PIC...

[jeff20578]

I was talking to a friend of mine who is currently building XC hours for his IFR training and he mentioned going up together and both logging hours. My question is can the pilot in the right seat log pic hours as well? Or only the left seat?

 

[poadeleted20]

If the pilot in the right seat is an instructor giving training to the pilot in the left seat, and the pilot in the left seat is "rated" in the aircraft (i.e., in a Bonanza, has an ASEL rating on his/her pilot certificate), then yes, both can log PIC time -- and do so for the entire flight.

However, I think you're talking about when the pilot in the right seat is not an instructor. In that case, the pilot flying the plane can log PIC time for the entire flight. However, the pilot in the other seat cannot log any time unless two pilots are required by the regulations. Since most folks in that situation are flying something like a C-172 rather than something like a LearJet or a DC-3, the only way a second pilot is required is if the left seat pilot is under the hood. In that case, the safety pilot in the right seat can log the time while the flying pilot is hooded (and only that time). The safety pilot logs that as SIC time, unless the safety pilot is also acting as PIC (which means the safety pilot needs to be fully PIC qualified, including 61.31 additional training endorsements, 61.57 landings, 61.56 flight review, etc), in which case the safety pilot can log it as PIC time.

See 61.51 paragraphs (e) and (f), and 91.109(c).

 

[Captain]

Lamest loophole ever IMO. I'll leave it there.

 

[dell30rb]

Lamest loophole ever IMO. I'll leave it there.

I don't see it that way. Left seat is flying the plane... Right seat CFI is on the hook if they bust a FAR or crash. So he is paying 100 percent attention to everything going on, though he is not actually flying

 

[dell30rb]

I don't see it that way. Left seat is flying the plane... Right seat CFI is on the hook if they bust a FAR or crash. So he is paying 100 percent attention to everything going on, though he is not actually flying

On further review it seems that you are probably a private pilot and you are going to act as safety pilot for your friend. You may both log PICif your friend is flying under the hood and you are acting as safety pilot. Same thing there, you are responsible both for traffic avoidance and for making sure your instrument student friend does not crash the plane while under the hood.

 

[Captain]

I don't see it that way. Left seat is flying the plane... Right seat CFI is on the hook if they bust a FAR or crash. So he is paying 100 percent attention to everything going on, though he is not actually flying

Sorry, no, I was not talking about a CFI flying with a student. That's fine. I was referring to the 'safety pilot' aspect. A safety pilot should not log PIC IMO. But...I don't write regs.

 

[poadeleted20]

On further review it seems that you are probably a private pilot and you are going to act as safety pilot for your friend. You may both log PICif your friend is flying under the hood and you are acting as safety pilot.

Not unless the safety pilot is also acting as PIC. If not, the safety pilot can only log SIC time. See 61.51 paragraphs (e) and (f).

 

[bqmassey]

Sorry, no, I was not talking about a CFI flying with a student. That's fine. I was referring to the 'safety pilot' aspect. A safety pilot should not log PIC IMO. But...I don't write regs.

In my opinion, if only one of the two could log PIC, it should be the person actually responsible for the safety of the flight that logs it. In VFR conditions, you have to have someone looking out, avoiding terrain, avoiding other aircraft, maintaining positional awareness, prepared to miss a flock of birds, etc. This person is pretty important to the flight.

The guy under the hood isn't doing anything helpful. He's functioning, at best, as a GPS-slaved autopilot.

That's just my (pretty unqualified) opinion.

 

[poadeleted20]

In my opinion, if only one of the two could log PIC, it should be the person actually responsible for the safety of the flight that logs it. In VFR conditions, you have to have someone looking out, avoiding terrain, avoiding other aircraft, maintaining positional awareness, prepared to miss a flock of birds, etc. This person is pretty important to the flight.

The guy under the hood isn't doing anything helpful. He's functioning, at best, as a GPS-slaved autopilot.

That's just my (pretty unqualified) opinion.

You are entitled to that opinion. However, logbooks for FAA purposes must be prepared according to FAA rules, and the FAA rules are different from what you say you think they should be. So please follow the FAA's rules when filling out your own logbook, and when answering the questions of others about pilot logbooks, because the penalties for entries which violate the FAA's rules are very harsh (almost invariably revocation).

 

[bqmassey]

You are entitled to that opinion. However, logbooks for FAA purposes must be prepared according to FAA rules, and the FAA rules are different from what you say you think they should be. So please follow the FAA's rules when filling out your own logbook, and when answering the questions of others about pilot logbooks, because the penalties for entries which violate the FAA's rules are very harsh (almost invariably revocation).

I was not making a suggestion. I was speaking hypothetically, in reference to Captain's response.

In my opinion, if only one of the two could log PIC,...

 

[NineThreeKilo]

I was talking to a friend of mine who is currently building XC hours for his IFR training and he mentioned going up together and both logging hours. My question is can the pilot in the right seat log pic hours as well? Or only the left seat?

If you're a CFI, I think you would know the answer.

If you're not a CFI, BUT you ARE licensed and rated to fly the plane as PIC, you can act as SAFETY PILOT, your buddy is under the hood, you lookout for traffic, you both get to log PIC.

Be sure to put his full name, license number in the co-pilot/pax column in your logbook (no need for him to sign) and write safety pilot by it.

Also remember you guys cant log the exact same amount of time, he obviously aint going to be under the hood for taxi, takeoff & landing right!

 

[MachFly]

Sorry, no, I was not talking about a CFI flying with a student. That's fine. I was referring to the 'safety pilot' aspect. A safety pilot should not log PIC IMO. But...I don't write regs.

If there was an option to log SIC (without being a safety pilot) on GA planes then I'd agree with you. However knowing how expensive flying is these days this loophole makes it significantly easier and cheaper for low time pilot to build up hours.

 

[tlglenn]

Since the original poster mentioned that his friend was building XC hours I should point-out that unless the regulations require two pilots for the entire flight from start to finish only one pilot can log XC hours. And that's only if he or she flies the plane from start to finish. There are some chief counsel letters on the subject.

 

[Captain]

If there was an option to log SIC (without being a safety pilot) on GA planes then I'd agree with you. However knowing how expensive flying is these days this loophole makes it significantly easier and cheaper for low time pilot to build up hours.

And that's my issue. If it was just the odd flight or two with a total of 10 or fewer hours going towards ratings then I'd be fine with it.

But some training schools take it to the extreme. I know PanAm in Florida (before the hurricanes blew them back to Arizona) used to sell entire courses of time building that way. Two students in a Seminole go on 2 two hour flights. One under the hood for one and then they switch and the other goes under the hood.

So they graduate with 80 hours of multi time each...but 40 of that is safety pilot hours.

If I'm hiring pilots for my company and I see 80 hours of multi that should mean 80 hours...not 40 hours of looking for birds and mountains in Florida.


This is off topic and I'll leave it alone. Cap'n Ron is right...the regs are the regs and flight time should be logged in a manner that is legal and accepted. The above is just my opinion and my opinion ain't worth jack.

Carry on...

 

[poadeleted20]

If you're not a CFI, BUT you ARE licensed and rated to fly the plane as PIC, you can act as SAFETY PILOT, your buddy is under the hood, you lookout for traffic, you both get to log PIC.

If and only if the safety pilot is acting as PIC, which is not a given. In that case, the safety pilot must be fully PIC qualified (including any additional training endorsements, flight review, landing currency, etc). If insurance is an issue, the safety pilot acting as PIC would also have to meet any insurance requirements or the policy will be invalidated. Otherwise, the safety pilot is the SIC, and logs only SIC time.

Be sure to put his full name, license number in the co-pilot/pax column in your logbook (no need for him to sign) and write safety pilot by it.

The FAA does not require recording the safety pilot's certificate number, just the name.

Also remember you guys cant log the exact same amount of time, he obviously aint going to be under the hood for taxi, takeoff & landing right!

Correct.

 

[Jaybird180]

If I'm hiring pilots for my company and I see 80 hours of multi that should mean 80 hours...not 40 hours of looking for birds and mountains in Florida.


This is off topic and I'll leave it alone. Cap'n Ron is right...the regs are the regs and flight time should be logged in a manner that is legal and accepted. The above is just my opinion and my opinion ain't worth jack.

Carry on...

if blood is spilled, who could be hurt? Why take a risk (no matter how small) if there is no reward?

 

[jeff20578]

Thank you for all the responses!

From what I've gathered, both pilots can log PIC if only the left seat pilot is under the hood.

 

[NineThreeKilo]

Thank you for all the responses!

From what I've gathered, both pilots can log PIC if only the left seat pilot is under the hood.

You got it

Remember you guys cant log the EXACT same PIC time, you both cant land a take off the plane at the same time right!

If and only if the safety pilot is acting as PIC, which is not a given. In that case, the safety pilot must be fully PIC qualified (including any additional training endorsements, flight review, landing currency, etc).

Yep, licensed and rated to fly the plane, obviously he needs to also have a medical, BFR, etc.

Otherwise, the safety pilot is the SIC, and logs only SIC time.

DO NOT try to log SIC time in a single pilot light GA plane, it's silly and veeeery obviously wrong if the feds, CFI, or anyone in the industry see's you were logging SIC in a 152 or something!

The FAA does not require recording the safety pilot's certificate number, just the name.

This is true, but it would be foolish not to have the info incase any questions are ever raised. At the very least put his name and license number in your logbook once, then write just his name in after that.


It shows you at least looked that he was licensed/rated and you have a document number to back it up if anyone ever asks.
I would not feel good just having Bob Smith in my logbook, there are a boat load of Bobs out there! Now “Bob Smith PSEL 5555555 (FAA)” that's better!

 

[poadeleted20]

DO NOT try to log SIC time in a single pilot light GA plane, it's silly and veeeery obviously wrong if the feds, CFI, or anyone in the industry see's you were logging SIC in a 152 or something!

Just what regulation says that you can't log SIC time in a C-152? The same one which led you to say in post #11 that a safety pilot always logs PIC time?

This is true, but it would be foolish not to have the info incase any questions are ever raised. At the very least put his name and license number in your logbook once, then write just his name in after that.

Foolish in what way? The regulation simply doesn't require it.

It shows you at least looked that he was licensed/rated and you have a document number to back it up if anyone ever asks.
I would not feel good just having Bob Smith in my logbook, there are a boat load of Bobs out there! Now “Bob Smith PSEL 5555555 (FAA)” that's better!

More personal opinion unsupported by the regulations, case law, or any FAA guidance. Leave it out, please.

 

[poadeleted20]

Thank you for all the responses!

From what I've gathered, both pilots can log PIC if only the left seat pilot is under the hood.

Then you've gathered in adequately, perhaps due to 93K's incorrect posts. Both pilots can log PIC time if the left seat pilot is under the hood and the safety pilot is acting as PIC. Otherwise, the safety pilot logs only SIC time.

 

[NineThreeKilo]

Then you've gathered in adequately, perhaps due to 93K's incorrect posts. Both pilots can log PIC time if the left seat pilot is under the hood and the safety pilot is acting as PIC. Otherwise, the safety pilot logs only SIC time.

Oh sigh,, IF YOU ARE ACTING AS SAFETY PILOT YOU BOTH LOG PIC and if you are going to take on the responsibilities of a safety pilot, you're responsible, so, LOG IT AS SUCH --> PIC time




The whole thing I am attempting to communicate is if you ACT AS SAFETY PILOT, you both log PIC while buddy is under the hood.


FAR Part 1 Defines pilot-in-command as follows: Pilot in command means the person who: (1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.
FAR Part 61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person— (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
FAR Part 91.3 Responsibility and authority of the pilot in command. (a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft. (b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency. (c) Each pilot in command who deviates from a rule under paragraph (b) of this section shall, upon the request of the Administrator, send a written report of that deviation to the Administrator.

Just what regulation says that you can't log SIC time in a C-152? The same one which led you to say in post #11 that a safety pilot always logs PIC time?

Nope, this one


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Guessing this isnt a SIC required part 135 or 121 flight in that lil 152 bug smasher???

Guessing the type cert doesnt require a SIC for a 152??

If this guy every decided to become a professional aviator, seeing SIC 172/152/etc will raise some eye brows at a interview.


PIC safety pilot time wouldnt be an issue, everyone knows about safety pilot time and chances are the guy interviewing you has some PIC safety pilot time in his log book too.

Foolish in what way? The regulation simply doesn't require it.

Having the guys license number, THOUGH NOT REQUIRED, is a damn good idea, it identifies him dead to rights.


If 5 years down the road something comes up, it's alot easier to give a FAA inspector a license number and name, then just some dudes name and hope they can find him.



I call it covering my basses.


It's amazing the chit shows good documentation will get you out of.

 

[wabower]

If a 135 requires two pilots in a B-200, it's pretty clear that the PIC logs his time as such. What does the the other pilot log? The airplane is certified as single-pilot.

Oh sigh,, IF YOU ARE ACTING AS SAFETY PILOT YOU BOTH LOG PIC and if you are going to take on the responsibilities of a safety pilot, you're responsible, so, LOG IT AS SUCH --> PIC time




The whole thing I am attempting to communicate is if you ACT AS SAFETY PILOT, you both log PIC while buddy is under the hood.


FAR Part 1 Defines pilot-in-command as follows: Pilot in command means the person who: (1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.
FAR Part 61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person— (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
FAR Part 91.3 Responsibility and authority of the pilot in command. (a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft. (b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency. (c) Each pilot in command who deviates from a rule under paragraph (b) of this section shall, upon the request of the Administrator, send a written report of that deviation to the Administrator.







Nope, this one


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Guessing this isnt a SIC required part 135 or 121 flight in that lil 152 bug smasher???

Guessing the type cert doesnt require a SIC for a 152??

If this guy every decided to become a professional aviator, seeing SIC 172/152/etc will raise some eye brows at a interview.


PIC safety pilot time wouldnt be an issue, everyone knows about safety pilot time and chances are the guy interviewing you has some PIC safety pilot time in his log book too.




Having the guys license number, THOUGH NOT REQUIRED, is a damn good idea, it identifies him dead to rights.


If 5 years down the road something comes up, it's alot easier to give a FAA inspector a license number and name, then just some dudes name and hope they can find him.



I call it covering my basses.


It's amazing the chit shows good documentation will get you out of.

 

[NineThreeKilo]

If a 135 requires two pilots in a B-200, it's pretty clear that the PIC logs his time as such. What does the the other pilot log? The airplane is certified as single-pilot.

He logs SIC


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Without autopilot in IFR carrying pax

"§ 135.101 Second in command required under IFR.

Except as provided in § 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft."

"§ 135.111 Second in command required in Category II operations.

No person may operate an aircraft in a Category II operation unless there is a second in command of the aircraft."


So if that King Air is carrying pax IFR and does not have a authorized/approved autopilot OR if they are Cat II, they must have a SIC -> your buddy, thus he may log SIC, if he meets all the SIC requirements for 135 ops.

 

[poadeleted20]

Oh sigh,, IF YOU ARE ACTING AS SAFETY PILOT YOU BOTH LOG PIC and if you are going to take on the responsibilities of a safety pilot, you're responsible, so, LOG IT AS SUCH --> PIC time




The whole thing I am attempting to communicate is if you ACT AS SAFETY PILOT, you both log PIC while buddy is under the hood.


FAR Part 1 Defines pilot-in-command as follows: Pilot in command means the person who: (1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.
FAR Part 61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person— (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
FAR Part 91.3 Responsibility and authority of the pilot in command. (a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft. (b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency. (c) Each pilot in command who deviates from a rule under paragraph (b) of this section shall, upon the request of the Administrator, send a written report of that deviation to the Administrator.







Nope, this one


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Guessing this isnt a SIC required part 135 or 121 flight in that lil 152 bug smasher???

Guessing the type cert doesnt require a SIC for a 152??

If this guy every decided to become a professional aviator, seeing SIC 172/152/etc will raise some eye brows at a interview.

PIC safety pilot time wouldnt be an issue, everyone knows about safety pilot time and chances are the guy interviewing you has some PIC safety pilot time in his log book too.

Having the guys license number, THOUGH NOT REQUIRED, is a damn good idea, it identifies him dead to rights.

If 5 years down the road something comes up, it's alot easier to give a FAA inspector a license number and name, then just some dudes name and hope they can find him.

I call it covering my basses.

It's amazing the chit shows good documentation will get you out of.

The above is total hogwash, and is nothing but the poster's personal opinion, which is completely at odds with the FAA's interpretations of its own regulations. I suggest ignoring it and any further posts he makes on the subject (as I will). Anyone requiring official confirmation of what I have posted and denial of his statements should contact the FAA Chief Counsel, AGC-200 at FAA HQ or their local FSDO.

 

[poadeleted20]

He logs SIC


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Without autopilot in IFR carrying pax

"§ 135.101 Second in command required under IFR.

Except as provided in § 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft."

"§ 135.111 Second in command required in Category II operations.

No person may operate an aircraft in a Category II operation unless there is a second in command of the aircraft."


So if that King Air is carrying pax IFR and does not have a authorized/approved autopilot OR if they are Cat II, they must have a SIC -> your buddy, thus he may log SIC, if he meets all the SIC requirements for 135 ops.

Since you say that a SIC required by Part 135 can log SIC time even if the aircraft's type certificate does not require two pilots, and correctly cite 61.52(f)(2) as the legal source for that, why do you say a second pilot required by 14 CFR 91.109(c) cannot?

 

[midlifeflyer]

The whole thing I am attempting to communicate is if you ACT AS SAFETY PILOT, you both log PIC while buddy is under the hood.

Unfortunately, what you are attempting to communicate is incorrect according to official FAA sources. A correct statement would be

if you ACT AS SAFETY PILOT and as PILOT IN COMMAND, you both log PIC while buddy is under the hood.

See, for example, the 1993 Hicks interpretation. Lays it out pretty well.
http://www.faa.gov/about/office_org...0/interpretations/data/interps/1993/Hicks.rtf

 

[Aileron]

In that case, the safety pilot in the right seat can log the time while the flying pilot is hooded (and only that time). The safety pilot logs that as SIC time, unless the safety pilot is also acting as PIC (which means the safety pilot needs to be fully PIC qualified, including 61.31 additional training endorsements, 61.57 landings, 61.56 flight review, etc), in which case the safety pilot can log it as PIC time.

See 61.51 paragraphs (e) and (f), and 91.109(c).

Safety Pilot would log PIC time, not SIC time.

 

[wabower]

What if a 91 imposes the same crew requirements?

He logs SIC


“61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. “

Without autopilot in IFR carrying pax

"§ 135.101 Second in command required under IFR.

Except as provided in § 135.105, no person may operate an aircraft carrying passengers under IFR unless there is a second in command in the aircraft."

"§ 135.111 Second in command required in Category II operations.

No person may operate an aircraft in a Category II operation unless there is a second in command of the aircraft."


So if that King Air is carrying pax IFR and does not have a authorized/approved autopilot OR if they are Cat II, they must have a SIC -> your buddy, thus he may log SIC, if he meets all the SIC requirements for 135 ops.

 

[NineThreeKilo]

Unfortunately, what you are attempting to communicate is incorrect according to official FAA sources. A correct statement would be



See, for example, the 1993 Hicks interpretation. Lays it out pretty well.
http://www.faa.gov/about/office_org...0/interpretations/data/interps/1993/Hicks.rtf

By acting as Safety Pilot, you need to be licensed/rated to act as PIC, as the intent is for saftey pilot to act as PIC. If the other guy is under the hood and you are Safety Pilot, by definition you are acting as PIC while buddy is under the hood (keeping buddy from hitting planes, crashing, etc). Being Safety Pilot and NOT also acting as PIC, I guess legaly you could, but why would you?

What if a 91 imposes the same crew requirements?

If 91 did then you could, but I dont believe it does.


Unless the plane requires a SIC, think you are SOL on that one.

Since you say that a SIC required by Part 135 can log SIC time even if the aircraft's type certificate does not require two pilots, and correctly cite 61.52(f)(2) as the legal source for that, why do you say a second pilot required by 14 CFR 91.109(c) cannot?

I dont cite any SIC for 91 since there is no SIC required for regulation of part 91 flight
(unless you are flying SIC required plane)


Under part 135/121 there are regs for NEEDING SIC under certain circumstances (like cat II ops), regardless of the plane.

The above is total hogwash, and is nothing but the poster's personal opinion, which is completely at odds with the FAA's interpretations of its own regulations. I suggest ignoring it and any further posts he makes on the subject (as I will). Anyone requiring official confirmation of what I have posted and denial of his statements should contact the FAA Chief Counsel, AGC-200 at FAA HQ or their local FSDO.

Sounds like someone didnt drink their ensure today!


Dude... how bout the regs I posted, guess that's hogwash too and just the FAA's personal opinion, maybe you should ignore that too LMAO.

 

[jesse]

I'm not going to engage too much in this - but I will weigh in and say that Ron is most certainly right on this subject and the other guy is off.

I could reference a bunch of stuff but there is no point. Ron has already done so.

 

[midlifeflyer]

By acting as Safety Pilot, you need to be licensed/rated to act as PIC, as the intent is for safety pilot to act as PIC.

Still wrong. Safety pilot minimum qualifications are private certificate with applicable category and class ratings and a medical (because of being required crew).

PIC requires more - applicable endorsements, currency, to mention two. Neither of which are required for a safety pilot.

You can also look at the SIC reg, 61.55, which specifically mentions safety pilots.

Or you can simply read FAA Chief Counsel's opinion I linked unless, of course, your "beliefs" are more important than reality.

 

[NineThreeKilo]

I'm not going to engage too much in this - but I will weigh in and say that Ron is most certainly right on this subject and the other guy is off.

I could reference a bunch of stuff but there is no point. Ron has already done so.

What did Ron reference, looks like I'm the only one on this damn thread that posted a single FAR.

One guy is sole manipulator of the controls and is under the hood -> PIC

Other guy is responsible for safety of the flight (acting as "look out") -> PIC


... F' it, you guys want to log SIC time flying GA in a 150, go for it.


I operate/operated the way I posted and I've had my documents gone through by the feds a few times and no one ever scratched their head at any of my hours, or anything else I have done flying wise, never had a issue with a the few ramp checks I've had ether... yea my "hogwash" must be some good chit!

 

[midlifeflyer]

What did Ron reference, looks like I'm the only one on this damn thread that posted a single FAR.

Ron referenced 91.109, 61.51(e) and 61.51(f). I added 61.55 and a formal written opinion by the FAA Chief Counsel.

 

[midlifeflyer]

I'm not going to engage too much in this - but I will weigh in and say that Ron is most certainly right on this subject and the other guy is off.

I could reference a bunch of stuff but there is no point. Ron has already done so.

It's probably not a real issue. Most people here have explored the issue before and know that NineThreeKilo is expressing personal belief and not the FAA's view of the issue.

 

[poadeleted20]

Safety Pilot would log PIC time, not SIC time.

Is this a troll? Whoever you are, Aileron, you need to read 61.51(e) and (f) again. The safety pilot cannot legally log PIC time unless the safety pilot is also acting as the PIC for the flight. That's black letter law as well as clearly stated in the FAA legal interpretations mentioned by Mark.

 

[NineThreeKilo]

Ron referenced 91.109, 61.51(e) and 61.51(f). I added 61.55 and a formal written opinion by the FAA Chief Counsel.

Nope, I was the first to actually post and cite the FARs

FAR Part 1 Defines pilot-in-command as follows: Pilot in command means the person who: (1) Has final authority and responsibility for the operation and safety of the flight; (2) Has been designated as pilot in command before or during the flight; and (3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.
FAR Part 61.51 (e) Logging pilot-in-command flight time. (1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person— (i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges;
FAR Part 91.3 Responsibility and authority of the pilot in command. (a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft. (b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency. (c) Each pilot in command who deviates from a rule under paragraph (b) of this section shall, upon the request of the Administrator, send a written report of that deviation to the Administrator.

It's probably not a real issue. Most people here have explored the issue before and know that NineThreeKilo is expressing personal belief and not the FAA's view of the issue.

Yea my personal belief backed by the frikin FARs I posted!



Why is it all the guys saying I'm wrong haven't cited a damn thing???



As for that link to the rtf letter,


That letter reaffirms what I said, both can log PIC, one is responsible for the safety of the flight (the safety pilot), the other is the sole manipulator (under the hood guy). Heck Ron even agreed with me earlier in this thread lol


And obviously to act/log as safety pilot you need to be qualified to act as PIC, which I said multiple times already.

[FONT=Courier New, serif]Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time [/FONT][FONT=Courier New, serif]simultaneously. PIC flight time may be logged by both the PIC responsible[/FONT][FONT=Courier New, serif] for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and the by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51.[/FONT]

On average here is how this safety pilot plays out in the real world.

You have two licensed guys who can legally act as PIC in whatever plane, both guys want to go flying, they both want to save money / log hours / get some hood time.

They both go up, one guy is under the hood, other is safety pilot, they both log it PIC, one guy also logs hood time, of course they dont log the exact same time due to take offs, landings, taxi; things you dont do under the hood.

 

[poadeleted20]

Ron referenced 91.109, 61.51(e) and 61.51(f). I added 61.55 and a formal written opinion by the FAA Chief Counsel.

Actually, I referenced 91.109(c), as that is the specific paragraph which makes the second pilot a regulatory requirement when the pilot manipulating the controls is hooded, thus triggering the "or the regulations under which the flight is being conducted" clause in 61.51(f)(2), thus entitling the safety pilot not acting as PIC to log SIC time. For the safety pilot acting as PIC as well as safety pilot, that regulatory requirement for a second pilot is what makes the safety pilot the pilot in command of an aircraft when more than one pilot is required by the regulations under which the flight is being conducted, and thus able to log PIC time under 61.51(e)(1)(iii).

 

[alaskaflyer]

On average here is how this safety pilot plays out in the real world.

You have two licensed guys who can legally act as PIC in whatever plane, both guys want to go flying, they both want to save money / log hours / get some hood time.

They both go up, one guy is under the hood, other is safety pilot, they both log it PIC, one guy also logs hood time, of course they dont log the exact same time due to take offs, landings, taxi; things you dont do under the hood.

I think the problem is that while you are right in some of your examples, you may not understand the distinction of why you COULD be wrong.

All Mark and Ron and others are saying is that while your scenario above COULD be correct, there are certainly times when it is NOT.

There is nothing preventing the pilot flying from legally acting as PIC while using a view limiting device, at least so far as the FAA is concerned. A safety pilot is not ALWAYS acting as PIC when the sole manipulator is under the hood. That might be because he cannot legally act as PIC (even though he is perfectly legal to be safety pilot), that also might be because for whatever reason the pilot flying (sole manipulator) chose to remain as acting PIC. One reason for THAT might be because of insurance requirements. Without an open pilot warranty, an in-motion policy only allows certain people to act as PIC.

To reiterate: One can be legal to be a safety pilot, and not legal to act as PIC. If you are not legal to act as PIC, you cannot be PIC. If you are not acting PIC as a safety pilot, you cannot log PIC.

It doesn't get any simpler than that

Being Safety Pilot and NOT also acting as PIC, I guess legaly you could, but why would you?

As multiple people have said, for a multiplicity of very good reasons. Insurance being one. Lack of qualifications to be PIC in that particular aircraft even though by regulation you are legal to act as safety pilot in the aircraft (I have been in that situation more than once myself.)

As to SIC time I leave that to others to argue.

 

[NineThreeKilo]

Actually, I referenced 91.109(c), as that is the specific paragraph which makes the second pilot a regulatory requirement when the pilot manipulating the controls is hooded, thus triggering the "or the regulations under which the flight is being conducted" clause in 61.51(f)(2), thus entitling the safety pilot not acting as PIC to log SIC time. For the safety pilot acting as PIC as well as safety pilot, that regulatory requirement for a second pilot is what makes the safety pilot the pilot in command of an aircraft when more than one pilot is required by the regulations under which the flight is being conducted, and thus able to log PIC time under 61.51(e)(1)(iii).

You have misread the SIC part, by regulations of the flight they are talking 135/121.


You fly any 135/121, I would think you would understand SIC a little better if you had.

Safety pilot logs PIC, if he cant log PIC for whatever reason, he doesn't log jack.

 

[poadeleted20]

That letter reaffirms what I said, both can log PIC, one is responsible for the safety of the flight (the safety pilot), the other is the sole manipulator (under the hood guy). Heck Ron even agreed with me earlier in this thread lol

No, I did not agree with that. You seem to have a mental block about the idea of the safety pilot being automatically the final authority responsible for the flight, which is simply not true. Yes, it is possible that the safety pilot may be fully PIC qualified, and the two pilots involved agree that the safety pilot will be PIC for the flight, in which case the safety pilot can indeed log PIC time while the pilot flying is hooded.

However, it is equally possible that the safety pilot may not be legally qualified to be PIC (lacking, say, an applicable complex or high performance endorsement, or a current flight review), or the two pilots may agree that the pilot flying, not the safety pilot, will be the PIC, perhaps because it's the flying pilot's airplane and the safety pilot doesn't meet the insurance requirements to act as PIC. In those cases, the safety pilot not acting as PIC does not qualify under any subparagraph of 61.51(e) to log PIC time. However, in that situation, as the second pilot when two pilots are required by the regulations, the safety pilot may still, under 61.51(f)(2), log the time the flying pilot is hooded.

And obviously to act/log as safety pilot you need to be qualified to act as PIC, which I said multiple times already.

Yes, you have. The only thing is, you're wrong. The safety pilot need only meet the requirements stated in 91.109(c) and the applicable portions of 61.55, which is a long way from the legal requirements to be PIC.

On average here is how this safety pilot plays out in the real world.

You have two licensed guys who can legally act as PIC in whatever plane, both guys want to go flying, they both want to save money / log hours / get some hood time.

They both go up, one guy is under the hood, other is safety pilot, they both log it PIC, one guy also logs hood time, of course they dont log the exact same time due to take offs, landings, taxi; things you dont do under the hood.

Actually, that is pretty much what these two yo-yo's did, and they got emergency revocations for their illegal efforts.
http://www.ntsb.gov/alj/o_n_o/docs/AVIATION/4008.PDF