I have spent most of my career in the military and just started flying for a civilian flight school, so I am still trying to learn some of the gray areas of the civilian world.

I am a CFI/CFII. An aircraft broke down and the maintainer needed to fly over. He needed me to fly with him (in a Cessna 172) since he did not have a medical. I was there making sure the flight went ok but he was the sole manipulator of the controls.

I assume for the flight, I am "acting PIC." Can I log that as PIC even though I did not touch the controls? It would not have to be dual received/given since I was not instructing, just me being there for safety?

It was only 0.4, it's not that I care about losing out on that 0.4, I am just curious and really like my logbook to be as accurate as it can be.


  • 1
    $\begingroup$ Look closer at 61.51(e)(1)(iii). Did your aircraft or operation require two pilots? $\endgroup$
    – StephenS
    Jun 10, 2021 at 2:32
  • $\begingroup$ The aircraft doesn't (C-172.) But he did need another pilot, in this case me, since he was not medically qualified. I've looked in the regs and did a lot of googling, I can't seem to find the answer. I would've thought this situation isn't super out of the ordinary, maybe I'm missing something obvious? $\endgroup$
    – Frank L
    Jun 10, 2021 at 3:10
  • 3
    $\begingroup$ I would say that for the purposes of the flight he was your student, you were PIC legally responsible for the flight, and you would log it all as PIC just as with any instructional flight. $\endgroup$
    – John K
    Jun 10, 2021 at 4:27
  • 1
    $\begingroup$ You were the only qualified pilot on the airplane. $\endgroup$
    – Raffles
    Jun 10, 2021 at 14:17

1 Answer 1


Short answer: no, you can't log it as PIC time. Remember that acting as PIC and logging PIC time are two completely different things.

I'm assuming here that the flight was VFR under part 91. The rules for logging PIC time are in 14 CFR 61.51(e). Simplified - and ignoring the ATP and student scenarios - the times you can log PIC are:

  1. Sole manipulator of the controls, if you're rated for the aircraft
  2. Sole occupant of the aircraft
  3. Acting PIC when more than one pilot is required by the aircraft's type certificate or the regulations for the operation
  4. Providing instruction

#1 doesn't apply because you didn't touch the controls. Neither does #2 because there were two people on board. #3 doesn't apply either: even though you were acting PIC, the C172's type certificate doesn't require more than one crewmember, and there's no regulation that requires more than one crewmember for VFR under part 91. As for #4, you said that you didn't provide instruction (which would include endorsing the other pilot's logbook to record the training).

I suspect you're getting a little distracted by the idea that you were there as a "safety pilot" but in the regulatory sense of 91.109(c)(1) that only applies to simulated instrument flight.

Assuming that the pilot who actually flew the C172 was rated to do so then they can log the time under reason #1 above. The regulations don't require you to have a medical to log PIC time.

  • $\begingroup$ Is the conclusion, then, that there can be flights for which no one can log the time? For instance, if a non-CFI pilot allows a non-pilot passenger to fly an entire flight (e.g. a parent helping a child to learn on days when the child's instructor isn't available), then the flight is therefore unloggable? $\endgroup$ Jun 10, 2021 at 15:04
  • $\begingroup$ @KennSebesta Yes, that's correct. The parent is acting PIC but can't log PIC time for the reasons I explained, and the child can't log it either because they aren't rated for the aircraft (even if they hold a student pilot certificate, students can only log PIC time when solo). As I mentioned, the key point is that acting as PIC and logging PIC time are two different things; acting as PIC doesn't automatically let you log PIC time. $\endgroup$
    – Pondlife
    Jun 10, 2021 at 16:01
  • $\begingroup$ I understand/accept your reasoning but it strikes me as odd to have a plane with unlogged flights. Maybe that's perfectly fine and appropriate, but in aviation where we have log books for everything down to the propeller, it's just so weird to think that there can be this legally required disconnect. Would the same apply to T/Os and LDGs? Could I legally have fewer T/Os than LDGs and vice versa? $\endgroup$ Jun 10, 2021 at 18:41
  • $\begingroup$ @KennSebesta I'm not sure where the disconnect is. Many private pilots don't log their flight time at all, because there's no need to and it doesn't benefit them in any way. Think of someone who's retired and flies their Cub for lunch nearby a few times a week. The FAA doesn't require pilots to log anything at all unless it's to get a new certificate or rating, or to document currency. $\endgroup$
    – Pondlife
    Jun 10, 2021 at 19:20

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