Jason Schappert

rframe said:
That's a bit oversimplified. Just because it's technically possible to log PIC as safety pilot, doesn't mean everyone "should". The only way you get to log PIC time as safety pilot is if you have agreed to act as PIC, which means you're effectively the captain and decision maker for that flight. Lets say I'm a pilot, I own my own Bonanza and I like to go fly approaches a couple hours per month for proficiency. I'm a nice guy so I ask a local certificated kid if he wants to ride along as safety pilot because I know he'd like it and he can log some time. This kids got no Bonanza experience and 100 hours total time. He is not acting as PIC, he doesn't get to log it as PIC, but he'd be pretty dumb not to take it as SIC and bump up his total time.
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Interesting point. However, I'm still going to point back to 91.3a, and say that by agreeing to be safety pilot, the local kid has agreed to be responsible for the safety of that aircraft, and is still PIC. Same scenario, except you (I don't have Bonanza owner money... ;)) are a flight instructor now, giving the kid transition training. He would still log PIC time, as he has the appropriate category and class ratings.

New scenario (YAY!) You're flying an approach, and misread the plate. The kid says "I'm not instrument rated, so I don't know what you're doing, but you're about to run us into a hill, my plane while you take the goggles off and figure out what you did wrong!" ...Directly responsible for the safety of the flight.
 
Every crew member is responsible for the safety of the flight, that's why they are crew members, and that's why there is even a provision allowing a safety pilot to log SIC, if the FAA didn't feel a safety pilot were required for the safety of the flight then they wouldn't even get to log it as SIC.

The PIC has "the final authority"... same reg you quote. A safety pilot advising the other pilot that they are going to hit another airplane or a hill is not an indicator that the safety pilot has final authority over that flight, it's just an indicator that they are doing their job as a crew member.

Dont get me wrong, there is nothing wrong with the safety pilot logging PIC, so long as they truly are acting as PIC while the other pilot is manipulating the controls. That should be agreed upon before the flight takes place. The PIC is the one who will make all final decisions. It's simply not legal to assume that a safety pilot has some inherent right to log PIC just because they are doing their job as a safety pilot.

It could even be a less pronounced example. Lets say I am renting a boring old Skyhawk to practice approaches. I'm paying for it, I'm PIC, someone else rides along as safety pilot. Do I agree to let them act as PIC so they can log it?... maybe, but maybe not. It's my dime, the airplane is my responsibility (it's rented to me)... so unless I'm feeling really generous, I will retain the role of PIC and safety pilot gets SIC time.

In your second scenario of him getting trained by a CFI, yes of course he can log PIC, he's manipulating the controls and he's appropriately rated, even that doesn't mean he's acting as PIC and he probably isn't if he's not familiar with the airplane but the CFI is training him, more than likely the CFI is acting as PIC, but the kid still gets to log it as PIC... that scenario is not related to the original question.
 
Hammertime said:
Basically, in this scenario, you have to look at the intent of the regs. I would hazard a guess that the original letter, that the interpretation was written in response to, was submitted by someone that was hoping to cheat the system in some way, and build X/C time as a safety pilot. You also have to look at the intent of the SIC position. The whole purpose of the SIC regs is for aircraft that are type rated for more than one pilot, or the cases where 135 or 121 regs require an SIC in what would normally be a single pilot airplane. Those SICs log the entire flight (including X/C time) as they are required for the whole flight. It is not intended for the guy that is sitting safety pilot in his buddies skychicken while they shoot some approaches.
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91.109 requires a safety pilot for simulated instrument flight. I don't see how that's any less valid or "intended" than anything in 121 or 135. Basically, there are two cases for an SIC: the aircraft requires two crew members, or the operational nature of the flight (FAR) requires it. You can't say it's perfectly falling under the intent of the FAR to have two PIC's in a 172 but then say to have an SIC in a 172 is somehow skirting the intent of the FAR. Under FAR 91.109, two licensed pilots are required. I don't see how that FAR is any less valid than anything in 135. Sure, safety pilot time isn't the most valuable time, and so the FAA says you can't log X/C or landing/takeoffs. I'm with rframe on this: if anything, the safety pilot is more of a legitimate SIC than acting PIC for most of us that have actually done it (except in the case of instruction). Having said that, I've always logged mine as PIC. ;)
 
Can we please put this issue to rest? The FAA has spelled it out in little friendly words, and it's not a trick, and there's nothing funny about people logging SIC for safety pilot time when they were not acting as the Pilot In Command. It's the way it should be logged UNLESS you're acting as the honest to goodness Pilot In Command, the ultimate authority responsible for the safety of the flight.

Let me put it a different way... if I'm going to log PIC time as safety pilot, I'm going to have checked the TFRs, checked the weather, checked the NOTAMs, checked the A/C docs, checked to make sure the aircraft is airworthy. I'm going to know what the pilot under the hood is doing at all times, and I'm going to know, say, where he is on the approach, keep track of airspace, etc., etc. I'm going to ensure that the aircraft complies with ATC instructions, etc. etc. ad nauseum.

If I'm just going to ride along and make sure that he doesn't hit another airplane or a building, it's going into my logbook as SIC.

My loss? Sure, but when I put something in my logbook, I mean it... and nobody should look askance at my correctly-logged SIC time.

~Fox
 
Christ, not another Internet argument about what is and is not PIC, SIC, and loggable. The FAA has made it so simple even I can understand it.

Also, employers who understand (and, not coincidentally, display active compliance with) the applicable regulations will not frown upon the time in your logbook.
 
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