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Logging PIC Time as a Commercial Pilot, Flying with a CFI

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FAA Regulations

Been reading 61.51 ad nauseum and my head hurts.

I hold a commercial instrument rating in both single and multi engine airplanes as well as helicopters. When flying a SEL (Cessna 172), under what circumstances may I log PIC time when flying with a CFI on board with me, and in what way (if any) must the logbook be signed (and/or annotated with remarks) by the CFI? And is this always logged as dual?

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2 Answers



  1. John D Collins on Nov 14, 2022

    Any time you are the sole manipulator of the controls in an aircraft you are rated in, you may log PIC in accordance with 61.51(e)(1)(i). If the instructor is providing training, you would also log dual received 61.51(h). To log PIC when you are rated (ASEL or AMEL or helicopter) and the sole manipulator of the controls. Either you or the instructor needs to be qualified to act as PIC, but it the instructor is acting as PIC, you don’t need to be current, have endorsements such high performance, nor do you need to hold a medical in order to log PIC as the logging regulation only requires you to be rated and the sole manipulator of the controls and nothing else.

    The instructor would only endorse your logbook if they were providing training. If they were a passenger, the instructor would not log anything. If the instructor was just a safety pilot and not providing any training, they could log either second in command or PIC for the time they were the safety pilot if it was agreed that they were acting as PIC.

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  2. Mark Kolber on Nov 18, 2022

    As John’s post indicates, the Universal Rule of Logging Flight time (61.51) does not make a distinction among recreational, private, commercial, and ATP when it comes to,logging PIC flight time as sole manipulator.

    Where I see this question raised often is in the 135 and 141 contexts where an employer is looking for “acting” PIC time rather than PIC flight time per the FAA rules. But even then, that’s a distinction between data collection and data presentation,

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