Safety Pilot Questions

[midlifeflyer]

Mark, are you saying you would log PIC AND SIC on the same flight? I would never have thought to do that. I never logged PIC when I was sole manipulator SIC although by rights I could have. My choice. But I am not sure about logging both on the same flight.

Why not? If you are sole manipulator of the controls of an aircraft you are rated for, you log PIC under 61.51(e)(1)

And if you happen to fit one of the SIC rules at the same time you log SIC (all of which are about "acting" as required crew) under

• 61.51(f)(1) - SIC qualified in aircraft requiring more than one pilot.
• 61.51(f)(2) - Rated in category and class (and instrument if the flight requires it) in an aircraft or an operation requiring more than one pilot.
• 61.51(f)(3) - serving as SIC on a flight with a 135.99(c) special SIC authorization.

you would log that as well.

Do you see anything about flying the airplane and acting as an SIC mutually exclusive from a regulatory standpoint.

Three hour flight, SIC flies for an hour. 3 hours SIC; 1 hour PIC.

 

[MauleSkinner]

Yup…nothing says you can’t log more than one type of pilot time…PIC and Instruction Received seems more of a logical stretch to me than PIC and SIC, but it’s perfectly legal and done all the time.

 

[Greg Bockelman]

I suppose. Just never thought about it like that before.

 

[midlifeflyer]

seems more of a logical stretch

There's the problem in a nutshell. We look for logic based on sometimes faulty assumptions when we should be reading words on a page.

Take PIC and instruction received. It's a logical stretch when we make either one of two assumptions. One is that logging 61.51 is about anything other than the choices the FAA has made about how to count time for certificates, ratings, regulatory qualification and currency. The other is that somehow, an ATP receiving training in an airplane they own and have flown thousands of hours in can't be in command when receiving instruction from a CFI with a 10th of their type experience.

 

[MauleSkinner]

There's the problem in a nutshell. We look for logic based on sometimes faulty assumptions when we should be reading words on a page.

Take PIC and instruction received. It's a logical stretch when we make either one of two assumptions. One is that logging 61.51 is about anything other than the choices the FAA has made about how to count time for certificates, ratings, regulatory qualification and currency. The other is that somehow, an ATP receiving training in an airplane they own and have flown thousands of hours in can't be in command when receiving instruction from a CFI with a 10th of their type experience.

The logical stretch is more about the FAA writing the regs to make numbers in a logbook just numbers in a logbook. And how we get to the point where we’re parsing regs so that we can have the absolute minimum amount of fun (aka, flying) to get the next certificate or rating.

Granted, I’m not sure how one would rewrite them, and we’re probably too far gone to turn back.

 

[RussR]

Three hour flight, SIC flies for an hour. 3 hours SIC; 1 hour PIC.

Yup…nothing says you can’t log more than one type of pilot time…PIC and Instruction Received seems more of a logical stretch to me than PIC and SIC, but it’s perfectly legal and done all the time.

You guys make my head hurt - after all these years of discussing acting vs logging, I had it all figured out, and now you slip this in, that I have never seen discussed anywhere before.

Granted, the usual discussions about logging/acting typically revolve around "safety pilot" or "receiving training after you're rated".

I guess the typical scenario for this would be two PIC type-rated pilots flying a plane or an operation that requires two pilots.

On a normal flight, Pilot A is the PIC and Pilot B is the SIC. This is due to company policy or seniority or whatever. Pilot A is the acting PIC.
Pilot A flies and Pilot B does normal copilot duties like gear and flaps and radios.
Pilot A logs PIC, Pilot B logs SIC.
I am reasonably sure this is normal.

However, one day Pilot A lets Pilot B fly.
Pilot A is still the designated acting PIC, Pilot B is designated acting SIC.
Pilot B does all the flying. Pilot A operates the radios and gear and other typical co-pilot-like duties.

It's a 3 hour flight.
Pilot A logs PIC under 61.51e(1)(iii).
Pilot B logs 3 hours PIC (61.51e(1)(i)) AND 3 hours SIC (61.51f(1))?

Then after many years of flying, Pilot B's resume says "10,000 total hours, 9000 PIC, 9000 SIC".

I have to bet that would raise questions on an interview.

Is this actually done? I agree the regulations seem to say "hey, this is legit", but man...

Wait, does Pilot A actually log SIC too? After all, they are qualified under 61.51f(1) as SIC as well.

 

[Mxfarm]

something only a CFO would love...

 

[MauleSkinner]

Is this actually done? I agree the regulations seem to say "hey, this is legit", but man...

I suspect that most people who log both stop doing so within a couple thousand hours.

 

[Greg Bockelman]

Wait, does Pilot A actually log SIC too? After all, they are qualified under 61.51f(1) as SIC as well.

ROTFLMAO. Thank you for the laugh, Russ.

I have approximately 12,000 hours of 777 co-pilot time. Approximately half of that was as pilot flying. Although even though I was (am) type rated and could log it as PIC sole manipulator, I chose not to.

Never have I ever thought to consider that I could log PIC AND SIC at the same time. That defies all logic, even for the FAA. But, alas, that is the way of the FAA.

 

[crash7]

The recent balloon commercial medical requirement also contains a clause that opens up basic med to any required crewmember which covers safety piloting even if you are not PIC.

The goofiness in the reg was that for expedience the FAA didn't stray from the congressional mandate on what basic med should be.

Is this in place now? Or still proposed to be active at some point in the undetermined future?


Sent from my iPad using Tapatalk

 

[Palmpilot]

Is this in place now? Or still proposed to be active at some point in the undetermined future?


Sent from my iPad using Tapatalk

Not yet. The comment period on the NPRM ends on January 18th. I don't know how long it takes after that to publish the final rule, but my recollection is that it is not a fast process.

https://www.federalregister.gov/doc...n-standards-for-commercial-balloon-operations


Sent from my HP Envy using Firefox

 

[RussR]

On the PIC & SIC logging issue, there is the Murphy 2015 interpretation:

https://www.faa.gov/about/office_or...rps/2015/Murphy_2015_Legal_Interpretation.pdf

Which seems to be about to answer this very question, but then inserts some key words which could possibly change the meaning.

"The second question, briefly stated, asks whether, in an aircraft type certificated for two pilots, a second-in-command (SIC) who is appropriately type rated to log flight time as PIC may also log the same time as SIC. As we interpret that question, a pilot may not "double log" flight time in a manner that would misrepresent that pilot's total flight hours."

and later:

"A pilot would therefore have no valid reason to double log flight time as both a PIC and an SIC. In fact, were a pilot to do so, he or she could misrepresent a segment of flight time as twice the flight time."

As first glance, it seems to say "no, you can't do this", but upon further reading doesn't QUITE say that.

The first excerpt says you can't do it "in a manner that would misrepresent" total flight time. Well, "total flight time" is a pretty standard column in most logbooks. So that sentence says to me "just don't try to say that the 3 hours of PIC and 3 hours of SIC equaled 6 hours of flight time on a 3 hour flight".

The second excerpt says there is "no valid reason to double log flight time". But that doesn't mean you can't do something. There's no valid reason to do lots of stuff that people do all the time. That doesn't mean they're prohibited.

And it also says you "could misrepresent that pilot's total flight hours". You could, but what if you didn't? I guess you're okay then.

To be clear, I think the concept of simultaneously logging both is ridiculous, and I seriously doubt that was intended by the wording of 61.51.

 

[IK04]

Why would you not log PIC as sole manipulator of the controls?

I would log PIC for the entire flight regardless of the safety pilot being qualified, current and medically qualified. His name goes in the remarks, but I don't care what he logs, if anything...

 

[Greg Bockelman]

"A pilot would therefore have no valid reason to double log flight time as both a PIC and an SIC. In fact, were a pilot to do so, he or she could misrepresent a segment of flight time as twice the flight time."

Wouldn’t it only be misrepresentation if the total time was double logged?

 

[midlifeflyer]

On the PIC & SIC logging issue, there is the Murphy 2015 interpretation:

https://www.faa.gov/about/office_or...rps/2015/Murphy_2015_Legal_Interpretation.pdf

Which seems to be about to answer this very question, but then inserts some key words which could possibly change the meaning.

"The second question, briefly stated, asks whether, in an aircraft type certificated for two pilots, a second-in-command (SIC) who is appropriately type rated to log flight time as PIC may also log the same time as SIC. As we interpret that question, a pilot may not "double log" flight time in a manner that would misrepresent that pilot's total flight hours."

and later:

"A pilot would therefore have no valid reason to double log flight time as both a PIC and an SIC. In fact, were a pilot to do so, he or she could misrepresent a segment of flight time as twice the flight time."

As first glance, it seems to say "no, you can't do this", but upon further reading doesn't QUITE say that.

The first excerpt says you can't do it "in a manner that would misrepresent" total flight time. Well, "total flight time" is a pretty standard column in most logbooks. So that sentence says to me "just don't try to say that the 3 hours of PIC and 3 hours of SIC equaled 6 hours of flight time on a 3 hour flight".

The second excerpt says there is "no valid reason to double log flight time". But that doesn't mean you can't do something. There's no valid reason to do lots of stuff that people do all the time. That doesn't mean they're prohibited.

And it also says you "could misrepresent that pilot's total flight hours". You could, but what if you didn't? I guess you're okay then.

To be clear, I think the concept of simultaneously logging both is ridiculous, and I seriously doubt that was intended by the wording of 61.51.

If you read it carefully, it's saying you don't get to log 3 hours PIC, 3 hours SIC, and 6 hours total time. You don't do that with any combination of loggable time.

Is logging PIC and dual received equally ridiculous? Same rules, same result, and according to professional pilots I have corresponded with, who say companies are looking for "acting" time, just as important to understand and properly present on an application or in an interview.

BTW, I've heard many pilots argue that the FAA never really intended to allow a pilot to log PIC unless qualified and acting as PIC. But the FAA has been pretty consistent every time the question has been raised about the role of 61.51 since 1980.

it really is just the decades old acting vs logging dichotomy.

 

[midlifeflyer]

Wouldn’t it only be misrepresentation if the total time was double logged?

That is exactly what that sentence says.

 

[Greg Bockelman]

That is exactly what that sentence says.

At that rate, that sentence has no reason to be included. Just stop with the previous sentence.

 

[RussR]

If you read it carefully, it's saying you don't get to log 3 hours PIC, 3 hours SIC, and 6 hours total time.

I didn't say it did. But it IS saying by implication that you can log both PIC and SIC as long as you DON'T try to misrepresent the total time. So, 3 PIC and 3 SIC and 3 total hours is "okay".

Is logging PIC and dual received equally ridiculous?

I think in some case it is, and some it's not, but I do know that the interpretations have been pretty consistent on this one, so, okay.

it really is just the decades old acting vs logging dichotomy.

I do think the PIC/SIC thing has quite a different flavor to it than the normal "safety pilot" or "PIC and dual" discussions. Because 61.51f is worded differently than the other paragraphs. If you notice, it doesn't require you to do anything. You just have to be a qualified SIC and sitting in a control seat. Since anybody qualified to be PIC in an airplane is automatically also qualified to be SIC, that means that the literal interpretation of this is that if you are the PIC of a two-person crewed airplane, you can always log SIC, whether you're actually flying and logging PIC also, letting the other guy fly, doing something or doing nothing.

Basically, with that reading, by 61.51f, every airline captain should be logging PIC and SIC for every flight. And I can't assume that's the intent. And the Murphy 2015 interpretation almost but not quite says that's not the intent.

But why would anybody do it? Not that it really makes a difference, because it wouldn't be artificially inflating time, but it's a logbook quirk that I have never heard discussed before. I assume because it just doesn't happen in real flying.

I can only imagine the discussion that would ensue on a checkride or interview logbook review.

 

[midlifeflyer]

the literal interpretation of this is that if you are the PIC of a two-person crewed airplane, you can always log SIC, whether you're actually flying and logging PIC also, letting the other guy fly, doing something or doing nothing.

I agree that in many situations PIC and SIC are redundant in both a regulatory and practical sense. But it's about benefit. Does the pilot perceive a benefit from logging anything other than the minimum requirements?

From your example, why would anyone acting as PIC and able to log it even bother to log SIC? What benefit to the pilot is there? Maybe there's one or two regs in all the FAR with a minimum of SIC time required as opposed to PIC or total time?

every airline captain should be logging PIC and SIC for every flight.

Not at all. Most of the logging rules in 61.51 are permissive. No one forces the ATP captain of a 121 operation to log SIC when not flying, and I can't even imagine the benefit of doing it. The SIC time would be meaningless to the pilot and to anyone else looking at it.

OTOH, I can imagine a pilot seeing a potential benefit to "I have 2200 hours PIC time and 800 hours as SIC crew in two pilot operations" (maybe even adding a "part 1 PIC" column to differentiate between being in command and being a sole manipulator regardless of status) and having the logbook entries to back up those statements.

The rules rules let them do it. But you don't have to.

 

[Lon Stratton]

Ran into that issue with a friend of mine.

He's BasicMed, and my plane's a Piper Lance.

The Lance is capable of being seven seats, which exceeds the capability of a BasicMed pilot. Thus, legally not allowed to be PIC, thus doesn't qualify as safety pilot.

There's an STC for the Lance which "removes" the capability of a seventh seat, thus, making the plane BasicMed qualified. I don't have this STC, and don't plan on getting it unless I need to at some future time.

You probably know this, but AOPA has that 6 seat STC available for free to members. Unless you want to keep the 7th seat option open. It's just a 337.

 

[RussR]

OTOH, I can imagine a pilot seeing a potential benefit to "I have 2200 hours PIC time and 800 hours as SIC crew in two pilot operations" (maybe even adding a "part 1 PIC" column to differentiate between being in command and being a sole manipulator regardless of status) and having the logbook entries to back up those statements.

There may or may not be benefit, but when the pilot's total time is something less than 3000, I'll bet any potential benefit will be immediately negated by an interviewer questioning what's going on, and the ensuing discussion.

Do you know of anybody actually logging PIC and SIC simultaneously? I have never heard it it, so I suspect it's an academic exercise more than a relevant one.

 

[MauleSkinner]

Do you know of anybody actually logging PIC and SIC simultaneously? I have never heard it it, so I suspect it's an academic exercise more than a relevant one.

Anything in my logbook under PIC is acting PIC, so when I was a 135 SIC, I added a column for Sole Manipulator.

The only interview it came up in, they didn’t like me for other reasons, so it’s probably moot.

 

[midlifeflyer]

There may or may not be benefit, but when the pilot's total time is something less than 3000, I'll bet any potential benefit will be immediately negated by an interviewer questioning what's going on, and the ensuing discussion.

Do you know of anybody actually logging PIC and SIC simultaneously? I have never heard it it, so I suspect it's an academic exercise more than a relevant one.

No. I don't. But how would I know?

The question was, do the rules permit it and the answer is yes,

I would expect the result of the ensuing discussion to depend on the interviewee. Explaining why they did it and what it means in terms of their qualifications and experience should go over well unless it's one of those anal interviewers who thinks it's bad to do what regulations permit. OTOH, if the answer is, "Mark said it's OK," I'd expect it to go quite badly. Rote vs Understanding vs Application vs Correlation .

 

[thito01]

There's an STC for the Lance which "removes" the capability of a seventh seat, thus, making the plane BasicMed qualified. I don't have this STC, and don't plan on getting it unless I need to at some future time.

This is not correct. The STC from AOPA is worded in such a way that the aircraft is restricted to 6 seats ONLY IF the PIC is using Basic Med. You can still have, and fill, 7 seats if the PIC has a standard medical. It's dependent on the status of the PIC on each flight and not some logbook entry.
.

 

[unsafervguy]

I agree that in many situations PIC and SIC are redundant in both a regulatory and practical sense. But it's about benefit. Does the pilot perceive a benefit from logging anything other than the minimum requirements?

From your example, why would anyone acting as PIC and able to log it even bother to log SIC? What benefit to the pilot is there? Maybe there's one or two regs in all the FAR with a minimum of SIC time required as opposed to PIC or total time?

Not at all. Most of the logging rules in 61.51 are permissive. No one forces the ATP captain of a 121 operation to log SIC when not flying, and I can't even imagine the benefit of doing it. The SIC time would be meaningless to the pilot and to anyone else looking at it.

OTOH, I can imagine a pilot seeing a potential benefit to "I have 2200 hours PIC time and 800 hours as SIC crew in two pilot operations" (maybe even adding a "part 1 PIC" column to differentiate between being in command and being a sole manipulator regardless of status) and having the logbook entries to back up those statements.

The rules rules let them do it. But you don't have to.

but do the rules allow it? think about this, from the pilots handbook of aeronautical knowledge FAA-H-8083-25B:
Secondary Flight Controls
Secondary flight control systems may consist of wing flaps,
leading edge devices, spoilers, and trim systems. in a two pilot operation the NFP selects the flaps up after take off and down during approach, so is either pilot really "sole manipulator of the controls" during a two pilot operation? i guess that is a question for the legal eagles to decide, if you were to log it under sole manipulator would you have to deduct the time that the NFP was manipulating the flap lever?
for me even though I am PIC type rated in the jet, if my name is not on the release as PIC i log it SIC, but thats just my way of doing it.

 

[Palmpilot]

but do the rules allow it? think about this, from the pilots handbook of aeronautical knowledge FAA-H-8083-25B:
Secondary Flight Controls
Secondary flight control systems may consist of wing flaps,
leading edge devices, spoilers, and trim systems. in a two pilot operation the NFP selects the flaps up after take off and down during approach, so is either pilot really "sole manipulator of the controls" during a two pilot operation? i guess that is a question for the legal eagles to decide, if you were to log it under sole manipulator would you have to deduct the time that the NFP was manipulating the flap lever?...

If you are the designated pilot-in-command, then this might apply:

61.51(e)(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

In some situations, this might apply:

61.51(e)(5) A commercial pilot or airline transport pilot may log all flight time while acting as pilot in command of an operation in accordance with § 135.99(c) of this chapter if the flight is conducted in accordance with an approved second-in-command professional development program that meets the requirements of § 135.99(c) of this chapter.

 

[unsafervguy]

If you are the designated pilot-in-command, then this might apply:

61.51(e)(2) If rated to act as pilot in command of the aircraft, an airline transport pilot may log all flight time while acting as pilot in command of an operation requiring an airline transport pilot certificate.

In some situations, this might apply:

61.51(e)(5) A commercial pilot or airline transport pilot may log all flight time while acting as pilot in command of an operation in accordance with § 135.99(c) of this chapter if the flight is conducted in accordance with an approved second-in-command professional development program that meets the requirements of § 135.99(c) of this chapter.

yes, that is why the captain gets to log PIC all the time no matter who is flying, but the question that is being debated is, can a PIC type rated SIC log the legs he is flying as PIC? lets make it even fuzzier, how about an augmented crew with a FB in the left seat and the FO in the right seat. who can log what?

 

[midlifeflyer]

but do the rules allow it? think about this, from the pilots handbook of aeronautical knowledge FAA-H-8083-25B:
Secondary Flight Controls
Secondary flight control systems may consist of wing flaps,
leading edge devices, spoilers, and trim systems. in a two pilot operation the NFP selects the flaps up after take off and down during approach, so is either pilot really "sole manipulator of the controls" during a two pilot operation? i guess that is a question for the legal eagles to decide, if you were to log it under sole manipulator would you have to deduct the time that the NFP was manipulating the flap lever?
for me even though I am PIC type rated in the jet, if my name is not on the release as PIC i log it SIC, but thats just my way of doing it.

Too much of a pin dance even for me. But if I had to give an answer I go with stick and rudder as the ones that count. It's a bit similar to the 91.109(a) requirement that in order to be used for instruction, an aircraft must have "fully functioning dual controls." That one has been addressed in two FAA Chief Counsel interpretation letters. They are "pitch, yaw, and roll controls," and reachable power controls. The first of those said dual brakes are not required. The FAA has said that's not an exclusive list but I feel comfortable that the flap lever belongs in the brakes column and not in the stick/rudder/power group.

YMMV

 

[unsafervguy]

Too much of a pin dance even for me. But if I had to give an answer I go with stick and rudder as the ones that count. It's a bit similar to the 91.109(a) requirement that in order to be used for instruction, an aircraft must have "fully functioning dual controls." That one has been addressed in two FAA Chief Counsel interpretation letters. They are "pitch, yaw, and roll controls," and reachable power controls. The first of those said dual brakes are not required. The FAA has said that's not an exclusive list but I feel comfortable that the flap lever belongs in the brakes column and not in the stick/rudder/power group.

YMMV

i agree,but it is fun to discuss what may and may not fit in under the regs. my feeling is if your in an operation that requires a designated PIC and SIC ie 135 and 121 the person who's name is printed on the dispatch as pic logs PIC and the persons name listed as SIC logs SIC that simple.

 

[flyingron]

yes, that is why the captain gets to log PIC all the time no matter who is flying, but the question that is being debated is, can a PIC type rated SIC log the legs he is flying as PIC?

He can't be flying as PIC if he only has a SIC type rating. Are you asking if he can log it as PIC when he's the sole manipulator when flying as SIC?

 

[midlifeflyer]

i agree,but it is fun to discuss what may and may not fit in under the regs.

I agree.

 

[unsafervguy]

He can't be flying as PIC if he only has a SIC type rating. Are you asking if he can log it as PIC when he's the sole manipulator when flying as SIC?

as of jan 1 2016 nobody can fly 121 PIC or SIC without a PIC type. thats what prompted the discussion. since all SIC's hold a PIC type rating can they log PIC as sole manipulator of the controls on the legs they are PF?

 

[MauleSkinner]

but do the rules allow it? think about this, from the pilots handbook of aeronautical knowledge FAA-H-8083-25B:
Secondary Flight Controls
Secondary flight control systems may consist of wing flaps,
leading edge devices, spoilers, and trim systems. in a two pilot operation the NFP selects the flaps up after take off and down during approach, so is either pilot really "sole manipulator of the controls" during a two pilot operation? i guess that is a question for the legal eagles to decide, if you were to log it under sole manipulator would you have to deduct the time that the NFP was manipulating the flap lever?
for me even though I am PIC type rated in the jet, if my name is not on the release as PIC i log it SIC, but thats just my way of doing it.

What constitutes “flight controls” for the purposes of various regs gets…interesting. Can I ACT as PIC if my takeoffs and landings for recency only involved sole manipulation of the PRIMARY flight controls? I’ve also been told by FAA inspectors that radios are considered flight controls for the purposes of 135.115, although I suspect that any violations for allowing someone to “run the radios” would actually fall under 135.95.

 

[flyingron]

as of jan 1 2016 nobody can fly 121 PIC or SIC without a PIC type. thats what prompted the discussion. since all SIC's hold a PIC type rating can they log PIC as sole manipulator of the controls on the legs they are PF?

I misparsed your sentence. The last "as PIC" refereed to the word log rather than flying.

 

[Greg Bockelman]

as of jan 1 2016 nobody can fly 121 PIC or SIC without a PIC type. thats what prompted the discussion. since all SIC's hold a PIC type rating can they log PIC as sole manipulator of the controls on the legs they are PF?

Yes.

 

[Bean Outdoors]

Yeah, the FAA and Congress went full retard with that bit of legislation and regulation. Can act as 1st in command but not second. Idiocracy at its finest.

its crazy

 

[jrcox19]

This is not correct. The STC from AOPA is worded in such a way that the aircraft is restricted to 6 seats ONLY IF the PIC is using Basic Med. You can still have, and fill, 7 seats if the PIC has a standard medical. It's dependent on the status of the PIC on each flight and not some logbook entry.
.

AOPA's own article says the seat must removed.

 

[MauleSkinner]

AOPA's own article says the seat must removed.

Yes…you have to remove it if you’re basic med, you can put it back in otherwise. Takes about as much time as it took me to type this.