MidlifeFlyer
Well-Known Member
If you are no longer required, what is the regulatory basis for logging SIC (unless it's a 2-pilot required airplane; I assume it's not a Part 135 passenger flight)? Don't look too hard, it's not there.
Matt13C
Well-Known Member
Yeah, I got a bit confused. I couldn't log it if I was no longer required. You are correct.
I cant find anything, just opinions from non-FAA sources supporting both sides.
Here is my take.
61.101 says to log XC, for the purpose of gaining a rating
- Conducted in appropriate aircraft
- include a landing at a point more than 50 miles from the point of departure
- be conducted using dead reckoning, pilotage.....to navigate to the landing point
The general definition includes "conducted by a person who holds a pilot certificate"
Also, for ATP the landing is not needed, only the distance from point of departure.
If, prior to departure, it is decided that the safety pilot will be the acting PIC, he is responsible for the flight. I take that as meaning, he is the one conducting the flight. The reg does not say who has to land the plane, just that it has to land. If you want to pply the time to your ATP, the plane does not even have to land.
If you take that a step further and an IR rated pilot files an IR flight plan and allows a PPL to fly while he is the safety pilot, then he is the acting regardless and even if the foggles come off, he is required the whole flight.
However, that is just my take and I am not in any position to make a determination. If the Part 61 FAQ that you mentioned still holds true, then I am wrong. Wouldnt be the first time and certainly wont be the last.
If anyone has a more recent FAA interpretation that would be great.
positiveR8
Well-Known Member
This concept of two types of PIC times is still somewhat new to me... but it makes sense.
So referencing the two concepts of PIC, is a hood even required?
Example:
I'm flying a two hour cross country with a pilot friend of mine. We decide that I will be the acting PIC (responsible for operation/safety of the flight) while my friend will actually do the flying for the whole flight. No hood involved. You're telling me we can BOTH log PIC time on that flight?
So referencing the two concepts of PIC, is a hood even required?
Example:
I'm flying a two hour cross country with a pilot friend of mine. We decide that I will be the acting PIC (responsible for operation/safety of the flight) while my friend will actually do the flying for the whole flight. No hood involved. You're telling me we can BOTH log PIC time on that flight?
germb747
Well-Known Member
No. FAR 61.51 spells out when you're allowed to log PIC (among other types of flight time). This has nothing to do with the official PIC for the flight (defined in Part 1).
Take a look at this link:
http://www.thecfi.com/pt61FAQ.doc
It'll answer all your questions about Part 61.
MidlifeFlyer
Well-Known Member
I more or less agree with your take. I'm just saying that in the old FAQ, John Lynch of Flight Standards didn't.
MidlifeFlyer
Well-Known Member
No. 61.51 is the Universal Rule of Logging Time. It sets out a number of boxes. If you fit into a box, you log the time; if you don't fit into a box you don't. Acting as PIC is irrelevant unless 61.51 says it is (and there's only 3 times that 61.51 says it is)
positiveR8
Well-Known Member
I'm just curious why the safety pilot would get to log the WHOLE duration of the flight just as the sole manipulator would. It seems for at least part of the flight such logging would fall into the same category as the situation I mentioned above (i.e. neither one is under the hood, but one is sole manipulator and the other is acting PIC). Personally I've always logged PIC as a safety pilot only when the other pilot was under the hood, but I'm just trying to clear up if there was a different way I should (or could) have been doing it.
MidlifeFlyer
Well-Known Member
Even the Chief Counsel can be guilty of being a bit unclear in the language used when trying to clarify things.
It doesn't really say that the safety pilot logs the whole duration of flight. It says that the safety pilot "may log all the flight time" as PIC. Perhaps he should have said "may log all his flight time" as PIC. "Flight time" itself has a definition - receiving instruction, giving instruction, or acting as required crew (see FAR 1.1).
Or maybe the opinion letter should have been a lot longer.
Or maybe, since there are holes to begin with in the safety pilot logging PIC scenario, you shouldn't look at it that closely.
Bottom line is that IMO, your read is correct and the safety pilot may only log the amount of time he is required as safety pilot under 91.109.
germb747
Well-Known Member
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 simultaneously. PIC flight time may be logged by both the PIC responsible 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.<O></O
Interesting Mr. Pompilio<O
(an FAA lawyer) says "PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1" since 1.1 doesn't address logging flight time at all. But who am I to argue with the FAA? Print out your legal interpretation and log away! (Although may I suggest getting a more up-to-date letter, this one is from 1993 and I know Part 61 has changed since then.) Why does this have to be so damn complicated that we have to get lawyers involved!?!?
Interesting Mr. Pompilio<O
I think that he's saying that the pilot is PIC based on 1.1, not that he can log PIC based on 1.1.
MidlifeFlyer
Well-Known Member
I think you are essentially correct, but I also think that you can't simply pull the sentence out of its context and say "ah ha!".
The whole opinion letter is about logging time in safety pilot ops. It has been talking about 61.51 and 2-pilot-required operations and how safety pilot ops is a 2-pilot op. The context tells us he is just saying that the pilot who is PIC may log PIC because he is the Part 1 PIC in a two-pilot-required operation.
Nihon_Ni
Well-Known Member
That's exactly how I read it. The letter discusses what a safety pilot can log. During taxi, take off, landing and any other time the pilot flying is not wearing a hood, the "safety pilot" isn't a "safety pilot" at all, he's a passenger who happens to be a pilot seated at a pilot station.
My advice is to take the conservative route and only log time while the PF is wearing a hood. In the long run, adding a few tenths to every flight isn't worth the hours you might have to spend defending them.
My advice is to take the conservative route and only log time while the PF is wearing a hood. In the long run, adding a few tenths to every flight isn't worth the hours you might have to spend defending them.