Pic

[Terry]

Hi All:

I flew as a safety pilot for a friend the other day and he said I could log my time as PIC since he can't fly "under the hood" by himself.

I said I didn't think it was right since I was just watching for other aircraft and the ground so I didn't log any time at all.

Was I right? If so ..where does it say so specifically? part61?

Thanks;

Terry

 

[Jeff Oslick]

In this circumstance he is correct. If he is under the hood in VMC, you are a required crew member, and you can/should be logging PIC. He would log PIC as well as "sole manipulator". When I'm logging simulated instrument time in the plane, I always also write in my log the name of the person acting as PIC while I'm under the hood, because if he/she isn't there, I'm not legal to be flying/logging simulated instruments.


It is actually in Part 91, I had not previously noted that this is listed under "flight instruction", when this actually seems to be done frequently outside of flight instruction (for currency). Anyone know if there is a similar reference elsewhere in the regs?

§ 91.109 Flight instruction; Simulated instrument flight and certain flight tests.

(a) No person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. However, instrument flight instruction may be given in a single-engine airplane equipped with a single, functioning throwover control wheel in place of fixed, dual controls of the elevator and ailerons when—
(1) The instructor has determined that the flight can be conducted safely; and
(2) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(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.
(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; and
(3) Except in the case of lighter-than-air aircraft, that aircraft is equipped with fully functioning dual controls. However, simulated instrument flight may be conducted in a single-engine airplane, equipped with a single, functioning, throwover control wheel, in place of fixed, dual controls of the elevator and ailerons, when—
(i) The safety pilot has determined that the flight can be conducted safely; and
(ii) The person manipulating the controls has at least a private pilot certificate with appropriate category and class ratings.
(c) No person may operate a civil aircraft that is being used for a flight test for an airline transport pilot certificate or a class or type rating on that certificate, or for a part 121 proficiency flight test, unless the pilot seated at the controls, other than the pilot being checked, is fully qualified to act as pilot in command of the aircraft.

Jeff

 

[Greg Bockelman]

With all due respect, the real answer is, "It depends." If you, the safety pilot are qualified to ACT as PIC in that particular airplane, IOW you have the landings Flight review, endorsments if necessary, and everything else necessary to ACT as PIC, AND if beforehand it is agreed that you will ACT as PIC, then you may log PIC for that time which the other pilot is under the hood. If you are not qualified to ACT as PIC, then you may log SIC for the time the other pilot is under the hood.

 

[Ed Guthrie]

If you are not qualified to ACT as PIC,

or otherwise do not act as legal PIC

then you may log SIC for the time the other pilot is under the hood.

Everything Greg wrote with the addition of the above.

 

[Terry]

Hi All:

This is "uncontrolled" air space. It is done in Visual conditions with NO interaction or communication with ATC.

Terry

 

[gismo]

Hi All:

This is "uncontrolled" air space. It is done in Visual conditions with NO interaction or communication with ATC.

Terry

Good to know, but that has absolutely no bearing on who logs what unless the wx (IMC) or flight type (IFR) precludes the safety pilot being PIC (IE if the SP isn't IFR rated and current).

 

[SkyHog]

Hi All:

This is "uncontrolled" air space. It is done in Visual conditions with NO interaction or communication with ATC.

Terry

Do you have at least a PPL? From the question I suspect that you may be a student pilot, and if thats true, then the answer would be no, you can't log it.

Interesting btw, I didn't know you could log SIC time. Where's the reference to that Greg, I trust ya, but I'd like to see it myself so I can quote it to others.

 

[gismo]

Interesting btw, I didn't know you could log SIC time. Where's the reference to that Greg, I trust ya, but I'd like to see it myself so I can quote it to others.

Nick, there's no specific FAR stating that you can log SIC time while performing the duties of safety pilot. That option is derived from the FAR that says you can log SIC if you are a "required crewmember" and not the PIC along with the rule that states that a safety pilot is needed making that SP a "required crewmember". It's all in part 61, but I don't remember the actual numbers.

 

[Greg Bockelman]

Interesting btw, I didn't know you could log SIC time. Where's the reference to that Greg, I trust ya, but I'd like to see it myself so I can quote it to others.

91.109(b) for the required crewmember part, and 61.51(e) or (f) for the PIC or SIC.

 

[SkyHog]

91.109(b) for the required crewmember part, and 61.51(e) or (f) for the PIC or SIC.

kewl - thanks Greg. Thats good info.

 

[Terry]

Hi All:

I'll decided not to log any of my time as a safety pilot. It is not worth the hassle and I want to insure "ALL" hours in my log book can be counted without any questions.

I will be finishing up my IR in a couple of months and then on to my commercial.

Thanks;
Terry

 

[gismo]

Hi All:

I'll decided not to log any of my time as a safety pilot. It is not worth the hassle and I want to insure "ALL" hours in my log book can be counted without any questions.

I will be finishing up my IR in a couple of months and then on to my commercial.

Thanks;
Terry

I'd log it as PIC if you can and SIC if you're not qualified and acting as PIC. Keep track in a separate column if you want to know your "real" hours but any time in your log can count towards total time and time in type, both of which may save you some insurance premiums some day even if you don't apply the time towards anything else.

 

[HPNPilot1200]

I found a link to an AOPA Page regarding this exact topic (Logging Time as a safety pilot) in last weeks AOPA ePilot:

http://www.aopa.org/members/files/topics/sftyplt.html

It clumps all the info discussed in this topic together...

Jason

 

[EdFred]

Where's Troy's chart when you need it?

Here's the quick and dity rule that covers most situations.
1) Are you rated in the aircraft?
2) Are you legal to fly the aircraft solo?
3) Are you legal to carry passengers in the aircraft?

If you answer yes to all three you can ACT and LOG PIC as safety pilot if agreed upon by both pilots. If you answer no to any of them you may not ACT as PIC, and cannot LOG it as PIC.

 

[grattonja]

Hi All:

I'll decided not to log any of my time as a safety pilot. It is not worth the hassle and I want to insure "ALL" hours in my log book can be counted without any questions.

I will be finishing up my IR in a couple of months and then on to my commercial.

Thanks;
Terry

I log it towards total time and under type (SEL in my case). That way I count the time, but don't enter into this long-disputed fray about who can log PIC under the circumstances. I have looked at the various FAR references myself and don't feel they are particularly clear (cloudy enough in fact so that the "red" board has a discussion that usually flares up on this topic about every 6 months or so, we heated positions all over the place).

For example, on the SIC logging recommendation, there are references out there seeming to suggest that you can only log SIC in aircraft where an SIC is required (which lets out the mighty skyhawk). So I don't log SIC. I agree with you that I want all my logged time to be clear. As I am clearly a required crewmember as safety pilot for a hooded pilot doing sim work, I figure total time is no problem.

Jim G

 

[poadeleted20]

I log it towards total time and under type (SEL in my case). That way I count the time, but don't enter into this long-disputed fray about who can log PIC under the circumstances.

The only folks confused about this are outside the FAA. Among those whose opinions count (the FAA Chief Counsel's office and the Flight Standards folks at HQ), there is neither dispute nor confusion.

I have looked at the various FAR references myself and don't feel they are particularly clear.

I do not agree. Plain reading of the rules (see below) shows them to be very clear on the subject of logging the time flown as safety pilot. If the safety pilot is acting as PIC as well as being the safety pilot, the safety pilot logs it as PIC time (14 CFR 61.51(e)(1)(iii) - acting as PIC when two pilots are required by the regulations under which the flight is conducted). If the hooded pilot is acting as PIC, the safety pilot logs it as SIC time (14 CFR 61.51(f)(2) - acting as SIC when two pilots are required by the regulations under which the flight is conducted).

For example, on the SIC logging recommendation, there are references out there seeming to suggest that you can only log SIC in aircraft where an SIC is required (which lets out the mighty skyhawk).

Unless someone stops reading 14 CFR 61.51(f)(2) before the end of the paragraph, there is nothing to suggest that.

(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(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.[emphasis added]
​

Note that the safety pilot is "required...under the regulations under which the flight is being conducted" because 14 CFR 91.109(b) says:

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.
​

So I don't log SIC.

And nobody says you have to -- you only have to log the time you plan to use for currency or higher certificates/ratings. But do not think for a second that there is any reason why you cannot log the safety pilot time as described above, or any confusion in the FAA's position on the subject. It is 100% completely legal to log the time as discussed as long as you are legally acting as safety pilot (i.e., have a PPL with appropriate category/class ratings and a medical certificate valid at 3rd class or higher).

 

[grattonja]

Ron, you have posted this very thorough analysis before. But others have posted also very thorough analyses suggesting, among other things, that the safety pilot cannot log either PIC or SEC time, that one can log PIC time even when the left seat is also logging PIC time, and that one can log time as a republican while voting democrat (alight so I made the last one up).

There is no specific regulation DIRECTLY, on it's own, addressing logging of safety pilot time. You must read and anaylze together several disparate pieces of the CFR to get there. I would ask why but it is the FAA and the Code of Federal Regulations, neither of which are always clear, or always make sense.

I log my time only towards total time and time in type. I may be wrong and I readily admit that. But, by the same token, I don't think that the way I log the time will be deemed as inappropriately logging time I didn't earn, by any of the parties who argue the issue. IOW, my way may be incorrect to the point of being too conservative, but it will not get me into trouble.

Jim G

 

[Greg Bockelman]

To each his own.

 

[poadeleted20]

Ron, you have posted this very thorough analysis before. But others have posted also very thorough analyses suggesting, among other things, that the safety pilot cannot log either PIC or SEC time,

Impossible -- no one could produce such an analysis based on plain reading of the regulations and the FAA legal interpretations on the subject.

that one can log PIC time even when the left seat is also logging PIC time,

Well, now, that is true, as I have said before. As the FAA Counsel has said, logging PIC time and being the PIC are two different things, and one can be logging PIC time without being the PIC.

I log my time only towards total time and time in type. I may be wrong and I readily admit that. But, by the same token, I don't think that the way I log the time will be deemed as inappropriately logging time I didn't earn, by any of the parties who argue the issue. IOW, my way may be incorrect to the point of being too conservative, but it will not get me into trouble.

Do what you wish, but you are cheating yourself out of valid flight time. And it is not fair to say that there is any question about the legality of logging this time the way I have stated -- it is 100%, completely, totally legal, and any FAA Counsel will back me up on that.