Beech 350 SIC

Greg Bockelman

Touchdown! Greaser!
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Greg Bockelman
Just when I think I have a handle on these things...

The Beech 350 is an airplane that requires a type rating, due to the fact that it weighs in over 12,500 pounds. However it is certified as a single pilot airplane, therefore no SIC required by type certificate.

However, while rehashing the Logging vs Acting as PIC and Safety pilot issues, a scenario came up that I can't resolve in my mind.

91.109(b) states in part:

(b) No person may operate a civil aircraft in simulated instrument flight unless—

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

It does not mention anything about type ratings. So, two questions.

Can a private pilot with a multi engine land rating act as a safety pilot on a Beech 350 without a type rating?

Can that same pilot log the safety pilot time as SIC?

If I take the regulation at face value, I would say the answer to both is "Yes".

Am I missing anything?
 
J
Can that same pilot log the safety pilot time as SIC?

I don't think you can log SIC in any airplane unless it type certificate requires SIC or type of operations requires SIC. However; I believe in this scenario safety pilot can log TT.
 
I don't think you can log SIC in any airplane unless it type certificate requires SIC or type of operations requires SIC. However; I believe in this scenario safety pilot can log TT.
I think the safety pilot can log both TT and SIC. You can log SIC as a safety pilot in many airplanes that do not require two pilots by type certificate. In fact that is the normal state of things in the small airplane world.
 
Can a private pilot with a multi engine land rating act as a safety pilot on a Beech 350 without a type rating?
Yes. First, type ratings are only required for the PIC in the USA. Second, 91.109(b) states that only the category/class ratings are required for a safety pilot; type rating is not listed, so it's not required.
Can that same pilot log the safety pilot time as SIC?
Yes. 61.55(f) exempts SIC's acting only as a 91.109(b) safety pilot from the usual SIC familiarization/currency rules in 61.55. So...
If I take the regulation at face value, I would say the answer to both is "Yes".
...you would be correct.
Am I missing anything?
No.
 
I don't think you can log SIC in any airplane unless it type certificate requires SIC or type of operations requires SIC.
That is correct. However, since 91.109(b) requires a second pilot, you can log it as SIC time per 61.51(f)(2).
 
I don't think you can log SIC in any airplane unless it type certificate requires SIC or type of operations requires SIC. However; I believe in this scenario safety pilot can log TT.
Safety pilot is required - safety pilot can log SIC.
 
That is correct. However, since 91.109(b) requires a second pilot, you can log it as SIC time per 61.51(f)(2).


"Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted."

Does instrument proficiency flight with safety pilot qualify for "regulation under which the flight is being conducted"?
 
"Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted."
Right -- 61.51(f)(2).
Does instrument proficiency flight with safety pilot qualify for "regulation under which the flight is being conducted"?
No. What makes the safety pilot required is that the pilot flying is using a vision restricting device (simulated instrument flight) and 91.109(b) says a safety pilot required in that case. The fact that the flight is for instrument proficiency is irrelevant. If the pilot flying is hooded, the safety pilot is required and may log the time. If the pilot flying is not hooded, the safety pilot is not required and may not log the time on that basis.
 
According to a FIRC instructor last week, the expected overhaul of Part 61 should remove such questions. Logging PIC simply as the sole manipulator and without the specific rating otherwise required will go by the wayside.
 
According to a FIRC instructor last week, the expected overhaul of Part 61 should remove such questions. Logging PIC simply as the sole manipulator and without the specific rating otherwise required will go by the wayside.
Unless they've rewritten those rules since the NPRM was published, and that FIRC Instructor is part of the rules committee and is leaking information without authorization, that instructor is speaking without knowledge. Here's what was proposed for that paragraph:
(e) Logging pilot in command flight time. (1) A recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights--
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges;
(ii) When the pilot is the sole occupant in the aircraft;
(iii) When the pilot, except for a recreational pilot, 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; or
(iv) When the pilot performs the duties of pilot in command while under the supervision of a qualified pilot in command provided--
(A) The pilot performing the duties of pilot in command holds a current and valid commercial or airline transport pilot certificate and aircraft rating that is appropriate to the category and class of aircraft being flown, if a class rating is appropriate;
(B ) The pilot performing the duties of pilot in command is undergoing an approved pilot in command training program that includes ground and flight training on the following areas of operation--

(1) Preflight preparation;
(2) Preflight procedures;
(3) Takeoff and departure;
(4) In-flight maneuvers;
(5) Instrument procedures;
(6) Landings and approaches to landings;
(7) Normal and abnormal procedures;
(8) Emergency procedures; and
(9) Postflight procedures;
(C) The supervising pilot in command holds a--
(1) Current and valid commercial pilot certificate and flight instructor certificate, and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; or
(2) Current and valid airline transport pilot certificate and aircraft rating that is appropriate to the category, class, and type of aircraft being flown, if a class or type rating is required; and
(D) The supervising pilot in command logs the pilot in command training in the pilot's logbook, certifies the pilot in command training in the pilot's logbook, and attests to that certification with his or her signature, and flight instructor certificate number.
(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.
(3) A certificated flight instructor may log pilot in command time for all flight time while serving as the authorized instructor in an operation if the instructor is rated to act as pilot in command of that aircraft.
The only change is the addition of the new business about logging PIC time when performing PIC duties under supervision, and as far as I can tell, the only new thing that allows is for pilots without type ratings to log time in a type-rating aircraft when flying the plane. The rest of the reg remains the same.
 
Unless they've rewritten those rules since the NPRM was published, and that FIRC Instructor is part of the rules committee and is leaking information without authorization, that instructor is speaking without knowledge.
He's not part of the rules committee but apparently is close friends with someone who is. He didn't give details other than to say many of those things are to be addressed in the rewrite.

He had given us a link to a document on the site but I can't recall what it was as that note book is at work. The document included all proposed Part 61 changes at the time. I recall him saying it was mostly a couple years old and was not the final, written word and that a final version was due out later this month (November 2008). Whether that was to be an updated NPRM or a final rules, I'm not sure.
 
There has been no "updated NPRM," and I just checked the NPRM last night. Either someone's talking out of school (the rule-writers are prohibited from releasing anything after the comment period closes until the Final Rule is published) or someone is talking out of his...whatever.
 
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