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Jason W (FlyNE)
Do you have to be current to carry passengers to act as safety pilot? (Assuming that you are not logging the time as acting PIC)
Do you have to be current to carry passengers to act as safety pilot? (Assuming that you are not logging the time as acting PIC)
You don't need to meet any PIC qualification/curency requirement if you are not acting as PIC.Hmm. That brings up something that I hadn't considered before. You also don't have to be night current to act as safety pilot at night.
"Under IFR" (the rules) is enough. The reference is 61.55(a) which deals with SIC qualifications.You mean an IFR flight plan or in IMC, Mark?
I can't say I have heard that one before.
Interesting -- I wonder if anyone in AFS-800 realizes what they did when they reorganized 61.55 in 2005 to cover the SIC type rating issue. I'll bet this was an inadvertant omission, and I've got an email out to AFS-800 to see whether that's true or not. It was certainly done without fanfare, and a lot of folks probably missed that change in the wording."Under IFR" (the rules) is enough. The reference is 61.55(a) which deals with SIC qualifications.
Until around 2005, there was a 61.55(d)(4) that exempted safety pilots from 61.55 altogether (if you have the old FAQ you'll see it referred to in one of the answers). You'll see that in the current version, the only safety pilot exemption (it's in 61.55(f)(4)) is from the special SIC familiarization requirements in 61.55(b).
Ron,Interesting -- I wonder if anyone in AFS-800 realizes what they did when they reorganized 61.55 in 2005 to cover the SIC type rating issue. I'll bet this was an inadvertant omission, and I've got an email out to AFS-800 to see whether that's true or not. It was certainly done without fanfare, and a lot of folks probably missed that change in the wording.
If you are seeing the old language with the full exemption in your current FAR hardcopy, I'd go to the publisher. Here's the US General Printing Office official site's version of 61.55, current as of September 4, 2008Ron,
I missed this too. Looking back in my hard copy versions of FAR/AIM, years 2005 and earlier and 2007 and later pretty much reflect the same wording. The 2006 version is the strange one, only lasting about one year/publication cycle.
gary
If you are seeing the old language with the full exemption in your current FAR hardcopy, I'd go to the publisher. Here's the US General Printing Office official site's version of 61.55, current as of September 4, 2008
http://ecfr.gpoaccess.gov/cgi/t/tex...v8&view=text&node=14:2.0.1.1.2.1.1.33&idno=14
Whether the limitataion of the exemption was intentional or not I haven't a clue, but I agree with Ron that it was without any real fanfare. I don't recall having seen anything about the changes to 61.55 that even mentioned it.
FWIW I'm pretty sure the exemption goes back at least to the 1997 FAR Part 61 revision.Mark,
Perhaps I worded my response poorly. My current hard copy and online versions are in synch. I was just saying that the only year I can find with the "exemption" that I believe you were referring to was in the published 2006 FAR/AIM.
FWIW I'm pretty sure the exemption goes back at least to the 1997 FAR Part 61 revision.
I'm not sure it makes it any more interesting - the FAQ was based on the wording of the 61.55 that existed before the change where the exemption for safety pilots was very clear.To make it MORE interesting, the Q&A from John Lynch before 2005 made it clear that an SIC safety pilot did NOT have to have an instrument rating, because
FWIW I'm pretty sure the exemption goes back at least to the 1997 FAR Part 61 revision.
The change which lost that exemption was introduced in the Federal Register in late 2004, and may be found at http://edocket.access.gpo.gov/2004/pdf/04-25415.pdf. There is nothing in that notice about eliminating the safety pilot exemption from 61.55(a)(2), and states that the old paragraph (d) is merely renumbered paragraph (f). Thus, it appears to have been an inadvertant omission, but I'll wait until I hear from John Lynch (the person listed as the point of contact on the matter) about it.
It doesn't. 61.55(f) still exempts safety pilots from 61.55(b) which is where the requirements you are talking about appear.At least some parts of 61.55 refer to "operations requiring a second-in-command pilot flight crewmember". I realize that a safety pilot is a "required crewmember" when the pilot flying is wearing a view limiting device but does that really require a "second-in-command pilot flight crewmember"?
If so the wording of the rule also requires that a safety pilot be rather well acquainted with the ship and have performed 3 takeoffs and landings as the sole manipulator. No way can I see this is supposed to apply to safety pilots.
Well, you're either a PIC crewmember or an SIC crewmember, and if you're not acting as PIC, then you're acting as SIC. And I believe I've seen an interpretation from the Chief Counsel's office saying a 91.109(b) safety pilot is an SIC if not acting as PIC.At least some parts of 61.55 refer to "operations requiring a second-in-command pilot flight crewmember". I realize that a safety pilot is a "required crewmember" when the pilot flying is wearing a view limiting device but does that really require a "second-in-command pilot flight crewmember"?
61.55(f)(4) specifically exempts SIC's required only as 91.109(b) safety pilots from those requirements, which are in 61.55(b), so that's clearly not an issue. The problem is that the paragraph 61.55(f)(4) replaced in the pre-SIC-type-rating version of 61.55 (paragraph (d)(4) in the old reg) also specifically exempted SIC's required only by 91.109(b) as safety pilots from the IR requirement in 61.55(a)(2) for IFR operations; that second phrase was lost when 61.55(d) became 61.55(f) in 2005, and that's what all this discussion is about.If so the wording of the rule also requires that a safety pilot be rather well acquainted with the ship and have performed 3 takeoffs and landings as the sole manipulator. No way can I see this is supposed to apply to safety pilots.
Not quite. The former 61.55(d)(4) did not "specifically" exempt safety pilots from the instrument rating requirement. It exempted safety pilots from all 61.55 requirements in general terms.pre-SIC-type-rating version of 61.55 (paragraph (d)(4) in the old reg) also specifically exempted SIC's required only by 91.109(b) as safety pilots from the IR requirement in 61.55(a)(2) for IFR operations; that second phrase was lost when 61.55(d) became 61.55(f) in 2005, and that's what all this discussion is about.
Thanks for that info. I didn't have a copy of the old wording and was going with the last sentence of John Lynch's explanation of the intent of the old wording:Not quite. The former 61.55(d)(4) did not "specifically" exempt safety pilots from the instrument rating requirement. It exempted safety pilots from all 61.55 requirements in general terms.
==============================
(d) This section does not apply to a person who is:
(4) Designated as a safety pilot for purposes required by
Sec. 91.109(b) of this chapter.
==============================
No language was lost. Language was added.
Result is the same, but we might as well get the situation straight when explaining it
Answer: Ref. § 61.55(d)(4); § 61.3(e); § 91.109(b); A safety pilot who is not acting as the PIC is not required to meet the instrument rating requirements of § 61.3(e). The instrument rating requirements of § 61.3(e) are PIC requirements.
As per § 61.55(d)(4), the rule provides an exception to the SIC pilot qualification requirements of § 61.55(a)(2) for being required to hold an instrument rating.
Define "appropriately rated safety pilot":
This person must hold at least a Private Pilot certificate. They must also have a current medical certificate and be current in the category and class of aircrat being flown. (i.e., airplane single-engine land). This person need not be instrument rated
According to the ASA Instrument Oral Exam Guide:
To follow up on Dan's comment, in an undocumented and unexplained change to 14 CFR 61.55 in 2005, the FAA removed the exception to the requirement for an IR for safety pilots when the flight is conducted under IFR. Thus, if the flight is done on an IFR clearance (regardless of actual conditions), the safety pilot must have an instrument rating (although instrument currency is not required unless the safety pilot is also acting as PIC -- 61.57(c) only applies to the PIC, not the SIC).
As a side note, I've queried the author of that regulation to find out why that change was made or if it was even done intentionally or not. I have not yet received a reply.
It's not a PIC issue, Dan, it's an SIC issue.Ron,
Wouldn't the Safety Pilot only need to be PIC when flying IFR only when the left seat pilot was working on the IR and not yet IR? Or in any condition when acting as SP?
...or if the left seat pilot wasn't instrument current per 61.57(c), or didn't have a current medical, etc.Wouldn't the Safety Pilot only need to be PIC when flying IFR only when the left seat pilot was working on the IR and not yet IR?
No -- the pilots may choose to make the safety pilot the PIC for any number of reasons, but the safety pilot is not required to be PIC unless the hooded pilot isn't PIC-qualified/current for the operation they conduct.Or in any condition when acting as SP?
If so, it's been wrong for 39 years or more, since it was that way when I started serious flight training in 1969. This isn't like the AGI/IGI issue, where they admitted almost immediately that they'd screwed up (but still took 10 years to propose the fix and heading towards another year and a half to implement it).I think I posted the two versions of the reg in another thread. Ron things it was probably unintentional. I tend to agree since the Federal Register that discusses the changes doesn't even mention it, although I've heard some folks argue that the FAA never really intended to exempt safety pilots from needing an IR when acting as required crew under IFR and that all the change did was to "fix" it.
Uhm..Did you read what I wrote compared to everything else in this thread? The ASA book says that the safety pilot must be current.And that's true as long as flight is not "under IFR."
That said, I doubt many DPEs will go into the legal whys and wherefores of this issue.
Uhm..Did you read what I wrote compared to everything else in this thread? The ASA book says that the safety pilot must be current.
The ASA book is wrong. Wouldn't be the first time.Uhm..Did you read what I wrote compared to everything else in this thread? The ASA book says that the safety pilot must be current.
Uhm..Did you read what I wrote compared to everything else in this thread? The ASA book says that the safety pilot must be current.
Reply received from AFS-840 -- the change was intentional. He admitted that they didn't explain it very well in the Federal Register, but it was their intent to require the safety pilot to have an IR if the flight was operating under IFR. So, we'll just have to start teaching it differently to match the new rule.As a side note, I've queried the author of that regulation to find out why that change was made or if it was even done intentionally or not. I have not yet received a reply.