Two instrument rated pilots, one under hood, in IMC, both log PIC?

[Tantalum]

if the pilot can't see out the window, regardless of what's on the other side, you need a safety.

Negative Ghost Rider. I have flown plenty of times solo IFR IMC thick in the soup. I couldn't see out the window more than 10 ft and didn't have, or need, a safety

 

[Palmpilot]

So answer me this:

What purpose is your safety pilot doing if you're flying around in the clouds with your hood on?

I see three purposes:

1. Fulfilling the regulatory requirement to have a safety pilot;

2. It's often the case that an aircraft will be popping in and out of clouds, in which case the safety pilot will be needed to watch for traffic; and

3. I believe it's possible for traffic to be close enough to be seen even when you are in a cloud.

 

[Palmpilot]

not really an interpretation, that's what it says. If we push it to extremes it also says that if you're the only one on board a 737 you can log that time as pilot-in-command even if you're just a 75 he ASEL PPL

Go figure

"You're not in simulated instrument flight when you're wearing a hood in instrument flight conditions" is an interpretation. And it's one that the FAA is on record as disagreeing with.

 

[dmspilot]

Negative Ghost Rider. I have flown plenty of times solo IFR IMC thick in the soup. I couldn't see out the window more than 10 ft and didn't have, or need, a safety

Seeing out the window 10 feet is seeing out the window.

 

[jordane93]

Lol

 

[midlifeflyer]

Negative Ghost Rider. I have flown plenty of times solo IFR IMC thick in the soup. I couldn't see out the window more than 10 ft and didn't have, or need, a safety

How do you know you couldn't see 10 feet out the window?

 

[pburger]

Two instrument rated pilots, one under hood, in IMC, walk into a bar...

 

[dtuuri]

The spirit of the reg is to let people keep their instrument currency even if there are no instrument conditions present.. and the safety pilot is there to help keep visual separation from aircraft, technically they can only log the time if there was an agreement up front that they're acting anyway

Oh, you can forget the "spirit of the regulation". For that, you need to go back to the 1940s. Since the 1970s, it's been "the spirit of the interpretations" and consequent amendments. That spirit is to log whatever makes you happy.

 

[timwinters]

Two instrument rated pilots, one under hood, in IMC, walk into a bar...

The one on the left says:

"Please make a 'damn the weather' for me, my buddy to my right is a bit more intrepid, he's hoping you can make a 'sea breeze' for him.

And in trail behind us is a guy named @EdFred, he's mulling over some sort of a whacked out flow chart. After listening to him talk about our flying I'm confident that he wants you to make him a 'blow my skull off'."

 

[PilotRPI]

Can a guy in the back seat making jet noises log turbine time?

 

[Clip4]

You forgot "Pull the trigger".

He may have, the typing stopped.

 

[Lindberg]

How do you know you couldn't see 10 feet out the window?

Or, how do you know that in ten seconds, the cloud wouldn't open up and you'd find yourself face-to-face with a solo student practicing turns around a point?

 

[genna]

I'll probably regret it, but here it goes. If you are NOT on IFR flight plan and the pilot is under the hood, then safety pilot is required(to watch for traffic primarily). No question about that. If you ARE on IFR flight plan, then it doesn't matter if you are in IMC or VMC. You are under positive separation control of ATC and safety pilot is NOT required. It is questionable(and may be illegal) to be under the hood in these conditions(the pilot is responsible for see and avoid if in VMC). Also completely unnecessary for logging or otherwise.

I'm not citing any regs and I may be completely wrong, but this makes logical sense to me.

EDIT: Ok, i thought about this some more and I rescind my comment. IFR plan, VMC, need the safety pilot to log instrument time. So, never mind

 

[Palmpilot]

I'll probably regret it, but here it goes. If you are NOT on IFR flight plan and the pilot is under the hood, then safety pilot is required(to watch for traffic primarily). No question about that. If you ARE on IFR flight plan, then it doesn't matter if you are in IMC or VMC. You are under positive separation control of ATC and safety pilot is NOT required. It is questionable(and may be illegal) to be under the hood in these conditions. Also completely unnecessary for logging or otherwise.

I'm not citing any regs and I may be completely wrong, but this makes logical sense to me.

The problem is that the FAA expects us to log according to the regs, and the FAA's interpretations of the regs, not what makes logical sense. There are many FAA interpretations that make no logical sense to ordinary people, but appeals courts have ruled that Federal agency interpretations are legally binding.

In this case, 61.51(e)(1)(iii) says that a pilot may log pilot-in-command time "When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted." [emphasis added]

 

[midlifeflyer]

I'll probably regret it, but here it goes. If you are NOT on IFR flight plan and the pilot is under the hood, then safety pilot is required(to watch for traffic primarily). No question about that. If you ARE on IFR flight plan, then it doesn't matter if you are in IMC or VMC. You are under positive separation control of ATC and safety pilot is NOT required. It is questionable(and may be illegal) to be under the hood in these conditions(the pilot is responsible for see and avoid if in VMC). Also completely unnecessary for logging or otherwise.

I'm not citing any regs and I may be completely wrong, but this makes logical sense to me.

EDIT: Ok, i thought about this some more and I rescind my comment. IFR plan, VMC, need the safety pilot to log instrument time. So, never mind

Bottom line is that our see and avoid responsibilities do not change depending on whether we are VFR or IFR and they dont change depending on the weather.

That's an operating rule, not a logging rule.

One big incorrect assumption you are making is the separation service being provided under IFR. In basic class E airspace separation is provided only from other IFR traffic, not from any VFR traffic.

 

[Witmo]

You can have a safety pilot whenever you want to have a safety pilot. You must have a safety pilot when you are VMC and under the hood. IFR or VFR, doesn't make a difference. If you are VMC and under the hood, YOU HAVE TO HAVE A SAFETY PILOT--it's required. The non flying (safety) pilot can only log time when a second pilot is required. Is this really that difficult to understand?

 

[Tantalum]

How do you know you couldn't see 10 feet out the window?

Fussy crowd here. I could see about halfway down the Cirrus wing.. maybe to the end of the flaps? The wingspan is 38 ft.. the cabin is 4 ft, so 34 ft for the wings, divide by two, maybe 17 ft then?

Is your point that 17 ft qualifies as adequate visibility outside the plane, so my "safety" pilot can log the time? What if it was 200 ft? Is that adequate? 500 ft? The regs are not mysterious or confusing. To legally act as safety pilot you have to have reasonable adequate visibility outside the plane. Just because your buddy throws the foggles on in IMC doesn't mean that your friend can now log the time. And yes, I know you can be VFR and IMC, but the point is that if you are IMC your friend is going to be limited in his (or her) usefulness in traffic seperation

But why anyone would wear foggles in the clouds is beyond me, and what usefulness your safety can actually provide in that situation is dubious at best. But different strokes for different folks.. and ultimately anyone can write whatever they want in their logbook

Is this really that difficult to understand?

Welcome to PoA.. where the crowd is pedantic and will argue ridiculous points. Also favorite (and similarly moronic) topics are planes taking off on treadmills, debates on the Mooney backwards tails maintaining more control authority in high AoA environments, Cirrus pilots are idiots, real pilots don't need a parachute.. let's see, oh and California (sorry, Kalifornia) is universally panned here.. spraying cold water with a garden hose on a hot engine..

It's also what makes this place fun

 

[MauleSkinner]

The problem is that the FAA expects us to log according to the regs, and the FAA's interpretations of the regs, not what makes logical sense. There are many FAA interpretations that make no logical sense to ordinary people, but appeals courts have ruled that Federal agency interpretations are legally binding.

In this case, 61.51(e)(1)(iii) says that a pilot may log pilot-in-command time "When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted." [emphasis added]

And like the FAA, many pilots are all about PIC time in the logbook rather than quality experience.

 

[Tantalum]

That spirit is to log whatever makes you happy

lol nice

In this case, 61.51(e)(1)(iii) says that a pilot may log pilot-in-command time "When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted." [emphasis added]

this is correct, and that's the part people focus on.. but for the safety pilot to legally be able to LOG the time they must also have the whole adequate visibility thing.. my opinion (dude) is that if you are IMC by default your visibility outside the plane is compromised. So condition A is met (legally need two crew because you have view limiting device on) but condition B is not met (safety pilot adequate vis outside). You can still go along for the ride to help your buddy, but you shouldn't be logging that as PIC. See 91.109.c.2

But I digress. I thought in the morning and after having slept off a few glasses of wine my thoughts would have changed, but alas, they have not

 

[midlifeflyer]

Fussy crowd here. I could see about halfway down the Cirrus wing.. maybe to the end of the flaps? The wingspan is 38 ft.. the cabin is 4 ft, so 34 ft for the wings, divide by two, maybe 17 ft then?

Is your point that 17 ft qualifies as adequate visibility outside the plane,

No, my point is much simpler. You know how far you can see because you don't have a hood on.

But why anyone would wear foggles in the clouds is beyond me,

It's obviously beyond you. It might not be beyond others. I've know pilots who have gone up with a friend on a scattered to-broken-to-overcast day for practice. They might decide to leave the hood off the entire time, to get the important feel of going in and out; to leave it on all the time so they have some consistency while working on some aspect of the procedures; or to do some combination. It may not be the way you choose to do it but that's our choice. Something else is their choice.

But that's not the point. The point is, the reasons someone might or might not choose to wear a view limiting device while in the clouds is a completely different question than what rules apply if he or she chooses to do so. You seem to be mixing those two separate questions into one in the same way people mix acting as and logging PIC.

You are welcome to your thought. Others are welcome to theirs.

 

[Tantalum]

I've know pilots who have gone up with a friend on a scattered to-broken-to-overcast day for practice

Fair enough. Speaking of practice, the sensation of going in and out of clouds is to me the most troubling, so it's worth experiencing that.. toss the foggles on if you expect to break out before the FAF, but there's value in seeing the real world conditions punching in and out of clouds, especially in a climbing or descending turn. It's trippy!

Speaking of, I had a friend once on his first time solo in the clouds (fresh out of IR ticket) get a little freaked out in the clouds so he threw his foggles on. It was a psychological safety blanket and it helped him get on top without losing his cool

After that he took a friend anytime he was going in the clouds.. because admittedly wearing foggles alone in the plane, even if IMC, is not the best idea. But it worked for him that day

 

[Tantalum]

PS https://allaboutairplanes.wordpress.com/2011/08/27/logging-pic-sic-flowchart/

It's the "..and able to act as PIC" that you can't do if you don't have adequate vision outside the plane"

 

[midlifeflyer]

Fair enough. Speaking of practice, the sensation of going in and out of clouds is to me the most troubling, so it's worth experiencing that.. toss the foggles on if you expect to break out before the FAF, but there's value in seeing the real world conditions punching in and out of clouds, especially in a climbing or descending turn. It's trippy!

Speaking of, I had a friend once on his first time solo in the clouds (fresh out of IR ticket) get a little freaked out in the clouds so he threw his foggles on. It was a psychological safety blanket and it helped him get on top without losing his cool

After that he took a friend anytime he was going in the clouds.. because admittedly wearing foggles alone in the plane, even if IMC, is not the best idea. But it worked for him that day

I don't disagree at all.

 

[EdFred]

I love how that guy copied my flow chart and then copyrighted it. What a ****tool.

 

[EdFred]

PS https://allaboutairplanes.wordpress.com/2011/08/27/logging-pic-sic-flowchart/

It's the "..and able to act as PIC" that you can't do if you don't have adequate vision outside the plane"

View attachment 71266

Again where does it back your statement in the regs ?

It doesn't. If I chew bubble gum and wear a purple shirt, I can't log time either because the regs don't have a provision for logging PIC while chewing gum and wearing purple, if you want to use our premise of why you think you can't log PIC as a safety pilot.

All the regs cited in the are you able are currency, endorsements, etc...

 

[Lindberg]

After that he took a friend anytime he was going in the clouds.. because admittedly wearing foggles alone in the plane, even if IMC, is not the best idea.

Not the best idea, and a violation of the regs.

 

[Tantalum]

If I chew bubble gum and wear a purple shirt, I can't log time either because the regs don't have a provision for logging PIC while chewing gum and wearing purple, if you want to use our premise of why you think you can't log PIC as a safety pilot

Sure, but, if the regs said you had to wear purple to log PIC as safety pilot and you wore green you couldn't technically log it.. in this case purple shirt = adequate vis outside

"In order to act as safety pilot you must have adequate vision out the plane" is written in there. Now what "adequate vision" entails.. that's up for debate. 6 inches, 1 mile, 5 miles.. ? My conjecture is that if you are in IMC (whether IFR or VFR) by default you don't have adequate vision to aid in the safety of the flight, etc. I do agree that people shouldn't be wearing foggles alone, period. And if you aren't comfortable in the clouds, etc., always smart to bring a buddy along. But it is funny the lengths people will go to add every little PIC time they can into their log books.. even though safety piloting really won't get you any landings, XC time, etc.

But at the end of the day it's really not that important to me.. (even though I know it looks that way). People can write whatever they want in their logbooks

Oddly enough I did ask 3 different CFIs about this, and I got 3 different answers. One CFI is brand new (600 hrs total?) one is old and seasoned (7K hours), and the other I have no idea hours but his day job is flying commercial jets.

One said no, can't log if in the clouds
One said yes, because you are required since your buddy is foggled
The other gave some cockamamie answer that I couldn't follow

Tangentially, the whole "sole manipulator of controls" is interesting too.. back in the days of flight engineers, did those guys get to log any time?

 

[Tantalum]

Not the best idea, and a violation of the regs

I completely agree. When he retold the story to me I got the impression he was on the verge of a total panic attack, and the foggles helped him out, psychological safety blanket, and probably kept his attention in the plane. But he never did that again!!

 

[EdFred]

Adequate means that there's nothing inside the plane blocking your view to see outside the plane. For example you can't throw a blanket over the guy's head next to you as a view limiting device because then you are blocked from seeing out the pilot side window. Whether you only see the tip of the wing or Mount Rainier from 100 miles away doesn't matter. You just have to have to have a view to the outside the aircraft.

 

[Palmpilot]

And like the FAA, many pilots are all about PIC time in the logbook rather than quality experience.

There's also the issue that a pilot on BasicMed can be a safety pilot only when designated as the pilot in command (as defined in 14 CFR 1.1).

 

[Palmpilot]

So condition A is met (legally need two crew because you have view limiting device on) but condition B is not met (safety pilot adequate vis outside). You can still go along for the ride to help your buddy, but you shouldn't be logging that as PIC. See 91.109.c.2

If you think 91.109(c)(2) is referring to weather conditions, then please explain why it provides the alternative of having an observer in the aircraft supplementing the safety pilot's vision. In instrument weather conditions, that would accomplish exactly nothing.

"(2) The safety pilot has adequate vision forward and to each side of the aircraft, or a competent observer in the aircraft adequately supplements the vision of the safety pilot;"​

There's also the issue that 91.109(c)(1) says that you need a safety pilot in simulated instrument flight, and as mentioned earlier in the thread, the FAA has put it in writing that "simulated instrument conditions" occur when the pilot's vision outside of the aircraft is intentionally restricted, such as by a hood or goggles. Your belief that you can't have a safety pilot in instrument flight conditions conflicts with 91.109(c)(1)'s requirement that you have one when you're wearing a hood.

 

[eman1200]

PS https://allaboutairplanes.wordpress.com/2011/08/27/logging-pic-sic-flowchart/

View attachment 71266

this is SO much better than edfred's

 

[midlifeflyer]

this is SO much better than edfred's

...and with a big error (or at least a misleading statement) too (mentioned in another thread).

 

[midlifeflyer]

PS https://allaboutairplanes.wordpress.com/2011/08/27/logging-pic-sic-flowchart/

It's the "..and able to act as PIC" that you can't do if you don't have adequate vision outside the plane"

View attachment 71266

To the extent it is correct, "able" refers to the pilot's qualifications.

 

[dmspilot]

but for the safety pilot to legally be able to LOG the time they must also have the whole adequate visibility thing.. my opinion (dude) is that if you are IMC by default your visibility outside the plane is compromised. So condition A is met (legally need two crew because you have view limiting device on)

Oops, no no no no no. Stop.

Having a safety pilot with adequate vision is a requirement for performing simulated instrument flight, not for "logging flight time". You apparently don't realize it, but you are saying that one is not allowed to wear a hood or foggles in IMC.

91.109(c): "No person may operate a civil aircraft in simulated instrument flight unless..."

Your opinion, dude, is a logical fallacy. You can't say "if you're wearing foggles, and it's IMC, then the safety pilot can't log flight time because he doesn't have adequate visbility". If the safety pilot doesn't have adequate vision, you can't wear foggles, as you would be in violation of 91.109(c).

Do you want to make the point that it's illegal to wear foggles in IMC? Because that's what you're doing. Otherwise your argument is logically nonsense.

 

[Tantalum]

Do you want to make the point that it's illegal to wear foggles in IMC? Because that's what you're doing. Otherwise your argument is logically nonsense.

The point everyone here seems to be making is that you can "spoof" the system by putting foggles on in actual IMC conditions to create "simulated" IMC conditions which carry different legal requirements than actual conditions. Is that what people here seem to think?

Because if yes, then several pilots here are basically arguing that you can avoid all the legal requirements that come with actual instrument conditions and just throw the foggles on and say "no Mr FAA, I am not instrument rated and did not file an IFR flight plan, but it wasn't actual, it was simulated since I had my foggles on and had my safety pilot with me" <- good luck arguing that

??

At the end of the day - "actual" conditions do not require more than one crew members, simulated conditions do. But you can't just create simulated conditions (even though you are in actual) simply by putting the foggles on. The aircraft is already operating by sole reference to instruments in actual conditions. A piece of plastic further blocking your view doesn't change the whole legal status of the plane and flight

Plus, if we just think in reasonable human terms: The deeper reasoning behind WHY a safety pilot is required under *simulated* conditions is pretty self explanatory, but the assumption is that you are VMC and VFR so your safety pilot is there to help spot traffic, etc. When I am up with my buddy and ATC says "734NK, traffic 2 o'clock, 3 miles, 4,500" the safety pilot can look for it. And yes, see and avoid traffic is always a responsibility of the PIC, even IFR, however when you are in actual conditions the safety pilot can't actually help do that either.. his view outside the aircraft is also obstructed just like the safety's, so he's useless, and hence unnecessary as a crew member. When I get traffic callouts in IMC I simply say "negative contact, IMC"

I'm out. But if we really have swaths of pilots out there flying around in the clouds with foggles on thinking that changes the legal status of the flight then that's worrisome

 

[EdFred]

Because if yes, then several pilots here are basically arguing that you can avoid all the legal requirements that come with actual instrument conditions and just throw the foggles on and say "no Mr FAA, I am not instrument rated and did not file an IFR flight plan, but it wasn't actual, it was simulated since I had my foggles on and had my safety pilot with me" <- good luck arguing that

Wrongo!

Do not pass go. Do not collect 200 dollars. Someone still needs to meet all the requirements of an acting PIC. In the case of being in and around clouds, instrument rated, instrument currency, etc...

How you made the jump to no one needs an Instrument Rating is beyond me.

 

[Tantalum]

Someone still needs to meet all the requirements of an acting PIC

Right.. so you acknowledge that the conditions are "actual" and hence require an acting PIC who is appropriately rated, and all that jazz, *and* more importantly, since you are in "actual" conditions the regs do not require a second crew member... <-that was my point with the whole thing. Putting a foggle on doesn't magically make you now "simulated" and change the rules of the flight if you are actually in actual

How you made the jump to no one needs an Instrument Rating is beyond me

my attempt at a reductio ad absurdium. There seems to be an impression here that putting the goggles on creates simulated conditions (even when in actual) and people here are being cafeteria pilots choosing which regs suits the narrative they're looking to tell

-Actual, no safety required, so you're buddy sitting next to you can't log the time, and you shouldn't be wearing foggles
-VMC, but you need to get current, practice, build hours for rating, whatever, then throw the foggles on but bring your safety pilot friend who can log the time. If you poke through a few clouds while doing this you log that as actual

It's pretty simple. The whole "I'm wearing foggles in the cloud" thing is absurd in its very premise, so it's no real surprise that there isn't an FAR that discusses wearing foggles when in actual

 

[midlifeflyer]

The point everyone here seems to be making is that you can "spoof" the system by putting foggles on in actual IMC conditions to create "simulated" IMC conditions which carry different legal requirements than actual conditions. Is that what people here seem to think?

No. I think it's the opposite. You seem to think following the rules is spoofing them and would prefer people follow your rules and allow you to make their decisions.

Now, if your objection is that the existing rule is subject to abuse, I agree with you. You apparently don't, but I do I see a difference between a pilot who chooses to don the hood even in actual because it meets a perceived proficiency need on the one hand, and some hypothetical pair of pilots who fly every single one of 50 flights in actual conditions with one of them under the hood for the sole purpose of allowing both to build PIC time. If you want to say the latter guys are spoofing or abusing the rule, I'd probably agree with you (It's arguably impossible to police, but so is any safety pilot time).

But that's true of a lot of other rules as well. The student pilot who does 20 touch & goes when getting back home in order to build an extra hour on his solo cross country is arguably abusing the way the FAA permits us to count cross country time. But it doesn't mean the student pilot who reaches his destination and does a few extra, plus a go-around, because she or her CFI thinks learning how to choose landmarks for a traffic pattern at a strange airport has a training benefit, is "spoofing" the rules. Two CFIs who give each other 200 hours of multi dual so they can both log it as multi PIC time (a real case) are arguably abusing the rule which allows instructors to log PIC when acting as an authorized instructor. But CFIs, just like real people, are ultimately just pilots and require recurrent training as well. Are you suggesting CFIs shouldn't be allowed to have any dual because it can be abused in that way?

 

[Tantalum]

some hypothetical pair of pilots who fly every single one of 50 flights in actual conditions with one of them under the hood for the sole purpose of allowing both to build PIC time. If you want to say the latter guys are spoofing or abusing the rule, I'd probably agree with you

Thanks for the pragmatic reply and appreciating the context of my position. Obviously if the regs were written such to prevent any abuse and detail every possible scenario then it would be prohibitively large, but the way the OP posed the question, at least to me, seemed to allude to the spoofing situation you described. They both build the time with this loophole (if we want to call it that) of wearing a hood in actual conditions.. the fact that the OP said "both instrument rated" seemed to acknowledge to me this desire to indicate "yes I know it's actual, and we're rated, but we both want to log time, can one of us wear the hood to do that?"

Are you suggesting CFIs shouldn't be allowed to have any dual because it can be abused in that way?

haha nope, not at all. And funny, when I was reading online forums of how many people could theoretically log PIC someone came up with 6.. it involved a safety pilot, a hooded pilot, two CFI's, and I think they even threw a DPE in there, actual conditions, and one IR pilot. Clearly it was in jest, but somehow the connections were made