IFR Currency question ... a little different

RogerT

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RogerT
I have a friend who had heart surgery so can't get his medical back
for a few months. He's wanting to go with a CFI to do approaches and
stay current. FAA guy says he can't do that since he doesn't have a medical.
HUH????? What am I missing here? If he's not PIC what difference does
it make? Do you have to be legal PIC for the approaches to count?
Am I missing part of the story?
 
That's complete BS.

As long as he's not acting as PIC or a required crew member, he doesn't need a medical, and he can still log the approaches he performs.

Now, without the medical, he can't act as safety pilot for someone else, but if he wants to go up with a CFI or a safety pilot who can ACT as PIC while he flies, he's fine.

Which FSDO said this?
 
FAA guy, as is a lot of times the case, does not know what he is talking about.
 
That's all why I'm wondering if I'm missing part of the question or answer ..
especially given the experience and qualifications of the inspector involved.
It's almost like someone misunderstood someone.
 
That's all why I'm wondering if I'm missing part of the question or answer ..It's almost like someone misunderstood someone.
Yup. Someone needs to find out the rest of the story. Asking the "FAA guy" involved would be a good place to start.
 
Yup. Someone needs to find out the rest of the story. Asking the "FAA guy" involved would be a good place to start.

And maybe ask him specifically if he thinks it's permissible for a pilot sans medical to practice approaches (and log the practice) as long as there's a PIC qualified pilot and/or CFI sitting at a control station and acting as PIC. If his answer is negative ask him to provide the FAR reference that he's basing this (incorrect) opinion on.
 
What is his reason as to why he can't? Because ... he can :)
 
What is his reason as to why he can't? Because ... he can :)

Well I was a little puzzled .. I sure can't see a reason why not. I actually
have a similar situation. I don't have a medical. Since the Exp I built
fell under Light Sport I never renewed my medical. No problem that I know
of to get one .. just didn't hassle with it. I didn't have insurance
on it so I didn't want to put a CFI in it. When I did my BFR's I just did them
in the FBO's TC'd aircraft and made clear to the CFI he'd be the legal
PIC for the flight.

Now that I sold that one and bought a Sonex and have insurance on it
I'll just do it in mine.

RT
 
A PP with an instrument rating can practice approachs with a safety pilot, but can not log any of the time or approach's with a safety pilot. A medical is required to do this. However he can log the time with a CFI as dual received, but not as PIC. For the approach's to count the dual must be from a CFII (for the same reason a CFI can not do ICC's)who is rated in the aircraft used. However he still must log it as dual received, and can not log it as PIC. (once the medical is obtained the approach's would count for currency) A current medical is a requirement to excersize any privledges granted in a standard catagory GA aircraft as PIC. This would be no different than taking a BFR. You can complete a flight review without a medical, but can not excersize the privledges of your certificate without a medical.


Can you cite a source for this? A pilot w/o a medical cannot act as PIC, but can log PIC for time that he's the sole manipulator and can log all those approaches too. This is presuming that the Safety Pilot is current (PP/FR/Medical/Endorsements) to act as PIC.

After he gets his approaches in (presuming he was <6 mo out of currency) along with the holding and intercepting/tracking, he cannot accept an IFR clearance without a medical, but he absolutely can shoot approaches without a CFII, log them for currency, and log PIC time while doing it.
 
Hmmm... I'm confused. (It's easy)

How can he legally log PIC time if he cannot act as PIC legally?

Because acting as PIC is not a prerequisite for logging PIC time. They're two entirely separate concepts.
 
A PP with an instrument rating can practice approachs with a safety pilot, but can not log any of the time or approach's with a safety pilot. A medical is required to do this. However he can log the time with a CFI as dual received, but not as PIC. For the approach's to count the dual must be from a CFII (for the same reason a CFI can not do ICC's)who is rated in the aircraft used. However he still must log it as dual received, and can not log it as PIC. (once the medical is obtained the approach's would count for currency) A current medical is a requirement to excersize any privledges granted in a standard catagory GA aircraft as PIC. This would be no different than taking a BFR. You can complete a flight review without a medical, but can not excersize the privledges of your certificate without a medical.

REALLY? Please show in the FARs where a medical is required to log flight time. Please then write an essay on the difference between LOGGING PIC and ACTING as PIC.

By your logic, an instrument student couldn't log approaches or PIC time.

The only thing in your statement that I find correct is that instrument flight training requires a CFII certificate. No wait, I think that's wrong too. Training towards the instrument rating must be given by a CFII or IGI. Generic instrument training (such as the required hood work for the private), does not (I believe) require a CFII.

It's true that the in the case of a pilot flying with a safety pilot, at least one person must have a current medical. That person must be acting as PIC. So a safety pilot ACTING as PIC must be properly rated, current, and have a medical. The pilot under the hood in this case is NOT a required crew member and does not need a medical.

In the case of a pilot without a medical going up for instrument proficiency work with a current safety pilot, here's how to do it.

Safety Pilot ACTS as PIC. This is agreed upon before the flight.
Safety Pilot logs flight time and PIC for the time he's actually flying the airplane or acting as safety pilot.
Pilot doing the instrument proficiency work logs flight time and PIC and all the approaches because he was sole manipulator. He does not log the time he wasn't flying the airplane.

I think we got fixated on the fact that the safety pilot requires a medical (because he's a required crew member even when acting as SIC), and took that to mean both pilots need medicals. That's only true when the safety pilot is NOT ACTING as PIC.
 
Because acting as PIC is not a prerequisite for logging PIC time. They're two entirely separate concepts.

If they are different concepts, then different terms should be used. That's why we call cats, "cats", and dogs, "dogs."

I agree with you, Jeff -- I just think the confusion that surrounds this topic is understandable, yet unnecessary.
 
Dan, I think it's a shame the confusion exists when there are FAQs and counsel opinions that really do make it obvious that logging PIC != acting PIC.

Once that concept (logging is NOT equal to acting) is in your brain (and it should really be firmly in every instructor's brain), than it's simply a matter of looking in 61 to find the rule that addresses what you want to LOG.

Edit: This may sound like it's pointed at you, Dan, and for that I apologize - it's not my intention. I just can't (and I've tried) figure out a way to make it sound different. It's pointed at folks who are confused but are sure they are not.
 
If they are different concepts, then different terms should be used. That's why we call cats, "cats", and dogs, "dogs."

There are different terms: Acting PIC and Logging PIC. But I agree that it must be easy to confuse the two since so many pilots and CFIs do so. But the real issue here is that these two "terms" are controlled by to completely different regulations. Acting as PIC falls under several different part 61 rules depending on the aircraft, ratings, flight rules, etc. Logging PIC time is regulated by 61.51(e).

I agree with you, Jeff -- I just think the confusion that surrounds this topic is understandable, yet unnecessary.

No argument there. But I don't think the solution would be new terms for logging PIC or acting PIC, just an explanation of the difference somewhere like the AIM.
 
The only thing in your statement that I find correct is that instrument flight training requires a CFII certificate. No wait, I think that's wrong too. Training towards the instrument rating must be given by a CFII or IGI. Generic instrument training (such as the required hood work for the private), does not (I believe) require a CFII.
Because the hoodwork for PP is not "instrument flight training" (see 61.109), it may be given by a CFI without a CFI-I rating. Also, because it is not "instrument flight training," it doesn't count towards the 15 hours regardless of the qualifications of the instructor who gave it.
I think we got fixated on the fact that the safety pilot requires a medical (because he's a required crew member even when acting as SIC)
Legally, no. The safety pilot requires a medical because the safety pilot is exercising a Private Pilot privilege (see 91.109(b)) and thus must hold a medical valid at Third Class or higher (61.23(a)(3)(i)). The issue of whether or not the safety pilot is acting as PIC or SIC or neither is irrelevant.
 
(for the same reason a CFI can not do ICC's)
I would also note that the term "ICC" went out some 12 years ago. It's been an Instrument Proficiency Check (IPC) since 1997 and the rules covering IPC's are significantly different than those for the old Instrument Competency Check.
 
Legally, no. The safety pilot requires a medical because the safety pilot is exercising a Private Pilot privilege (see 91.109(b)) and thus must hold a medical valid at Third Class or higher (61.23(a)(3)(i)). The issue of whether or not the safety pilot is acting as PIC or SIC or neither is irrelevant.

Unless in a LSA eligible aircraft, I assume.
 
Legally, no. The safety pilot requires a medical because the safety pilot is exercising a Private Pilot privilege (see 91.109(b)) and thus must hold a medical valid at Third Class or higher (61.23(a)(3)(i)). The issue of whether or not the safety pilot is acting as PIC or SIC or neither is irrelevant.

You are, as nearly always, correct. I believe the way the FAA put it was that because a safety pilot is a required crewmember when another pilot is under the hood, he must have the medical. But that may have been an AOPA rewording.

Do you agree that the hooded pilot doesn't need a medical as long as he's not acting as PIC, and can log the time and approaches?
 
Unless in a LSA eligible aircraft, I assume.
Bad assumption. 91.109(b) does not have any exception for LSA's -- safety pilot still requires PP or better, and 61.23 says you need a medical to exercise those PP privileges in any airplane. If a Sport Pilot wants to get hood time, the person in the right seat must have a PP or better and hold a medical, even if the Sport Pilot flying the airplane is not required to have either.
 
You are, as nearly always, correct. I believe the way the FAA put it was that because a safety pilot is a required crewmember when another pilot is under the hood, he must have the medical. But that may have been an AOPA rewording.
I think so. The FAA said it was because the safety pilot was exercising PP privileges.
Do you agree that the hooded pilot doesn't need a medical as long as he's not acting as PIC, and can log the time and approaches?
Assuming two pilots aren't otherwise required (like in a DC-3), yes.
 
There are different terms: Acting PIC and Logging PIC. But I agree that it must be easy to confuse the two since so many pilots and CFIs do so. But the real issue here is that these two "terms" are controlled by to completely different regulations. Acting as PIC falls under several different part 61 rules depending on the aircraft, ratings, flight rules, etc. Logging PIC time is regulated by 61.51(e).



No argument there. But I don't think the solution would be new terms for logging PIC or acting PIC, just an explanation of the difference somewhere like the AIM.

Mr. Machado clears this up nicley
http://www.rodmachado.com/Articles/Logging_Flight_Time.htm

You may log pilot-in-command flight time when:
There are only three conditions in which a private or commercial pilot can log PIC time.
1. You are the sole manipulator of the controls of an aircraft for which you are rated (if you are flying a Cessna 172 and you have an airplane, single engine land rating, then you can log this time as PIC. Of course, some folks want to know if this still applies when the airplane is being flown by the autopilot. The answer to this question is: Don't ask that question and don't brag about using the autopilot, either. Just log the time as PIC and be happy.);
2. You are the sole occupant of the aircraft (if you are the only one in the airplane then there's a very good chance that you're the only one flying it, so log the time as PIC. How do you log this if you have a split personality? I suppose you'll need to get a twin rating);
3.You are acting as pilot in command on an aircraft on which more than one pilot is required under the type certification or the regulations under which the flight is conducted (this one needs a bit of explanation)
To understand item #3 you must understand the difference between logging PIC and acting as the PIC. Keep in mind that FAR 91.109(b)1 wisely requires that a safety pilot be on board if the person flying is operating under simulated instrument conditions. Yes, I think this is a good rule, too:). The regulations also require that one person on board the aircraft always act as PIC. This will be the person who is legally responsible for the operation of that aircraft. The person acting as the pilot in command can obviously log this time as PIC. On the other hand, the regulations also allow an additional person to log PIC if that person does something that generates experience of sufficient value. Here's an example.
Suppose you and a friend both have private pilot certificates with airplane, single-engine-land ratings. Let's also say that each of you is legally qualified to act as the legal PIC (meaning that you are both current, have current medicals, etc., etc.). Both of you hop into a Cessna 172 for a flight. Your friend wears a view-limiting device and is the sole manipulator of the flight controls while you act as the safety pilot.
In this instance, if your friend elects to act as the legal PIC as well as be the sole manipulator of the flight controls, then he alone logs the flight time as PIC while you log the time as second in command (SIC). [This is also the example where, if the airplane is either complex or high performance, and if you don't have a complex or high performance endorsement, then you can still act as safety pilot and log it as SIC since you're not acting as (the legal) PIC.]
On the other hand, you may elect to act as the safety pilot as well as the legal PIC while your friend is the sole manipulator of the controls. If so, then you can log the time as PIC and your friend can also log the time as PIC. Do you see why this is? Being the safety pilot doesn't mean you can automatically log the time as PIC. You must be willing to act as the legal PIC (as well as the safety pilot) to log this time as PIC. Since your friend is the sole manipulator of the controls, he gets to log PIC time as well. If anything goes wrong in this scenario, you're the one whose ticket will be on the line.
Here's another commonly asked question regarding the information above. Suppose you and the same friend go flying in that same Cessna 172 and no one wears a view-limiting device. Is there any situation where both of you log the time as PIC?
Sorry, but there's absolutely no way this can happen.
Yes, I realize that some folks suggest it's possible for both pilots to simultaneously log all the flight time as PIC here but the FAA doesn't seem to think so (and they are the folks who count in this instance). The only condition where these two pilots can log PIC is when one pilot is operating under simulated conditions as stated above. Under this condition the regulations require that two pilots be on board the airplane. There's no type certificate (or any condition, for that matter) that requires that two private or commercial pilots be on board a Cessna 172. When two private or commercial pilots are on board an aircraft and neither wears a view limiting device, only one pilot can log PIC at a time. This will be the pilot who is the sole manipulator of the flight controls.


Logging Flight Time
By Rod Machado
©2005 Rod Machado​
 
Bad assumption. 91.109(b) does not have any exception for LSA's -- safety pilot still requires PP or better, and 61.23 says you need a medical to exercise those PP privileges in any airplane. If a Sport Pilot wants to get hood time, the person in the right seat must have a PP or better and hold a medical, even if the Sport Pilot flying the airplane is not required to have either.

So, like, I can fly the airplane solo. I can act as PIC, I can log PIC, but I can't sit there and watch for traffic if someone else has a hood on?

Ya gotta wonder about the people who write these rules. :loco:
 
Dan, I think it's a shame the confusion exists when there are FAQs and counsel opinions that really do make it obvious that logging PIC != acting PIC.

Once that concept (logging is NOT equal to acting) is in your brain (and it should really be firmly in every instructor's brain), than it's simply a matter of looking in 61 to find the rule that addresses what you want to LOG.

Edit: This may sound like it's pointed at you, Dan, and for that I apologize - it's not my intention. I just can't (and I've tried) figure out a way to make it sound different. It's pointed at folks who are confused but are sure they are not.

No problem -- taken as intended. I think this thread is an example that the issue is clouded by nearly synonomous terms.

*I* know the difference between acting and logging, but I can't tell you a single PP I 've flown with that would do more than say "If I fly it, I log it."

:dunno:
 
So, like, I can fly the airplane solo. I can act as PIC, I can log PIC, but I can't sit there and watch for traffic if someone else has a hood on?
Yup.
Ya gotta wonder about the people who write these rules. :loco:
I think it's more a matter of unintended consequnces when they wrote the Sport Pilot rules that any true intent to require the safety pilot in an LSA to hold a PP ticket. 91.109 (which is where the PP requirement for safety pilots exists) is written by a different bunch of people than Part 61, so it may be just a lack of coordination/communication. Probably worth a suggestion to get it changed.
 
I think it's more a matter of unintended consequnces when they wrote the Sport Pilot rules that any true intent to require the safety pilot in an LSA to hold a PP ticket. 91.109 (which is where the PP requirement for safety pilots exists) is written by a different bunch of people than Part 61, so it may be just a lack of coordination/communication. Probably worth a suggestion to get it changed.

You are right (big surprise? NOT!) 91.109. Sez "at least PP".:frown3:

Looking at 61.315 (13) "Without visual reference to the surface" This suggests that I can't put a hood on either? That is less clear (at least to me).

Oh, well...
 
Looking at 61.315 (13) "Without visual reference to the surface" This suggests that I can't put a hood on either?
Hmmm...it might do. That would require the safety pilot to act as PIC while you have the hood on, but to be PIC of a LSA, you need only a Sport Pilot and DL, not a PP and medical certificate. I'll see what the FAA says in response to my query.
 
Yup.
I think it's more a matter of unintended consequnces when they wrote the Sport Pilot rules that any true intent to require the safety pilot in an LSA to hold a PP ticket. 91.109 (which is where the PP requirement for safety pilots exists) is written by a different bunch of people than Part 61, so it may be just a lack of coordination/communication. Probably worth a suggestion to get it changed.

So...here's a question for you...

If they change the Safety Pilot qual to being LSA+ vs. PP+, then you would still need a medical, albeit the Driver's License medical would suffice.

I've got a guy at work who has his PP, but it's been over a decade since he flew or held a medical. Obviously he hasn't done a flight review in the last 24 calendar months.

Could I use him as a Safety Pilot (not talking wisdom, just legality) if he had a DL?
 
So...here's a question for you...

If they change the Safety Pilot qual to being LSA+ vs. PP+, then you would still need a medical, albeit the Driver's License medical would suffice.

I've got a guy at work who has his PP, but it's been over a decade since he flew or held a medical. Obviously he hasn't done a flight review in the last 24 calendar months.

Could I use him as a Safety Pilot (not talking wisdom, just legality) if he had a DL?

In an LSA qualified airplane? As I understand it, the safety pilot needs to be able to act as PIC in any aircraft in which he's performing safety pilot duties. Think of it it this way. Could the safety pilot legally go up and make a similar flight by himself (minus the hood). If the answer is yes, then he can act as a safety pilot for you if you got in and put on a hood. This obviously doesn't account for the requirement that the safety pilot hold a PP or greater.
 
In an LSA qualified airplane? As I understand it, the safety pilot needs to be able to act as PIC in any aircraft in which he's performing safety pilot duties. Think of it it this way. Could the safety pilot legally go up and make a similar flight by himself (minus the hood). If the answer is yes, then he can act as a safety pilot for you if you got in and put on a hood. This obviously doesn't account for the requirement that the safety pilot hold a PP or greater.
Not quite. You need to be able to act as PIC in the same category and class.

If we were in an Arrow and I had the complex endorsement I could have a private pilot without a complex endorsement be my safety pilot. Although they could not be the legal PIC of the flight.
 
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Not quite. You need to be able to act as PIC in the same category and class.

If we were in an Archer and I had the complex endorsement I could have a private pilot without a complex endorsement be my safety pilot. Although they could not be the legal PIC of the flight.

I think you meant Arrow
 
If they change the Safety Pilot qual to being LSA+ vs. PP+, then you would still need a medical, albeit the Driver's License medical would suffice.
Obviously, that would depend on how they word the change (assuming they even make it), but if they were to change 91.109(b) to say that you only need a Sport Pilot certificate to act as safety pilot in a LSA, then you'd need either a medical or a DL to do that.
I've got a guy at work who has his PP, but it's been over a decade since he flew or held a medical. Obviously he hasn't done a flight review in the last 24 calendar months.

Could I use him as a Safety Pilot (not talking wisdom, just legality) if he had a DL?
If they were to change the rules as discussed, yes, in a LSA.
 
In an LSA qualified airplane? As I understand it, the safety pilot needs to be able to act as PIC in any aircraft in which he's performing safety pilot duties.
Not so. As long as the hooded pilot is qualfied to be and acting as the PIC, the safety pilot need only meet the basic 91.109(b)/61.23 requirements -- PP with applicable cat/class ratings and a medical valid at Third Class. That's it -- no flight review, no landing currency, no complex/HP, etc.
Think of it it this way. Could the safety pilot legally go up and make a similar flight by himself (minus the hood). If the answer is yes, then he can act as a safety pilot for you if you got in and put on a hood.
While that's true, he can still act as safety pilot without meeting those qualifications -- just not act as PIC while doing it.
 
Not quite. You need to be able to act as PIC in the same category and class.

If we were in an Arrow and I had the complex endorsement I could have a private pilot without a complex endorsement be my safety pilot. Although they could not be the legal PIC of the flight.

Right, I forgot about that part. Thanks for catching that.
 
Not quite. You need to be able to act as PIC in the same category and class.
Not unless you're going to be PIC as well as safety pilot. Otherwise, the safety pilot only has to meet the safety pilot requirements, not the PIC requirements. While it's true that you need the applicable cat/class ratings on your PP or better certificate, you don't have to be able to act as PIC in that cat/class -- that would require a flight review and any applicable additional training endorsements, as well as currencies if you're flying IFR or with passengers.
If we were in an Arrow and I had the complex endorsement I could have a private pilot without a complex endorsement be my safety pilot. Although they could not be the legal PIC of the flight.
Correct.
 
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