PIC Time: Part 61.51 or Part 1. What's the difference?

Determining how to correctly show pilot flight time on the various employment applications is a recurring dilemma. In particular, the issue of pilot-in-command (PIC) time, or to be more precise, the type of PIC time, is frustrating for most pilots and for those (me) trying to explain it as well. Getting into a deep discussion about this topic can and has brought me to my knees since there are so many things to consider and exceptions to the rule. But I think I might have broken the code on finding a way to help explain this topic without too much confusion. However, before I begin, I will review some FAR rules and definitions. Bear with me. This will all come together in the end—I promise.

To help you better understand the issue of PIC time, there are two main concepts to consider and keep separate. First, there is “logging of PIC time” and the many conditions under which this can happen, and second, applying the “definition of PIC” according to FAR Part 1 when logging time in this category. Let’s look at the rules.

1) Logging of PIC Time—61.51:

FAR Part 61.51 outlines the conditions under which a pilot can log PIC time. We call this the “sole manipulator” rule. FAR Part 61.51 states that a recreational, private, or commercial pilot may log as PIC time only that flight time:

during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated in class (airplane, rotorcraft, etc.) and category (multiengine land, single engine land, etc.), or
when the pilot is the sole occupant of the aircraft (including solo flight time as a student pilot), or
except for a recreational pilot, when acting as PIC of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

Furthermore, an ATP may log as PIC all of the flight time while acting as PIC of an operation requiring an ATP (such as a Part 121 air carrier) and lastly, a certified flight instructor may log as PIC time all flight time during which he acts as a flight instructor.

Why does the FAA allow more than one pilot to log PIC hours at the same time? This is done to help pilots build PIC time for the purpose of getting other licenses and ratings. Likewise, in commercial airline operations, the SIC can count, not log, his leg as PIC only for the purpose of meeting experience requirements for his eventual upgrade to captain with his current employer, but not for getting hired with another airline. This is explained in more detail under item number three below.

I have known pilots to slice and dice this issue many different ways, and while, yes, there are many conditions under which you can actually log PIC, there is only one condition when you can log PIC under the FAR Part 1 definition.

2) Definition of Pilot-in-Command—FAR Part 1:

While Part 61.51 defines when a pilot can log PIC time, FAR Part 1 defines what a PIC is (according to the FAA anyway). As such, FAR Part 1 defines PIC as the pilot who:

has final authority and responsibility for the operation and safety of the flight,
has been designated as pilot-in-command before or during the flight, and
holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

To simplify this, under the FAR Part 1 definition, there is only one pilot who “signs” for the aircraft. In commercial operations, the PIC would “sign” the dispatch release and maintenance log. In Part 121 operations, the dispatch release indicates only one designated PIC—once you are captain, you are captain, period. Even if you fly with another type-rated captain, it is only you who has the final authority under Part 1. This is similar to military operations since all missions of which you are the designated aircraft commander are the same as applying the Part 1 definition of PIC. Is this starting to make sense?

3) Part 121 Operations Pilot Qualifications—FAR Part 121.437:

The rules for flying passengers for hire under Part 121 (and 135) add another element that may make all of this clearer. Under FAR Part 121.437, no pilot may act as PIC of an aircraft (or as SIC of an aircraft in a flag or supplemental operation that requires three or more pilots) unless he holds an airline transport pilot certificate (ATP) and the appropriate type rating for that aircraft.

A final item worth noting is that this same section of the FARs further states that any pilot who currently works for a certificate holder and meets the applicable training requirements for that carrier and the proficiency check requirements may be issued the appropriate category and class ratings by presenting proof of compliance with those requirements to a Flight Standards District Office. In other words, as a first officer with your 121 carrier, you get PIC credit for the purpose of upgrading to captain and through that training the type rating as well. Only then would you be certified and legal to fly as PIC for your airline. And from that time forward, all of your time logged would be as Part 1 PIC under FAR Part 121. If you consider the military to be the certificate holder, then this would not be much different for military pilots either. As a military pilot, you are getting credit for your flight time and have been meeting all the training requirements in preparation for your eventual aircraft commander upgrade or other rating checkride. Are you starting to see the similarities?

Type Rating Requirements—FAR Part 61.31

FAR Part 61.31 defines the conditions under which a Type Rating is required and states that a pilot must be type rated if she operates as PIC:

large aircraft (12,500 pounds maximum takeoff weight)
turbojet-powered aircraft; and/or
other aircraft specified by the administrator through aircraft type certificate procedures.

Most Part 121 airlines operate aircraft requiring a type rating. Copilots or first officers, on the other hand, are legal to fly these aircraft without a type rating since they are qualified in class and category and they are not flying as the designated PIC (they have not yet upgraded to captain and received the type rating). There is no FAA type certification requirement for military aircraft, but if there were, pilots operating most military aircraft would be required to have the appropriate type rating. Since most military aircraft would meet the conditions for FAA Type certification, it stands to reason that when you upgrade to Aircraft Commander in the C-141, for example, you are completing the equivalent of a commercial captain’s upgrade program and getting type rated as well. Therefore, all of your aircraft commander time from this point forward would be considered Part 1 PIC time provided you are the designated aircraft commander for all of your missions from now and into the foreseeable future. Is it coming together now?

In general, most civilian pilots have a better handle on the logging of pilot time than their military counterparts. This is probably because civilian pilots have more access to the FARs, and how to log pilot time starts the first day they begin flying. Perhaps the biggest issue arises when the commuter SIC thinks he can log his leg as PIC, which in some cases is true. Military pilots on the other hand, are completely out of the system until they, at some point in their career, decide to get a civilian pilot license. Until that point, the military has tracked and recorded pilot times in a fashion that is more similar than different to FAR Part 61.51. We do strongly recommend that military pilots get a civil license as soon as possible and keep a civilian logbook logging all of their flight time according to FAR Part 61.51 up until the time they upgrade to aircraft commander, first pilot, or flight commander.

However, our recommendation to all pilots, both civilian and military, is to differentiate in their logbooks that PIC time is either 61.51 or Part 1. Simply draw a line down the middle of the PIC entry column, and re-label the column as Part 61.51 on one side and Part 1 on the other. Then, whenever you fly, make the appropriate entry in the applicable column. This way, when it comes time to complete your employment application, it will be much easier to give the airline what it wants.

So how do you apply these FARs? It’s actually easier than you think. You will have to apply a few hypotheticals when trying to determine which time is considered Part 1 PIC. Ask yourself the following questions.

Have I received a specific type ride or checkride for this aircraft?
Did I sign the dispatch release and maintenance logs for this mission?
Am I listed on the dispatch release as the designated aircraft commander, flight commander, or plane commander?
Does the aircraft I fly have jet engines and/or a maximum takeoff weight of 12,500 pounds or more?
Am I the sole occupant of this aircraft?
Is this a training flight of which I am the designated rated instructor pilot, check pilot, examiner, or evaluator?

If you answered “yes” to any or all of these questions, the time would be classified as Part 1 PIC time. That’s all there is to it—really!

If you answered no to these questions, you should be logging your PIC time according to Part 61.51 rules.

The airlines are looking at Part 1 PIC time as true leadership experience on the flight deck. Some companies such as AirTran look at both Part 61.51 and Part 1 time. They do require 500 hours Part 121 PIC which automatically is Part 1 time, or the military equivalent. Other companies may only look at Part 1 PIC time. Part 1 PIC time is not only a competitive qualification, but there is a demonstrated correlation between this level of experience and success in training and future upgrade events. You have heard it said time and time again that airlines hire future captains, not first officers, and this is very true. There is a big investment made in training, and the airline wants to hire people who will succeed throughout their career. But the bottom line is this: Until you have either upgraded to aircraft commander or captain under FAR Part 121 with your current airline, your career development as a professional pilot is still in progress. Don’t stop until you have reached this goal. Always look for opportunities to upgrade as quickly as possible—providing you are ready of course. (We’ll save that topic for another article.)

I hope that you now have a better understanding of how to apply the rules correctly and make them work for you. Doing so could mean the difference between getting or not getting the interview. Know that your flight times will be carefully reviewed as the recruiter evaluates your application. At this point, your logbook should be in good order since it is the source of the information you provided on your application. But be prepared and expect to continue the flight time discussion during the interview. It is typical to talk about your flight time accounting with the flight operations recruiter. Being prepared and having a solid knowledge of what you have done will allow you to answer any question with confidence and clarity. And having one less thing to worry about will let you focus 100 percent on what is really important—the actual interview.

AIR, Inc. is dedicated to helping you succeed, so please let us know if you have additional questions about your flight times—ideally before you complete your applications. We can ensure you get and stay on the right track from start to finish.

Don’t let frustration keep you from winning the game. Your job is to learn and understand the rules so you can maximize your interview experience and land the job for which you have been working so hard to get.

Boiling Down the Definition

Here is a quick rundown of PIC/SIC/student questions asked over the years:
Simulator time: This is never flight time. It satisfies flight time experience requirements for some FAA ratings, but it is not flight time.
Solo time in a fighter jet, but under constant supervision of your IP on your wing: Part 1 and Part 61.51 PIC time. While your IP is the one who is ultimately in charge of your training sortie, you are the sole occupant of a high performance aircraft.
Time serving as aircraft commander on a long mission while resting outside of the flight deck: PIC time. Use the definition in FAR Part 1. You are responsible for the conduct of the flight, even while absent from the flight deck.
International Relief Pilot: PIC under FAR Part 61.51 only. Even though you have the type rating and relieve the primary PIC during a given flight, your name is not registered on the dispatch as the designated PIC. Thus, you would not be able to log this as Part 121 PIC, only PIC under Part 61.51.
Time serving as first officer on a long mission or flight while resting outside of the flight deck: Not to be logged as flight time. There is no “definition” for SIC in section one. FAR Part 61.51 states that SIC may be logged only when the pilot “…occupies a crewmember station in an aircraft that requires more than one pilot…”
Instruction time in the military (IP) or as a civilian (CFI): This time satisfies the PIC requirements under FAR Part 1. Be sure you separate this time from your Part 61.51 PIC time on the applications.
Evaluator Time: This is a very sticky area. Generally, the argument can be made that evaluation is an instructor’s function. Therefore, the time should be logged the same as other instructional flights. Of course, the evaluator must be rated and current in the aircraft, which means non-pilot instrument evaluators cannot log flight time.
Time serving as first officer in an aircraft in which you possess a type rating: Log the time that you were flying as PIC under FAR Part 61.51. The sole manipulator rule applies to recreational, private, and commercial pilots. Remember to keep this time separate from your FAR Part 1 time, as most airlines will not be interested in this time as PIC.
Flight Engineer Time: This is not flight time. Keep records in your logbook, however, and carefully read the application. Many ask for your FE time.
Time serving as SIC on an aircraft that normally does not require two pilots, but our charter company provides a first officer by contract to certain customers: Usually SIC time. Normally, when an airline provides this service, it is referenced in the Operations Specifications and/or in the Operators Manual. These documents are approved by the FAA, and become regulatory. FAR Part 61 states that a pilot may log SIC when he or she holds the appropriate category, class, and instrument rating for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulation under which the flight is being conducted.
Time shared with a buddy who owns a light twin-engine aircraft: Part 61.51 PIC when you are flying the aircraft (including manipulating the autopilot). Otherwise it is not flight time. If you are a certified flight instructor and your buddy has authorized you to provide flight instruction, then you can log the entire flight as Part 1 PIC.