Acting as Safety Pilot

You guys have to help me please, for I’m not clearly able to delineate when a safety pilot is needed or when it not required. Guaranteed, under VMC, you do need one specifically when you’re under the hood? I believe I’ve locked that in a point of fact. Now, why is it, under IMC and under the hood, you’re not able to log safety pilot time? Not that I’m agreeing or disagreeing, for I’ve no position to support my position either way, but I am trying to understand either the FAR that states no, or the logic where it should not be done or cannot be done.

I’ve also been told doing extreme dark conditions at night, that can considered IMC given perhaps a starless/moonless/no light situation, you have no visual reference to ascertain which way is up other than with instruments. In those cases, yes. . .I can see the need for no safety pilot. If, however, I’m shooting an approach under those circumstances under that same situation, I can see the need for a safety pilot to confirm I’m not compromising either the aircraft or myself as I shoot and approach to minimums.

. . .yep, I’m trying to get a clear understanding behind the rationale of the FAR.

DE727UPS

Where might I be potentially compromised by logging safety pilot in IMC conditions at least from an interview perspective? Again, how is it perceived as a "loophole?" Simply because it's IMC?
 
The generally acknowledged reason for the safety pilot is to visually scan for traffic in VMC conditions because the pilot flying is unable to, simply due to the view limiting device. All the rest of the discussion spans from that premise, although I'll certainly bow to Midlife and others when it comes to actually *understanding* the FARs and their interpretations and implementation. :D
 
MFT1Air said:
You guys have to help me please, for I’m not clearly able to delineate when a safety pilot is needed or when it not required. Guaranteed, under VMC, you do need one specifically when you’re under the hood? I believe I’ve locked that in a point of fact. Now, why is it, under IMC and under the hood, you’re not able to log safety pilot time? Not that I’m agreeing or disagreeing, for I’ve no position to support my position either way, but I am trying to understand either the FAR that states no, or the logic where it should not be done or cannot be done.

I’ve also been told doing extreme dark conditions at night, that can considered IMC given perhaps a starless/moonless/no light situation, you have no visual reference to ascertain which way is up other than with instruments. In those cases, yes. . .I can see the need for no safety pilot. If, however, I’m shooting an approach under those circumstances under that same situation, I can see the need for a safety pilot to confirm I’m not compromising either the aircraft or myself as I shoot and approach to minimums.

. . .yep, I’m trying to get a clear understanding behind the rationale of the FAR.

DE727UPS

Where might I be potentially compromised by logging safety pilot in IMC conditions at least from an interview perspective? Again, how is it perceived as a "loophole?" Simply because it's IMC?
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Whenever you meet someone that is flying under the hood in IMC, please let me know and I will pay you $5 for each instance.

The whole idea of the 'safety pilot' is to assist you in watching for traffic in VMC conditions. When you are IMC, you are on an IFR flight plan (or better be) and therefore, the controller is acting as your safety pilot.

If you were doing the safety pilot thing and entered IMC conditions, there is no longer a scenario for a safety pilot. The safety pilot becomes a passenger in that case.

Again, the point of the hood is to simulate IMC conditions. If you are in IMC conditions what is there to simulate? Think about it. What is the point for a fire drill? In your logic, you would be simulating a fire drill, and then going back in the building and starting a real fire to be put out.
 
Chewie von Nubbins said:
Whenever you meet someone that is flying under the hood in IMC, please let me know and I will pay you $5 for each instance.

The whole idea of the 'safety pilot' is to assist you in watching for traffic in VMC conditions. When you are IMC, you are on an IFR flight plan (or better be) and therefore, the controller is acting as your safety pilot.

If you were doing the safety pilot thing and entered IMC conditions, there is no longer a scenario for a safety pilot. The safety pilot becomes a passenger in that case.
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Agreed but not completely for again, I can see those quick transitions from IMC/VMC/IMC/VMC where the continuity of having a safety pilot through those transitions would be both appropriate and practical.

Chewie von Nubbins said:
Again, the point of the hood is to simulate IMC conditions. If you are in IMC conditions what is there to simulate? Think about it. What is the point for a fire drill? In your logic, you would be simulating a fire drill, and then going back in the building and starting a real fire to be put out.
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For the last part of your questions, if I were a fireman, yes - I would initiate fire in practice areas to practice my ability to put out fires.

So, help me here with something more approximate:

I looked at airport EFD - ILS Rwy 17R on airnav. If AWOS reported visibility 1/4 mile with ceiling scattered/broken (not overcast) 700, at 4.4 nm out, am I in IMC? If I have erred significantly on the glideslope and placed myself a few hundred feet below it, that mistake is going to cascade all the way through to my DH. At 700 feet, that safety pilot is going to recognize we've been compromised and immediately work to abort the approach something me as the pilot under the hood hasn't seen yet. That same response would be in both IMC or VMC, correct? The safety pilot is also checking to ensure all that applies to how I've handled both preparing the aircraft for the approach and landing (flaps, gear, etc.) and how I've flown the final phase of the landing, or is that something more a CFI-I would do?

Now, where am I going wrong in my thought process here? And do feel you're patronizing me if you have to spoon feed me an explanation. I've not gotten my IFR ticket yet, but I do wish to fully understand.
 
DE727UPS said:
Interesting concept, though....I like the way you think.
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Consider: Clouds are not uniform. It is a scattered or broken layer the flight is taking place in. The flying pilot flies under the hood because he cants it all to count. The safety pilot is there primarily for "see and avoid" purpose which are required any time you can see outside.

As I said, I can't see much reason, even in this situation, for the flying pilot to want to put the hood on - from a training/experience standpoint, being required to move bank and forth between the gauges and visual is an important skill. If the FAA were faced with a case in which there was some kind of pattern that suggested that the =only= reason for doing it was to allow both pilots to log the time (jn orther words, a sham), I don't think there would be a problem. Unfortunately, if it ended up with the NTSB full board, chances are it would be precisely because there was that kind of a pattern (like the case about the two MEIs who claimed that they gave each other instruction on every flight).
 
MFT1Air said:
Agreed but not completely for again, I can see those quick transitions from IMC/VMC/IMC/VMC where the continuity of having a safety pilot through those transitions would be both appropriate and practical.
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Negs. This would be an IFR flight plan. And, the purpose of the safety pilot is to simulate IMC/IFR conditions while in VMC conditions. Meaning, an IFR flight plan isn't just for 80-100% flying in IMC. Flying an IFR flight plan after getting the IRA while in 100% VFR/VMC conditions is probably the best practice to follow until the comfort level with flying and filing IFR is better achieved. The minute you enter IMC conditions, you have to legally be on an IFR flight plan. More often than not, the majority of an IFR flight plan will be performed under VMC conditions. You can't reasonably expect to cancel the IFR flight plan the minute you hit VMC conditions and expect to keep getting pop-up clearances the next minute you have IMC conditions. Otherwise, you might have a 1-800 number to call once you land. :)

Although, I could see that 'legally' when you encounter VMC/VFR conditions, you probably could get away with pulling the safety pilot thing. But, that guy that you are splitting time and the bill with will be short changed if you follow and log the time appropriately. I just haven't heard of someone wanting to split 5 hours in a multi at +$200 an hour and knowing that they 'might' be able to log 2 hours because VMC conditions existed along the way of an IFR flight plan.


For the last part of your questions, if I were a fireman, yes - I would initiate fire in practice areas to practice my ability to put out fires.

So, help me here with something more approximate:

I looked at airport EFD - ILS Rwy 17R on airnav. If AWOS reported visibility 1/4 mile with ceiling scattered/broken (not overcast) 700, at 4.4 nm out, am I in IMC? If I have erred significantly on the glideslope and placed myself a few hundred feet below it, that mistake is going to cascade all the way through to my DH. At 700 feet, that safety pilot is going to recognize we've been compromised and immediately work to abort the approach something me as the pilot under the hood hasn't seen yet. That same response would be in both IMC or VMC, correct? The safety pilot is also checking to ensure all that applies to how I've handled both preparing the aircraft for the approach and landing (flaps, gear, etc.) and how I've flown the final phase of the landing, or is that something more a CFI-I would do?

Now, where am I going wrong in my thought process here? And do feel you're patronizing me if you have to spoon feed me an explanation. I've not gotten my IFR ticket yet, but I do wish to fully understand.
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I think you are a little off with your interpretation of what a safety pilot's job really is. The job of a safety pilot (as stated above) is to watch for traffic while simulating IFR/IMC conditions while operating in VMC/VFR conditions. The scenario above you give have really nothing to do with the modern interpretation of a 'safety pilot,' but rather a CFII. The job of the safety pilot is not to bail you out if you start screwing up an approach. That is the job of a CFII. The above scenario of the ILS that you provide will not allow for a safety pilot, because you are in IMC conditions. That scenario is for a CFII and NOT a safety pilot. If you are using a safety pilot in the regards that you list above.....well....that just shouldn't ever happen.
 
MFT1Air said:
Agreed but not completely for again, I can see those quick transitions from IMC/VMC/IMC/VMC where the continuity of having a safety pilot through those transitions would be both appropriate and practical.
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While I agree that this is a scenario in which a pilot might =want= to put on the hood, I don't really think it's appropriate, except perhaps in a training environment where hours of actual or simulated instrument conditions are part of the requirements.

Even then, real instrument flight =is= often an IMC/VMC/IMC/VMC situation and the "quick transitions" from one to the other (remembering that "see an avoid" responsibility takes place so long as you can see outside, no matter how little) is an important instrument pilot skill that is really not simulated very well with a hood's blinders to reality

(I have heard anecdotes about the instrument student under the hood who enters the clouds. The CFII tells him to take off the hood. The student takes off the hood and, within 10 seconds, says, "Can I put it back on again?")
 
"Where might I be potentially compromised by logging safety pilot in IMC conditions at least from an interview perspective?"

Well, the reg (someone quoted it above) metions that you only need a safety pilot when flying in conditions where one is required. I cut, pasted, and edited for effect, the reg below:

"...private, or commercial pilot may log pilot-in- command time only for that flight time during which that person is acting as pilot in command of an aircraft on which more than one pilot is required under....the regulations under which the flight is conducted"

I think it's a stretch to say a safety pilot is needed in IMC. 99.9 percent of the world will say you don't need a safety pilot in IMC, so you can't log that time as safety pilot. You start "getting creative" with how you log stuff and an interviewer is going to catch it. Now, you have to explain how you are doing something that 99.9 percent of the world thinks in incorrect. The only way for you to do that and come out ahead it to quote chapter and verse of the FAR's to make your point and, based on the above reg, I think you'd have a tough time convincing me. Midlife is the King of FAR interps, and I bow to his knowledge, but he'd have a hard time convincing me at an interview that he's right on this one. ATP has a system for making sure their timebuilders don't log IMC safety pilot. I've asked about it before (you know me...)

"Again, how is it perceived as a "loophole?"

I'm the one who called it a loophole, so it falls completely under the opinion catagory, but the concept that two guys can "split time" and both log PIC multi is, well, sort of fishy to me. But it's clearly legal per the FAR's. In fact, I'm hoping to do timebuilding flights in my Apache taking advantage of the loophole to save guys money. I'll go so far as to say that a bit of safety pilot time can be beneficial in the right circumstances, most guys that have done it say it is. I still think 20-25 hours would max out the learning curve and anything over 50 hours is padding your logbook. I just can't recommend more than that.
 
DE727UPS said:
Well, the reg (someone quoted it above) metions that you only need a safety pilot when flying in conditions where one is required. I cut, pasted, and edited for effect, the reg below:

"...private, or commercial pilot may log pilot-in- command time only for that flight time during which that person is acting as pilot in command of an aircraft on which more than one pilot is required under....the regulations under which the flight is conducted".
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Exactly where does the logging reg say what conditions a safety pilot is required in? Note that your quote only says, in effect, "if the flight operation requires more than on pilot, the acting PIC may log PIC." Like the rest of 61.51, which deals exclusively with how to log time, the requirements for a flight operation are somewhere else.

The reg that deals with the requirement for a safety pilot, 91.109(b) only says, "No person may operate a civil aircraft in simulated instrument flight unless ... The other control seat is occupied by a safety pilot..." That's the reg that deals with the issue we are discussing.

Now you're certainly welcome to your opinion that being in actual instrument conditions (I'd avoid the use of "IMC" in this context) precludes simulated instrument conditions, just as I am welcome to mine that " 'Simulated' instrument conditions occur when the pilot's vision outside of the aircraft is intentionally restricted, such as by a hood or goggles." regardless of what is happening outside. (The quote is FAA Legal's; the statement that what is outside doesn't matter is mine)
 
Okay, the light came on. Thanks. Still see your argument as a stretch, though, if you look at it from what I think the intent of a safety pilot in the first place is, which is to look for other airplanes during VMC. No need for one in IMC. The logic of it is pretty cut and dried, and if you log safety pilot PIC multi IMC time, some people might look at you weird.

I still wouldn't recommend logging safety pilot IMC. You'll blow some gaskets at interviews. I mean, if ATP has a procedure for making sure their guys don't log it, then you're dealing with something most guys who turn into eventual interviewers are going to disagree with. Call it negative training, if you want, but 99.9 percent will look at the logic of this and you'll need a claw hammer to get someone to see it from Midlife's perspective (just like it did me).

Logbooks get looked at. I can't imagine trying to explain this in a way that would go over well at an interview...
 
DE727UPS said:
I still wouldn't recommend logging safety pilot IMC.
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BTW, the reason I said I avoid the term IMC in favor of "actual instrument conditions" is that, flying at 3000 msl 400' below a cloud deck with nothing below and 100 miles visibility is technically speaking "IMC."
 
"flying at 3000 msl 400' below a cloud deck with nothing below and 100 miles visibility is technically speaking "IMC."

Now you really have me scratchin' my head, as IMC is in the clouds and what you describe, with 100 mile vis, would not be in the clouds. But whatever....

VMC...you can see out the window. IMC....you can't see out the window. Let's keep it simple for simple minds like mine....
 
DE727UPS said:
"flying at 3000 msl 400' below a cloud deck with nothing below and 100 miles visibility is technically speaking "IMC."

Now you really have me scratchin' my head, as IMC is in the clouds and what you describe, with 100 mile vis, would not be in the clouds. But whatever....

VMC...you can see out the window. IMC....you can't see out the window. Let's keep it simple for simple minds like mine....
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Not entirely. From the PCG

INSTRUMENT METEOROLOGICAL CONDITIONS−
Meteorological conditions expressed in
terms of visibility, distance from cloud, and ceiling
less than the minima specified for visual meteorological
conditions.

I didn't think so either until I looked it up, but there it is.

-mini
 
minitour said:
Not entirely. From the PCG

INSTRUMENT METEOROLOGICAL CONDITIONS−
Meteorological conditions expressed in
terms of visibility, distance from cloud, and ceiling
less than the minima specified for visual meteorological
conditions.

I didn't think so either until I looked it up, but there it is.

-mini
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Yep. That's about it. All "IMC" means in FAA parlance is cloud and visibility less than VFR requirements.

It can get a bit confusing, especially since the FAR uses a number of variations of the phrase. In 61.57 for example, the FAR uses "instrument conditions" in one part of the reg and "weather conditions less than the minimums prescribed for VFR" in the other. The definitions in Part 1 says "IFR conditions means weather conditions below the minimum for flight under visual flight rules." FAR 170.3 says "Instrument meteorological conditions (IMC) means weather conditions below the minimums prescribed for flight under Visual Flight Rules (VFR)." And, of course, the practical meaning changes with airspace. Change the altitudes in my scenario to above 10,000 msl and flight on an otherwise CAVU day 900' below the clouds is "IMC". Make it Class B and, if visibility is otherwise >3, it's not IMC until you are in a cloud.

Headache? Yep. Fortunately, even the FARs are pretty consistent in using the term "simulated" and "actual" to differentiate "can't see anything outside" from "less than VFR."

I know a lot of people use "IMC" and "actual" synonymously, but the lack of precision can make for misunderstanding, especially when talking about what the regs mean.

Anyway, that's why I avoid "IMC" in favor of "actual" when talking about being in the clouds.

"Actual" keeps it simple and fits with how the FAA uses the term.
 
MidlifeFlyer said:
Headache? Yep. Fortunately, even the FARs are pretty consistent in using the term "simulated" and "actual" to differentiate "can't see anything outside" from "less than VFR."

I know a lot of people use "IMC" and "actual" synonymously, but the lack of precision can make for misunderstanding, especially when talking about what the regs mean.

Anyway, that's why I avoid "IMC" in favor of "actual" when talking about being in the clouds.

"Actual" keeps it simple and fits with how the FAA uses the term.
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Before the Motrin - :banghead:

After the shot of Cognac - :bandit:

OK, it's starting to make sense.
 
Once again. Learned something new...

Though it makes totally no sense in my old skool head. And I'm not going to change what I say to ATC when they ask me flight conditions. If I can see, it's VMC, if I can't, it's IMC. Whatever....
 
DE727UPS said:
Once again. Learned something new...

Though it makes totally no sense in my old skool head. And I'm not going to change what I say to ATC when they ask me flight conditions. If I can see, it's VMC, if I can't, it's IMC. Whatever....
Click to expand...

Agreed. If I can see, I'm reporting VMC too.

-mini
 
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