According to FAA regulations, your friend has to be the PIC, which means that in addition to being rated in category and class, he/she must also have any endorsement or type rating if one is required for the aircraft. You can log PIC time for the time that you are sole manipulator of the controls as long as you are rated in category and class, including type rating if one is required for the aircraft.
It is legal. Your buddy is PIC (and responsible). You are a passenger the PIC is allowing to fly the airplane.
What if my buddy and I both want to log PIC time as if he is the safety pilot?
A safety pilot is required by the regs when the pilot flying is wearing a view limiting device. It doesn't need to be VFR or even VMC.
I agree, just pointing it out.
I'm not sure why one would need to submit a question that was answered by the Chief Counsel in 1984 - the somewhat famous "moonless night" letter.
I think that's a common misreading of Walker.
It is easy to answer. In fact, I'd expect the Chief Counsel to punt it as not being "present[ing] a novel or legally significant issue.
OTOH, IMHO, it's a completely worthless question to bother the FAA Chief Counsel with.
You have it as well as the pilot flying if he weren't hooded. Being in reduced visibility doesn't remove the visibility forward and to the side. You see OUT OF the aircraft just fine.
Yes. The key is thatchedthe requirement for “adequate vision” is tied to the requirement to
Sorry, but I agree with the FAA interpretation of the regulation. Not allowing the logging of the time does not decrease the safety of the flight.
Fortunately, the interpretation neither says that nor supports that argument. It’s a hollow argument supported by nothing and contrary to everything.
It would also complicate logging when flying in a broken layer.
I’d like to see the reg that says that. Don’t believe that’s true.
Did you read the Walker interpretation that is linked in post #12? The FAA legal department doesn’t agree with you.
Yes. I did read it.
Nonsense. An instrument rating on the instructor certificate is only needed to log instrument instruction for certain certificates/ratings and IPCs. A regular CFI is free to instruct otherwise in actual conditions. Further, an instructor rating is not required at all for a pilot in command to allow someone else to manipulate the controls in any meteorological conditions.
Perhaps you should read the Walker letter linked above, where it says:
It's "logging PIC 101." 61.51 says, "A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights- ... when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated." Note: rated for the "aircraft," not for the "operation." I don't know how long it's been for you, but the FAA has been absolutely consistent on this for the past 40+ years. Basically, the "logging" rules are independent of the "acting" rules.
This is a lot of words to give the wrong answer when the correct answer was linked in the first reply and explained in the second.
You could try asking them for a copy of the Carr letter first.
That would answer my question if I didn't already have a copy. I think Mark provided it to me. By posting an answer on their website would communicate to a much wider audience. If I have my count right, I have asked the General Counsel for opinions in 8 cases, they decline to answer only one of them, and it was referred to Flight Standards for a response, which was never forthcoming, even though I followed up several times with them. I think the lack of an answer in this case was because they simply did not have one.
Might want to let that CFII expire because, damn, there's a lot of wrong being said.
61.51
Maybe. It could have been many people. That letter has definitely made the rounds though the years. I think I first saw it on rec.aviation.ifr in the mid-1990s,