Logging XC Time When Safety Pilot?
- Thread starter Skinnah
- Start date
mavsfflife
Well-Known Member
Yes you can, I called the FAA office not too long ago to confirm this. I am currently logging time as PIC XC while being a safety pilot for a friend.
Ralgha
Well-Known Member
If you're logging it to meet the ATP requirement, then you're ok. If you're logging it to meet the Commercial requirement, then you're not, unless you made the landings. Commercial X/C requirements require a landing be made 50 NM away from take off. If you don't make that landing, it doesn't count.
FAA FSDOs don't always know what's right.
FAA FSDOs don't always know what's right.
MidlifeFlyer
Well-Known Member
The Part 61 FAQ says you can't. But I think the FAQ is wrong. (wouldn't be the first time)
Look at what the regulation says. All of the definitions in 61.1(b)(3) contain one thing in common. They all define a cross country as "time acquired during flight" which meets certain requirements. The "flight" has to meet the requirements, not necessarily the pilot. Of course, the pilot needs legitimate flight time, which is satisfied by being safety pilot.
Let's take an example: the cross country used for most certificates and ratings:
==============================
For the purpose of meeting the aeronautical experience requirements ... for a private pilot certificate ... a commercial pilot certificate, or an instrument rating, ..., time acquired during a flight--
(A) Conducted in an appropriate aircraft;
(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and
(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
==============================
Maybe someone else sees in (B) "That includes a point of landing performed by the pilot who logs the time at a point that was at least a straight-line distance of more than 50 nautical miles from the original point of departure." I can't find it.
Look at what the regulation says. All of the definitions in 61.1(b)(3) contain one thing in common. They all define a cross country as "time acquired during flight" which meets certain requirements. The "flight" has to meet the requirements, not necessarily the pilot. Of course, the pilot needs legitimate flight time, which is satisfied by being safety pilot.
Let's take an example: the cross country used for most certificates and ratings:
==============================
For the purpose of meeting the aeronautical experience requirements ... for a private pilot certificate ... a commercial pilot certificate, or an instrument rating, ..., time acquired during a flight--
(A) Conducted in an appropriate aircraft;
(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and
(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
==============================
Maybe someone else sees in (B) "That includes a point of landing performed by the pilot who logs the time at a point that was at least a straight-line distance of more than 50 nautical miles from the original point of departure." I can't find it.
bike21
9-5 Ruins Lives
I think the more appropriate question is: can I count it toward the Instrument or Commercial rating? This is where most folks usually try to split time and gain some XC time. The regs can be gray on the matter, always open to interpretation. However, I agree with the Part 61 FAQ, how can a safety pilot possbily log XC time when he/she doesn't touch the controls during takeoff or landing? The safety pilot would certainly seem to a mere passenger for the VFR portions of the flight.
One could possibly 'log' it, but it may not count toward the requirements for a rating. I certainly would not want to be in the position of justifying the logged time during an interview or to an FAA inspector. Shortcuts and saving money are certainly nice, but sometimes its better to hang on the conservative side. Trust me, as a chief pilot i've seen some interesting things!
One could possibly 'log' it, but it may not count toward the requirements for a rating. I certainly would not want to be in the position of justifying the logged time during an interview or to an FAA inspector. Shortcuts and saving money are certainly nice, but sometimes its better to hang on the conservative side. Trust me, as a chief pilot i've seen some interesting things!
MidlifeFlyer
Well-Known Member
[ QUOTE ]
However, I agree with the Part 61 FAQ, how can a safety pilot possibly log XC time when he/she doesn't touch the controls during takeoff or landing? The safety pilot would certainly seem to a mere passenger for the VFR portions of the flight.
[/ QUOTE ]Try this one.Base your answers on the same principles that the FAQ is based on unless you can point to something in the regulation that makes it different.
You and I decide to go on a trip and share the flying duties. We are in an airplane with plenty of range, so we decide to do our trip in one 500 NM leg. You take off and fly 250 NM and then the controls become mine. I finish the trip and land. Doesn't the FAQ suggest that neither of us can log the flight as cross country?
Neither performs the takeoff and the landing. Each are merely passengers for 1/2 the flight. So no one gets to count =any= of the time as cross country.
The problem with the incorrect portions of the FAQ is that they tend to be results oriented rather than regulation oriented. Yup maybe it makes sense that a safety pilot who is acting as PIC and is responsible for the flying pilot's navigational errors like getting lost or busting airspace can't log any of the flight time as cross country, but the regulation quite simply isn't written that way.
However, I agree with the Part 61 FAQ, how can a safety pilot possibly log XC time when he/she doesn't touch the controls during takeoff or landing? The safety pilot would certainly seem to a mere passenger for the VFR portions of the flight.
[/ QUOTE ]Try this one.Base your answers on the same principles that the FAQ is based on unless you can point to something in the regulation that makes it different.
You and I decide to go on a trip and share the flying duties. We are in an airplane with plenty of range, so we decide to do our trip in one 500 NM leg. You take off and fly 250 NM and then the controls become mine. I finish the trip and land. Doesn't the FAQ suggest that neither of us can log the flight as cross country?
Neither performs the takeoff and the landing. Each are merely passengers for 1/2 the flight. So no one gets to count =any= of the time as cross country.
The problem with the incorrect portions of the FAQ is that they tend to be results oriented rather than regulation oriented. Yup maybe it makes sense that a safety pilot who is acting as PIC and is responsible for the flying pilot's navigational errors like getting lost or busting airspace can't log any of the flight time as cross country, but the regulation quite simply isn't written that way.
Heath
Well-Known Member
The regs are very clear that the safety pilot IS able to log the time as "pilot-in-command." Therefore, it would logically follow that as "pilot-in-command" of a legitimate cross-country flight that you would log the time as cross-country.
As has been stated, the requirement for the commercial rating states that the flight must "include" a landing at an airport at least 50NM away, it doesn't state that to log the time you must be "sole manipulator of the controls." As this verbiage is used in other areas when that is the requirement, I would further argue that safety pilot time on a cross country is legitimate PIC x-country time.
The fact that a call to the FAA got the same answer would further bolster this argument.
Heath
As has been stated, the requirement for the commercial rating states that the flight must "include" a landing at an airport at least 50NM away, it doesn't state that to log the time you must be "sole manipulator of the controls." As this verbiage is used in other areas when that is the requirement, I would further argue that safety pilot time on a cross country is legitimate PIC x-country time.
The fact that a call to the FAA got the same answer would further bolster this argument.
Heath
GaTechKid
Well-Known Member
Same discussion, different thread:
http://jetcareers.com/forums/showflat.php?Cat=&Number=258572&page=0&view=collapsed&sb=5&o=&fpart=1
http://jetcareers.com/forums/showflat.php?Cat=&Number=258572&page=0&view=collapsed&sb=5&o=&fpart=1
MidlifeFlyer
Well-Known Member
[ QUOTE ]
The fact that a call to the FAA got the same answer would further bolster this argument.
[/ QUOTE ]Unless you spoke to Blakey or someone from the Chief Counsel's office, a cal to the FAA only gives you that one person's opinion. Even if wrong, the Part 61 FAQ represents (what should be) the FAA's effort to standardize interpretations and, with an obvious exception or two, carries more weight than any individual person.
The fact that a call to the FAA got the same answer would further bolster this argument.
[/ QUOTE ]Unless you spoke to Blakey or someone from the Chief Counsel's office, a cal to the FAA only gives you that one person's opinion. Even if wrong, the Part 61 FAQ represents (what should be) the FAA's effort to standardize interpretations and, with an obvious exception or two, carries more weight than any individual person.
bike21
9-5 Ruins Lives
[ QUOTE ]
Even if wrong, the Part 61 FAQ represents (what should be) the FAA's effort to standardize interpretations and, with an obvious exception or two, carries more weight than any individual person.
[/ QUOTE ]
Agreed. You guys bring up some very valid points here. Too bad its not more clear cut heh?
I thought thats what legalese was written for, not to be interpreted!
I would love to easily agree that the SP time can be counted as XC time. Obviously a lot of folks have done it that way and continue to do so. But since there is no clear answer anywhere you look (at least to me; again with one person being wrong/right) I would be concerened to blindly count it. Perhaps both pilots should do a t/o and landing at each airport to CYA!!
Even if wrong, the Part 61 FAQ represents (what should be) the FAA's effort to standardize interpretations and, with an obvious exception or two, carries more weight than any individual person.
[/ QUOTE ]
Agreed. You guys bring up some very valid points here. Too bad its not more clear cut heh?
I would love to easily agree that the SP time can be counted as XC time. Obviously a lot of folks have done it that way and continue to do so. But since there is no clear answer anywhere you look (at least to me; again with one person being wrong/right) I would be concerened to blindly count it. Perhaps both pilots should do a t/o and landing at each airport to CYA!!
Windchill
Well-Known Member
I'm revisiting these threads concerning logging hood time as well as xc while splitting the time/duties/costs with a guy I met the other night at an FBO I fly with who is also working toward the Part 61 reqs. for the IR ticket.
I agree that the verbage doesn't say a pilot logging xc time must make the landing himself ... however, I also agree that during the t/o and landing, the safety pilot isn't logging PIC because he's not required, and therefore since the safety pilot can't log the entire flight, but only the time while the other pilot is under the hood, how can he log an entire flight when he's only allowed to log during just a portion of it.
How about this? The safety pilot does the takeoff and landings, this way one gets cross-country time while the other gets hood ... instead of one getting all and the other a little. Although after the return trip I guess it all evens out in the end.
I agree that the verbage doesn't say a pilot logging xc time must make the landing himself ... however, I also agree that during the t/o and landing, the safety pilot isn't logging PIC because he's not required, and therefore since the safety pilot can't log the entire flight, but only the time while the other pilot is under the hood, how can he log an entire flight when he's only allowed to log during just a portion of it.
How about this? The safety pilot does the takeoff and landings, this way one gets cross-country time while the other gets hood ... instead of one getting all and the other a little. Although after the return trip I guess it all evens out in the end.