Safety pilot CAN log cross-country time

The letter says pretty much exactly what I said in the OP, except it does not address a scenario where both pilots do a landing and a take off. Also I would like the point out that the letter specifically states that the only pilot that can log everything is the pilot that does the take offs and landings.
Another good example of what R&W wrote in another thread about pilots always trying to find a way to get around the regulations. Here, we know what the FAA's position is, but MachFly doesn't like it, so he's trying to beat the system. You want to risk a revocation for violating 61.59, go right ahead and do what he suggests. You want to be sure to keep your tickets, find another way to bag XC PIC time.
 
How is this less legitimate than logging time with Otto flying?
Because the FAA Chief Counsel is on record on both counts -- against safety pilots logging XC time, and for logging PIC time when manipulating the autopilot which is manipulating the controls. You don't like it, get the Chief Counsel to write a new letter saying it's OK to do what MachFly wants to do. Otherwise, you haven't a legal leg on which to stand if the FAA pings you for a 61.59 violation.
 
The letter of interpretation on this subject is ridiculous. A flight does not stop being a flight just because someone else landed.
If you really believe that, feel free to take the FAA before the US Court of Appeals to have this letter overturned. Otherwise, it's what they FAA will act on and your statement before the NTSB calling it "ridiculous" won't help your case -- only prove that you knew what the FAA's position was and deliberately crossed it.
 
I guess that just depends on how you interpret it.
No, it only depends on how the FAA Chief Counsel interprets it (other than if the US Court of Appeals overturns that interpretation, and it's very expensive to make that happen).
 

That letter makes sense if you have two pilots flying a 50nm cross-country for the purpose of logging time for some raining that requires a certain amount of cross-countrys or cross-country time that must be at least 50nm. It seems though the person that was writing the letter did not think that it's possible to fly a 1000nm cross-country and half way switch PICs. Then you will have a pilot who is the sole manipulator of controls and a PIC for 500nm, yet he won't be able to log cross-country because he did not fly the other 500nm. Doesn't make much sense.
 
Because the FAA Chief Counsel is on record on both counts -- against safety pilots logging XC time, and for logging PIC time when manipulating the autopilot which is manipulating the controls. You don't like it, get the Chief Counsel to write a new letter saying it's OK to do what MachFly wants to do. Otherwise, you haven't a legal leg on which to stand if the FAA pings you for a 61.59 violation.

I have no problem with either. I'm pointing out the hypocrisy of Captain looking down his nose at anyone who would log Safety Pilot time, while simultaneously logging all his time as Safety Pilot while Otto flies. His snobbery is not based in the regulations.
 
I have no problem with either. I'm pointing out the hypocrisy of Captain looking down his nose at anyone who would log Safety Pilot time, while simultaneously logging all his time as Safety Pilot while Otto flies.
Except that's not being a "safety pilot" as the FAA uses that term. In the FAA's eyes, as stated in writing by the Chief Counsel, if he's pushing Otto's buttons, he remains both the PIC and the sole manipulator of the controls. The only way he becomes a Safety Pilot is if the SIC is manipulating the controls while wearing a vision restricting device, and in that case, he remains the PIC of an aircraft when two pilots (including a designated SIC) are required, and that is an exception in the Chief Counsel's letter which allows him to log XC time even when functioning as safety pilot.
 
Except that's not being a "safety pilot" as the FAA uses that term. In the FAA's eyes, if he's pushing Otto's buttons, he remains both the PIC and the sole manipulator of the controls. The only way he becomes a Safety Pilot is if the SIC is manipulating the controls while wearing a vision restricting device, and in that case, he remains the PIC of an aircraft when two pilots (including a designated SIC) are required, and that is an exception in the Chief Counsel's letter which allows him to log XC time even when functioning as safety pilot.

Ron, his snobbery is not based on the regulations, and my criticism of his snobbery is not, nor is it intended to be, based in the regulations either.

He looks down his nose at those who, in full compliance with the regulations, log safety pilot time. In effect, that's what he's doing while Otto flies the plane. He is acting as the safety pilot for the microchips. Is that a legal position the FAA takes? No.
 
The discussion isn't about the FAA's opinion or findings. The FAA says it's perfectly acceptable to log safety pilot time. The discussion is about Captains's opinion of logging FAA acceptable safety pilot time. The comparison made is logging that allowable safety pilot time is just as valid and comparable to babysitting Otto. If he is good with logging his safety pilot over the auto pilot, he should be just as good with people logging the FAA allowable safety pilot time.
 
The comparison made is logging that allowable safety pilot time is just as valid and comparable to babysitting Otto.
That is strictly a personal opinion, and I won't enter that discussion.

If he is good with logging his safety pilot over the auto pilot, he should be just as good with people logging the FAA allowable safety pilot time.
One more time -- he is not "logging his safety pilot over the auto pilot". When the autopilot is moving the flight controls, the pilot punching the autopilot's buttons is, in the FAA's language, the sole manipulator of the controls, not a "safety pilot", and, if appropriately "rated", entitled to log it as PIC time IAW 14 CFR 61.51(e)(1)(i), not the "PIC while 2-pilots required" clause further down that section. Perhaps if you all understand and recognize that very important regulatory difference it would make it easier for you folks to discuss this matter.
 
That is strictly a personal opinion, and I won't enter that discussion.

One more time -- he is not "logging his safety pilot over the auto pilot". When the autopilot is moving the flight controls, the pilot punching the autopilot's buttons is, in the FAA's language, the sole manipulator of the controls, not a "safety pilot", and, if appropriately "rated", entitled to log it as PIC time IAW 14 CFR 61.51(e)(1)(i), not the "PIC while 2-pilots required" clause further down that section. Perhaps if you all understand and recognize that very important regulatory difference it would make it easier for you folks to discuss this matter.

Sure he is, the safety pilot for someone under the hood interacts as well. When I see traffic or the imminent penetration of a cloud I will execute my powers as PIC by saying something on the order of "come left to 330". In effect I have done the same thing as the pilot using an AP has done by turning the heading bug. That is why the FAA allows the safety pilot to log PIC. Again, this isn't about regulatory difference because the regulation allows logging of PIC in either scenario because they 'get it'.
 
DualXCPIC.jpg


If a pilot is allowed to reposition from A to B and fly B-->D-->A for the purposes of a commercial cross country, then by that logic why couldn't both pilots couldn't log XC and PIC?

:stirpot:
 
Sure he is, the safety pilot for someone under the hood interacts as well. When I see traffic or the imminent penetration of a cloud I will execute my powers as PIC by saying something on the order of "come left to 330". In effect I have done the same thing as the pilot using an AP has done by turning the heading bug. That is why the FAA allows the safety pilot to log PIC. Again, this isn't about regulatory difference because the regulation allows logging of PIC in either scenario because they 'get it'.
None of that is consistent with anything in the regulations or the interpretations on point. If you're going to abuse the terminology like that, further discussion is pointless, and merely demonstrates the reason it's so hard to get people to understand the actual rules on this -- failure to stick to a common language, which, since this involves the FAA's regulations, must be the FAA's language.
 
NOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO:mad2::mad2::mad2::mad2:

Sure, why not? This isn't one of those situations where the wrong answer would hurt something, the two possible outcomes are "status quo" which is no, or a reconsideration which would allow it.
 
No, it only depends on how the FAA Chief Counsel interprets it (other than if the US Court of Appeals overturns that interpretation, and it's very expensive to make that happen).

Small correction: The NTSB hearing board has to give equal weight to the FAA Counsel and your own counsel's legal opinion, thanks to the pilot bill of rights.

With respect to safety pilot = autopilot, that's just silly.

An autopilot that could fly in the airspace system without human supervision would be called an 'autonomous UAV', and we are probably decades away from letting one of those loose in the civil airspace system.

That's why it is fine for the pilot to log the time he's flying the airplane without respect to the mode of any existing autopilot.
 
None of that is consistent with anything in the regulations or the interpretations on point. If you're going to abuse the terminology like that, further discussion is pointless, and merely demonstrates the reason it's so hard to get people to understand the actual rules on this -- failure to stick to a common language, which, since this involves the FAA's regulations, must be the FAA's language.

Correct me if I'm wrong, but don't both of you agree that PIC time can be logged by

1. safety pilots who are qualified and have been designated as acting as PIC, during the time the other pilot is under the hood,

and

2. PICs who are using an autopilot?

If so, what are you two arguing about? :confused:
 
Small correction: The NTSB hearing board has to give equal weight to the FAA Counsel and your own counsel's legal opinion, thanks to the pilot bill of rights.

With respect to safety pilot = autopilot, that's just silly.

An autopilot that could fly in the airspace system without human supervision would be called an 'autonomous UAV', and we are probably decades away from letting one of those loose in the civil airspace system.

That's why it is fine for the pilot to log the time he's flying the airplane without respect to the mode of any existing autopilot.

It's being used the other way around, Autopilot isn't = safety pilot in this argument, Pilot = safety pilot for AP is the way it is being used. The AP is no more autonomous than the pilot under the hood in VMC.

BTW, autonomous operations with the system being up linked programming and monitoring by human pilots is already under trials here.
 
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Small correction: The NTSB hearing board has to give equal weight to the FAA Counsel and your own counsel's legal opinion, thanks to the pilot bill of rights.
No, they do not. The PBOR doesn't say that, and the legal precedents on point don't say that. It's a popular belief among a certain segment of the pilot population, but it simply isn't true.
 
Correct me if I'm wrong, but don't both of you agree that PIC time can be logged by

1. safety pilots who are qualified and have been designated as acting as PIC, during the time the other pilot is under the hood,

and

2. PICs who are using an autopilot?

If so, what are you two arguing about? :confused:
Something else entirely. Go back and reread the thread for details.
 
...
BTW, autonomous operations with the system being up linked programming and monitoring by human pilots is already under trials here.

Yes and I think two of those crashed this week.

What isn't even being considered is an autonomous UAV that isn't monitored by any human.

Implying that a pilot using even the most sophisticated existing autopilot in the most sophisticated existing aircraft (I'm thinking G650) is somehow 'babysitting' is just ridiculous. Pilots who start thinking that way are likely to end up in SFO bay on a CAVU day.
 
Safety pilot and using an auto pilot are not equivalent.

Safety Pilot: you look out side while someone else flies the plane. That "someone else flying" is my main issue.

Auto Pilot use: YOU fly the plane through the use of automation. It make little difference what causes the ailerons to move. Me pushing through pushrods, cables and bell cranks with the yoke or me causing the autopilot to do the same thing.

Ones a passenger (admittedly one with a job) and the other is making decisions and flying a plane.

As far as snobby goes I'm at a loss. I'm a snob for feeling 'watching time' isn't 'pilot in command' time? Okay, I guess I'm a snob cause that's my position.
 
Yes and I think two of those crashed this week.

What isn't even being considered is an autonomous UAV that isn't monitored by any human.

Implying that a pilot using even the most sophisticated existing autopilot in the most sophisticated existing aircraft (I'm thinking G650) is somehow 'babysitting' is just ridiculous. Pilots who start thinking that way are likely to end up in SFO bay on a CAVU day.

I'm talking about airliners coming into SFO from across the Pacific, the program has been in use for a while and I think has also been expanded to other airports.
 
Safety pilot and using an auto pilot are not equivalent.

Safety Pilot: you look out side while someone else flies the plane. That "someone else flying" is my main issue.

Auto Pilot use: YOU fly the plane through the use of automation. It make little difference what causes the ailerons to move. Me pushing through pushrods, cables and bell cranks with the yoke or me causing the autopilot to do the same thing.

Ones a passenger (admittedly one with a job) and the other is making decisions and flying a plane.

As far as snobby goes I'm at a loss. I'm a snob for feeling 'watching time' isn't 'pilot in command' time? Okay, I guess I'm a snob cause that's my position.

Makes a big difference. Go to work flying a Jetstream for a while and tell me it's the same as flying with an autopilot.
 
Makes a big difference. Go to work flying a Jetstream for a while and tell me it's the same as flying with an autopilot.

Henning, you're usually good at seeing the point. It makes little difference to the spirit of flying what's causing the pushrods and bell cranks to move. If George is doing my bidding or I use the yoke, either way its me flying.
 
Henning, you're usually good at seeing the point. It makes little difference to the spirit of flying what's causing the pushrods and bell cranks to move. If George is doing my bidding or I use the yoke, either way its me flying.

So, how is that different if you happen to have a carbon-based autopilot while you, acting as PIC, happen to be the safety pilot?
 
So, how is that different if you happen to have a carbon-based autopilot while you, acting as PIC, happen to be the safety pilot?

I guess I don't understand what a safety pilot is. I thought the pilot under the hood made decisions as to where to fly, how fast, descent rate selection, navigation, corrections left, right, up and down.

You're saying the safety pilot does all that through the pilot under the hood? The SP tells the hooded guy what to do? That's not how I've ever done it. I've always just sat there and watched out for traffic or earth.

Well, I guess the safety pilot IS pic. In that case though maybe the hooded guy shouldn't log PIc as he isn't doing anything really. I could teach a 7 year old to fly IMC if all that was required was 'do what I say when I say it'.
 
I guess I don't understand what a safety pilot is. I thought the pilot under the hood made decisions as to where to fly, how fast, descent rate selection, navigation, corrections left, right, up and down.

You're saying the safety pilot does all that through the pilot under the hood? The SP tells the hooded guy what to do? That's not how I've ever done it. I've always just sat there and watched out for traffic or earth.

Well, I guess the safety pilot IS pic. In that case though maybe the hooded guy shouldn't log PIc as he isn't doing anything really. I could teach a 7 year old to fly IMC if all that was required was 'do what I say when I say it'.

If you want to log PIC time, then you need to act as the PIC. If I'm a safety pilot, logging PIC time, then I take full and complete responsibility for the safe conduct of the flight. I do my own briefing on weather/TFRs, I plan the route, I do all of the things I would normally do if I were flying solo, just someone else manipulates the controls, and gets practice flying by reference to instruments.

You spoke earlier of the safety improvements of using Otto. I don't disagree with you there, particularly on the heavier aircraft (I don't have data on it, but might suggest that over-reliance on Otto may diminish some people's proficiency with flying...again, just an impression unsupported by data). By that same token, more time flying on instruments can also be said to improve safety, both for folks who fly in IMC from time to time to keep up proficiency, and for those who do not to gain proficiency in the event of an inadvertent entry. As such, it makes sense for the regulations to encourage such practices wherever feasible.
 
Henning, you're usually good at seeing the point. It makes little difference to the spirit of flying what's causing the pushrods and bell cranks to move. If George is doing my bidding or I use the yoke, either way its me flying.

Yes, but so is the pilot manipulating the controls when you are telling him the corrections. Under your auspices a CFI should only log the time he is manipulating the controls as PIC as well.
 
It may be time to call in professor Irwin Corry on this matter. Anyone know how to contact him? Used to be on Johnny Carson a lot.
 
I guess I don't understand what a safety pilot is. I thought the pilot under the hood made decisions as to where to fly, how fast, descent rate selection, navigation, corrections left, right, up and down.

You're saying the safety pilot does all that through the pilot under the hood? The SP tells the hooded guy what to do? That's not how I've ever done it. I've always just sat there and watched out for traffic or earth.

Well, I guess the safety pilot IS pic. In that case though maybe the hooded guy shouldn't log PIc as he isn't doing anything really. I could teach a 7 year old to fly IMC if all that was required was 'do what I say when I say it'.

Did you never call out a heading or diversion for avoidance of that traffic or land mass? Personally I don't care, I have no dog in this hunt, none of my logged time is as safety pilot and around 20 is on AP and there are plenty of flights I never got around to logging, time just isn't that big of a deal to me at this point outside proving legal requirements. I just don't think there is any significant difference in the physical skills between being safety pilot or watching the AP fly the plane and they also have the same duty of care and responsibility.
 
Henning, you're usually good at seeing the point. It makes little difference to the spirit of flying what's causing the pushrods and bell cranks to move. If George is doing my bidding or I use the yoke, either way its me flying.

You said it better than me.

slight off topic: There are NO airplanes in the civil system that are not carefully and directly monitored by a human. There are handful in the civil system in which the human doesn't sit in the actual craft, but there is still a human operator.
 
... If I'm a safety pilot, logging PIC time, then I take full and complete responsibility for the safe conduct of the flight. ....

That is a ridiculous mode in which to fly an airplane. Which is why 'safety pilot PIC' is so bogus.
 
I guess I don't understand what a safety pilot is. I thought the pilot under the hood made decisions as to where to fly, how fast, descent rate selection, navigation, corrections left, right, up and down.
Sometimes yes, sometimes no. Depends on which one of the two is the PIC, and it's not always the control manipulator.

Well, I guess the safety pilot IS pic.
I've heard that said before, and while it may (through prior arrangement) be true, it isn't necessarily true.
 
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