Two instrument rated pilots, one under hood, in IMC, both log PIC?

Discussion in 'Flight Following' started by Skid, Feb 1, 2019.

  1. Skid

    Skid Pre-takeoff checklist

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    So I just want to make sure I'm interpreting the regs correctly for this one:

    There are two instrument rated pilots (both current, have medical, etc) looking to get some practice approaches in, in weather that will often go between VMC and IMC. Because of this an IFR flight plan will be filed.

    I know there's a difference between acting as pic and logging pic. Both of the pilots have the ability to act as pic, and for logging pic:

    1) Sole manipulator of controls in aircraft for which you are rated
    2) Alone in the aircraft
    3) When you are the acting PIC and more than one pilot is required

    So because someone is wearing the hood, a safety pilot is required (i.e. more than one pilot required) and thus both pilots can log PIC right? I'm not sure where there is any stipulation about the type of flight plan or conditions outside the aircraft. Is that correct?
     
  2. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    *closes tab on browser*
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    *puts shotgun in mouth*
    ...
     
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  3. Skid

    Skid Pre-takeoff checklist

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    Lol, I just read your "The definitive PIC thread", but I may be reading it wrong...
     
  4. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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  5. Skid

    Skid Pre-takeoff checklist

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    I saw that too, and it seems as though both would be able to log PIC. I just want to be sure that the IFR flight plan or IMC doesn't have any impact on "under the hood" and the need for a safety pilot.
     
  6. Clip4

    Clip4 En-Route

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    But if you pull the mixture to idle cut off can you both log glider IMC?
     
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  7. MauleSkinner

    MauleSkinner Final Approach

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    No, because the airworthiness certificate still says “airplane”. ;)
     
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  8. Tantalum

    Tantalum En-Route

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    No, you cannot both log PIC. When your friend is under the hood but you're flying under visual flight rules, a second pilot is required as a crew member for visual separation. Once you rae in the clouds, assuming legally, you are then under instrument flight rules and that second pilot to look out the window is no longer required
     
  9. Lindberg

    Lindberg En-Route

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    What does the reg say about IFR flight plans, being under the hood, and IMC?
     
  10. Skid

    Skid Pre-takeoff checklist

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    I'm not sure what regulation that is
     
  11. arkvet

    arkvet Line Up and Wait

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    Idk if this is trolling or a legit question but the idea of two people both wearing foggles at same time while going in and out of IMC is foolish and likely illegal. When you enter VMC which one of you is looking for the VFR traffic
    Maybe I’m misteading this extreme “what if” question.

    I mean in that regard if a backseat pax had long enough arms and could reach the yoke from the back seat could 3 of you log PIC at same time? Maybe the backseat PIC could be foggleless and be the safety pilot in VMC. When entering the clouds he could grab the controls and turn th back over when popping out. Would def want a good stopwatch.
     
  12. Skid

    Skid Pre-takeoff checklist

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    Not saying your wrong, but could you tell me where the regs state anything about the visual part. I'm just seeing "simulated instrument flight" which would imply a hood, but the conditions outside aren't mentioned.
     
  13. Skid

    Skid Pre-takeoff checklist

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    I think you misread, or maybe I didn't explain it well enough. This is just two guys instrument rated doing the same foggle stuff as on a VFR day only now its IFR or rather IMC conditions. One person is under the hood, the other is...'looking outside'.
     
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  14. MauleSkinner

    MauleSkinner Final Approach

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    Is the safety pilot required?
     
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  15. Skid

    Skid Pre-takeoff checklist

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    I think so, one person is practicing simulated instrument conditions with the hood on.

    I'll also add 91.113b states:

    "When weather conditions permit, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, vigilance shall be maintained by each person operating an aircraft so as to see and avoid other aircraft."
     
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  16. blueskyMD

    blueskyMD Pre-takeoff checklist

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    I don't think you need any specific rule for VFR or IFR . If wx is IMC then you file IFR flight plan . Period . And a safety pilot no more needed because you are under direct control of ATC. . So in IMC question of who logs as PIC is moot. The guy/girl who filed the FP and is operating plane will log PIC
     
  17. MauleSkinner

    MauleSkinner Final Approach

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    Do weather conditions permit “see and avoid”?
     
  18. Skid

    Skid Pre-takeoff checklist

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    I see your point, however it just seems a bit off that filing an IFR flight plan could prevent someone from logging approaches. If the weather isn't necessarily down around the FAF inbound then I can't log the approach. If the foggles were then put on, then I'd expect a safety pilot to be there to be looking outside regardless of the flight plan or specific conditions.
     
  19. MauleSkinner

    MauleSkinner Final Approach

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    That part is correct. It’s a matter of whether the safety pilot is required prior to breaking out.
     
  20. eman1200

    eman1200 Touchdown! Greaser! PoA Supporter

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    are you sole manipulator of the shotgun?
     
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  21. donjohnston

    donjohnston Line Up and Wait

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    You forgot "Pull the trigger".
     
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  22. texasclouds

    texasclouds Line Up and Wait

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    In actual conditions only one person could log pic. In simulated conditions, the safety pilot could too. If you were on a filed IFR flight plan but not in actual conditions then safety pilot required for simulated. If on filed IFR in actual conditions only one person logs. Right?
     
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  23. Lindberg

    Lindberg En-Route

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    Try EdFred's link.
     
  24. Tantalum

    Tantalum En-Route

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    It is more about when the safety pilot is required as a crew member. If you are legally flying IMC then a crew member is not required.. you only become a legally required crew member under simulated instrument flight (hood), once you are in the clouds you are no longer simulated and that condition is null.. you are now in actual conditions and a safety pilot is not required for actual conditions
     
  25. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    They may, they may not. Vis might be unlimited but you might be 400 under the deck. Or it might be 2.5sm of haze and no clouds anywhere. Or you might be in and out of puffies.
     
  26. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    Please cite the regulation backing this up.
     
  27. iamtheari

    iamtheari Pattern Altitude

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    But who's the shortstop?
     
  28. Tantalum

    Tantalum En-Route

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    yes, see below, or look up 91.109.c

    First let's all be clear on who can actually log PIC, 61.51.e.1
    -you can log PIC when you are sole occupant of aircraft
    -you can log PIC when you are the sole manipulator of the controls and you are rated for that aircraft
    -you can log PIC when you are the *acting* pilot in command on a flight where more than one pilot is required

    Now to discuss "simulated" instrument conditions, 61.57.c
    -IFR pilots need to maintain currency, they do this by logging 6 approaches, doing holds, etc. in ACTUAL conditions... **OR** with the use of a view limiting device to create simulated conditions. The FAR very clearly uses the word "or"

    Okay.. and now the part about safety pilots, 91.109.c
    -you cannot fly an aircraft in SIMULATED conditions without a safety pilot on board, and importantly, part 2 of 91.109.c very clearly states that they must be able to SEE OUT, verbatim "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"

    Okay... lastly, when can the safety pilot log time
    -we covered that above, the third bullet of 61.51.e.1 up top.. if you agree to be ACTING pilot in command then you can log the time while your friend is the sole manipulator of the controls.. however, as ACTING pic if you crash that is on you

    *****So, piecing this altogether, it's quite apparent that you can be either in actual conditions **OR** simulated conditions, but not both, and that your safety pilot must have adequate vision outside of the airplane. In the situation described by the OP you can't fly into the cloud but log the time because your friend put a hood on.. according to the FAA you cannot legally act as a safety pilot because you do not have outside vision of the aircraft (which is required by the FAR, 91.109c) and because you are now in ACTUAL conditions, and a safety pilot is NOT required in actual conditions..
     
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  29. Tantalum

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    ..so I think that's the rub, simply putting the hood on doesn't mean the person next to you can log the time also, a set of other conditions need to take place as well, such as having adequate vision outside of the plane, etc. as noted above. And in the FAA's eye you are either in actual conditions OR visual conditions. You can't simulate IFR and be IFR at the same time. And no safety is required when in actual conditions, because the whole point of the safety is to see outside of the plane so you can visually keep separation from other planes and stuff

    It's fun stuff to think about going down the rabbit holes of what the FAA says, but when you piece it altogether they do a fairly decent job at filling in the blanks

    **Now, in practice, for your situation, I've gone flying as safety pilot on marginal VFR days where we were in and out of the clouds.. and I always just match my PIC time with whatever the person put as simulated.. this A.) serves the purpose of being a good check on things in case the FAA ever questions his simulated time, and B.) since actual time is more important anyway most people will log whatever actual they can. So me and my buddy go flying, the whole flight is 1.2, the simulated is 0.6, and the actual is 0.2.. I'll log the 0.6 as PIC (not the full 0.8)

    Anyway.. it's Friday night, time for a cold one!
     
  30. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    See post 25.
     
  31. Lindberg

    Lindberg En-Route

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    Which reg says what "adequate vision" is when you're in IMC? Does a pilot under the hood have it? What if you're IFR 100' above the clouds and the pilot is wearing the hood?
     
  32. Tantalum

    Tantalum En-Route

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    Side note, where does the post number show up on a smart phone?

    ?? IMC means you are no longer VMC and you are now operating under instrument flight rules

    the whole point of the safety pilot is so you don't crash into other people because you're flying in visual flight rules but blindfolded. IFR you don't need a safety. just because you are wearing a hood doesn't mean that you're required to have someone there because you're in instrument flight rules operating by reference to instruments anyway.. wearing a hood is overkill

    I feel like I'm being trolled, it's pretty obvious

    But ultimately you can log whatever you want in your logbook.. so if it makes reasonable sense for somebody to put a pair of foggles on when they are already IMC just so their friend can sit next to them and log time then go for it. It's not legal but you can write anything you want
     
  33. Kritchlow

    Kritchlow Final Approach

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    Who in this world is going to bring a stopwatch to time when you’re in and out of the puffies?
    Sheesh.... a bit of judgement goes a long way.
     
  34. Palmpilot

    Palmpilot Touchdown! Greaser!

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    The trouble with that interpretation is that it would mean that you could wear a hood without a safety pilot as long as you were in actual instrument flight conditions. I don't think the FAA would buy that. My understanding is that the FAA considers you to be in simulated instrument flight whenever the pilot at the controls has a hood on, regardless of the flight conditions.

    It's important to look at the actual wording of 91.109(c)(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;..."

    "Adequate vision forward and to each side of the aircraft" is not a weather requirement, it's a requirement that the safety pilot's view through the windows not be blocked. If it were a weather requirement, the clause "or a competent observer in the aircraft adequately supplements the vision of the safety pilot" would not have been included, because it wouldn't do any good.

    And if you're still not convinced, one of our attorney members quoted the FAA Chief Counsel's office as saying

    "Simulated instrument conditions" occur when the pilot's vision outside of the aircraft is intentionally restricted, such as by a hood or goggles.
    https://www.pilotsofamerica.com/community/threads/simulated-ifr-without-a-hood.87891/#post-1946096
     
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  35. Tantalum

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    So answer me this:

    What purpose is your safety pilot doing if you're flying around in the clouds with your hood on? he or she is not going to be able to see other aircraft anyway when you can't even see the end of the wing..

    The spirit of the reg is to let people keep their instrument currency even if there are no instrument conditions present.. and the safety pilot is there to help keep visual separation from aircraft, technically they can only log the time if there was an agreement up front that they're acting anyway
     
  36. Tantalum

    Tantalum En-Route

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    not really an interpretation, that's what it says. If we push it to extremes it also says that if you're the only one on board a 737 you can log that time as pilot-in-command even if you're just a 75 he ASEL PPL

    Go figure
     
  37. Lindberg

    Lindberg En-Route

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    Common misconception. IMC and IFR are not the same thing. It is possible to operate VFR in IMC.
     
  38. EdFred

    EdFred Touchdown! Greaser! PoA Supporter

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    Only if you're signed off to solo for a rating. Can't just go joyriding and log it.

    You don't have to be in the clouds to be considered IMC IFR. What if you're 400-foot below the clouds?
     
  39. Lindberg

    Lindberg En-Route

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    This is an example of a bifurcation fallacy. CAVU and in thick soup are not the only conditions we fly in. Nevertheless, as had been pointed out, if the pilot can't see out the window, regardless of what's on the other side, you need a safety.
     
  40. Tantalum

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    I said IMC as in operating by reference to instruments.