Must Safety Pilot Have Complex Endorsement?

[mkosmo]

If the statement was "If they lack a HP endorsement, they cannot act as PIC, but can be the safety pilot and act as and log SIC", well, that would be true.

A bit of a tangent... but has anybody here actually bothered to log SIC in that case? I just don't see the value in putting it in my logbook unless it was something cool and unusual that I would want to document for the purposes of storytelling.

 

[jsstevens]

Dumbest FAQ answer ever.

Yep, you can fly in the soup at 200+kts, in a 6,000lb air craft and you're good. But to watch for other traffic in a ********* ********* ********* **** ******** 172 when it's CAVU requires a class III. Is MacPherson back at the FAA? Holy **** they are retarded.

Don't hold back Ed. How do you really feel?

And welcome back.
John

 

[EdFred]

A bit of a tangent... but has anybody here actually bothered to log SIC in that case? I just don't see the value in putting it in my logbook unless it was something cool and unusual that I would want to document for the purposes of storytelling.

I've never logged SIC. If I'm not (logging) PIC or getting instruction received, it doesn't go in.

 

[Palmpilot]

If only there was a flowchart to answer all these questions.

If only there were a link to such an FAQ.

 

[Palmpilot]

Dumbest FAQ answer ever.

Yep, you can fly in the soup at 200+kts, in a 6,000lb air craft and you're good. But to watch for other traffic in a ********* ********* ********* **** ******** 172 when it's CAVU requires a class III. Is MacPherson back at the FAA? Holy **** they are retarded.

It was Congress, not the FAA, that made that rule. The FAA had to follow the language of the statute exactly in order to meet the deadline in the statute; otherwise, they would have had to go through the NPRM notice-and-comment process, which would have seriously delayed its implementation. From the first answer in the FAQ:

"The FAA did not develop these requirements. The requirements are from the U.S.
Congress, which enacted the FAA Extension, Safety, and Security Act of 2016 (PL 114-
190) (FESSA) on July 15, 2016. Section 2307 of FESSA, Medical Certification of
Certain Small Aircraft Pilots, directed the FAA to “issue or revise regulations to ensure
that an individual may operate as pilot in command of a covered aircraft” if the pilot and
aircraft meet certain prescribed conditions as outlined in FESSA. The FAA regulations
implement the provisions in § 2307 of FESSA."
​

 

[dmspilot]

His statement was:

"If they lack a HP endorsement, they cannot log PIC in a HP aircraft."

That is completely untrue, regardless of context.

The "they" is referring to the safety pilot. The safety pilot can neither act as nor log PIC in a complex aircraft without a complex endorsement. Therefore, his statement is completely true.

 

[MauleSkinner]

A bit of a tangent... but has anybody here actually bothered to log SIC in that case? I just don't see the value in putting it in my logbook unless it was something cool and unusual that I would want to document for the purposes of storytelling.

I saw quite a few logbooks with significant SIC time in Arrows back when I was instructing near a college aviation program.

Didn't think much of it at the time, either, based on those pilots' ability (or lack thereof) to fly a complex airplane.

 

[EdFred]

If only there were a link to such an FAQ.

The link was included in 20,000+ posts of mine until I realized it wasn't being used because the same questions kept coming up over and over, and I said screw it. If you're too stupid to read, you're too stupid to educate. (the general you, not the personal you)

As far as Congress/FAA. The FAA could have easily had Congress word it correctly. I still place the blame squarely on the FAA.

 

[Matthew]

Dumbest FAQ answer ever.

Yep, you can fly in the soup at 200+kts, in a 6,000lb air craft and you're good. But to watch for other traffic in a ********* ********* ********* **** ******** 172 when it's CAVU requires a class III. Is MacPherson back at the FAA? Holy **** they are retarded.

Basic Med can be used for safety piloting, but only if the Basic Med safety pilot is PIC too.

Basic Med was the add-on, and a lot of the other regs still refer to medical requirements.
Maybe, someday real soon now, the other regs will be re-written to simplify things. Or, maybe, Basic Med might be re-written so it isn't limited to PIC roles.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_68-1A.pdf

>>
5.2.2 Status of Required Flightcrew Members

5.2.2.1

...

A pilot acting as a safety pilot per part 91, § 91.109(c), however, would be a required pilot flightcrew member by regulation rather than a passenger. Section 91.109(c) provides that no person may operate a civil aircraft in simulated instrument flight unless 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. Because a safety pilot is a required pilot flightcrew member, the safety pilot is required to hold a valid and appropriate medical certificate in accordance with § 61.3(a). BasicMed privileges can only be exercised by a person acting as safety pilot when that person is also acting as PIC. BasicMed privileges do not extend to anyone other than the person acting as PIC.
<<

 

[Palmpilot]

The link was included in 20,000+ posts of mine until I realized it wasn't being used because the same questions kept coming up over and over, and I said screw it. If you're too stupid to read, you're too stupid to educate. (the general you, not the personal you)

The personal me would find it convenient not to have to search through 20,000+ old posts to find the link when I need it. Also, wasn't that link in the signature line of those posts? Deleting something from your sig line deletes it from the sig line of all your previous posts on this forum as well.

 

[flyingcheesehead]

A bit of a tangent... but has anybody here actually bothered to log SIC in that case? I just don't see the value in putting it in my logbook unless it was something cool and unusual that I would want to document for the purposes of storytelling.

Yes, once. SIC time is still good towards total time, and I didn't yet have 1500 hours at that point so total time was still worth something.

The "they" is referring to the safety pilot. The safety pilot can neither act as nor log PIC in a complex aircraft without a complex endorsement. Therefore, his statement is completely true.

Your misquoting him and changing "complex" to "HP" reveals flaws in your reading comprehension.

I did not misquote him, and I did not change anything. I clicked "Quote". In fact, if you go back to the post I quoted, it still says HP there too, so I'm not even sure what you're talking about.

 

[mkosmo]

Yes, once. SIC time is still good towards total time, and I didn't yet have 1500 hours at that point so total time was still worth something.

I have no professional aspirations, so I didn't even think about using it for TT.

 

[EdFred]

The personal me would find it convenient not to have to search through 20,000+ old posts to find the link when I need it. Also, wasn't that link in the signature line of those posts? Deleting something from your sig line deletes it from the sig line of all your previous posts on this forum as well.

Which is why I used the past tense, of was and not the present tense of is. It was around for almost 10 years, and easily discovered. When I realized absolutely no one was looking it up, before asking a stupid question (OK, there are not stupidquestions, just stupid people that ask questions) about logging PIC, I said eff it. A sticky was requested of the mods numerous times, along with a sticky for this thread but we see how well management listened.

 

[flyingcheesehead]

I have no professional aspirations, so I didn't even think about using it for TT.

I didn't either, but I figured that it might be nice to get higher certificates for fun someday.

I got the commercial for fun. I've used it exactly twice. I was going to get the ATP, but they changed the rules and made it prohibitively expensive.

 

[EdFred]

Basic Med can be used for safety piloting, but only if the Basic Med safety pilot is PIC too.

Basic Med was the add-on, and a lot of the other regs still refer to medical requirements.
Maybe, someday real soon now, the other regs will be re-written to simplify things. Or, maybe, Basic Med might be re-written so it isn't limited to PIC roles.

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_68-1A.pdf

>>
5.2.2 Status of Required Flightcrew Members

5.2.2.1

...

A pilot acting as a safety pilot per part 91, § 91.109(c), however, would be a required pilot flightcrew member by regulation rather than a passenger. Section 91.109(c) provides that no person may operate a civil aircraft in simulated instrument flight unless 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. Because a safety pilot is a required pilot flightcrew member, the safety pilot is required to hold a valid and appropriate medical certificate in accordance with § 61.3(a). BasicMed privileges can only be exercised by a person acting as safety pilot when that person is also acting as PIC. BasicMed privileges do not extend to anyone other than the person acting as PIC.
<<

Which does no good when someone wants/needs to go shoot approaches in a Comanche/Bonanza/182/Toga/Lance/etc...and the only people available only have BasicMed and no HP and/or complex endorsement, or they aren't passenger current. The FAA could have easily had congress word it to say something to the effect of "...BasicMed is an appropriate substitute for third class medical in all instances where a third class medical required provided the aircraft is under 6000, operated under 18000 feet..." etc. But no, because, well, the FAA.

 

[dmspilot]

I did not misquote him, and I did not change anything. I clicked "Quote". In fact, if you go back to the post I quoted, it still says HP there too, so I'm not even sure what you're talking about.

I was mistaken, he was the one that changed "complex" to "HP". Still does not change the fact that the "they" is referring to the safety pilot. The safety pilot can only log PIC if they act as PIC, and in order to act as PIC you need to meet all the requirements of doing so.

 

[Juliet Hotel]

I was going to get the ATP, but they changed the rules and made it prohibitively expensive.

They did? Its been a while since I've paid attention. What changed?

 

[Palmpilot]

Which is why I used the past tense, of was and not the present tense of is. It was around for almost 10 years, and easily discovered. When I realized absolutely no one was looking it up, before asking a stupid question (OK, there are not stupidquestions, just stupid people that ask questions) about logging PIC, I said eff it. A sticky was requested of the mods numerous times, along with a sticky for this thread but we see how well management listened.

Thanks for the link.

 

[labbadabba]

I was mistaken, he was the one that changed "complex" to "HP". Still does not change the fact that the "they" is referring to the safety pilot. The safety pilot can only log PIC if they act as PIC, and in order to act as PIC you need to meet all the requirements of doing so.

Correct, I stated HP, I meant complex. Either way the reasoning is the same. For a SP you must have the appropriate Category and Class so that's fine but if the SP wants to log it as PIC time they will need the endorsement for complex or HP if in a HP or complex aircraft. You can't be a PIC of a complex or HP plane without the endorsement. Seems fairly cut and dry to me.

 

[flyingcheesehead]

Correct, I stated HP, I meant complex. Either way the reasoning is the same. For a SP you must have the appropriate Category and Class so that's fine but if the SP wants to log it as PIC time they will need the endorsement for complex or HP if in a HP or complex aircraft. You can't be a PIC of a complex or HP plane without the endorsement. Seems fairly cut and dry to me.

Maybe, having been a pilot for 15+ years and having been on online aviation forums for longer than that, I'm a bit sensitive to anything that brings up these arguments again, but if you had said it the way you said it here the first time, I wouldn't have made a peep. Your first statement, taken on its own, can easily perpetuate the myth that you have to be endorsed to log PIC, period.

 

[labbadabba]

Maybe, having been a pilot for 15+ years and having been on online aviation forums for longer than that, I'm a bit sensitive to anything that brings up these arguments again, but if you had said it the way you said it here the first time, I wouldn't have made a peep. Your first statement, taken on its own, can easily perpetuate the myth that you have to be endorsed to log PIC, period.

None taken. Safety pilot and PIC debates are why I became a pilot in the first place.

 

[flyingcheesehead]

I was going to get the ATP, but they changed the rules and made it prohibitively expensive.

They did? Its been a while since I've paid attention. What changed?

Now, before taking the written, you have to take the "ATP-CTP" course, with 30 hours of ground school and 10 hours in a Level C or higher sim representing a multiengine turbine airplane with a MTOW of >40,000 pounds. From what I've heard, that sim time isn't cheap (like $1500/hr), not to mention the class plus sim time means probably taking a week of vacation to do it.

That kind of time and money puts it well outside the realm of things I would do for "fun".

 

[ja_user]

The CTP is about 5k, let the employer pay for it.

 

[flyingcheesehead]

The CTP is about 5k, let the employer pay for it.

What employer? That's the problem, you can't do the ATP just for fun and to improve your skills any more. I fly for myself, not anyone else.

It does sound like it's a lot cheaper than it was predicted to be, though. Pan Am International Flight Academy has it for $4K. I remember that the initial estimates were for it to be in the $30K-$40K range.

I did take the written a few days before the rule change, but I wasn't able to get enough AMEL time in time to do the checkride. The only twin for rent here locally is $450/hr.

 

[MauleSkinner]

What employer? That's the problem, you can't do the ATP just for fun and to improve your skills any more. I fly for myself, not anyone else.

It does sound like it's a lot cheaper than it was predicted to be, though. Pan Am International Flight Academy has it for $4K. I remember that the initial estimates were for it to be in the $30K-$40K range.

I did take the written a few days before the rule change, but I wasn't able to get enough AMEL time in time to do the checkride. The only twin for rent here locally is $450/hr.

You could always get the single-engine ATP...doesn’t require the CTP course.

 

[ja_user]

What employer? That's the problem, you can't do the ATP just for fun and to improve your skills any more.

You can still do it, you just can't get the plastic. YOu can get the plastic for SEL, and do whatever you want with a CFI, or a DPE acting as an instructor.

I didn't have the total time, so I didn't take the written during the 2 year grace period.

If there is no employer, than there isn't much use in learning the CTP stuff. Most of that would be covered by insurance requirements if you were flying something big, wouldn't it?

 

[MauleSkinner]

If there is no employer, than there isn't much use in learning the CTP stuff. Most of that would be covered by insurance requirements if you were flying something big, wouldn't it?

Not really...here’s what’s required in the CTP course...

(a) Academic training. The applicant for the knowledge test must receive at least 30 hours of classroom instruction that includes the following:

(1) At least 8 hours of instruction on aerodynamics including high altitude operations;

(2) At least 2 hours of instruction on meteorology, including adverse weather phenomena and weather detection systems; and

(3) At least 14 hours of instruction on air carrier operations, including the following areas:

(i) Physiology;

(ii) Communications;

(iii) Checklist philosophy;

(iv) Operational control;

(v) Minimum equipment list/configuration deviation list;

(vi) Ground operations;

(vii) Turbine engines;

(viii) Transport category aircraft performance;

(ix) Automation, navigation, and flight path warning systems.

(4) At least 6 hours of instruction on leadership, professional development, crew resource management, and safety culture.

(b) FSTD training. The applicant for the knowledge test must receive at least 10 hours of training in a flight simulation training device qualified under part 60 of this chapter that represents a multiengine turbine airplane. The training must include the following:

(1) At least 6 hours of training in a Level C or higher full flight simulator qualified under part 60 of this chapter that represents a multiengine turbine airplane with a maximum takeoff weight of 40,000 pounds or greater. The training must include the following areas:

(i) Low energy states/stalls;

(ii) Upset recovery techniques; and

(iii) Adverse weather conditions, including icing, thunderstorms, and crosswinds with gusts.

(2) The remaining FSTD training may be completed in a Level 4 or higher flight simulation training device. The training must include the following areas:

(i) Navigation including flight management systems; and

(ii) Automation including autoflight.

It’s all covered to some degree in initial type training, but when it has to get crammed into a systems course that’s pretty much filled up with “systems stuff”, it’s pretty tough to get in depth on any of it.

Things like “turbine engines” used to be taught more “on the job”...you had a significant amount of time in the right seat (hours and/or years) to gain knowlege from the guys next to you, as well as reading a few years’ worth of Pro Pilot articles in the pilot lounge. That’s decreased tremendously.

Overall, I think if it was taken seriously by the instructors, the CTP course would be a very good thing. I’m not hearing much that indicates that many of the programs’ instructors are doing that, however. One of these years I’m going to get my company to let me audit our CTP course, so at least I have a really good idea what I can expect from the applicants. The new ATP ACS draft looks like it’s going to require significantly more on the oral for that stuff, too.

 

[midlifeflyer]

Nope. Again, we are confusing ACTING and LOGGING PIC. Anyone can LOG PIC if they are appropriately rated (category, class, and type). So a PP-ASEL can LOG PIC in a HP aircraft even though they do not have a HP if they are the sole manipulator.

https://www.aopa.org/training-and-s...ject-report-logging-pilot-in-command-pic-time

I thought he was correct, in context - the safety pilot. Just to be sure we are on the same page.

The private pilot flying may log PIC without the endorsements. He is the sole manipulator of the controls of an aircraft he is rated for under 61.51(e)(1)(i). Nothing else required.

But the safety pilot, the required pilot not flying, logs PIC time under a different subsection, 61.51(e)(1)(iii), which requires the safety pilot to be acting as PIC in order to log PIC time. And, in order to act as PIC, a pilot must be qualified to do so, which includes applicable endorsements. It is one of the times "acting" and "logging" intersect.

 

[midlifeflyer]

Dumbest FAQ answer ever.

Yep, you can fly in the soup at 200+kts, in a 6,000lb air craft and you're good. But to watch for other traffic in a ********* ********* ********* **** ******** 172 when it's CAVU requires a class III. Is MacPherson back at the FAA? Holy **** they are retarded.

Stupid but sadly accurate. This obvious dumbetry was a combination of the way the statute was written and the FAA/DOT decision to adopt it almost verbatim rather than writing its own.

 

[azure]

Dumbest FAQ answer ever.

Yep, you can fly in the soup at 200+kts, in a 6,000lb air craft and you're good. But to watch for other traffic in a ********* ********* ********* **** ******** 172 when it's CAVU requires a class III. Is MacPherson back at the FAA? Holy **** they are retarded.

It's a dumb rule, not a dumb FAQ answer. The answer is almost completely accurate, right down to explaining that the reason is the statutory language. The only thing missing is an explanation that "we didn't want to go through the NPRM process to clean up this idiotic language", but this being the FAA, they weren't going to say that anyway.

 

[midlifeflyer]

I saw quite a few logbooks with significant SIC time in Arrows back when I was instructing near a college aviation program.

It counts toward FAA total flight time requirements, such as

§61.129 Aeronautical experience.
(a) For an airplane single-engine rating. Except as provided in paragraph (i) of this section, a person who applies for a commercial pilot certificate with an airplane category and single-engine class rating must log at least 250 hours of flight time as a pilot that consists of at least:

(1) 100 hours in powered aircraft, of which 50 hours must be in airplanes.​

Not surprising to see it used in a college aviation program.

​

 

[flyingron]

I think you misunderstood DMS's statement. He's talking about a safety pilot. If a safety pilot is PIC, he needs the endorsement and he can log PIC time.
If the safety pilot is not PIC (not required), than they can't log PIC because they don't fit any of the 61.51(e) requirements (sole manipulator, PIC in a multipilot op, instructor, ...).

 

[Juliet Hotel]

Now, before taking the written, you have to take the "ATP-CTP" course, with 30 hours of ground school and 10 hours in a Level C or higher sim representing a multiengine turbine airplane with a MTOW of >40,000 pounds. From what I've heard, that sim time isn't cheap (like $1500/hr), not to mention the class plus sim time means probably taking a week of vacation to do it.

That kind of time and money puts it well outside the realm of things I would do for "fun".

Holy Toledo! If/when I bought a plane I always figured I'd do the ATP just to do it. Guess it'll have to be single engine if it happens at all.

 

[azure]

I think you misunderstood DMS's statement. He's talking about a safety pilot. If a safety pilot is PIC, he needs the endorsement and he can log PIC time.
If the safety pilot is not PIC (not required), than they can't log PIC because they don't fit any of the 61.51(e) requirements (sole manipulator, PIC in a multipilot op, instructor, ...).

That's very easy to do when a correct reading hinges on a single word or phrase, in this case, "safety pilot". The fault is not entirely on the reader's side. I was guilty of it too, over on the Red Board, when I said that you can't do the physical exam as a consultation before the AME enters the MedXPress code into the system. Cap'n Ron went after me on that even though he agrees with my point, saying that you can certainly do a consultation prior to the live exam. The point of contention was really the word "the" (as in THE physical exam), and I have to admit that I was being a bit cryptic.

Same thing here, I think. DMS's statement was factually correct, but it only applies to the safety pilot in his role as safety pilot, and that distinction could easily be missed in a casual reading.

 

[dmspilot]

That's very easy to do when a correct reading hinges on a single word or phrase, in this case, "safety pilot". The fault is not entirely on the reader's side. I was guilty of it too, over on the Red Board, when I said that you can't do the physical exam as a consultation before the AME enters the MedXPress code into the system. Cap'n Ron went after me on that even though he agrees with my point, saying that you can certainly do a consultation prior to the live exam. The point of contention was really the word "the" (as in THE physical exam), and I have to admit that I was being a bit cryptic.

Same thing here, I think. DMS's statement was factually correct, but it only applies to the safety pilot in his role as safety pilot, and that distinction could easily be missed in a casual reading.

My statements all had the words "safety pilot" in them. Plus the thread title is "Must Safety Pilot Have Complex Endorsement?"

 

[azure]

Yeah, checking back, *yours* did, sorry. The unclear statement was by a different poster, something to the effect that without an endorsement, "they" can't log PIC in a complex aircraft. True in context, but not as a general statement.

 

[James331]

Just because you can doesn’t mean you should.

I wouldn’t want to be PIC of any plane I couldn’t PIC on my own.

 

[midlifeflyer]

Just because you can doesn’t mean you should.

I wouldn’t want to be PIC of any plane I couldn’t PIC on my own.

If the reason you can't be PIC on your own is an FAA reg, that's automatic. But it's a good policy even if there are non-FAA reasons..

 

[James331]

If the reason you can't be PIC on your own is an FAA reg, that's automatic. But it's a good policy even if there are non-FAA reasons..

You can also fly a ultralight with zero training.

Thing is people who need rules to tell them obvious things are why some people need rules

 

[labbadabba]

Yeah, checking back, *yours* did, sorry. The unclear statement was by a different poster, something to the effect that without an endorsement, "they" can't log PIC in a complex aircraft. True in context, but not as a general statement.

Again, my bad... I'll more clearerer next time.