Logging Bonanza time with no complex/high performance endors.
- Thread starter CFI_Ty
- Start date
Jeff_S_KDTW
New Member
[ QUOTE ]
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]Just the contrary--in order for you to LOG PIC while serving as a safety pilot in a 182, you must be able to ACT as PIC.
Lets walk through it. The flying pilot gets to log PIC as the sole manipulator (61.51(e)(1)(i)). However, as the safety pilot, you are not the sole manipulator of the controls and must find another provision of 61.51(e) that allows you to log PIC. You certainly aren't solo (61.51(e)(1)(ii)), so that one is out. However, if you are ACTING as PIC of an aircraft on which more than one pilot is required under the regulations under which the flight is conducted, you get to log PIC (61.51(e)(1)(iii)).
In order to ACT as PIC, the safety pilot must be:
1) rated in the plane as defined by 61.5,
2) must also have a type rating if applicable per 61.31 as well as any other endorsements covered by that provision and applicable to the aircraft,
3) must meet the currency requirements of 61.57,
4) must still have a current and valid medical as required by 61.3 and 61.23, and
5) must meet the flight review requirements defined by 61.56.
If the safety pilot qualifies, then 61.51 allows the safety pilot to log PIC time for that period of time during which the other pilot is wearing the view limiting device. (61.51(e)(1)(iii))
___________________________________________
June 17, 1985
Mr. John J. Sheehan
Vice President, Aviation Policy
Aircraft Owners and Pilots Association
421 Aviation Way
Frederick, Maryland 21701
Dear Mr. Sheehan:
This is in response to your November 26, 1984, annotated letter from Mr. James M. Thoburn of Rochester, New York, in which you request written clarification of Federal Aviation Regulations (FAR) requirements to function as a safety pilot.
As you know, FAR Section 91.21(b)(1) provides that no person may operate a civil aircraft in simulated instrument flight unless an "appropriately rated" pilot occupies the other control seat as a safety pilot.
"Appropriately rated" as used under this section, refers to the category, class, type, and instrument ratings described in FAR Section 61.5. Thus, the safety pilot must have the category, class, type, and instrument rating appropriate to the aircraft being flown and rules under which it is being operated.
Section 61.3(c) of the FAR provides, with certain exceptions, that no person may act in any capacity as a required pilot flight crewmember under a certificate issued to him or her under Part 61 unless he or she holds a current appropriate airman medical certificate. Under FAR Section 1.1 "flight crewmember," as it applies here, means a pilot assigned to perform a duty in an aircraft during flight time. Therefore, since the safety pilot must be appropriately rated and is assigned to perform certain duties under Section 91.21(b) of the FAR, it follows that the safety pilot is a required pilot flight crewmember and must hold a current appropriate airman medical certificate.
Section 61.57(a) of the FAR, pertaining to the biennial flight review, applies only to a person who serves as pilot in command. Therefore, as long as the safety pilot does not act as pilot in command, he or she need not comply with the currency requirements of this section.
Section 61.57(c) and (d) of the FAR, applies only to a person who serves as pilot in command on a flight in which passengers are carried. Therefore, unless the safety pilot acts as pilot in command with passengers on board, he or she need not meet the currency requirements of this section.
Both of the pilots on board an aircraft in operations requiring two pilots are crewmembers. The mere manipulation of controls, however, does not make a person a crewmember. For example, a student pilot taking lessons from a certificated flight instructor is a passenger with respect to the flight instructor and, therefore, the flight instructor must meet the recency experience requirements of Section 61.57(a), (c) and (d). Further, should the aircraft be operated under instrument flight rules, even in visual meteorological conditions, Section 61.3(e) requires the pilot in command to hold an instrument rating appropriate to the aircraft operated. If, under such conditions, a pilot who is not instrument rated is flying an aircraft under a hood simulating instrument flight, the safety pilot on board the aircraft must then act as pilot in command and must also hold an instrument rating appropriate to the aircraft operated.
We are aware that advice to the contrary has been given to the public concerning this issue in the past. However, this letter has been coordinated with the Office of the Chief Counsel, and reflects current Federal Aviation Administration policy. Finally, we wish to apologize for the delay in our response and trust this adequately responds to your inquiry.
Sincerely,
/s/
Carol S. Rayburn
Manager, General Aviation and Commercial Division
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]Just the contrary--in order for you to LOG PIC while serving as a safety pilot in a 182, you must be able to ACT as PIC.
Lets walk through it. The flying pilot gets to log PIC as the sole manipulator (61.51(e)(1)(i)). However, as the safety pilot, you are not the sole manipulator of the controls and must find another provision of 61.51(e) that allows you to log PIC. You certainly aren't solo (61.51(e)(1)(ii)), so that one is out. However, if you are ACTING as PIC of an aircraft on which more than one pilot is required under the regulations under which the flight is conducted, you get to log PIC (61.51(e)(1)(iii)).
In order to ACT as PIC, the safety pilot must be:
1) rated in the plane as defined by 61.5,
2) must also have a type rating if applicable per 61.31 as well as any other endorsements covered by that provision and applicable to the aircraft,
3) must meet the currency requirements of 61.57,
4) must still have a current and valid medical as required by 61.3 and 61.23, and
5) must meet the flight review requirements defined by 61.56.
If the safety pilot qualifies, then 61.51 allows the safety pilot to log PIC time for that period of time during which the other pilot is wearing the view limiting device. (61.51(e)(1)(iii))
___________________________________________
June 17, 1985
Mr. John J. Sheehan
Vice President, Aviation Policy
Aircraft Owners and Pilots Association
421 Aviation Way
Frederick, Maryland 21701
Dear Mr. Sheehan:
This is in response to your November 26, 1984, annotated letter from Mr. James M. Thoburn of Rochester, New York, in which you request written clarification of Federal Aviation Regulations (FAR) requirements to function as a safety pilot.
As you know, FAR Section 91.21(b)(1) provides that no person may operate a civil aircraft in simulated instrument flight unless an "appropriately rated" pilot occupies the other control seat as a safety pilot.
"Appropriately rated" as used under this section, refers to the category, class, type, and instrument ratings described in FAR Section 61.5. Thus, the safety pilot must have the category, class, type, and instrument rating appropriate to the aircraft being flown and rules under which it is being operated.
Section 61.3(c) of the FAR provides, with certain exceptions, that no person may act in any capacity as a required pilot flight crewmember under a certificate issued to him or her under Part 61 unless he or she holds a current appropriate airman medical certificate. Under FAR Section 1.1 "flight crewmember," as it applies here, means a pilot assigned to perform a duty in an aircraft during flight time. Therefore, since the safety pilot must be appropriately rated and is assigned to perform certain duties under Section 91.21(b) of the FAR, it follows that the safety pilot is a required pilot flight crewmember and must hold a current appropriate airman medical certificate.
Section 61.57(a) of the FAR, pertaining to the biennial flight review, applies only to a person who serves as pilot in command. Therefore, as long as the safety pilot does not act as pilot in command, he or she need not comply with the currency requirements of this section.
Section 61.57(c) and (d) of the FAR, applies only to a person who serves as pilot in command on a flight in which passengers are carried. Therefore, unless the safety pilot acts as pilot in command with passengers on board, he or she need not meet the currency requirements of this section.
Both of the pilots on board an aircraft in operations requiring two pilots are crewmembers. The mere manipulation of controls, however, does not make a person a crewmember. For example, a student pilot taking lessons from a certificated flight instructor is a passenger with respect to the flight instructor and, therefore, the flight instructor must meet the recency experience requirements of Section 61.57(a), (c) and (d). Further, should the aircraft be operated under instrument flight rules, even in visual meteorological conditions, Section 61.3(e) requires the pilot in command to hold an instrument rating appropriate to the aircraft operated. If, under such conditions, a pilot who is not instrument rated is flying an aircraft under a hood simulating instrument flight, the safety pilot on board the aircraft must then act as pilot in command and must also hold an instrument rating appropriate to the aircraft operated.
We are aware that advice to the contrary has been given to the public concerning this issue in the past. However, this letter has been coordinated with the Office of the Chief Counsel, and reflects current Federal Aviation Administration policy. Finally, we wish to apologize for the delay in our response and trust this adequately responds to your inquiry.
Sincerely,
/s/
Carol S. Rayburn
Manager, General Aviation and Commercial Division
MidlifeFlyer
Well-Known Member
[ QUOTE ]
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]Jeff's absolutely right. Keep in mind that the rule that allows you to log PIC as a safety pilot says that you may log PIC when
==============================
acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted. [61.51(e)(iii)]
==============================
So this is one of those times that 61.51 says that you have to =act= as PIC in order to =log= PIC.
And, of course, in order to =act= as PIC, you need certificate, ratings, endorsements, currency...
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]Jeff's absolutely right. Keep in mind that the rule that allows you to log PIC as a safety pilot says that you may log PIC when
==============================
acting as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted. [61.51(e)(iii)]
==============================
So this is one of those times that 61.51 says that you have to =act= as PIC in order to =log= PIC.
And, of course, in order to =act= as PIC, you need certificate, ratings, endorsements, currency...
MidlifeFlyer
Well-Known Member
[ QUOTE ]
I take offence at being called a 'newbie'.
[/ QUOTE ]I apologize. The offense was unintended. I never thought of the term as being pejorative. I apply the term to myself regularly.
This issue has been discussed online in many forums literally for years. I think my earliest involvement in one of these discussions was 7 or 8 years ago, and it had been going on well before then. Same questions, same answers, same arguments, same citation to FAA authority, same stunned disbelief by some (I'm not referring to you) that it is possible for it to be that way.
With that kind of history, I tend to think that someone who gets it wrong is new to dealing with the regulation, but I'm sorry if you took offense.
Besides, the kind words of some here aside (the checks are in the mail), as my friends sometime point out, I =can= be a condescending blowhard at times.
I take offence at being called a 'newbie'.
[/ QUOTE ]I apologize. The offense was unintended. I never thought of the term as being pejorative. I apply the term to myself regularly.
This issue has been discussed online in many forums literally for years. I think my earliest involvement in one of these discussions was 7 or 8 years ago, and it had been going on well before then. Same questions, same answers, same arguments, same citation to FAA authority, same stunned disbelief by some (I'm not referring to you) that it is possible for it to be that way.
With that kind of history, I tend to think that someone who gets it wrong is new to dealing with the regulation, but I'm sorry if you took offense.
Besides, the kind words of some here aside (the checks are in the mail), as my friends sometime point out, I =can= be a condescending blowhard at times.
kellwolf
Piece of Trash
[ QUOTE ]
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]
Like everyone else said, you'd be ACTING as PIC, so you'd need the endorsement. Now, here's the screwed up thing: you could fly the plane under the hood with someone else with a HP endorsement as the safety pilot and log it as PIC. Makes a lot of sense, huh?
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]
Like everyone else said, you'd be ACTING as PIC, so you'd need the endorsement. Now, here's the screwed up thing: you could fly the plane under the hood with someone else with a HP endorsement as the safety pilot and log it as PIC. Makes a lot of sense, huh?
BrianNC
Well-Known Member
[ QUOTE ]
[ QUOTE ]
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]
Like everyone else said, you'd be ACTING as PIC, so you'd need the endorsement. Now, here's the screwed up thing: you could fly the plane under the hood with someone else with a HP endorsement as the safety pilot and log it as PIC. Makes a lot of sense, huh?
[/ QUOTE ]
And kind of confusing. I'm not sure I understand it yet.
[ QUOTE ]
So having established this, then I really didn't need to get a high performance checkout a few years ago to ride safety pilot in a 182 to log it as PIC time?
[/ QUOTE ]
Like everyone else said, you'd be ACTING as PIC, so you'd need the endorsement. Now, here's the screwed up thing: you could fly the plane under the hood with someone else with a HP endorsement as the safety pilot and log it as PIC. Makes a lot of sense, huh?
[/ QUOTE ]
And kind of confusing. I'm not sure I understand it yet.
kellwolf
Piece of Trash
Let me see if I can clear it up a bit....
The person flying under the hood can log PIC since he is sole manipulator and rated ASEL. He's sole manipulator, not the ACTING PIC.
The safety pilot is ACTING as PIC and assuming the responsibility for the safety of the flight. He's also a required crewmember, so that's where the reg MF posted comes in. In order to act as PIC, he needs the HP endorsement as well as the ASEL rating.
In the original case, the person flying the Bonanza can log PIC since he's sole manipulator, and the instructor on board is the acting PIC. As an instructor, you can only instruct in aircraft in which you're qualified to act as PIC. So, since I don't have a HP endorsement, I can't instruct in a 182 (or any other HP aircraft), even if I had my CFI already. That's one of the main reasons I plan on doing a couple of flights in the 182 as part of my CFI training.
Clear as mud?
The person flying under the hood can log PIC since he is sole manipulator and rated ASEL. He's sole manipulator, not the ACTING PIC.
The safety pilot is ACTING as PIC and assuming the responsibility for the safety of the flight. He's also a required crewmember, so that's where the reg MF posted comes in. In order to act as PIC, he needs the HP endorsement as well as the ASEL rating.
In the original case, the person flying the Bonanza can log PIC since he's sole manipulator, and the instructor on board is the acting PIC. As an instructor, you can only instruct in aircraft in which you're qualified to act as PIC. So, since I don't have a HP endorsement, I can't instruct in a 182 (or any other HP aircraft), even if I had my CFI already. That's one of the main reasons I plan on doing a couple of flights in the 182 as part of my CFI training.
Clear as mud?
BrianNC
Well-Known Member
[ QUOTE ]
Let me see if I can clear it up a bit....
The person flying under the hood can log PIC since he is sole manipulator and rated ASEL. He's sole manipulator, not the ACTING PIC.
The safety pilot is ACTING as PIC and assuming the responsibility for the safety of the flight. He's also a required crewmember, so that's where the reg MF posted comes in. In order to act as PIC, he needs the HP endorsement as well as the ASEL rating.
In the original case, the person flying the Bonanza can log PIC since he's sole manipulator, and the instructor on board is the acting PIC. As an instructor, you can only instruct in aircraft in which you're qualified to act as PIC. So, since I don't have a HP endorsement, I can't instruct in a 182 (or any other HP aircraft), even if I had my CFI already. That's one of the main reasons I plan on doing a couple of flights in the 182 as part of my CFI training.
Clear as mud?
[/ QUOTE ]
Would you mind repeating that?
I think I got it. But don't quote me on that.
Let me see if I can clear it up a bit....
The person flying under the hood can log PIC since he is sole manipulator and rated ASEL. He's sole manipulator, not the ACTING PIC.
The safety pilot is ACTING as PIC and assuming the responsibility for the safety of the flight. He's also a required crewmember, so that's where the reg MF posted comes in. In order to act as PIC, he needs the HP endorsement as well as the ASEL rating.
In the original case, the person flying the Bonanza can log PIC since he's sole manipulator, and the instructor on board is the acting PIC. As an instructor, you can only instruct in aircraft in which you're qualified to act as PIC. So, since I don't have a HP endorsement, I can't instruct in a 182 (or any other HP aircraft), even if I had my CFI already. That's one of the main reasons I plan on doing a couple of flights in the 182 as part of my CFI training.
Clear as mud?
[/ QUOTE ]
Would you mind repeating that?
I think I got it. But don't quote me on that.
Jeff_S_KDTW
New Member
Brian -
Let's simplify Kellwolf's example even more--the scenario does not even require a safety pilot or a hood!
Pilot 1 (PPASEL; no HP endorsement) - he is sole manipulator of the controls in an aircraft for which he is rated (For determining whether he is "rated" we look at the plane and then look at his certificate. Cessna 182 is a SEL airplane. Period. His pilot license says he is a Private Pilot for Airplane Single Engine Land. We have a match.) He can LOG PIC (61.51(e)(1)(i)) for the entire time he is sole manipulator.
But, we still need someone onboard to ACT PIC.
Pilot 2 (PPASEL, HP endorsement) - if he meets the list I stated above, he is the ACTING PIC.
Now, if Pilot 1 is not under the hood, there is no need for a safety pilot. But, we still need someone to ACT PIC. So, Pilot 2 sits there, is ACTING PIC, and is ultimately responsible for the safety of the flight. Does he get to LOG PIC? No.
Let's simplify Kellwolf's example even more--the scenario does not even require a safety pilot or a hood!
Pilot 1 (PPASEL; no HP endorsement) - he is sole manipulator of the controls in an aircraft for which he is rated (For determining whether he is "rated" we look at the plane and then look at his certificate. Cessna 182 is a SEL airplane. Period. His pilot license says he is a Private Pilot for Airplane Single Engine Land. We have a match.) He can LOG PIC (61.51(e)(1)(i)) for the entire time he is sole manipulator.
But, we still need someone onboard to ACT PIC.
Pilot 2 (PPASEL, HP endorsement) - if he meets the list I stated above, he is the ACTING PIC.
Now, if Pilot 1 is not under the hood, there is no need for a safety pilot. But, we still need someone to ACT PIC. So, Pilot 2 sits there, is ACTING PIC, and is ultimately responsible for the safety of the flight. Does he get to LOG PIC? No.
MidlifeFlyer
Well-Known Member
Um, I think at this point Brian's yanking your chain.
The concepts are simple enough. The FAA issues pilot certificates and ratings. The FAA gets to decide what kind of time it will count for the requirements. The FAA decided for reasons unknown to mere mortals to allow pilots to "log PIC" toward certificate and ratings under rules that sometimes require the pilot to be the responsible pilot and sometimes don't.
One rule that doesn't require the pilot to be responsible for the flight in order to write numbers in the PIC column is the so-called "sole manipulator" rule in 61.51.
One rule that does require the pilot to be responsible for the flight in order to write numbers in the PIC column is when not handling the controls but acting as part of required 2+ pilot crew.
The concepts are simple enough. The FAA issues pilot certificates and ratings. The FAA gets to decide what kind of time it will count for the requirements. The FAA decided for reasons unknown to mere mortals to allow pilots to "log PIC" toward certificate and ratings under rules that sometimes require the pilot to be the responsible pilot and sometimes don't.
One rule that doesn't require the pilot to be responsible for the flight in order to write numbers in the PIC column is the so-called "sole manipulator" rule in 61.51.
One rule that does require the pilot to be responsible for the flight in order to write numbers in the PIC column is when not handling the controls but acting as part of required 2+ pilot crew.
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