Logging high performance and multi time

H

henryqs1

Well-Known Member
Hi Everyone,

Can you log safety pilot time in Cessna 310 ( high performance, multi a/c), if you have only a multi commercial license? I don't have a high performance endorsement.

Also I just logged 23 hours of multi for my commercial multi initial training, my instructor told me that I can log about 13 hours of pic time. Is that true? Base on my research, some instructors mention that students can log anytime after 10 hours of dual instruction training, others disagree.

Any response would be greatly appreciated. Thanks.
Henry
 
Hi Everyone,

Can you log safety pilot time in Cessna 310 ( high performance, multi a/c), if you have only a multi commercial license? I don't have a high performance endorsement.

//Begin pot stir

If you are the safety pilot then you are ACTING as PIC and thus need the high perf endorsement to log it. If you were under the hood then you are LOGGING PIC time (sole manipulator) and do not need the high perf. I'm sure someone will disagree with me as far as who is "logging" and who is "acting" but when you think about it...the ACTING PIC is responsible for the safety of the flight...if you can't see outside under VFR (i.e. the one under the hood), then how can you be responsible for the safety of the flight??

//End pot stir

Also I just logged 23 hours of multi for my commercial multi initial training, my instructor told me that I can log about 13 hours of pic time. Is that true? Base on my research, some instructors mention that students can log anytime after 10 hours of dual instruction training, others disagree.

You can not log PIC in an airplane for which you do not hold the appropritate category and class ratings. I.e. you need to hold your CMEL before you can log any time as PIC in a twin. Your CFI is wrong.

Any response would be greatly appreciated. Thanks.
Henry
 
You don't say what your certificates and aircraft ratings were at the time you logged those 23 hours.

In terms of sole manipulator time, the rule for logging PIC in a multi is the same as for a single:

If you are at least a private pilot with a AMEL rating on the back of your pilot certificate, you can log every moment that you are the sole manipulator of the controls of a multi as PIC (so long as the airplane doesn't require a type rating).

If you do not have an AMEL rating on the back of your pilot certificate, you cann't log even one second as PIC unless you are the only human being in the airplane.

In terms of the safety pilot time, all the safety pilot rule requires is category and class ratings, which you say you have. Of course, none of that time is PIC since in order to log PIC as a safety pilot you have to act as PIC, which you can't do without the HP endorsement in a HP aircraft.

It's all in 2 regs. 61.51 (universal rule of logging time) and 91.109 (the safety pilot requirement).
 
henryqs1 said:
Hi Everyone,

Can you log safety pilot time in Cessna 310 ( high performance, multi a/c), if you have only a multi commercial license? I don't have a high performance endorsement.

Also I just logged 23 hours of multi for my commercial multi initial training, my instructor told me that I can log about 13 hours of pic time. Is that true? Base on my research, some instructors mention that students can log anytime after 10 hours of dual instruction training, others disagree.

Any response would be greatly appreciated. Thanks.
Henry
Click to expand...

To act as safety pilot, you must be current and rated in category and class, plus type, if applicable. In order to act as PIC in a high performance aircraft, you must have the applicable endorsement. I suppose there's an argument to be made that you could log safety pilot SIC time without the endorsement, but you're not qualified to log PIC. Regardless, this is the sort of "letter" versus "spirit" of the regulation stuff that can get you in trouble, so be careful.

As to your second question, under normal circumstances, you can only log multi-PIC prior to getting your multi rating during: 1) any solo time (note that "simulated solo" time used towards your rating does not count), and 2) your checkride.
 
ClearedToThe said:
//Begin pot stir

If you are the safety pilot then you are ACTING as PIC and thus need the high perf endorsement to log it. If you were under the hood then you are LOGGING PIC time (sole manipulator) and do not need the high perf. I'm sure someone will disagree with me as far as who is "logging" and who is "acting" but when you think about it...the ACTING PIC is responsible for the safety of the flight...if you can't see outside under VFR (i.e. the one under the hood), then how can you be responsible for the safety of the flight??

//End pot stir
Click to expand...
Sounds like you have a broken stirrer. There is nothing in the safety pilot rules that requires the safety pilot to act as PIC.

You're making a common error in equating responsibility for a flight (acting as PIC) with the performance of specific flight duties. The ATP Captain of a 747 is still the PIC, even when he leaves his station to go to the restroom. PIC means command responsibility and the hooded pilot is as capable to issuing commands to his crew as the sighted one.

The basic FAA Legal discussion of safety pilot logging makes this clear when it says:

==============================
In your second question you ask "how shall two Private Pilots log their flight time when one pilot is under the hood for simulated instrument time and the other pilot acts as safety pilot?" The answer is the pilot who is under the hood may log PIC time for that flight time in which he is the sole manipulator of the controls of the aircraft, provided he is rated for that aircraft. The appropriately rated safety pilot may concurrently log as second in command (SIC) that time during which he is acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i).
==============================

Assuming two pilots qualified as PIC, who is PIC is a choice, even in the safety pilot situation.
 
MidlifeFlyer said:
In terms of sole manipulator time, the rule for logging PIC in a multi is the same as for a single:

If you are at least a private pilot with a AMEL rating on the back of your pilot certificate, you can log every moment that you are the sole manipulator of the controls of a multi as PIC (so long as the airplane doesn't require a type rating).

If you do not have an AMEL rating on the back of your pilot certificate, you cann't log even one second as PIC unless you are the only human being in the airplane.

In terms of the safety pilot time, all the safety pilot rule requires is category and class ratings, which you say you have. Of course, none of that time is PIC since in order to log PIC as a safety pilot you have to act as PIC, which you can't do without the HP endorsement in a HP aircraft.

It's all in 2 regs. 61.51 (universal rule of logging time) and 91.109 (the safety pilot requirement).
Click to expand...

I will have to respectuflly disagree here. 61.51 allows you to LOG anything you are rated for if you are the sole manipulator. In order to ACT as pic in an aircraft you need any applicable endorsements (high perf, complex, etc.). It is for this reason that all flight training in a complex airplane towards gaining a complex endorsement may be LOGGED as pic time. The CFI is ACTING as PIC in these flights. See 61.31(e) and note the use of the word "ACT" versus the word "LOG" in 61.51.
 
MidlifeFlyer said:
Sounds like you have a broken stirrer. There is nothing in the safety pilot rules that requires the safety pilot to act as PIC.

You're making a common error in equating responsibility for a flight (acting as PIC) with the performance of specific flight duties. The ATP Captain of a 747 is still the PIC, even when he leaves his station to go to the restroom. PIC means command responsibility and the hooded pilot is as capable to issuing commands to his crew as the sighted one.

The basic FAA Legal discussion of safety pilot logging makes this clear when it says:

==============================
In your second question you ask "how shall two Private Pilots log their flight time when one pilot is under the hood for simulated instrument time and the other pilot acts as safety pilot?" The answer is the pilot who is under the hood may log PIC time for that flight time in which he is the sole manipulator of the controls of the aircraft, provided he is rated for that aircraft. The appropriately rated safety pilot may concurrently log as second in command (SIC) that time during which he is acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i).
==============================

Assuming two pilots qualified as PIC, who is PIC is a choice, even in the safety pilot situation.
Click to expand...

In this is done (in the FAAs example), then it sounds to me like the safety pilot would be the ACTING pic ("responsible for the operation and safety of the aircraft during flight" - almost verbatim definition of PIC from 1.1). How can you ACT as a pic in a high perf a/c without the necessary endorsement.

I'm with you 100% on being able to LOG time for which you are the sole manipulator if you hold the appropriate category/class ratings for the a/c you are manipulating. (Back to my training in a complex a/c example)
 
ClearedToThe said:
I will have to respectuflly disagree here. 61.51 allows you to LOG anything you are rated for if you are the sole manipulator.
Click to expand...
The safety pilot is =not= the sole manipulator. The other pilot is. Isn't that the whole idea?

When a safety pilot logs PIC, it's not under the "sole manipulator" clause, but under the "acting as PIC in a 2-pilot required operation" clause.
 
ClearedToThe said:
In this is done (in the FAAs example), then it sounds to me like the safety pilot would be the ACTING pic ("responsible for the operation and safety of the aircraft during flight" - almost verbatim definition of PIC from 1.1). How can you ACT as a pic in a high perf a/c without the necessary endorsement.
Click to expand...
You can't.

But the point is that the safety pilot doesn't have to be the one acting as PIC.
 
MidlifeFlyer said:
The safety pilot is =not= the sole manipulator. The other pilot is. Isn't that the whole idea?
Click to expand...
MidlifeFlyer said:
We are on the same page here.


When a safety pilot logs PIC, it's not under the "sole manipulator" clause, but under the "acting as PIC in a 2-pilot required operation" clause.
Click to expand...



To be able to ACT as a PIC you need the high perf endorsement.

Ref. 61.31(f)
"...no person may ACT as pilot in command of a high-performance airplane, unless the person has - ...[received the endorsment]"


The person under the hood can LOG the time per the "sole manipulator" reg.

The non-hooded safety pilot is ACTING as pic and thusly can put the time in the "pic" column of a log book.

This is the whole loop-hole in the reg.
 
ClearedToThe said:



To be able to ACT as a PIC you need the high perf endorsement.

Ref. 61.31(f)
"...no person may ACT as pilot in command of a high-performance airplane, unless the person has - ...[received the endorsment]"


The person under the hood can LOG the time per the "sole manipulator" reg.

The non-hooded safety pilot is ACTING as pic and thusly can put the time in the "pic" column of a log book.

This is the whole loop-hole in the reg.
Click to expand...

Sometimes the pilot flying is also ACTING as pic, and then the safety pilot can log SIC time. :)
 
Thanks everyone for the quick reply. To clarify a few things:

I did my multi commercial training on a twin Comanche. I got my commercial initial after 23 hours of training including the checkride.

Last week I went with my friend to Puerto Rico from nyc. He owns a cessna 310. I logged about 3 hours as a safety pilot and 2 hours under the hood.
Can I log these hours if I don't have a high performance endorsement. 310 has over 200 horsepower per engine.
 
MidlifeFlyer said:
You can't.

But the point is that the safety pilot doesn't have to be the one acting as PIC.
Click to expand...

Then how can the safety pilot put the flight time in their logbook under the "pic" column?

91.109 mentions NOTHING about the ability to "LOG" or "ACT" as PIC if you are the safety pilot. Just simply states you need a safety pilot if you are flying under a hood (duh, right? lol).

The only way for the "loop-hole" to work is hooded pilot = logging pic by sole manipulator, and safety pilot = acting pic (and requireing endorsement).
 
ClearedToThe said:
Then how can the safety pilot put the flight time in their logbook under the "pic" column?.
Click to expand...
He can't if he wasn't acting as PIC.

Your "pot stir" stated with "If you are the safety pilot then you are ACTING as PIC." That at least appears to be saying that a safety pilot =must= be the acting PIC. That's not correct.

A safety pilot who is acting as PIC may log PIC.

A safety pilot who is not acting as PIC may log SIC.

In order to act is PIC, as safety pilot, just like any other pilot whi is acting as PIC , must be qualified to do so.
 
MidlifeFlyer said:
He can't if he wasn't acting as PIC.

Your "pot stir" stated with "If you are the safety pilot then you are ACTING as PIC." That at least apears to be saying that a safety pilot =must= be the acting PIC. That's not correct.
Click to expand...

And that is still my position. Otherwise both people can't log it.

Let's (for arguments sake) say that the hooded pilot was ACTING as PIC... Then what reg allows the safety pilot to log that time under "pic". And do not quote 91.109, b/c again, no where in that reg does it mention logging / acting of any time. It simply states a safety pilot is required.
 
henryqs1 said:
Last week I went with my friend to Puerto Rico from nyc. He owns a cessna 310. I logged about 3 hours as a safety pilot and 2 hours under the hood. Can I log these hours if I don't have a high performance endorsement. 310 has over 200 horsepower per engine.
Click to expand...

You can only log the safety pilot time as SIC. To log it as PIC, you would have to be qualified to ACT as PIC, which you were not.

For the time you were sole manipulator, you can log that as PIC.

(Midlife, this is kinda late in the evening for you.;))
 
tgrayson said:
You can only log the safety pilot time as SIC. To log it as PIC, you would have to be qualified to ACT as PIC, which you were not.

For the time you were sole manipulator, you can log that as PIC.

(Midlife, this is kinda late in the evening for you.;))
Click to expand...

I agree that only the time you were under the hood can be logged as PIC.

I disagree with the statement that the time you were the safety pilot can be logged as SIC. You can not log that time at all since the airplane was only type certified for one pilot. And the "hood/safety pilot operation" does not require a second-in-command...its requires a "safety pilot" per 91.109. Look at the difference in phraseology used in 61.55(a) - Second In Command Qualifications.
 
ClearedToThe said:
You can not log that time at all since the airplane was only type certified for one pilot.
Click to expand...

Or the regulations under which the flight is conducted. With the pilot under the hood, the safety pilot is a required crewmember.

(f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(2) Holds the appropriate category, class, and instrument rating (if an instrument rating is required for the flight) for the aircraft being flown, and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted.
​
(Vast support with letters of interpretation.)
 
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