Why category AND class for safety pilot?

TangoWhiskey

TangoWhiskey

Touchdown! Greaser!
Joined
Feb 23, 2005
Messages
14,210
Location
Midlothian, TX
Display Name
Display name:
3Green
91.109(b)(1) requires the safety pilot to have category and class appropriate to the aircraft being flown under simulated instrument conditions. Since my duty as safety pilot is not to fly the plane, nor to monitor the safety pilot's instrument flying performance (evidenced by the fact that an instrument rating is not required to act as safety pilot), but simply to watch out for other aircraft the pilot flying can't see while under the hood, why is "class" required?

I can't see how it would make any difference for a PP-ASEL who wants to perform safety pilot duty for a friend who owns a AMEL airplane. :dunno: My eyes work just as well looking for traffic when two engines are spinning. What am I missing?

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

<snip (a)>

(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
Click to expand...
 
You're missing two things:

Practically - you may have to take the controls and fly the airplane - a safety pilot is not just a pair of eyes.

Legally - because the FAA says so, that's why! :)
 
TangoWhiskey said:
91.109(b)(1) requires the safety pilot to have category and class appropriate to the aircraft being flown under simulated instrument conditions. Since my duty as safety pilot is not to fly the plane, nor to monitor the safety pilot's instrument flying performance (evidenced by the fact that an instrument rating is not required to act as safety pilot), but simply to watch out for other aircraft the pilot flying can't see while under the hood, why is "class" required?

I can't see how it would make any difference for a PP-ASEL who wants to perform safety pilot duty for a friend who owns a AMEL airplane. :dunno: My eyes work just as well looking for traffic when two engines are spinning. What am I missing?
Click to expand...

It is if you fly under and IFR flight plan.

It's actually fully consistent. The safety pilot needs to be qualified to fly under the regulations the flight is conducted under. VFR flight in a SEL, then the SP needs to be a PP SEL. VFR in a SES, then you need your float rating.

I kind of look at it as the SP needs to understand all the operations that are going on. So, if you're on an IFR flight plan, he needs to understand and be able to tell the pilot when you're about to bust a clearance. For ME, there's this whole extra set of levers in the middle, and what if the pilot decides to practice an engine-out approach? Wouldn't the SP understanding what Vmc means be helpful to that?

All that said, whatever the reason, the regulation is quite clear!
 
JeffDG said:
It is if you fly under and IFR flight plan.

It's actually fully consistent. The safety pilot needs to be qualified to fly under the regulations the flight is conducted under. VFR flight in a SEL, then the SP needs to be a PP SEL. VFR in a SES, then you need your float rating.

I kind of look at it as the SP needs to understand all the operations that are going on. So, if you're on an IFR flight plan, he needs to understand and be able to tell the pilot when you're about to bust a clearance. For ME, there's this whole extra set of levers in the middle, and what if the pilot decides to practice an engine-out approach? Wouldn't the SP understanding what Vmc means be helpful to that?

All that said, whatever the reason, the regulation is quite clear!
Click to expand...

Where does it say a safety pilot must have an instrument rating? That would be needed for a safety pilot to understand 'busting a clearance' or other IFR procedure.
 
TangoWhiskey said:
Where does it say a safety pilot must have an instrument rating? That would be needed for a safety pilot to understand 'busting a clearance' or other IFR procedure.
Click to expand...

I THINK 61.55(a)(2) is the operative reg on that. It was a change not too long ago that sort of went unnoticed for awhile.
 
TangoWhiskey said:
Where does it say a safety pilot must have an instrument rating? That would be needed for a safety pilot to understand 'busting a clearance' or other IFR procedure.
Click to expand...

Only if the flight is operated under IFR (ie. on a IFR flight plan with an appropriate clearance).
 
Greg Bockelman said:
I THINK 61.55(a)(2) is the operative reg on that. It was a change not too long ago that sort of went unnoticed for awhile.
Click to expand...

That's the one:
Sec. 61.55 Second-in-command qualifications.

(a) A person may serve as a second-in-command of an aircraft type
certificated for more than one required pilot flight crewmember or in
operations requiring a second-in-command pilot flight crewmember only if
that person holds:
(1) At least a current private pilot certificate with the
appropriate category and class rating; and
(2) An instrument rating or privilege that applies to the aircraft
being flown if the flight is under IFR; and
(3) The appropriate pilot type rating for the aircraft unless the
flight will be conducted as domestic flight operations within United
States airspace.
Click to expand...
 
"Sec. 61.55 Second-in-command qualifications.

(a) A person may serve as a second-in-command of an aircraft type
certificated for more than one required pilot flight crewmember or in
operations requiring a second-in-command pilot flight crewmember only if
that person holds:
(1) At least a current private pilot certificate with the
appropriate category and class rating; and
(2) An instrument rating or privilege that applies to the aircraft
being flown if the flight is under IFR; and
(3) The appropriate pilot type rating for the aircraft unless the
flight will be conducted as domestic flight operations within United
States airspace."

But this isn't relevant to the discussion of Safety Pilot, is it? This explicitly defines the rules for an aircraft that requires two crewmembers.
 
murphey said:
"Sec. 61.55 Second-in-command qualifications.

(a) A person may serve as a second-in-command of an aircraft type
certificated for more than one required pilot flight crewmember or in
operations requiring a second-in-command pilot flight crewmember only if
that person holds:
(1) At least a current private pilot certificate with the
appropriate category and class rating; and
(2) An instrument rating or privilege that applies to the aircraft
being flown if the flight is under IFR; and
(3) The appropriate pilot type rating for the aircraft unless the
flight will be conducted as domestic flight operations within United
States airspace."

But this isn't relevant to the discussion of Safety Pilot, is it? This explicitly defines the rules for an aircraft that requires two crewmembers.
Click to expand...

Aircraft or operations...like when one crewmember has a view-limiting device on.
 
murphey said:
But this isn't relevant to the discussion of Safety Pilot, is it? This explicitly defines the rules for an aircraft that requires two crewmembers.
Click to expand...

Well, acually it is. You have to parse the regulation carefully. Any time the other pilot is under the hood, a second pilot is required. If that pilot is acting as PIC, the PIC rules apply. If not, it sort of gets dumped into the SIC rules.
 
TangoWhiskey said:
91.109(b)(1) requires the safety pilot to have category and class appropriate to the aircraft being flown under simulated instrument conditions. Since my duty as safety pilot is not to fly the plane, nor to monitor the safety pilot's instrument flying performance (evidenced by the fact that an instrument rating is not required to act as safety pilot), but simply to watch out for other aircraft the pilot flying can't see while under the hood, why is "class" required?
Click to expand...
The answers are skewing towards the SIC regulation because that would be the logging rule.

Disregarding how to log it, since you don't have to log it, and you just want to know why you cannot be just a set of 'eyes' to be a safety pilot as required in 91.109(b)(1)
Read on to (b)(3) and you see the aircraft must have fully functioning dual controls.

That would indicate that your duty may be to take the controls, therefore, you would need a class rating.

As in an extreme example for clarity, if you have only flown a Cessna 150, and you are being Safety Pilot in a King Air 350 or something, that would probably not work too well.
 
Where are you getting that 61.55 is a logging rule?

"A person may serve as a second-in-command..."

That's acting, not logging.
 
JeffDG said:
That's the one:
Click to expand...

Yeah, but the situation I was discussing--and should have explicitly stated--was a flight in VMC, under VFR, to practice approaches with the instrument-rated pilot under the hood and the safety pilot being the "lookout" for traffic.
 
TangoWhiskey said:
Yeah, but the situation I was discussing--and should have explicitly stated--was a flight in VMC, under VFR, to practice approaches with the instrument-rated pilot under the hood and the safety pilot being the "lookout" for traffic.
Click to expand...

Yep...

I pointed it out to show how it's consistent. When flying under Instrument rules, the safety pilot must be competent in those rules (IR). When operating under multi-engine rules, the SP must be competent in operating a ME plane.

Out of curiosity...if someone receives their ME in a Cessna 336/337, can they be a safety pilot in a 340?
 
Greg Bockelman said:
http://www.pilotsofamerica.com/forum/showthread.php?t=34664&highlight=Safety+Pilot+Instrument+Rated


Post #9
Click to expand...

I don't disagree with anything in Ron's post. Thanks for referencing it Greg. I still don't understand why the FAA requires a class rating to be a safety pilot under VMC conditions for visual practice approaches with the PF under the hood. Presume for this discussion that as safety pilot I don't want or need to log the time, I'm not acting as PIC, and the entire flight is in CAVU conditions.

Tim said above that my role as safety pilot is not just to watch for traffic. Where does the FARs define what my role as safety pilot is? Since the PF is under the hood, it's quite obvious (to me) that my role is to be looking outside the window for traffic and to make sure he doesn't fly into terrain. My role is NOT to ensure he sets the radios correctly, follows correct altitudes and courses, etc. If my role were the latter, the FAA would require that I be instrument rated to be a safety pilot, to ensure I understand the charts, rules, regs, and procedures.
 
TangoWhiskey said:
Presume for this discussion that as safety pilot I don't want or need to log the time, I'm not acting as PIC, and the entire flight is in CAVU conditions.
Click to expand...

This has nothing to do with logging time, and everything to do with the fact that you are a required crewmember and thus you must be properly rated.
 
nosehair said:
The answers are skewing towards the SIC regulation because that would be the logging rule.

Disregarding how to log it, since you don't have to log it, and you just want to know why you cannot be just a set of 'eyes' to be a safety pilot as required in 91.109(b)(1)
Read on to (b)(3) and you see the aircraft must have fully functioning dual controls.

That would indicate that your duty may be to take the controls, therefore, you would need a class rating.

As in an extreme example for clarity, if you have only flown a Cessna 150, and you are being Safety Pilot in a King Air 350 or something, that would probably not work too well.
Click to expand...

So one cannot practice approaches in a Bonanza with a throw over yoke?
 
TangoWhiskey said:
OK, that I can buy... but then shouldn't I need an instrument ticket, too?
Click to expand...

If you're flying under IFR, you do.

You need the qualifications appropriate to the rules under which the flight is conducted.
 
TangoWhiskey said:
I don't disagree with anything in Ron's post. Thanks for referencing it Greg. I still don't understand why the FAA requires a class rating to be a safety pilot under VMC conditions for visual practice approaches with the PF under the hood.
Click to expand...
Fortunately, understanding the "why" of the FAR's is not required -- only knowing the "what." If the "why" was required knowledge, none of us could pass the test.

Tim said above that my role as safety pilot is not just to watch for traffic.
Click to expand...
That may be Tim's interpretation, but it's not law. Other than traffic lookout, the safety pilot's role is whatever the PIC says it is, and that could be a lot or a little. Just make sure that the roles and responsibilities for PF and SP are fully discussed and agreed before engine start.
 
alaskaflyer said:
So one cannot practice approaches in a Bonanza with a throw over yoke?
Click to expand...
Check 91.109(b)(3) again. It's legal, but only at the safety pilot's discretion, and I don't do it. Folks coming to me for IR or refresher training in a Bonanza or Baron with a throwover yoke have to rent a dual yoke assembly for the duration of their training.
 
flyingcheesehead said:
Not if you're flying VFR. And like Jeff said, if you're IFR, you do need an instrument ticket.
Click to expand...

Understood, but as stated multiple times, the question was about practicing instrument approaches, under VFR rules, under the hood in VMC conditions with a safety pilot.

As Ron said, I don't *have* to understand it for it to be the law, but I *like* to understand it. Maybe asking the rules to make sense is too much. :rofl:
 
TangoWhiskey said:
Understood, but as stated multiple times, the question was about practicing instrument approaches, under VFR rules, under the hood in VMC conditions with a safety pilot.
Click to expand...

In which case, the safety pilot doesn't need an IR, but does need category and class. :yes:
 
TangoWhiskey said:
As Ron said, I don't *have* to understand it for it to be the law, but I *like* to understand it. Maybe asking the rules to make sense is too much. :rofl:
Click to expand...

Now you're learning!

The "required crewmember" is the real basis for the class rating requirement.

It's quite possible that the hooded pilot may tell the safety pilot not to touch the controls. I personally wouldn't act as a safety pilot for someone who told me that.

When I'm under the hood I make it clear that I expect the safety pilot to warn me of traffic or terrain, tell me if he needs me to do something, and to say "my airplane" and take the controls if he needs to do so to keep us alive. And that's the minimum I expect to do when I'm acting as a safety pilot for someone else.
 
TMetzinger said:
When I'm under the hood I make it clear that I expect the safety pilot to warn me of traffic or terrain, tell me if he needs me to do something, and to say "my airplane" and take the controls if he needs to do so to keep us alive. And that's the minimum I expect to do when I'm acting as a safety pilot for someone else.
Click to expand...

That's pretty much the role I expect to play, too. :thumbsup:
 
TangoWhiskey said:
Understood, but as stated multiple times, the question was about practicing instrument approaches, under VFR rules, under the hood in VMC conditions with a safety pilot.

As Ron said, I don't *have* to understand it for it to be the law, but I *like* to understand it. Maybe asking the rules to make sense is too much. :rofl:
Click to expand...

If you can find a way to fly a ME under SE rules, then you're golden!

You *can* fly instrument procedures under VFR rules, and if you do, the SP only needs to be a VFR pilot.
 
TangoWhiskey said:
Understood, but as stated multiple times, the question was about practicing instrument approaches, under VFR rules, under the hood in VMC conditions with a safety pilot.

As Ron said, I don't *have* to understand it for it to be the law, but I *like* to understand it. Maybe asking the rules to make sense is too much. :rofl:
Click to expand...
Don't know if it's "too much" but it certainly can be frustrating. I agree with you that requiring a safety pilot to have an AMEL rating if the flight is in a twin (or even more crazy disallowing a SP with AMEL or ASES without ASEL) has no logic behind it, especially when you realize that an AMEL allows acting as SP in a King Air C90 even if the SP has never flown anything but a Seminole.
 
gismo said:
Don't know if it's "too much" but it certainly can be frustrating. I agree with you that requiring a safety pilot to have an AMEL rating if the flight is in a twin (or even more crazy disallowing a SP with AMEL or ASES without ASEL) has no logic behind it, especially when you realize that an AMEL allows acting as SP in a King Air C90 even if the SP has never flown anything but a Seminole.
Click to expand...

Well, considering the regs would allow the same person who has only flown a Seminole to get in that King Air and fly it as PIC, I think they're at least consistent - And while that would be a crazy thing to do, if the FAA were to outlaw it then we'd all be screaming about over-regulation.

As imperfect as the FAA is, they're really pretty decent for a government organization. Their rules aren't ridiculously restrictive and they do have solid reasons behind them, and the people seem to be generally helpful. :thumbsup:
 
flyingcheesehead said:
Well, considering the regs would allow the same person who has only flown a Seminole to get in that King Air and fly it as PIC, I think they're at least consistent - And while that would be a crazy thing to do, if the FAA were to outlaw it then we'd all be screaming about over-regulation.

As imperfect as the FAA is, they're really pretty decent for a government organization. Their rules aren't ridiculously restrictive and they do have solid reasons behind them, and the people seem to be generally helpful. :thumbsup:
Click to expand...

Yeah, because having to grab the yoke and perform an evasive maneuver in a twin with two turning props is soooooo difficult. :rolleyes:
 
EdFred said:
Yeah, because having to grab the yoke and perform an evasive maneuver in a twin with two turning props is soooooo difficult. :rolleyes:
Click to expand...

Yep...so difficult that someone who has 200 hours in the last year in SE planes cannot do it, but someone with an ME rating who hasn't seen the inside of anything smaller than a 737 for the last 20 years can.:hairraise:
 
JeffDG said:
Yep...so difficult that someone who has 200 hours in the last year in SE planes cannot do it, but someone with an ME rating who hasn't seen the inside of anything smaller than a 737 for the last 20 years can.:hairraise:
Click to expand...

So much for the FAA and their solid reasons. :D
 
JeffDG said:
I've said they're consistent, not that they have solid reasons.
Click to expand...
I'm not terribly impressed with their consistency either (within the rules as well as within the various interpretations of those rules by field FAA folks).
 
JeffDG said:
Yep...so difficult that someone who has 200 hours in the last year in SE planes cannot do it, but someone with an ME rating who hasn't seen the inside of anything smaller than a 737 for the last 20 years can.:hairraise:
Click to expand...

To me, this still makes sense, for three reasons:

1) If an actual engine failure occurs and the hooded pilot does not handle it properly, the safety pilot should know how to handle it.

2) If the pilot is not properly paying attention to their airspeed, the safety pilot will be able to recognize it and alert the pilot to not fixate on other things.

3) Let's say said safety pilot isn't the brightest bulb and/or the pilot has not properly given them the "hands off!" briefing - A non-multi rated person might get the bright idea to fail an engine at a very inopportune time. The chances of this are slim, but not zero.

Sure, an ASEL pilot can do normal maneuvers with both engines turning - But as we all know, the training that we go through and the rules that exist are not there merely to keep us safe when everything goes right.
 
Only way to find out their reasoning for sure is to go find the Federal Register issue where the NPRM for this rule was first published. Since it's been this way as long as I've been flying, that would take you back before 1969 -- no idea how much before.

Good luck, and good hunting.
 
flyingcheesehead said:
To me, this still makes sense, for three reasons:

1) If an actual engine failure occurs and the hooded pilot does not handle it properly, the safety pilot should know how to handle it.
Click to expand...
While that would be nice but what does the view limiting device have to do with that assuming (as should be the case) the ME pilot removes said device as soon as either pilot discovers the failure?
2) If the pilot is not properly paying attention to their airspeed, the safety pilot will be able to recognize it and alert the pilot to not fixate on other things.
Click to expand...
Seems like an ASEL safety pilot would just as capable of doing that.
3) Let's say said safety pilot isn't the brightest bulb and/or the pilot has not properly given them the "hands off!" briefing - A non-multi rated person might get the bright idea to fail an engine at a very inopportune time. The chances of this are slim, but not zero.
Click to expand...
Seems like the chances would be the same whether or not the pilot flying was hooded.
Sure, an ASEL pilot can do normal maneuvers with both engines turning - But as we all know, the training that we go through and the rules that exist are not there merely to keep us safe when everything goes right.
Click to expand...
I could see a requirement for the SP to be multi rated if (and only if) the instrument practice included engine cuts or single engine work, otherwise (with an appropriate briefing) I still say anyone capable of acting as SP in a single could do as good a job in a twin with or without a multi rating.
 
gismo said:
While that would be nice but what does the view limiting device have to do with that assuming (as should be the case) the ME pilot removes said device as soon as either pilot discovers the failure?
Click to expand...

Were it me, I'd be trying to handle the failure under the hood - As I would assume anyone confident with their skills would be - But if that confidence is not warranted...

Seems like an ASEL safety pilot would just as capable of doing that.
Seems like the chances would be the same whether or not the pilot flying was hooded.
Click to expand...

Well, to an ASEL pilot the danger zone lies at the bottom of the white arc, and they don't necessarily know what the blue line and that other red line mean...

I could see a requirement for the SP to be multi rated if (and only if) the instrument practice included engine cuts or single engine work, otherwise (with an appropriate briefing) I still say anyone capable of acting as SP in a single could do as good a job in a twin with or without a multi rating.
Click to expand...

99.9% of the time, I agree.
 
You must log in or register to reply here.
Back
Top