Can two certificated and rated pilots both log simultaneous PIC flight time if neither is a CFI? Surprisingly, the answer is yes! To see why and how, we’ll first need to consult the FARs for guidance.

FAR section 1.1 states:

“Pilot in Command means the person:

  1. Has final authority and responsibility for the operation and safety of the flight.
  2. Has been designated as the pilot in command before or during the flight.
  3. Holds the appropriate category, class and type rating, if appropriate, for the conduct of the flight.”

FAR 61.51 (e) Logging of PIC flight time:

  1. When the pilot is the sole manipulator of the controls for which the pilot is rated or has sport pilot privileges for that category and class of aircraft, if the class rating is appropriate;
  2. When the pilot is the sole occupant of the aircraft;
  3. When the pilot , except for the holder of a sport or recreational pilot certificate, acts as PIC 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”

FAR 91.109 (b):

“Pilot in Command means the person:

  1. The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.”

To paraphrase all the above, a pilot can log as PIC time the period they are the “final authority” and legally responsible for the safety of a flight in aircraft that he/she is certificated and rated for. A pilot can also log PIC time for the flight time they are the sole manipulator of the controls of an aircraft they are certificated and rated for even if they do not “Act” as PIC (be the final authority/responsibility for safety). So, while there can be only one final authority for a flight, there can be more that one pilot logging PIC time for the same flight!

Let’s say two Private Pilots, ASEL rated/current with valid medicals and are going to do a $100(+) hamburger flight in a Cessna 172 on a perfect VFR day. The pilot who will be the sole manipulator of the controls is also the final authority/responsibility for the flight during this time. The pilot in the other seat is only a passenger as the aircraft does not require more than one crew member. So, only the pilot flying can log PIC time.

Once airborne the pilot at the controls tells his passenger that he’d like to do some simulated instrument time. The passenger (also a pilot) agrees and the pilot flying dons a “view limiting device” (Foggles or a hood). He continues “being” sole manipulator of the controls of an aircraft for which he is certificated and rated.  The flight is VFR but since he can no longer “see and avoid” obstacles and other aircraft, the pilot in the other seat has prior agreed to fill that role by becoming the “safety pilot” and is now responsible for the safety of the flight of an aircraft in which he/she is certificated and rated.  The safety pilot (who must hold a Private or higher grade of certificate) is now “required crew” per FAR 91.109 (b), and can log his safety pilot time as PIC time per FAR 61.51 (e)(iii).

Once the pilot at the controls removes the hood he goes back to both “Acting” as PIC (Final Authority) & sole manipulator of the controls and the right seat pilot returns to passenger status.  At the end of the flight the pilot who was at the controls the entire flight logs all the flight time as PIC and the time he was under the hood as simulated instrument time. He must also log the name of his safety pilot. The right seat (safety) pilot can log only the time the left seat pilot was under the hood as PIC time as well. It’s not required but a good idea to note who they were safety pilot for. That’s all there is to it, both pilots logging simultaneous PIC time! Note that if the flight was a cross country (more than 50 NM) flight, the safety pilot cannot log any portion of the flight as cross country. For Private Pilots to log cross country time for the purpose of obtaining a higher certificate or rating there must at least one landing more that 50NM straight line distance from the starting point (FAR 61.1 (b)). Only the pilot who was the sole manipulator of the controls including the takeoff and landing can log the cross country time.*

Why not take advantage of this little understood rule and fly with another pilot each doing some “under the hood” and “safety pilot” time! Or volunteer to be a safety pilot for an instrument rating student! In both cases you’ll be spending a lot less to log valuable PIC time and even hone your flying skills!

Some additional interesting things to note about logging PIC time:

  • A “safety pilot” must hold a valid medical. Though FAR 91.109 makes no mention of a medical, findings by the FAA’s Legal Counsel have upheld that a pilot performing the duties of a safety pilot is a required crew member and therefore must have a valid medical per FAR 61.3 (c)(1). Interesting to note that the safety pilot does not need to be “current” (90 currency or valid BFR not required) to act as a safety pilot. However, they must be properly certificated (Private and higher) and rated in the aircraft being flown.
  • If you are receiving instruction from a CFI, the flight instructor can log all the flight instruction time as PIC time regardless of the ratings/certifications/currency of the person at the controls. The CFI is always responsible for the safety of the entire flight. The person receiving instruction is considered a student and not a passenger. A CFI does not need a medical if the person receiving instruction/flying the aircraft is properly certificated, rated, current  and has a valid medical. A CFI without a medical cannot give instruction to a primary student (as they are not yet certificated) but can give instruction for additional certifications, endorsements, ratings or a BFR to a certificated pilot who is rated, current and has a valid medical. If the flight is a cross country (50+NM) the CFI can also log cross country time even though he/she was not the manipulator of the controls at any time.  The holder of a Commercial Pilot Certificate (which a CFI must hold) can log any flight time of more than 50NM from the starting point as cross country time whether or not a landing was made at or beyond that distance (FAR 61.1 (b)(vi).*
  • There are provisions in the FAR’s for a pilot taking instruction for an additional rating to log PIC time in an aircraft that they are not yet rated for. For example, to obtain a Multi-engine rating one must log a certain number of hours as PIC.  Insurance companies are not very eager to cover a multi-engine aircraft flown by a student solo.  The FARs allow a student in this circumstance to log PIC time when the other occupant of the aircraft is a properly rated/current CFI and the student performs all the duties of the PIC during the flight (see FAR 61.51 (e)(iv)(A)(B)).
  • A certificated pilot with an ASEL rating taking the additional required flight training for the ASEL High Performance, Complex or Tailwheel endorsement can log those flights as dual received and PIC time as well. An endorsement is not considered a rating. But he/she cannot “Act” as PIC (fly solo or take passengers) of an HP/Complex or Tailwheel ASEL aircraft until he/she has the required logbook endorsement to do so.  A pilot pursuing an additional rating (i.e. Commercial or Instrument Rating) or recurrent training can log all dual received from a CFI/CFII as PIC during those flights as long as they are already certificated and rated for the aircraft being flown.
  • You cannot log time in an ATD or PCATD as PIC Time. ATD, PCATD time is logged only as “Pilot Time”.
  • Up until several years ago, a student pilot flying solo could not log that flight time as PIC even though they were the sole occupant of the aircraft!

Keep the shiny side up!


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Article by: Mike Berlin, CFII-MEI, AGI, IGI