Safety pilot question, letting pilot go into IMC

Based on the "pretty clear (if not simple)" rules above, one could conclude the following:

Assume a two hour flight in IMC.

Two IFR pilots in IMC can both log PIC in their logbooks. The first pilot is manipulating the controls (rule #1), and the second pilot acting as PIC (rule #2).

Hmmmm? Somehow I don't think this is true, but from the rules you listed, this seems to be the case?

What do you think?
 
While even if it was possible, its not something I would like to have to explain in an interview:

Interviewer: "Gee Mr. Smith, I see you logged a good deal of actual instrument time as PIC before you even got your instrument rating. And its not even dual received! Care to tell me how you managed to do that?"

Dumbass who logs PIC in IMC with no IR or CFII: "Uhhhhhhh......."

I swear theres an underground group of people somewhere who's sole misson is to find rediculous ways to interpret regs.
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On a serious note, I concur wholeheartedly with Junkstream's post. Its not worth the risk.
 
[ QUOTE ]
Two IFR pilots in IMC can both log PIC in their logbooks. The first pilot is manipulating the controls (rule #1), and the second pilot acting as PIC (rule #2).


[/ QUOTE ]I think the answer is "no" here, unless the operation requires 2 pilots. I think this came up somewhere else on Doc's site, and the answer was that a safety pilot acting as PIC can only log the time when a second pilot is required--that is, when the flying pilot is under the hood. When the flight enters IMC, the hood requirement goes away, as does the need for the safety pilot as a required crewmember. Even tho the 2nd pilot is the only one who may act as PIC in IMC, only one pilot is required, so only one of them can then log the flight time--and it's probably the one manipulating the controls.
 
Ok, guess I should clear this up a bit more.

Typical around here, have fog into late morning this time of year. At the worst, it goes from about 200AGL up to 1000AGL or so during the night. By 9am or so, if it is still around, from like 800-1100MSL or so. Just enough so you can see through it looking down from above usually. This is the only time I'd want to consider sitting safety side, while the other guy flies, under a plan filed in my name obviously.

See, thing is, I really don't want to do this in IMC. I'd just like to be able to justify easy, a, "lets go stop over there, and switch seats, and I'll fly us back home" kinda thing. Way fog is around here, you can get to other local fields with 5-10 minutes no matter which way you go (as long as it isn't west, out into the Pacific Ocean
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) and would be able to switch seats.

On the other hand, because of how stuff clears, I wouldn't have a problem if the stuff is real thin, and just going through as it clears (which would be most like the case, if anything, while coming back in).

The other time is departing. If going early, there may still be fog. I've not flown right seat on the DP from WVI in IMC, but have VFR a little.

Or, this can all be avoided, just a little scud running on the hills to the east
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This may all never happen, but I want to address any questions with some backing, so all the comments are much appreciated.

And the CFI thing helps by knowing that it is an acting, and logging thing.

Thanks,
Josh
 
[ QUOTE ]
Based on the "pretty clear (if not simple)" rules above, one could conclude the following:

Assume a two hour flight in IMC.

Two IFR pilots in IMC can both log PIC in their logbooks. The first pilot is manipulating the controls (rule #1), and the second pilot acting as PIC (rule #2).

Hmmmm? Somehow I don't think this is true, but from the rules you listed, this seems to be the case?

What do you think?

[/ QUOTE ]It's not true. The acting PIC can't log the time. This is one of those acting vs. logging differences. Take a look at 61.51. It represents the universe of logging PIC. Can you find where it says that one is entitled to log PIC is one acts as PIC? It isn't there. (And, no, this doesn't meet the "more than one pilot required" part — only one pilot is required for a flight in IMC).

So in the Pilot #1 (IFR rated) is acting as PIC and Pilot #2 (not IFR rated) is manipulating the controls, as strange as it sounds, Pilot #2 can log the time, but Pilot #1 cannot.

FWIW, here's my own personal FAQ on the logging junk:

==============================
Here's a simple version of the rules as they have been written in the FAR and repeatedly and consistently interpreted by the FAA Chief Counsel for at least 20 years.

(I'm limiting it to student, recreational, private, and commercial pilots. CFIs and ATPs can fend for themselves. If they don't know the rules, tough.)

Rule 1 If you are a recreational, private or commercial pilot, you may log PIC any time you are the sole manipulator of the controls of an aircraft you are rated for.

"Rated" means the category and class (and type, if a type rating is necessary for the aircraft) that is listed on the back of your pilot certificate. Nothing else matters. Not instrument ratings. Not endorsements for high performance, complex, tailwheel aircraft. Not medical currency. Not flight reviews. Not night currency. Nothing.

Rule 2 If you are a student, recreational, private or commercial pilot, you may log PIC any time you are the only person in the aircraft.

This means that even without category and class ratings, you may log PIC time if you are solo. In addition to the obvious (student solo) it also means, for example, that if you are ASEL and solo in an AMEL or ASES, you may log the time as PIC.

Rule 3 If you are a private or commercial pilot, you may log PIC any time you are acting as PIC* of an aircraft on which more than one pilot is required.

More than one pilot may be required because the aircraft is not certified for single-pilot operations. But more common for us, it covers simulated instrument flight where a second "safety pilot" is required by the regulations all the time that the "manipulator" is under the hood. If the two pilots agree that the safety pilot is acting as PIC, the safety pilot can log the time as PIC.

Rule 4
Based on a unpublished 1977 Chief Counsel opinion (there is some reasonable disagreement on whether it's still any good), you may log PIC if you are acting as PIC* and you are the only person on board with the necessary aircraft ratings.

This is the answer to the silly question: "Can I log PIC while I let my two year old fly the airplane?" Frankly, I can't imagine that the FAA gives a hoot about this one way or another.

Rule 5
If you are a student, recreational, private, or commercial pilot and don't fit into Rules 1-4, you may not log the time as PIC even if you are acting as PIC.


*"Acting as PIC" assumes that you are qualified to act as PIC. That does mean being current and having the appropriate endorsements in addition to ratings.
 
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