Safety pilot CAN log cross-country time

MachFly

MachFly

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MachFly
Every few weeks a thread comes up here with someone asking something regarding logging time as a safety pilot, in which case someone comes in and explains that you can log PIC & can't log XC time. Is that really the case?
Part 61.1(a)(3) says that to log cross-country time you essentially need to land at an airport where you did not take off and use some kind of navigation to get there. The problem with the safety pilot is that the safety pilot usually just sits there and scants for traffic, so he does not do any take offs or landings which does not allow him to log cross-country time. Next, if the pilot A (the pilot doing most of the flying) takes off, then pilot B (safety pilot) takes the controls, does one touch and go and give the plane back to pilot A. Then they arrive at another airport, pilot A does a touch and go, pilot B takes the airplane and does a full stop. Now you have two pilots that can both legally log PIC time for the flight, and both of them took off at one airport and landed at another....so now per 61.1(a)(3) they can both log cross-country time as well.

Thoughts?
 
Are you really going to want to try explaining that to a DPE during your commercial checkride? Even if you're right?
 
MAKG1 said:
Are you really going to want to try explaining that to a DPE during your commercial checkride? Even if you're right?
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It has been quite some time since my commercial checkride, however if I do stumble upon a DPE that thinks otherwise I would be happy to discuss it with him.
If you show the DPE that you know the rules, it may increase the chances of passing a checkride...
 
Since the FAA Chief Counsel has already answered this question "no", your belief is irrelevant and it isn't legal to log it unless you can get the Chief Counsel to modify that interpretation. Good luck getting that.
 
Ron Levy said:
Since the FAA Chief Counsel has already answered this question "no", your belief is irrelevant and it isn't legal to log it unless you can get the Chief Counsel to modify that interpretation. Good luck getting that.
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Are you referring to a letter of interpretation?
 
JeffDG said:
Yes

http://www.faa.gov/about/office_org...009/gebhart - (2009) legal interpretation.pdf
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Thanks for the link.

The letter says pretty much exactly what I said in the OP, except it does not address a scenario where both pilots do a landing and a take off. Also I would like the point out that the letter specifically states that the only pilot that can log everything is the pilot that does the take offs and landings.

Just to clarify. Pilot A won't be able to log the time that it takes pilot B to do a touch and go (and the same for pilot B ), therefore neither pilot will be able to log all of the flight time because during the touch and go part only one of them is a required crew member. But because they both did a touch and go, both can log all their time as cross-country.
 
MachFly said:
Thanks for the link.

The letter says pretty much exactly what I said in the OP, except it does not address a scenario where both pilots do a landing and a take off. Also I would like the point out that the letter specifically states that the only pilot that can log everything is the pilot that does the take offs and landings.

Just to clarify. Pilot A won't be able to log the time that it takes pilot B to do a touch and go (and the same for pilot B ), therefore neither pilot will be able to log all of the flight time because during the touch and go part only one of them is a required crew member. But because they both did a touch and go, both can log all their time as cross-country.
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Sounds legit to me :dunno:
 
Think we found a loop hole. Quick, fire up the truck and let's drive through it. Flight schools offering multi time AND cross country time for foggle clad journeymen in eppauletts.
 
Captain said:
Think we found a loop hole. Quick, fire up the truck and let's drive through it. Flight schools offering multi time AND cross country time for foggle clad journeymen in eppauletts.
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How is this less legitimate than logging time with Otto flying?
 
If a pilot does a touch and go and hands controls over to the other pilot, I would think that this break in the journey would necessarily fail to be a continuous flight. The problem I think you have with the Gebhart letter isn't the need for a takeoff and landing by each PIC. I think the problem you have is with the portion of the interpretation that says:

Gebhart Letter said:
However, Pilot B may not log any cross-country flight time because that pilot was a required flight crewmember for only a portion of the flight.
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If I wanted to take the most negative interpretation, I could argue that this means that NEITHER pilot could log cross country time, particularly if pilot A flew the takeoff for the same leg that pilot B landed. I have seen / heard of lots of people flying legs of trips where the individual legs qualified for whatever rating's cross country requirement, and logically and reasonably splitting the PIC time, the XC time, and the cost of the flight. I've also heard of people doing what you suggests and frankly it seems to go against the letter AND the spirit of the Gebhart letter, not to mention what the FAA would reasonably expect XC flying to demand of a certificate candidate.
 
The letter of interpretation on this subject is ridiculous. A flight does not stop being a flight just because someone else landed.
 
dmspilot said:
The letter of interpretation on this subject is ridiculous. A flight does not stop being a flight just because someone else landed.
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But a pilot's participation in that flight ceases to be continuous, which to me is the most critical part of the letter.

Where this is ridiculous is if I let my 9 year old fly for a few minutes (which is probably what I would have said if I were trying to make myself look stupid). No one - not me, nor the FAA - would call my 9 year old's participation in the execution of the flight a break in continuity; however, my 9 year old is neither rated nor current and has no intention of logging PIC time.
 
Although it is a variation on the theme and may pass muster it depends on the definition of a cross country is as described in 61.1 (b).

It is possible that the wording: "(C) That includes a landing at a point other than the point of departure" might exclude a landing at the same airport of departure as would be the case for one of the pilots. Say pilot A was the pilot under the hood and pilot B was the safety pilot and by prior agreement or necessity was acting as PIC. Pilot B does once around the pattern and then lets Pilot A depart, fly the entire flight and land at the cross country destination. Pilot B then does once around the pattern. By the prior rulings, Pilot A can log the cross country flight as PIC and cross country. Pilot B can log the time as PIC when acting as the safety pilot and during the time flying around the two patterns, but it depends on if this time meets the definition of cross country time since the takeoff and landing occurred at the same airports, albeit at two different airports. This would argue that a cross country time would include multiple takeoffs and landings at the same airport in a simpler case where Pilot A flies between two airports and then spends the next several hours in the pattern at either the departure airport, destination airport, or both to accumulate additional cross country time.
 
14 CFR 61.1(b) said:
Cross-country time means—
(i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight—
(A) Conducted by a person who holds a pilot certificate;
(B) Conducted in an aircraft;
(C) That includes a landing at a point other than the point of departure; and
(D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
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It doesn't say anything about being a required crewmember.
 
John Collins said:
Although it is a variation on the theme and may pass muster it depends on the definition of a cross country is as described in 61.1 (b).

It is possible that the wording: "(C) That includes a landing at a point other than the point of departure" might exclude a landing at the same airport of departure as would be the case for one of the pilots. Say pilot A was the pilot under the hood and pilot B was the safety pilot and by prior agreement or necessity was acting as PIC. Pilot B does once around the pattern and then lets Pilot A depart, fly the entire flight and land at the cross country destination. Pilot B then does once around the pattern. By the prior rulings, Pilot A can log the cross country flight as PIC and cross country. Pilot B can log the time as PIC when acting as the safety pilot and during the time flying around the two patterns, but it depends on if this time meets the definition of cross country time since the takeoff and landing occurred at the same airports, albeit at two different airports. This would argue that a cross country time would include multiple takeoffs and landings at the same airport in a simpler case where Pilot A flies between two airports and then spends the next several hours in the pattern at either the departure airport, destination airport, or both to accumulate additional cross country time.
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You mean pilot A's and pilot B's landing occurred at the same airport?
 
MachFly said:
...if the pilot A (the pilot doing most of the flying) takes off, then pilot B (safety pilot) takes the controls, does one touch and go and give the plane back to pilot A. Then they arrive at another airport, pilot A does a touch and go, pilot B takes the airplane and does a full stop.
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Pilot B did the take off for the XC flight..Pilot A did a landing for the XC flight.

Neither gets to log XC flight.

Mike
 
ChrisK said:
If a pilot does a touch and go and hands controls over to the other pilot, I would think that this break in the journey would necessarily fail to be a continuous flight. The problem I think you have with the Gebhart letter isn't the need for a takeoff and landing by each PIC. I think the problem you have is with the portion of the interpretation that says:



If I wanted to take the most negative interpretation, I could argue that this means that NEITHER pilot could log cross country time, particularly if pilot A flew the takeoff for the same leg that pilot B landed. I have seen / heard of lots of people flying legs of trips where the individual legs qualified for whatever rating's cross country requirement, and logically and reasonably splitting the PIC time, the XC time, and the cost of the flight. I've also heard of people doing what you suggests and frankly it seems to go against the letter AND the spirit of the Gebhart letter, not to mention what the FAA would reasonably expect XC flying to demand of a certificate candidate.
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Imagine this scenario, pilot A and pilot B go on a cross-country flight. They have no intention of logging flight time at the same time and no intention of logging safety pilot. Pilot A does 90% of the flying, pilot B take the airplane for 10 minutes or so during the cruise portion and logs those 10 minutes. As pilot A was not the sole manipulator of the controls he does not log those 10 minutes in the middle. The question is can pilot A log his hours as cross-country?
 
MachFly said:
Imagine this scenario, pilot A and pilot B go on a cross-country flight. They have no intention of logging flight time at the same time and no intention of logging safety pilot. Pilot A does 90% of the flying, pilot B take the airplane for 10 minutes or so during the cruise portion and logs those 10 minutes. As pilot A was not the sole manipulator of the controls he does not log those 10 minutes in the middle. The question is can pilot A log his hours as cross-country?
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I agree with the intent of what you're saying. If pilot B flies and logs PIC for 10 minutes, pilot A can't log pic and does not meet the seeming standard of continuous flight as stated in the letter. In this case, I think no one gets to log XC. I'd tell Pilot B that I as Pilot A am still PIC and if he doesn't agree then Pilot A shouldn't stop flying for 10 minutes =)
 
Did the FAA ever say that you can't have a break in the middle of the flight?

What happens when you have an aircraft that requires two pilots and sometime in the middle of the flight one pilot leave to cockpit to use the lavatory? Does that pilot not get to log cross-country?
 
MachFly said:
Did the FAA ever say that you can't have a break in the middle of the flight?
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It is how I read the 2nd to last paragraph in the Gebhart interpretation linked above.
MachFly said:
What happens when you have an aircraft that requires two pilots and sometime in the middle of the flight one pilot leave to cockpit to use the lavatory? Does that pilot not get to log cross-country?
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I think there is a difference between the 2nd pilot using the john and the 2nd pilot not being able to log XC because another crewmember took over as required and OMG THIS iS GETTING SILLY

This example is completely different from your proposal where you take 4 flights and stitch them together to make 2 simultaneous overlapping XC's with 2 pilots in an aircraft that only requires 2 crewmembers due to the safety pilot inclusion.
 
ChrisK said:
It is how I read the 2nd to last paragraph in the Gebhart interpretation linked above.
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I guess that just depends on how you interpret it.
I don't believe FAA ever specifically said that you can't do that.

I don't think you can call it 4 separate flights. It's one single flight in which certain parts require one crew member.
 
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ChrisK said:
It is how I read the 2nd to last paragraph in the Gebhart interpretation linked above.

I think there is a difference between the 2nd pilot using the john and the 2nd pilot not being able to log XC because another crewmember took over as required and OMG THIS iS GETTING SILLY

This example is completely different from your proposal where you take 4 flights and stitch them together to make 2 simultaneous overlapping XC's with 2 pilots in an aircraft that only requires 2 crewmembers due to the safety pilot inclusion.
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I think the FAA's interpretation is what's silly.
 
MikeELP said:
Now you're just being a troll. :rolleyes:


Mike
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So let me get this straight. You make three posts in a thread, two of which are supposed to offend me and the other one is just repeating what someone else has said.
Please stop spamming.
 
MachFly said:
Please stop spamming.
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Please quit trolling. :D

You've been given the answer to your original scenario.....then you change the scenario...then you attack those who try to tell you that your assumptions are wrong.

:dunno:

And I'm most certainly not "spamming". I post with my real name.


Mike
 
dmspilot said:
It doesn't say anything about being a required crewmember.
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"...time acquired during flight—
(A) Conducted by a person who holds a pilot certificate;..."
​

If you were not a required crewmember, then in what sense did you 'conduct' the flight?
 
Problem is that the interpretation is a matter of fitting the reg to a policy decision where, in not just one interpretation but a few, the FAA has made it pretty clear that it does not want safety pilots or pilots splitting a leg to both log xc time toward later certificates and ratings. There are flaws in the interpretation if you look strictly at the regulatory language, but that' sweat we have.

Finding technical loopholes in those situations is good as a brain-teaser but rarely translates to the real world.
 
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JeffDG said:
How is this less legitimate than logging time with Otto flying?
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Suggesting pilots stop logging when the AP is on is stupid. For one, that would disincentivize using the auto pilot and that would be bad from a safety standpoint.

But you did get me thinking. I don't give two hoots, really, about logging any time. I still do log every flight but that's more out of habit and a desire to not 'spoil it now'. But I don't get excited at all about putting time in my book. I have close to 10K hours and am at the point where it doesn't matter any more.

So, for me, it's a standard thing. As long as we all log the same way you can use the hours to roughly gauge experience. But it requires all pilots to log the same way. If people log differently then it's perceived as cheating if it results in more hours and stupid if it results in less.
 
Captain said:
Suggesting pilots stop logging when the AP is on is stupid. For one, that would disincentivize using the auto pilot and that would be bad from a safety standpoint.
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Besides, if you are not flying the airplane when Otto is handling a few of the tasks, you need better autopilot training.

And I think many people misunderstand logging flight time under 61.51 and the other regs dealing with logging. It's not about "real" experience. It's just about using FAA guidelines to write FAA numbers in an FAA-required record to show you meet FAA set requirements for FAA certificates and FAA ratings and FAA currency. It doesn't have to make any sense whatsoever beyond that.
 
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midlifeflyer said:
Problem is that the interpretation is a matter of fitting the reg to a policy decision...
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Mark, I think that's a really good summation of the crux of the problem (and there is a problem) with lots of Chief Counsel interpretations. Those lawyers don't know enough about the aviation business to know when the "policy", as they understand the policy, isn't in tune with the actual intent of the rule. Sometimes that's Chief Counsel's fault, sometimes it's the policy-maker's.

Take the IFR fuel requirement for instance. Part 91 and Part 121 have slightly different wordings that change the fuel requirements between the two types of operations, all other factors being the same. But there's an interpretation that essentially makes them the same and adds in more fuel not mentioned in either rule. The net result is, it makes a fuel-guzzling old turbojet now carry enough fuel (read unwanted extra weight) for three climbs to altitude rather than the obvious two of departure and destination after a missed approach.
EDIT: See slides #9 thru #15: http://www.avclicks.com/Flash2/Flight_Planning_for_Government/index.html

There's another one, on carrying passengers, related to your business or employment; one on meeting airworthiness requirements with respect to the definition of "current"; and as far as I'm concerned, the whole cockeyed notion of allowing anybody other than the person actually responsible for the operation of the aircraft to log the time as PIC. In my generation, nobody taking flight instruction did that. Nor did they log safety pilot time at all. We were just as desperate to put free hours in our logbooks as today's generation is, but our aviation elders were less permissive. Pilot in command time meant just that, not "wiggling the controls" time.

dtuuri
 
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midlifeflyer said:
...
And I think many people misunderstand logging flight time under 61.51 and the other regs dealing with logging. It's not about "real" experience. It's just about using FAA guidelines to write FAA numbers in an FAA-required record to show you meet FAA set requirements for FAA certificates and FAA ratings and FAA currency. It doesn't have to make any sense whatsoever beyond that.
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In other words, 'STOP MAKING SENSE'!!

Our part 61 logging rules are a national embarrassment, and the crack legal minds in the FAA who churn out these letters make things worse.

My advice: Have fun with 61.5, see how many pilots can be log PIC/Crosscountry/astronaut time in one airplane. Knock yourself out. See what the DPE will buy. It's all good. Maybe you can take that checkride a few hours before someone who logs reality.

But if you ever want to fly professionally please also log reality. And the reality is that there is ONE pilot-in-command at time, and in 99% of all flights there is one PIC per flight. If you are not sure who that is, read the definition in FAR-1.

Keep a 'reality' section in your logbook where you log FAR-1 PIC, SIC in airplanes that really require two crewmembers, and dual instruction time. Do this for two reasons:

1) A lot of professional flying organizations want to know your real PIC/SIC/Dual time, and not this fake 61.5 PIC. You don't want to have to tap dance in an interview.

2) In the long there is a school of thought that says integrity means something. Attend that school.

Don't conflate reality with the 61.5 bizzaro world.

Strong message follows.
 
MachFly said:
Thanks for the link.

The letter says pretty much exactly what I said in the OP, except it does not address a scenario where both pilots do a landing and a take off. Also I would like the point out that the letter specifically states that the only pilot that can log everything is the pilot that does the take offs and landings.

Just to clarify. Pilot A won't be able to log the time that it takes pilot B to do a touch and go (and the same for pilot B ), therefore neither pilot will be able to log all of the flight time because during the touch and go part only one of them is a required crew member. But because they both did a touch and go, both can log all their time as cross-country.
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I think you have a valid position that should get a clarification/interpretation from Chief Counsel, write the letter.
 
Captain said:
Suggesting pilots stop logging when the AP is on is stupid. For one, that would disincentivize using the auto pilot and that would be bad from a safety standpoint.
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As would forbidding safety pilots. Use of rated safety pilots incentivizes proficiency in flight by reference to instruments, which is certainly a positive from a safety standpoint.

My point is, you look down on Safety Pilot logging, but don't seem to have a problem when people activate Otto the moment they can and turn it off at DH.
 
JeffDG said:
As would forbidding safety pilots. Use of rated safety pilots incentivizes proficiency in flight by reference to instruments, which is certainly a positive from a safety standpoint.

My point is, you look down on Safety Pilot logging, but don't seem to have a problem when people activate Otto the moment they can and turn it off at DH.
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You just introduced a new issue...using the AP too much (in your opinion). I thought we were talking about logging flight time, not excessive use of equipment. If you'd like to talk about correct auto pilot usage I'd think a new thread would be in order.
 
Captain said:
You just introduced a new issue...using the AP too much (in your opinion). I thought we were talking about logging flight time, not excessive use of equipment. If you'd like to talk about correct auto pilot usage I'd think a new thread would be in order.
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Well, if you're on autopilot, aren't you just playing safety pilot for Otto? I think that is the correlation being made.
 
Henning said:
Well, if you're on autopilot, aren't you just playing safety pilot for Otto? I think that is the correlation being made.
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:yeahthat:

Yep, Otto flies solely by reference to the instruments, that's for sure.
 
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