PIC Terminology

8 Answers

1. 
   

   
   

   Mark Kolber on Aug 01, 2013

   “Acting PIC” (more correctly, “Acting as PIC”) refer to the pilot who has taken on final authority and responsibility for a flight.

   “Performing The Duties as PIC” (more correctly, “Performing the Duties of PIC”) is a regulatory construct created strictly for the purpose of meeting the requirements for acting as PIC. It involves a student performing as though he were the PIC, but with an instructor on board.

   For airplanes (the term may have previously existed for airships), it was originally created (in 1997, as I recall) because of the problems of multi-engine students not being able to solo due to insurance limitations. So, for example, the 61.129(b) requirements for the commercial certificate with a multi-engine rating to have 10 hours of solo flight time was amended to allow for “10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor…”

   Later, I think in 2009, the use of the “performing the duties” in lieu of solo flight time was expanded to the requirements for the other commercial certificate ratings. I think the real reason was parity, although the FAA also justified it in terms of insurance requirements for some of the newer high performance singles and as a way of bringing CRM into the cockpit, where the CFI plays “first officer” to the student’s “captain.”

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2. 
   

   
   

   Dan Chitty on Aug 01, 2013

   Thank you for the feedback Mark.

   To make sure I understand:For example, a CFI is providing instruction to a commercial student and both are qualified to act as PIC, the CFI is therefore “acting PIC” but the student is manipulating the flight controls and is therefore “performing the duties as PIC”.

   Am I correct?

   Is there a situation where 2 pilots can both be ” acting as PIC”?

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3. 
   

   
   

   Wes Beard on Aug 01, 2013

   Dan,

   Only one pilot can “Act as the pilot in command” at one time. Per 91.3 they are legally responsible for the safe operation of the flight.

   If a CFI is providing instruction to a commercial pilot student who is performing the duties of PIC, then the commercial student cannot be rated in the airplane and the CFI must act as the pilot in command.

   In your scenario, if both the CFI and commercial student are rated in the airplane then either can act as pilot in command but both cannot at the same time. Typically, the CFI will act as the pilot in command though there are scenarios where the student must act as pilot in command (i.e. the instructor does not have a current / valid medical).

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4. 
   

   
   

   Mark Kolber on Aug 02, 2013

   Dan, this isn’t one of those acting/logging dichotomies. A student can be PTD “performing the duties of PIC” whether or not the student is even qualified to act as PIC. The rules about it are there in order to leta pilot fulfill solo requirements. Actually, I think the best way to think of “performing the duties of PIC” is “Replacement Solo.”

   The most common scenario is the one the rule was meant for: A Commercial Pilot, ASEL is doing a multi-engine add-on as his first multi-engine rating. Since he’s not multi-rated, he can’t act as PIC in the airplane.

   One of the requirements for the commercial multi is “10 hours of solo flight time in a multiengine airplane…” Problem is that no one will rent a multi-engine airplane to a pilot for what is effectively a student solo. Even if the pilot owns his own multi, his insurance company may well say, “Sorry. No solo until you have the multi rating and at least 30 hours dual in it.”

   So, what can he do?

   Fortunately, the 10 hour solo requirement was changed to read, “10 hours of solo flight time in a multiengine airplane or 10 hours of flight time performing the duties of pilot in command in a multiengine airplane with an authorized instructor.”

   So now, instead of solo, the multi-engine student can do a Replacement Solo – he can performs all of the duties that would normally take place in a solo flight but with an instructor on board as the real PIC to satisfy insurance requirements.

   That’s really all there is to it – a way to enable someone who can’t solo because he doesn’t meet the minimum requirements of an FBO or insurance company to get solo credit. If you try to read more into it than that, you only going to confuse yourself unnecessarily.

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5. 
   

   
   

   Mark Kolber on Aug 02, 2013

   And, yes, Wes is absolutely right – there are no scenarios in which more than one person can be (definition of plot in command)

   ==============================
   … 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.
   ==============================

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6. 
   

   
   

   Dan Chitty on Aug 03, 2013

   Thank you Mark and Wes for the great examples and explanations.

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7. 
   

   
   

   Kris Kortokrax on Aug 03, 2013

   One thing to keep in mind, (even though the question is about “acting”, not “logging”) is that you may not log the time as PIC time when you are performing the duties of a PIC with an authorized instructor on board.

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8. 
   

   
   

   Kyle Simms on Feb 25, 2023

   The CFI on board can’t log it as PIC time? 61.51e3 does not apply?

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