Clearing The Air On Logging PIC Time
by Bob Black
AIR, Inc. Military Correspondent
Reprinted from the Airline Pilot Job Monthly Newsletter
AIR, Inc. counselors handle dozens of calls each week from military pilots confused about transferring military flight time to airline job applications. Due to the increased number of questions we receive about flight time and in particular the logging of Pilot-in-Command (PIC) time, we felt it was time to devote an article to this issue. What we came up with will negate some of the old ideas in logging flight time which we have suggested throughout our publications. We are now recommending that you use this article as the new guideline for documenting flight time for the purpose of your resumes and employment applications.
Some of the common questions which are being asked include: Exactly when is a military pilot allowed to log PIC time? Will the airlines give pilots full credit for the PIC time they log? What about instructor time?
We'd all like to maximize the pilot-in-command time we record in our log books and take to our interviews, but when we try to define PIC time, we run into the source of all this confusion: both the definition and intent of PIC time differ between the FAA, military, and the airlines. Let's take a look at the differences. Unfortunately, the airlines generally adhere to the strictest interpretation of the logging of actual PIC time. We'll start with the FAA.
FAR Part 61:51 deals with pilot logbooks and cites the instances in which pilots can log pilot-in-command flight time. These are:
1.only that flight time during which [the] pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, OR
2.when the pilot is the sole occupant of the aircraft, OR
3.when acting as pilot-in-command of an aircraft on which more than one pilot is required (by type certification or flight regulations).
Additionally, airline transport pilots and certificated instructor pilots may log as pilot-in-command time that flight time during which they act as a pilot-in-command or instructor, respectively.
Note the FAA's intent in defining pilot-in-command time, and in requiring pilots to record PIC in their logbooks, is to allow pilots to document aeronautical training and experience used to obtain specific certificates or ratings. For instance, airmen need 100 hours of pilot-in-command time to obtain a Commercial certificate, and 250 hours PIC for the Airline Transport Pilot certificate. Such flight time must be logged and presented as evidence in qualifying for these certificates.
The FAA never set our to establish or document airline hiring criteria.
Remember the five specific instances in which FAR Part 61:51 allows pilots to log PIC time: as sole manipulator of the controls, as sole aircraft occupant, when acting as pilot-in-command of a mandated multi-pilot aircraft, as an ATP acting as pilot-in-command, or as an instructor when giving instruction. This section of the FAR's seems to allow for the possibility that two pilots in the same aircraft can be logging PIC time simultaneously. Example: a commuter captain (the designated PIC) monitoring the radios while his copilot flies the airplane (sole manipulator of the controls).
Many military pilots have used this situation to record PIC time while flying as a copilot. In fact, it's quite common to find copilots logging half or more of their flight time as PIC, and FAR Part 61:51 allows it! Let's take a look now at how the military addresses the question of PIC time.
The Air Force, Navy and Marines divide flight time into these categories:
1.Primary (USAF) or First Pilot (USN, USMC) time, which designates hands-on flight time during which the pilot is actively controlling the aircraft. This matches the FAA's "sole manipulator" definition of PIC.
2.Secondary (USAF) or Copilot (USN, USMC) time, during which the pilot is assisting the other pilot actually flying the aircraft. The FAA calls this second-in-command time.
Neither of these categories applies to crew specialty rank, or designation as pilot-in-command. In other words, a C-141 aircraft commander logs Primary time when he is flying the airplane, and Secondary time when his copilot flies. In actual practice, most military pilots in large multi-pilot aircraft split Primary and Secondary (or First Pilot and Copilot) flight time evenly between the two crew members, regardless of who actually did the flying.
(Army aviators: your military flight time designators, such as PI, PC, IE, MP, etc. are much more crew-specialty specific. Be sure your personal logbook reflects hands-on-flight time, and not just your crew position.)
Keeping in mind the FAA's "sole manipulator" definition of PIC, military pilots are justified in logging Primary or First Pilot time as PIC, even before they've upgraded to aircraft commander status. Using the FAA's "pilot-in-command" definition, designated aircraft commanders are also justified in logging both Primary and Secondary time as PIC. Finally, FAR Part 61:51 allows designated military instructor pilots to log all instruction time as PIC, even if they don't sit at the controls.
The good news here is the FAA seems to be letting an awful lot of PIC time build up in the logbooks of our nation's military pilots. Almost everybody gets to log some time as PIC -- copilots, first pilots aircraft commanders, instructors, etc.
The bad news is, the airlines aren't buying it. Let us explain.
In most cases, when the airlines talk about PIC flight time, what they really mean is
captain flight time, the kind you get when you sit in the left seat, sign for the aircraft, make all the final decisions and wear four bars on your shoulder. In FAA parlance this is "designated pilot-in-command" time, and the military calls it "aircraft commander" time. This definition of PIC refers to who you are in the cockpit, not what you're doing with the controls.
Some airline applications are very clear about this when asking you to list your PIC and SIC hours. Look at UPS' and TWA's application and you'll see they define PIC as quoted from FAR 61:51.
United Airlines' application states: "PIC means you were totally responsible for aircraft and crew." Alaska's States "PIC means designated 'In Command' in flight". America West's flight time grid has separate headings for
Captain and
First Officer with the added instruction that Captain time is when you were assigned and designated PIC by the operator or owner of the airplane. American Airline's headings are
Aircraft Commander, Captain or PIC, and
Copilot. Clearly, these airlines are not using the "sole manipulator" criteria from FAR Part 61 to define PIC time.
Other airline applications are more ambiguous. FedEx and Northwest simply ask for PIC and SIC. Southwest Airlines uses familiar Navy terms: "
1st Pilot" and "
Copilot." With so many definitions and usages floating around, it's hardly surprising that so many pilots are confused when trying to reconcile their military flight records, pilot logbooks, and airline job applications. If they're concerned about discrepancies, they should be; no pilot wants to get in the hot seat at an interview while trying to explain why his flying hours don't seem to add up. Perhaps in the future the interested parties -- the FAA, the military services and the airlines -- can agree on common terms and definitions for logging flight time and experience. In the meantime, here are some suggestions.
Keep a master pilot logbook that reflects the FAA's allowed usage's of pilot-in-command flight time. Enter your flight time in the appropriate PIC, SIC, or Other columns as determined by your military branch's designations of Primary, Secondary, First Pilot, Copilot, Instructor, etc. In addition, annotate in the remarks column your status as designated aircraft commander, copilot, first pilot, etc., for that flight.
Evaluate the allowed PIC or SIC criteria as defined on the application of the individual airline you're applying to. Again, most airlines intend for you to log PIC time for only those flights on which you were the designated pilot-in-command, regardless of who actually flew the airplane. AIR, Inc. members can contact our counselors or the airline recruiting office if you have questions regarding a specific airline.
List your PIC and SIC time on the application based on the airline's definition of these terms. This may result in different totals for different airlines, or differences between a given application, your military fight records, and your pilot logbook. If questioned about these differences during an interview, simply indicate you followed guidance in FAR Part 61:51 for logging flight time, but used the airline's own criteria for completing the application. It should be noted, however, that you could drive yourself crazy trying to conform to each and every airlines' different way of doing things. You don't have much choice for the employment application, but for your resumes we suggest that you prepare only one resume using the most conservative criteria for listing flight times.
(Pay particular attention to Instructor categories. This is another area where the FAR's allow more than one pilot to log PIC time simultaneously, but the airlines may ask you to separate your instructor flight time from the rest of your PIC time. If so, subtract your instructor hours from PIC time, but don't panic! You're getting credit for all of it. Double-check your flight time totals. If your category totals add up to more than you really have, you've made a mistake somewhere.)
For some of you, this will result in a shocking reduction in the amount of PIC time you thought you were going to get credit for. What the FAA giveth, the airline taketh away. Before you lose hope, however, remember this: as a seasoned military aviator, you are a known quantity at an airline interview. If your career has progressed normally from copilot to aircraft commander and, perhaps, on to instructor and evaluator, you are competitive in today's job market. The airlines know who you are, and they're looking for you. The loss of a few hundred hours of PIC time logged as a copilot will not significantly reduce your standing in the job race.
We've looked at how three key entities -- the FAA, the military and the airlines-- differ in their definitions for important categories of flight time. Two standards, those of the FAA and the military, are easily reconciled, and can be logged quite compatibly. A third, the "designated pilot-in-command" standard used by the airlines, requires some closer scrutiny, and a change in the way you transfer information from your logbook to an airline application. Using the steps outlined, you should be able to present accurate information to your prospective employer, backed up with military fight records and a correctly annotated FAA-approved logbook.
Editors note: Some of the issues pertaining to the logging of PIC time presented in this article also have a civilian application. According to the FAR's it would seem that you can legally log PIC when you are sole manipulator of the controls. Keep in mind that as a first officer, when flying your leg of a trip, the company you are flying for gives you credit towards PIC time for preparation towards your eventual upgrade. However, the airlines you are applying to will not count this time as actual PIC since you haven't been checked out as PIC in that airplane. Many applicants have lost the interview battle trying to argue this point with the recruiter.
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