Logging Instrument Time

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James D Hudson

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JamesDHudson
I am an instrument pilot working towards my commercial. Im going up to build hours.
My buddy is a PPL and needs hours towards his instrument.
In VFR weather one of us can log PIC under the hood as sim instrument while the other logs PIC as safety pilot.

What about if we go on an IFR Flight plan, I being PIC. While not in clouds my buddy has hood on logging as such. But what if we enter a long period in the clouds?
Can he take his hood off and log it as actual instrument, or does he have to keep the hood and do it all simulated?
 
I'm no expert, but I believe in your scenario, your non-instrument-rated buddy cannot log PIC or any other kind of time in IMC with you in the plane. He can't just put a hood on and call it simulated, he is in IMC and he must have an instrument rating to log PIC in IMC. The only way he can log any time in IMC would be with an instructor logging dual. That's my opinion, off the top of my head.
 
I forgot about that legal interpretation. I remember having this discussion a couple of years ago. I still don't quite understand why an instrument rated private pilot can just allow a non-IR pilot to be the sole manipulator of the controls of a flight in IMC, but that FAA legal interpretation covers that scenario explicitly. It's like the IR pilot is acting as a pseudo-safety pilot for the other guy, even though as spelled out in the legal interpretation quoted, the IR pilot is NOT a required crewmember and is NOT a safety pilot and cannot log time while the non-IR pilot is the sole manipulator of controls. It just seems wonky to me. But hey, it's a good way for guys to get some instrument experience, so I'm not complaining.
 
pburger said:
I forgot about that legal interpretation. I remember having this discussion a couple of years ago. I still don't quite understand why an instrument rated private pilot can just allow a non-IR pilot to be the sole manipulator of the controls of a flight in IMC, but that FAA legal interpretation covers that scenario explicitly. It's like the IR pilot is acting as a pseudo-safety pilot for the other guy, even though as spelled out in the legal interpretation quoted, the IR pilot is NOT a required crewmember and is NOT a safety pilot and cannot log time while the non-IR pilot is the sole manipulator of controls. It just seems wonky to me. But hey, it's a good way for guys to get some instrument experience, so I'm not complaining.
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You don't need the legal interpretation, because it's always been that way.

You can ~log~ PIC in two situations:
1. Be sole manipulator of an aircraft for which you are rated.
2. If more than one crewmember is required and you're ~acting~ as PIC.

Since only one crewmember is required to fly in actual instrument conditions, nobody can log time under the provision of #2. The only person who can log can only do so under the provision of #1.
 
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dmspilot said:
You can ~log~ PIC in two situations:
1. Be sole manipulator of an aircraft for which you are rated.
2. Be a required crewmember when more than one crewmember is required.
(Who ~acts~ as PIC is irrelevant for the purpose of logging.)
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It's relevant for the safety pilot since that determines if he or she is logging PIC or SIC time. In the case of the OP the safety pilot has to act as PIC under IFR so would be logging PIC time when allowed to log flight time.
 
tlglenn said:
It's relevant for the safety pilot since that determines if he or she is logging PIC or SIC time. In the case of the OP the safety pilot has to act as PIC under IFR so would be logging PIC time when allowed to log flight time.
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Post edited. What I meant was that acting PIC is not sufficient to log time. Just to be clear, the safety pilot can only log time when the other pilot is under the hood.
 
Wheels said:
If you are in actual then your friend can still log PIC as the sole manipulator of the controls. What changes is that you will not be able to log the time while he flies in IMC.

Here’s what the lawyers at the FAA have to say about it. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2011/walker - (2011) legal interpretation.pdf
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I would modify your second sentence to read "What changes is that you will not be able to log the time while he flies without a hood." My recollection is that a safety pilot is required whenever the pilot at the controls is wearing a hood, regardless of flight conditions, and that makes both pilots required under the regulations. If the pilot at the controls flies without the hood while the aircraft is in instrument flight conditions, then only the pilot at the controls can log that portion of the flight time.
 
I think where many are having trouble with this scenario is that the actual instrument rated PIC of the plane, who is ultimately responsible for the safe conduct of the flight while in IMC, isn’t allowed by regulation or CC interpretation to log that time as PIC just because he isn’t manipulating the controls. He basically has operational control but not physical control of the controls. :confused: It does seem to defy logic and the whole concept of being “in command”. :D
 
Palmpilot said:
I would modify your second sentence to read "What changes is that you will not be able to log the time while he flies without a hood." My recollection is that a safety pilot is required whenever the pilot at the controls is wearing a hood, regardless of flight conditions, and that makes both pilots required under the regulations. If the pilot at the controls flies without the hood while the aircraft is in instrument flight conditions, then only the pilot at the controls can log that portion of the flight time.
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I disagree. According to 91.109 one of the requirements is that the safety pilot has adequate vision forward and to the sides of the plane. If you are in IMC then that visibility doesn’t exist so it doesn’t matter if the person flying keeps his hood on or not, he is not flying in simulated instrument flight so a safety pilot is not required. If a safety pilot is not required then he can not log the time.
 
Being PIC by virtue of being "in charge" (responsible) for the flight (ie, "captain") IS independent of manipulating the controls. Manipulating the controls has been assigned to a crewmember. The "captain" is still PIC.
 
Wheels said:
I disagree. According to 91.109 one of the requirements is that the safety pilot has adequate vision forward and to the sides of the plane. If you are in IMC then that visibility doesn’t exist so it doesn’t matter if the person flying keeps his hood on or not, he is not flying in simulated instrument flight so a safety pilot is not required. If a safety pilot is not required then he can not log the time.
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Do you believe that I could legally wear a hood inside a cloud without a safety pilot present?
 
Palmpilot said:
Do you believe that I could legally wear a hood inside a cloud without a safety pilot present?
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The FARs only define or require a safety pilot for simulated instrument flight so if you are in actual IMC a safety pilot is not required no matter what you are wearing.
 
Wheels said:
The FARs only define or require a safety pilot for simulated instrument flight so if you are in actual IMC a safety pilot is not required no matter what you are wearing.
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As long as the hood is on, it is simulated instrument conditions no matter what can or cannot be seen outside the window. Otherwise, how would the person under the hood know whether or not he was in actual conditions?

Having said that, in the research I have done, there is no clear cut guidance on this. No definitive answer, so let your conscience be your guide.

Having also said that, it would be poor training for the safety pilot to allow someone to remain under the hood if in actual IMC conditions.
 
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Greg Bockelman said:
As long as the hood is on, it is simulated instrument conditions no matter what can or cannot be seen outside the window.
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91.109
c) No person may operate a civil aircraft in simulated instrument flight unless—
(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;

IMC prevents the safety pilot from having adequate vision to perform his duties as safety pilot, therefore operating an aircraft in simulated instrument flight in IMC would be a violation of the FARs.
 
Wheels said:
IMC prevents the safety pilot from having adequate vision to perform his duties as safety pilot, therefore operating an aircraft in simulated instrument flight in IMC would be a violation of the FARs.
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Ok... I'm the dullest knife in the drawer on this, but I must be missing something here.... How can you be in real IMC and be "simulating instrument flight? Wouldn't you have to be on an IFR flight Plan to even enter a cloud? And if so, who's who in the zoo? Regardless of who is manipulating the controls, somebody better be IFR rated, right? I thought the concept of a safety pilot was to allow a student or a IR pilot to practice in VMC while the safety pilot insures compliance with VFR and watches for the safe conduct of the flight while the pilot is under the hood....
 
Wheels said:
91.109
c) No person may operate a civil aircraft in simulated instrument flight unless—
(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;

IMC prevents the safety pilot from having adequate vision to perform his duties as safety pilot, therefore operating an aircraft in simulated instrument flight in IMC would be a violation of the FARs.
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"Simulated Instrument flight" just means the pilot having vision restricted by artificial means and "adequate vision" just means the safety pilot having a view out the windows not restricted by the aircraft or artificial means. The entire purpose of a safety pilot is to have someone who is able to fulfill see and avoid responsibilities. Those do not end in IMC.

There is nothing about being in IMC which precludes simulated instrument flight. They are not mutually exclusive.

I think your personal read is far more restrictive than the FAAs, so I guess we'll have to agree to disagree.
 
Wheels said:
91.109
c) No person may operate a civil aircraft in simulated instrument flight unless—
(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;

IMC prevents the safety pilot from having adequate vision to perform his duties as safety pilot, therefore operating an aircraft in simulated instrument flight in IMC would be a violation of the FARs.
Click to expand...
I always assumed that "adequate vision forward and to each side of the aircraft" just meant that the safety pilot's view through the windows couldn't be excessively blocked, not that visibility outside the aircraft had to meet some requirement. :dunno:

For example, if the simulated instrument conditions were created by covering the windows, that would not allow the safety pilot to do his or her job.
 
Palmpilot said:
I always assumed that "adequate vision forward and to each side of the aircraft" just meant that the safety pilot's view through the windows couldn't be excessively blocked, not that visibility outside the aircraft had to meet some requirement. :dunno:

For example, if the simulated instrument conditions were created by covering the windows, that would not allow the safety pilot to do his or her job.
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Your assumption is quite correct.
 
SkyDog58 said:
I think where many are having trouble with this scenario is that the actual instrument rated PIC of the plane, who is ultimately responsible for the safe conduct of the flight while in IMC, isn’t allowed by regulation or CC interpretation to log that time as PIC just because he isn’t manipulating the controls. He basically has operational control but not physical control of the controls. :confused: It does seem to defy logic and the whole concept of being “in command”. :D
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Every flight needs a PIC. Every flight needs someone who is 'sole manipulator' of the controls. Typically the same person does both.

If the non-instrument rated pilot is manipulating the controls he can LOG PIC time, whether in IMC or under the hood.

If not in IMC, the other pilot can either log SIC time, or if both pilots agree that the non-flying pilot is PIC, then they can BOTH log PIC time.

If in IMC, the instrument rated pilot is (by definition) PIC, since he is the only one rated, and the other pilot who is flying can still log PIC time as sole manipulator. This is also the scenario when a CFII gives dual in actual IMC.

Can a pilot wear a hood when in IMC? Of course he CAN, but it is redundant. The other pilot better be instrument rated as long as they are in IMC.
 
SkyDog58 said:
I think where many are having trouble with this scenario is that the actual instrument rated PIC of the plane, who is ultimately responsible for the safe conduct of the flight while in IMC, isn’t allowed by regulation or CC interpretation to log that time as PIC just because he isn’t manipulating the controls. He basically has operational control but not physical control of the controls. :confused: It does seem to defy logic and the whole concept of being “in command”. :D
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The trouble is understandable. Here's the underlying concept that's required.

Acting as PIC or as required crew is about duty and responsibility.

Logging flight time, whether called PIC or goopdeloop is an artificial construct solely for the purpose of demonstrating qualification in accordance with FAA rules.

They are that divorced in concept.
 
DGlaeser said:
If in IMC, the instrument rated pilot is (by definition) PIC, since he is the only one rated, and the other pilot who is flying can still log PIC time as sole manipulator. This is also the scenario when a CFII gives dual in actual IMC.
Click to expand...

It's not the same scenario for the instrument rated pilot because the instrument rated pilot cannot log anything while the instrument rated pilot who is a CFII can log PIC time due to serving as an authorized instructor (and being rated to act PIC).
 
midlifeflyer said:
I think your personal read is far more restrictive than the FAAs, so I guess we'll have to agree to disagree.
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I agree, neither of us is going to agree with the other’s interpretation and the only thing that would settle it is an opinion from the chief counsel. I think we already have too many of those so I won’t be writing a letter asking for their opinion. You log it your way and I’ll do it mine and hopefully it will never be a problem for either of us.
 
labbadabba said:
So you can log PIC time in IMC if you're not instrument rated when only flying with a safety pilot?
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Yes. LOGGING of PIC time has nothing to do with VMC or IMC. If you are the sole manipulator and you are RATED, that’s good enough. The regs don’t say anything about weather conditions in regards to LOGGING PIC.
 
labbadabba said:
So you can log PIC time in IMC if you're not instrument rated when only flying with a safety pilot?
Click to expand...
I'm not sure what you are saying. So here are some breakdowns.

A non-instrument rated pilot can log PIC time when flying in actual or simulated instrument conditions.

Simulated instrument conditions require a safety pilot under 91.109.
Actual instrument conditions do not require a safety pilot.
 
midlifeflyer said:
Your assumption is quite correct.
Click to expand...

Back in the 1960s someone came up with the idea of placing orange cellophane on the side windows and windscreen while the instrument student wore blue glasses (or maybe it was the other way around). In any event, the effect was to have the outside world blacked out from the student's perspective while the instructor/safety pilot could still see through the cellophane. It worked (I was a student at the time) but it wasn't long before the feds shut it down because the observer's visibility was too impaired.

Bob
 
midlifeflyer said:
I'm not sure what you are saying. So here are some breakdowns.

A non-instrument rated pilot can log PIC time when flying in actual or simulated instrument conditions.

Simulated instrument conditions require a safety pilot under 91.109.
Actual instrument conditions do not require a safety pilot.
Click to expand...

So this is what was said: "If the non-instrument rated pilot is manipulating the controls he can LOG PIC time, whether in IMC or under the hood."

Which states, within the context of a conversation where a safety pilot was being used, that a non-instrument rated pilot can log PIC time whether in IMC or under the hood.
 
labbadabba said:
So this is what was said: "If the non-instrument rated pilot is manipulating the controls he can LOG PIC time, whether in IMC or under the hood."

Which states, within the context of a conversation where a safety pilot was being used, that a non-instrument rated pilot can log PIC time whether in IMC or under the hood.
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That is correct. But that sentence actually runs two completely independent thought together, so let's deal with them one at a time.

"a non-instrument rated pilot can log PIC time whether in IMC or under the hood." That statement is correct standing all by itself. Here's the rule verbatim, although with some extraneous words about other pilot certificates (sport, recreational, etc) removed.

61.51(e). "A private 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."​

The words mean exactly what they say. No more and no less.

"where a safety pilot was being used." That's just one of a number of things things which can make the flight itself proper or improper. If simulated instrument flight, there must be a safety pilot. If in IMC or on an IFR flight plan, there must be an instrument rated pilot acting as the pilot in command. But neither of those (nor any others) affect the basic logging PIC rule - that a private pilot is entitled to log time spent as the sole manipulator of the controls of an aircraft the pilot is rated for as PIC time toward FAA qualifications and currency.
 
bobmrg said:
Back in the 1960s someone came up with the idea of placing orange cellophane on the side windows and windscreen while the instrument student wore blue glasses (or maybe it was the other way around). In any event, the effect was to have the outside world blacked out from the student's perspective while the instructor/safety pilot could still see through the cellophane. It worked (I was a student at the time) but it wasn't long before the feds shut it down because the observer's visibility was too impaired.

Bob
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I wasn't flying back then, but I remember stories about it.
 
If a tree falls in the middle of the forest and there is no one there except you and your buddy, can you log the time?
 
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