log flight time unless it is during a scenario outline in 61.51? Don’t people split rental costs and both log the hours all time?

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  7. Kris Kortokrax on Oct 28, 2013

    One way for two pilots to simultaneously log PIC time in the R-44 would be for one to be under the hood and the other acting as safety pilot. The safety pilot could only log PIC time while the other pilot is under the hood.

    The only other way is for one of the pilots to be an instructor giving instruction to the other pilot who is manipulating the controls.

    Splitting costs only works for logging time in the safety pilot scenario.

    The other case where people would split costs would be a private pilot carrying passengers who could pay a pro rata share of the costs of the flight. As passengers, they would not be interested in logging time.

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  8. Tim on Nov 14, 2013

    Why can’t I log “total time” when I am not PIC in an aircraft that I am not required in? For example, say my buddy wants to go on an IFR flight but wants a second pilot, during most of that flight I am backing up my buddy on checklists, crosschecking, navigating and talking on radios and lets say I end up shooting an approach. Assume the flight was 2 hours.
    The FARs clearly state we can not both log PIC. My buddy will log 1.8 PIC and 2.0 total. I will log 0.2 PIC (when I was sole manipulator of the controls during approach) and 2.0 Total.

    Does anyone have a reference from the FARs saying I CAN’T log total time in an airplane with dual controls that I am rated in? The FARs are very clear about when I can log flight time as PIC or SIC, but never actual seems to mention “Total Time” as even existing.

    However, lets look at 61.129 Aeronautical Experience, Commercial Pilots.
    It states you must log at least 250 hours of “flight time as a pilot” that includes 100 in powered aircraft, 100 PIC, 20 Dual and 10 solo. Note this does not add to 250 and it does not say 250 as PIC. If you have to be PIC to log “Total time”, why would it specifically state that 100 of your 250 total must be PIC?

    So I would say yes, you can log “Total time”, but in all practicality, it is absolutely meaningless. No employer will accept it, they want to see PIC and will think you are joke if you claim to have 500 hours “total time” while taking a nap in the front seat of your buddy’s 172. You can log what you want, but PIC is what counts.

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