The FAA interpretation that prompted this column addresses an interesting question, and in doing so focuses on the difference between logging PIC time and acting as PIC. The situation presented to the FAA was that of a private pilot with an airplane single-engine land rating who is receiving training in a complex or high-performance airplane specifically for the purpose of complying with these additional training requirements. The question is: May the pilot log the training time as pilot in command even though the pilot does not yet meet the requirements of FAR 61.31(e) or (f)? The FAA answered the question, "Yes," such a pilot may log the training time as PIC during the time that he or she is the sole manipulator of the controls.

In reaching this answer, the FAA referred to FAR 61.51(e), which governs the logging of pilot-in-command time. It says that a recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated. The term rated refers to the pilot holding the appropriate aircraft rating (category, class, and type, if a type rating is required). In the situation presented, the private pilot had an airplane single-engine land rating, and so may log the time as PIC.

The interpretation was careful to draw the distinction between acting as pilot in command and logging pilot-in-command time. This is a subtle distinction not always well understood in the pilot community, except among those involved in flight training. The FAA explained that in order to act as pilot in command (i.e., the pilot who has final authority and responsibility for the operation and safety of the flight), a person must not only be properly rated in the aircraft but must also be authorized to conduct the flight. In order to log PIC time, a person who is the sole manipulator of the controls only needs to be properly rated in the aircraft.

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A private or commercial pilot may log PIC time if that person is "the sole manipulator of the controls of an aircraft for which the pilot is rated" [61.51 (e)(1)(i)]
Thus a non-instrument rated pilot taking instrument flight instruction, if rated in the aircraft, may log PIC based on the "sole manipulator of the controls" rule. Since there is nothing in the rules that addresses meteorological conditions, the pilot may log PIC while in the clouds. This is supported by FAA chief counsel opinions [Federal Regulations Explained-Jeppesen].

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