Herman interpretation and safety pilots

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airheadpenguin

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airheadpenguin
I was reading the Herman letter from 2009 today and it made me wonder if the flowing is legal:

An ASEL rated private pilot without complex is working on their instrument rating, a friend with a Mooney invites them on a trip. The student flies as sole manipulator and the owner is safety pilot and PIC.

The Herman letter seems to permit this since it s specifies that you do not need the proper endorsements to log PIC in connection with being sole manipulator and the FARs define three safety pilot as a required crew member.

Aside from the say pilot notation in three log what else would be required to stay on the right side of the FAA here

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Completely legal. Pilot 1 (no complex endorsement) is appropriately rated (Pvt ASEL) and the sole manipulator of the controls. Pilot 2 is acting as PIC.

The title of the thread caught my attention... :D
 
Hi Jason. Word from the professor back at the Univ. has it that you're doing well (!) :)

And penguin, you and Jason have got it completely correctly.
 
If the roles were reversed could I be safety pilot and log SIC without being properly endorsed?

The only benefit here is the SIC time would count towards the 250 total time for commercial

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airheadpenguin said:
I was reading the Herman letter from 2009 today and it made me wonder if the flowing is legal:

An ASEL rated private pilot without complex is working on their instrument rating, a friend with a Mooney invites them on a trip. The student flies as sole manipulator and the owner is safety pilot and PIC.

The Herman letter seems to permit this since it s specifies that you do not need the proper endorsements to log PIC in connection with being sole manipulator and the FARs define three safety pilot as a required crew member.

Aside from the say pilot notation in three log what else would be required to stay on the right side of the FAA here

Sent from my GT-P5113 using Tapatalk HD
Click to expand...

I'm a little confused here - is the non-complex endorsed pilot acting PIC or is the appropriately endorsed owner?

Assuming it's the latter, a "safety pilot" isn't relevant. If it's the former, are you saying the non-complex ASEL pilot can act PIC if there is a complex endorsed crewmember that can serve as a safety pilot?
 
Sac Arrow said:
I'm a little confused here - is the non-complex endorsed pilot acting PIC or is the appropriately endorsed owner?

Assuming it's the latter, a "safety pilot" isn't relevant. If it's the former, are you saying the non-complex ASEL pilot can act PIC if there is a complex endorsed crewmember that can serve as a safety pilot?
Click to expand...

The complex endorsed ASEL rated pilot IS PIC, the non-complex endorsed ASEL rated is logging PIC due to being the sole manipulator of the controls. This is due to the fact that there can be 2 people logging PIC (required crew of 2) in the event that one is safety pilot, and the other is under the hood, during VMC.

When flying with a safety pilot, they are acting PIC while I'm under the hood.

This seems like an interesting unintended corner case
 
airheadpenguin said:
If the roles were reversed could I be safety pilot and log SIC without being properly endorsed?
Click to expand...
If you read 61.31, 91.109(c), and 61.51(f)(2), you'll see those additional training endorsements are required only to act as PIC, not to act as safety pilot or log SIC while acting as non-PIC safety pilot.
 
HPNPilot1200 said:
Indeed! I am supposed to have lunch with the Grump later this week when I am in town for a visit. Hope he is not giving you too much of a hard time. :)
Click to expand...
Say hi!
The professor despite being "the Grump" is actually very very fond of you guys.....
 
If only there was a easy way to determine when you can log PIC.

Oh, wait....
 
So can I fly a complex high-performance airplane without an endorsement and still count the hours as PIC while the non-CFI owner acts as safety pilot PIC?
 
To answer your question simply: Yes.

Provided you have at least a PP-ASEL (ie. not a Student Pilot)
 
Since I don't have a complex endorsement, I'm curious how much of an end run this really is. How much time does it take to get a sign off?
 
A bit more of clarification here. If I am flying as safety pilot with a friend in VFR conditions while he is under the hood in his Bonanza. He has his complex endorsement and can act as PIC (BFR, medical etc). I do not have my complex endorsement. Can I legally act as safety pilot without an endorsement? If so, what can I log?
 
jsnapp said:
A bit more of clarification here. If I am flying as safety pilot with a friend in VFR conditions while he is under the hood in his Bonanza. He has his complex endorsement and can act as PIC (BFR, medical etc). I do not have my complex endorsement. Can I legally act as safety pilot without an endorsement? If so, what can I log?
Click to expand...

Assuming you hold a private certificate (ASEL) and have a medical, then you can act as safety pilot.

Since you're not capable of ACTING as PIC, you may act and log SIC time.
 
jsnapp said:
A bit more of clarification here. If I am flying as safety pilot with a friend in VFR conditions while he is under the hood in his Bonanza. He has his complex endorsement and can act as PIC (BFR, medical etc). I do not have my complex endorsement. Can I legally act as safety pilot without an endorsement?
Click to expand...
Yes. Once again -- the 61.31 additional training endorsements are required only to act as PIC.

If so, what can I log?
Click to expand...
SIC time, pilot time, and flight time.
 
TMetzinger said:
Assuming you hold a private certificate (ASEL) and have a medical, then you can act as safety pilot.
Click to expand...
Correct.
Since you're not capable of ACTING as PIC, you may act and log SIC time.
Click to expand...
Although you can log SIC time, you are not acting as SIC for this flight since the aircraft does not require two pilots and the operation does not require a "second in command" (as does most Part 121 flying). See the recently issued Beaty interpretation.
 
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