AOPA Article - Logging Time

[Workin'Stiff]

I thought this would kick off a big 'ole debate. AOPA just printed this article about the most debated regs in the FARs. There was a section about logging time as "safety pilot". Here's the snippet...

"Two private pilots can't log PIC at the same time. Airline pilots aren't the only ones allowed to log time in either seat. According to FAR 91.109, a safety pilot must be present if you want to fly under the hood. Because the safety pilot is a required flight crewmemember, he may log the time. But how do you log the time?

If both pilots agree that the safety pilot is PIC, he may log the time as PIC if he is qualified to act as such. If not, the safety pilot should log second-in-command. The pilot flying will also log PIC, per FAR 61.51. The regulations make a distinction between acting as PIC and logging PIC time."

Ref: AOPAPilot November 2005 "Talking about the Regs" pg. 36

Can you imagine walking into an interview with 100 hours of C-172 SIC??? Good luck explaining your way outta that one....

Ref: FAR 61.51(f) Logging Second-in-Command flight time

(f)Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate; or
(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.



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Ref: FAR 61.55(f) Second-in-Command Qualifications

(f) This section does not apply to a person who is:
(1) Designated and qualified as pilot in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(2) Designated as the second in command under subpart K of part 91, part 121, 125, or 135 of this chapter in that specific type of aircraft;
(3) Designated as the second in command in that specific type of aircraft for the purpose of receiving flight training required by this section, and no passengers or cargo are carried on the aircraft; or
(4) Designated as a safety pilot for purposes required by §91.109(b) of this chapter.




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So if the pilot occupying the right seat as a safety pilot doesn't qualify as second-in-command per 61.51(f) - (in the Skyhawk example) and 61.55(f), then they should not be allowed to log SIC time for acting as a safety pilot in a Skyhawk, right??? Anyone else's take???

 

[erj-145mech]

If you're not qualified as a PIC in category and class, then you're also not legal as a safety pilot either. The safety pilot must be qualified and current to perform those duties too. So basing that the safety pilot is qualified and current, then he may log PIC.

 

[Workin'Stiff]

Yeah, that part didn't make any sense either. I kinda think that AOPA should really evaluate that section of the article alittle more. There are some pretty big inaccuracies in it..

 

[dmspilot00]

First of all, the article contradicts itself. The very first sentence says, "Two private pilots can't log PIC at the same time," but then it goes on to tell you how two pilots can log PIC at the same time.

However, it is perfectly legitimate to log safety pilot time as SIC instead of PIC, because of 61.51(f)(2):

(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.

Since a safety pilot "required under the regulations under which the flight is being conducted" he/she may log SIC if it is decided that he/she will not be acting as the pilot in command. That doesn't mean it would be a good idea to add it in with your B737 SIC time though...

 

[Workin'Stiff]

Well, I interpret that part "required under the regulations under which the flight is being conducted" as being part 121, part 135, etc. So with that under consideration and the section above that stating "more than one pilot is required under the type certification of the aircraft," as the conditionary "or statement", I really don't see how you can log SIC in a Skyhawk...

In my opinion...

 

[dmspilot00]

According to your interpretation, the safety pilot would not be able to log PIC either, because the wording that allows the safety pilot to log PIC is the exact same as the wording allowing him or her to log SIC.

61.61
(e) Logging pilot-in-command flight time.
(1) A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person—
(iii) Except for a recreational pilot, is 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.

 

[Workin'Stiff]

Sorry, maybe I didn't get across what I meant. The way that I interpret "more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted" is that under Part 121 and Part 135 (Turbojet ops), atleast two flight crewmembers are required. I guess I'm not aware of any Part 91 requirements that place that same burden on minimum flight crew, aside from aircraft type certification.

Since I'm not aware of that sort of requirement under Part 91 (regulation-wise only), the only way that you would be able to log SIC under Part 91, would be if you were operating in an aircraft where the type certificate required a minimum flight crew of two pilots. Hence you would not be able to log SIC in a Skyhawk or Cherokee, for instance.

 

[Workin'Stiff]

After re-reading what I posted, Part 91 does require another pilot to perform Safety Pilot duties. So yes, 91 does require another pilot... But I'm still not sure I'd log SIC in this type of situation...

 

[midlifeflyer]

BTW, stiff... looks like you posted your last one while I was still writing this:

Well, I interpret that part "required under the regulations under which the flight is being conducted" as being part 121, part 135, etc.

You''re certainly welcome to interpret it that way, but the FAA doesn't Flight in simulated instrument conditions under 91.109 is also an operation that requires more than one pilot under the regulations.

You're welcome to debate this as much as you want. But the FAA settled both questions quite a while ago. Here's what the FAA Chief Counsel said on the subject 13 years ago in 1992 (the interpretation of the regs is even older than that):

==============================
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).
==============================

No, I can't imaging someone going into an interview and talking about his "172 SIC" time either. Just like I can't see someone going to an interview for an accounting position and talking about his "fincnail experience" working the register at McDonalds. But I =can= imaging him using the time as total flight time toward his next FAA certificate or ratings And that's what logging under FAR 61.51 is for.

 

[Workin'Stiff]

Yeah, it's one of the many things that are allowed under the regs... But precedent steers us into doing things a certain way...