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Can You Log PIC Time In The Clouds If You Aren't Instrument Rated?

Boldmethod

Not instrument rated? You can still log PIC time in the clouds, in certain cases. Here's why...

Logging PIC Flight Time vs. Acting As PIC

According to FAR 61.51(e), there are four ways you can log pilot in command (PIC) time in your logbook:

  • 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.
  • When the pilot is the sole occupant in the aircraft.
  • 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. (This is why captains at airlines can log PIC time even when they aren't physically flying the airplane)
  • When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command (with a few sub-requirements).
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Here's where things get confusing. To act as PIC, you have entirely separate requirements. According to FAR 61.3(e), in order to act as PIC under IFR or in weather less than VFR, you must hold:

  • The appropriate aircraft category, class, type (if required), and instrument rating on that person's pilot certificate for any airplane, helicopter, or powered-lift being flown, or;
  • An airline transport pilot certificate with the appropriate aircraft category, class, and type rating (if required) for the aircraft being flown, or;
  • For a glider, a pilot certificate with a glider category rating and an airplane instrument rating, or;
  • For an airship, a commercial pilot certificate with a lighter-than-air category rating and airship class rating.
Swayne Martin

Flying With A CFI or CFII

When you fly with a CFI or CFII, you can log PIC time during your instrument training when you're the sole manipulator of the controls. As long as you're rated for the aircraft, you're allowed to log the time. You're not rated in an airplane until you hold a pilot's certificate, which means you'll need to be more than a student pilot.

Under FAR 61.51(d)(3), a CFI can always log PIC time when they're serving as the authorized instructor (when rated in the aircraft). Because of this, both you and your instructor are allowed to log PIC time during training flights, even in the clouds.

Why You Should Always Log PIC Time (When You're Allowed)

Some pilots recommend to not log PIC time when you're not the final authority for the airplane. This would mean, unless you're acting as PIC, you wouldn't log PIC time that's limited to the "sole manipulator of the controls" definition.

If you're pursuing an ATP certificate, there are numerous PIC flight time requirements. Any loggable PIC time may be used to fulfill these requirements, including PIC time when you're receiving training. This means PIC time you log with a CFI on board can be used towards your ATP certificate.

Boldmethod

Do you log PIC time when you're flying with a CFI? Tell us in the comments below.

Swayne Martin

Swayne is an editor at Boldmethod, certified flight instructor, and an Embraer 145 First Officer for a regional airline. He graduated as an aviation major from the University of North Dakota in 2018, holds a PIC Type Rating for Cessna Citation Jets (CE-525), and is a former pilot for Mokulele Airlines. He's the author of articles, quizzes and lists on Boldmethod every week. You can reach Swayne at swayne@boldmethod.com, and follow his flying adventures on his YouTube Channel.

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