What does performing the duties of PIC mean?

Flying an aircraft as the sole occupant while training is considered to be one of the riskiest conditions a student can be in while undergoing training. For some schools, it is considered to be so risky that they try to minimize the amount of time a student spends in an aircraft by themselves. For a commercial pilot certificate, a student can actually meet the aeronautical experience requirements for said certificate without ever flying solo (assuming they're already a private pilot).

Let's take a look at the regulations:

"...Ten hours of solo flight time in a single engine airplane or 10 hours of flight time performing the duties of pilot in command in a single engine airplane with an authorized instructor onboard..."

FAR §61.129(a)(4)
What we just read says that the student can choose to either fly ten hours solo or while performing the duties of pilot in command. Essentially, a pilot can perform the duties of pilot in command with an instructor onboard and substitute that ten hours for the otherwise needed solo flight time. This means the instructor is not supposed to teach during the flight.

Notice the "or"

This has been a touchy subject over the years, and remains so: Can you combine the 10 hours of solo/performing the duties of PIC time? Say, if you'd like to do 3 hours of solo flight time and 7 hours of performing the duties of PIC. According to the legal interpretation from Mr. Grannis in 2016, the answer is no.

"...The language of the requirement in §61.126(a)(4) is clear that a pilot must choose either to log the 10 hours as solo flight time or log the 10 hours as flight time performing the duties of pilot in command with an authorized instructor on board..."

Grannis (2016) FAA legal interpretation

What can the student log?

The student (not student pilot) will be able to log the following:
  • Total time
  • Conditional time (cross-country, day, night, etc.)
  • Pilot in command

  • It's important to note that the student cannot log solo (they're not the solo occupant) or dual instruction received (the instructor is passive).

    What does it mean for the instructor?

    It's important to note that the instructor is not performing their instructional role, which means the student does not log dual instruction received in their logbook, and the instructor will therefore not be putting the flight down as dual given. Both parties will be able to log the entire flight as pilot in command, as both are rated in the category and class with an instructor onboard. I know, it's confusing. Refer to Mr. Kuhn (2014) FAA Legal interpretation.

    I hope this information will help any students and instructors that are confused my this little segment of the FARs. Performing the duties of pilot in command and its role in flight training is often misunderstood, resulting in frustrating rescheduling with DPEs and unnecessary additional spending on flight time. Please note these rules also are applicable to other certificates, such as rotorcraft.