Help me understand the regs! Can I log?

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Corncob

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Corncob
Howdy PoA, my questions feel a bit complicated and step into multiple definitions and regs. I was hoping for some discussion regarding your thoughts! I've also seen "The definitive PIC thread" and EdFred's links to the flowchart and app to clarify PIC rules. Please call me out if any legal interpretation/assumption in this post is incorrect!

I'm private, instrument-rated, ASEL. No further endorsements past what you would typically expect after training in 172s. Friend owns a Cirrus. He is also private, ASEL, not instrument-rated yet but is training for it. I have no Cirrus-related training or endorsements by a CFI, but friend lets me fly with him. Of course both of us are within the flight review period, VFR current, and have valid medicals.

The engine is over 200 HP. It has flaps, controllable-pitch propeller, but no retractable landing gear.
Q1) Would these specifications classify the aircraft as high performance, but not complex?

By EdFred's app, rating "pertains to being rated in category and class, or a type rating. It does not refer to an instrument rating, nor any endorsements such as [...] high performance, complex [...] Nor does it apply to being current." By this assumption, I should be rated to fly the Cirrus. If rated, but not endorsed, I believe I cannot be acting PIC in any scenario, but I could log PIC under other circumstances below.
Q2) Am I rated to fly the Cirrus?

Scenario 1: My instrument currency has just lapsed, and I have 6 calendar months to perform & log "6 HITS" in simulated IMC with a safety pilot. I'm under the hood, friend is safety pilot (required crew, thus not a passenger). I'm the sole manipulator of the controls (and assuming I am rated to fly the aircraft).
Q3) Can I renew my instrument currency in this manner?
Q4) Can I log PIC time while under the hood?

Scenario 2: Friend would like a safety pilot as part of the 40 hour actual/simulated instrument minimum aeronautical experience requirement. Assuming I am rated, in this case I am not the sole manipulator of the controls. By EdFred's flowchart, in order to log PIC time as a safety pilot, I would need to be endorsed for the aircraft (any applicable high-performance / complex designation).
Q5) Can I act as a legal safety pilot for friend?
Q6) Can I log PIC time as a safety pilot without the appropriate high-performance / complex endorsement(s)?
 
The answer is "yes" to everything except #6. You cannot log PIC because you are neither sole manipulator nor acting as PIC (of an aircraft or operation requiring more than 1 pilot), because you can't act as PIC. You aren't qualified to do so. You can act as, and log, SIC instead.
 
As I become more familiar with FAA regulations and their application, I predict the answer to each of your questions is yes, no, and maybe.
 
The engine is over 200 HP. It has flaps, controllable-pitch propeller, but no retractable landing gear.
Q1) Would these specifications classify the aircraft as high performance, but not complex?
Correct - HP, not Complex

Q2) Am I rated to fly the Cirrus?
Yes, you are rated - but "rated" and "should" are different questions. I would not fly the Cirrus until being trained by the nice Cirrus people. And I think his insurance people would want that as well.

Scenario 1: My instrument currency has just lapsed, and I have 6 calendar months to perform & log "6 HITS" in simulated IMC with a safety pilot. I'm under the hood, friend is safety pilot (required crew, thus not a passenger). I'm the sole manipulator of the controls (and assuming I am rated to fly the aircraft).
Q3) Can I renew my instrument currency in this manner?
Yes

Q4) Can I log PIC time while under the hood?
Yes

Scenario 2: Friend would like a safety pilot as part of the 40 hour actual/simulated instrument minimum aeronautical experience requirement. Assuming I am rated, in this case I am not the sole manipulator of the controls. By EdFred's flowchart, in order to log PIC time as a safety pilot, I would need to be endorsed for the aircraft (any applicable high-performance / complex designation).
Q5) Can I act as a legal safety pilot for friend?
Yes

Q6) Can I log PIC time as a safety pilot without the appropriate high-performance / complex endorsement(s)?
No. If flying in a Cirrus, you need a High Performance endorsement. It's not that hard - maybe two, three flights with a CFI. I would go ahead and get it anyway - good to have.
 
61.31(f).
f) Additional training required for operating high-performance airplanes.

(1) Except as provided in paragraph (f)(2) of this section, no person may act as pilot in command of a high-performance airplane (an airplane with an engine of more than 200 horsepower), unless the person has -

(i) Received and logged ground and flight training from an authorized instructor in a high-performance airplane, or in a full flight simulator or flight training device that is representative of a high-performance airplane, and has been found proficient in the operation and systems of the airplane; and

(ii) Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a high-performance airplane.
 
You must be new to these questions as they have been answered hundreds of times.

Q1 You are rated, you can log PIC when you are sole manipulator of the controls, but not act as PIC because you don't have the required High Performance endorsement
Q2 The rating is single engine - land, the Cirrus is a single engine - land aircraft and you are rated, but may not act as PIC without the High Performance endorsement
Q3) You are rated and may log PIC while sole manipulator of the controls, you may not act as PIC, you may log the conditions of flight and any of the 6 HITS+ towards your IFR currency
Q4) Absolutely
Q5) You may act as safety pilot as long as you hold a medical or basic med, but the pilot under the hood must act as PIC, as you are not qualified
Q6) Yes, but you can't log the time as PIC, just log it as safety pilot and second in command
 
Corncob said:
Howdy PoA, my questions feel a bit complicated and step into multiple definitions and regs. I was hoping for some discussion regarding your thoughts! I've also seen "The definitive PIC thread" and EdFred's links to the flowchart and app to clarify PIC rules. Please call me out if any legal interpretation/assumption in this post is incorrect!

I'm private, instrument-rated, ASEL. No further endorsements past what you would typically expect after training in 172s. Friend owns a Cirrus. He is also private, ASEL, not instrument-rated yet but is training for it. I have no Cirrus-related training or endorsements by a CFI, but friend lets me fly with him. Of course both of us are within the flight review period, VFR current, and have valid medicals.

The engine is over 200 HP. It has flaps, controllable-pitch propeller, but no retractable landing gear.
Q1) Would these specifications classify the aircraft as high performance, but not complex?

By EdFred's app, rating "pertains to being rated in category and class, or a type rating. It does not refer to an instrument rating, nor any endorsements such as [...] high performance, complex [...] Nor does it apply to being current." By this assumption, I should be rated to fly the Cirrus. If rated, but not endorsed, I believe I cannot be acting PIC in any scenario, but I could log PIC under other circumstances below.
Q2) Am I rated to fly the Cirrus?

Scenario 1: My instrument currency has just lapsed, and I have 6 calendar months to perform & log "6 HITS" in simulated IMC with a safety pilot. I'm under the hood, friend is safety pilot (required crew, thus not a passenger). I'm the sole manipulator of the controls (and assuming I am rated to fly the aircraft).
Q3) Can I renew my instrument currency in this manner?
Q4) Can I log PIC time while under the hood?

Scenario 2: Friend would like a safety pilot as part of the 40 hour actual/simulated instrument minimum aeronautical experience requirement. Assuming I am rated, in this case I am not the sole manipulator of the controls. By EdFred's flowchart, in order to log PIC time as a safety pilot, I would need to be endorsed for the aircraft (any applicable high-performance / complex designation).
Q5) Can I act as a legal safety pilot for friend?
Q6) Can I log PIC time as a safety pilot without the appropriate high-performance / complex endorsement(s)?
Click to expand...
Substitute FAR 61 for drugs

 
WDD said:
Q2) Am I rated to fly the Cirrus?
Yes, you are rated - but "rated" and "should" are different questions. I would not fly the Cirrus until being trained by the nice Cirrus people. And I think his insurance people would want that as well.
Click to expand...

Absolutely agreed. Insurance is a whole different topic. Just interested in the legal definitions here :)
 
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"Rated" for the aircraft = the category and class (and type if the airplane requires a type rating) of the airplane is printed on the back of your pilot certificate.

(no, a Cirrus SR20 OR SR22 is not a jet that requires a type rating.)

(No, your question is not complicated)
 
midlifeflyer said:
"Rated" for the aircraft = the category and class (and type if the airplane requires a type rating) of the airplane is printed on the back of your pilot certificate.

(no, a Cirrus SR20 OR SR22 is not a jet that requires a type rating.)

(No, your question is not complicated)
Click to expand...

I guess the only real question here was to clarify some definitions and determine if a Cirrus required a type rating, and determining if endorsements were apart of the “rating” definition. After reading the responses, I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
 
Corncob said:
I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
Click to expand...
A lot of people are surprised when they read the regs critically.
 
Corncob said:
I guess the only real question here was to clarify some definitions and determine if a Cirrus required a type rating, and determining if endorsements were apart of the “rating” definition. After reading the responses, I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
Click to expand...
The simplest explanation is the very first part of the Universal Rule of Logging Flight Time (61.51).

§ 61.51 Pilot logbooks.
(a) Training time and aeronautical experience. Each person must document and record the following time in a manner acceptable to the Administrator:
(1) Training and aeronautical experience used to meet the requirements for a certificate, rating, or flight review of this part.
(2) The aeronautical experience required for meeting the recent flight experience requirements of this part.​

That's the only thing the FAA cares about. The FAA issues certificates and ratings. The FAA gets to decide what types of time counts toward those certificates, ratings and qualifications.

And, of course, that friend who is acting as PIC is also taking responsibility for your screw-ups (you are too).

If you want a broad brush, try my article, Logging vs Being PIC.
 
Corncob said:
I guess the only real question here was to clarify some definitions and determine if a Cirrus required a type rating, and determining if endorsements were apart of the “rating” definition. After reading the responses, I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
Click to expand...
Just to be clear, once you have your single engine land certificate, you can PIC in pretty much any single engine piston aircraft you can lay your hands on. The only exceptions are the ones you also need an endorsement for (tail wheel, high performance, complex, pressurized). But there is no Faa requirement to have training in a specific model before being PIC. I’m fairly noob compared to many here and I’ve been PIC in 3 or 4 planes that I’d never even sat in before, let alone had training in. Read the poh and make sure you know where everything is and how it works, and go fly…..
 
Corncob said:
After reading the responses, I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
Click to expand...

There is nothing in the regulations that requires ANY training for, with a couple of exceptions, any aircraft that you have the appropriate ratings (category, class, type if required) and endorsement (HP, complex, high altitude, tailwheel).

You can train in a 172, and fly, without any training any ASEL fixed gear with 200 HP or less. Or, say you do your PP in a J3 Cub, so you have tailwheel endorsement. You could then jump into a Pitts and fly it.

INSURANCE drives the requirements to fly specific make/model aircraft. But they only drive the requirements to BE the PIC.
 
Corncob said:
I guess the only real question here was to clarify some definitions and determine if a Cirrus required a type rating...
Click to expand...
Why would an SR-series require a type rating. The SF50 does, though.
 
Cirrus has a specific training syllabus and most renters and many insurance won’t cover you unless you’ve taken the official training. That’s a cirrus thing, not an Faa thing.
 
Corncob said:
I guess the only real question here was to clarify some definitions and determine if a Cirrus required a type rating,
Click to expand...
Does this help?

§ 61.31 Type rating requirements, additional training, and authorization requirements.
(a) Type ratings required. A person who acts as a pilot in command of any of the following aircraft must hold a type rating for that aircraft:
(1) Large aircraft (except lighter-than-air).
(2) Turbojet-powered airplanes.
(3) Other aircraft specified by the Administrator through aircraft type certificate procedures.​

You'll discover a Cirrus piston doesn't fit any of those.
 
Corncob said:
...., I am a bit surprised that I am able to renew instrument currency, log PIC time, act as safety pilot, and pretty much anything else in a plane I have 0 training in, as long as friend next to me is acting PIC.
Click to expand...

I'm with you, and I think we all agree it's a bad idea. It's a case where we can legally choose to do unwise things. A good reminder that flying smart starts with being wise.
 
There are also the MU-2, R-22 and R-44 that require specific training and currency to fly. But those are the exceptions.
 
WDD said:
I'm with you, and I think we all agree it's a bad idea. It's a case where we can legally choose to do unwise things. A good reminder that flying smart starts with being wise.
Click to expand...
I'm not sure everything in that list is unwise. Sure, an inexperienced 152 pilot would not be smart hopping into a pn SR20 and go fly. But what's unwise about an experienced PIC in a Cirrus allowing their friend, who has never flown anything other than that 152 to handle the controls or be their safety pilot? My very first light GA flight was with a friend who let me handle the controls of his Cutlass. I didn't log anything. I wasn't even a pilot.

This sole manipulator logging has been with us for a long long time. Just a guess, but I doubt it has had any appreciable effect on the accident rate.
 
Wasn’t referring to everything in that list. Just the part of flying a plane you’ve not been checked on or trained could very well be unwise.
 
WDD said:
Wasn’t referring to everything in that list. Just the part of flying a plane you’ve not been checked on or trained could very well be unwise.
Click to expand...
Self-checkouts are a very reasonable option for a lot of pilots.
 
WDD said:
Wasn’t referring to everything in that list. Just the part of flying a plane you’ve not been checked on or trained could very well be unwise.
Click to expand...
It could indeed. It could also be ok. It's an experience thing. Not hours.

The thing about transitions is that, the more you've done, the easier they get. Your brain begins to focus on the handful of things that are different. At the same time, the transition experience tells you when you need more.
 
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