Can a safety pilot log X-CTY time?

[mklyce]

I am spliting time with another pilot at the airport I fly at and we can't figure out if we both can log PIC and X-cty or just the pilot under the hood can log the x-cty? Any help would be much appreciated.

Thanks!

MK

 

[nosehair]

I think it's a legal toss-up.

I would not log it if it is for a certificate or rating, but otherwise, I would.

 

[ackattacker]

I think it's a legal toss-up.

I would not log it if it is for a certificate or rating, but otherwise, I would.

My thinking is the opposite... the only reason to log this sort of time is for a certificate or rating. Nobody else really cares about x-c time. And safety-pilot time looks pretty bad at an interview.

I don't see any reason why it would not be legal to log it as x-c though. I log x-c time when I'm an SIC, so why not any other legally required crewmember.

 

[nosehair]

I don't see any reason why it would not be legal to log it as x-c though.

Just the wording of the definition of x/c under 61.1 which defines the aeronautical experience requirements: "X/C time includes a landing at a point more than 50 nm..."

If you, as the safety pilot, make a landing at the destination, then it fits the legal requirement of 61.1.

 

[Amish RakeFight]

Cross country as per ATP certification only requires a flight beyond 50 NM. A landing is not required.

Go ahead and log x-ctry time as SIC. Just dont log the landing.

 

[Amish RakeFight]

Both can log PIC. The safety pilot needs to be the designated PIC (ACTING), while the person under the hood can LOG PIC as sole manipulator.

 

[ackattacker]

Just the wording of the definition of x/c under 61.1 which defines the aeronautical experience requirements: "X/C time includes a landing at a point more than 50 nm..."

If you, as the safety pilot, make a landing at the destination, then it fits the legal requirement of 61.1.

Ah, you're right, that is a bit nebulous. One might argue it either way.

To be safe I suppose you could *both* make a landing at the destination. Then both log it x-c.

 

[nosehair]

Cross country as per ATP certification only requires a flight beyond 50 NM. A landing is not required.

Go ahead and log x-ctry time as SIC. Just dont log the landing.

Ah! This is true. When I said "for a certificate or rating", I meant Pvt,Com, Inst.

I would log the time for other than that which would include the 500 x/c pic for 135 and for the ATP.

IMOH, those 500 hours can be gained in many a wide variety of ways - that's doing 500 hours in many ways which broadens your experience.

However, I think the 50 hrs x/c for com/inst, should be on your own.

Now, if you are actually, really 'running the flight', doin' the nav, and overseeing all things and the guy under the hood is just flying basic instruments - then it is loggable x/c. That's how I think we are supposed to log - what you actually do.

 

[midlifeflyer]

Just the wording of the definition of x/c under 61.1 which defines the aeronautical experience requirements: "X/C time includes a landing at a point more than 50 nm..."

But that's not the wording. The wording is, "time acquired during a flight...That includes a point of landing that was at least..."

There's nothing in the reg other than that the =flight= needs to meet the requirements and that the person logging it has to have some otherwise loggable time.

But you were right in your earlier observation that it's a toss-up. I thought the reasoning was suspect, but the old, officially disowned, Part 61 FAQ took the view that it didn't count and there is an FAA Regional Legal opinion floating around that essentially punted the question back to flight standards.

All other things being equal, my purely personal view is that until the question is answered, to be on the safe side, I'd try to fulfill the certificate requirements with "sole manipulator" cross country time.

 

[nosehair]

But that's not the wording. The wording is, "time acquired during a flight...That includes a point of landing that was at least..."

?? your wording is closer to the actual print - ? but still has the same meaning, ie. "includes a point of landing..."

There's nothing in the reg other than that the =flight= needs to meet the requirements and that the person logging it has to have some otherwise loggable time.

The 'flight', under 61.1(b)(3)(ii) includes (A) "appropriate" aircraft. (towards the certificate or rating) (B) Landing more than 50... (C) means of nav...

So, that (B) is what you're wiggling around when you use it for a cert or rating...

 

[BLing]

You as the safety pilot are required to be there. So if your going cross country, you log it. I know that ATP bases their whole career pilot program on this (didnt do it myself, but still know). They send two guys in a Seminole to fly all ver the country to build time for their ratings. One guy under the hood, the other being the safety pilot.

However, dont rely on getting a majority of your total time from being a safety pilot if you ever pan on going to an airline! Yes, its legal to log, but its not looked at real well at a job interview.

 

[Doc Holiday]

Bling had some good thoughts that I would like to add to. This is not an attack on you, I know at this point in the game every minute matters.

Logging time as a "required" pilot in a 2000 pound airplane (while not instructing) is pretty lame. The way to become a better pilot is to have patience, study, and be diligent. Fly an aircraft you can handle and work your way up from there. Teach. The time in your logbook is not necessarily proportional to your experience. With patience and a strong work ethic, the opportunity for QUALITY experience will come. Then you won't be a liability to the person sitting next to you.

Be patient, study, and work hard.

 

[avbug]

The weight of the airplane isn't relevant, nor is your position as PIC, or SIC. If the flight went cross country, then you may log cross country.

So far as the safety pilot goes, you are indeed a required flight crewmember, in accordance with 14 CFR 91.109(b).

Logging of flight time is also very clear, in establishing that you may be required by the type certification of the airplane or the regulations under which it's operated. An aircraft operated under 135 under IFR, for example, may require a SIC, even though the aircraft type certification doesn't require it. The SIC is then a required crewmember. Whereas 91.109(b) stipulates the safety pilot as a required crew member, one may also log the time under this application.

If as safety pilot you are the acting PIC, you may log the time as PIC, and the person manipulating the controls may log the time as PIC also, as sole manipulator of the controls. And yes, you may both log cross country. You may also both log instrument, night or any other condition of flight, as you're both there together.

So far as requiring a landing; if you're using the cross country for a purpose other than the ATP in meeting the requirements of a certificate or rating, yes, the flight needs a landing at a point other than the point of departure, and in most cases at least 50 nm away, to be a cross country flight. However, you don't need to be the one making the landing to make it a cross country flight.

 

[Doc Holiday]

Well avbug, I believe we've conflicted once before, as I don't participate here often.

I was not arguing about the legality of logging the time. My point is splitting time merely to fill the logbook is worthless experience wise. Two guys going to low density/uncontrolled airports in VMC for the sole reason of burning gas is ridiculous. Tuck in your skirt, be patient, be diligent and get some time that is worth while.

I will guess that the reg that has be referenced many times above was not intended to get inexperienced pilots into a job quickly.

 

[avbug]

The original poster said nothing about a job or otherwise; he asked a question regarding the logging of time, and a true and correct answer has been given. Arguing beyond that is pointless. Further, the poster said nothing about low density, VFR, or otherwise. These are concepts that, with respect to the thread, you have made up.

 

[AC560]

So far as the safety pilot goes, you are indeed a required flight crewmember, in accordance with 14 CFR 91.109(b).

You are only required when the other pilot is wearing the hood. Once he takes it off your no longer required. My personal opinion is you can't log it but that isn't worth much, so I go with nosehair in that it is a toss up.

 

[avbug]

The safety pilot is required so long as simulated instrument flight is conducted. The presence of a "hood" isn't necessary.

 

[Immune83]

Log PIC, if youre "required" for the flight as safety pilot, and you go on an XC > 50nm then you both can log it.

** unles your flying an a/c youre not rated for (cat. or class).

2ndly, how would anyone be able to prove who was safety pilot? Unless both of you were interviewing for the same company at the same time with the same interviewee..... not likely

 

[AC560]

The safety pilot is required so long as simulated instrument flight is conducted. The presence of a "hood" isn't necessary.

As nosehair said and I agree it is a toss up. In my opinion you aren't simulating instrument flight while landing and as such only the sole manipulator gets to log it as cross country for most things (those under 61.1 which require a landing) as there is no longer a requirement for a SIC.

2ndly, how would anyone be able to prove who was safety pilot? Unless both of you were interviewing for the same company at the same time with the same interviewee..... not likely

Your odds of being caught don't play into whether it is right or wrong.

 

[FreightPup]

I'm using a friend's site, yet again. Avbug, you are absolutely correct. I personally know the guy who started and owns ATP Inc. I posed this same question to him, in his home, many years ago. His explanation was in perfect correlation with what you've said all along here. So much so, in fact, that I was considering going out and doing something similar myself on a much smaller scale than ATP, and just offering the time, not the rating.

It's all about it being a simulated IFR flight, not being 'under the hood'. You can log time as PIC from the right seat as "Safety Pilot", and you can log time from the left seat as "Sole Manipulator". It sounds hokey, but that's not the only goofy sounding reg in the book. Not to mention the fact that this is how all these "airline" type flight schools are conducting this, and getting away with it. It's a good way for beginning pilots to build up a little multi-time so they can get insurance. Flying every other leg, is just like sitting as a co-pilot for any regular airline. You're still there, still helping and you're still learning something... you're just paying for it, instead of getting paid for it.

 

[BLing]

If as safety pilot you are the acting PIC, you may log the time as PIC, and the person manipulating the controls may log the time as PIC also, as sole manipulator of the controls. And yes, you may both log cross country. You may also both log instrument, night or any other condition of flight, as you're both there together.

Please explain to me and the rest of us when both pilots can log instrument time outside of the training environment.

 

[avbug]

Instrument time is a condition of flight. Whomever may log during flight in instrument conditions may log instrument time. If two people are logging the time as PIC/SIC, PIC/PIC, or any other manner of logging as required crew members, then each may log the conditions of flight...night, instrument, etc.

You don't understand this, brightspark?

 

[BLing]

Instrument time is a condition of flight. Whomever may log during flight in instrument conditions may log instrument time. If two people are logging the time as PIC/SIC, PIC/PIC, or any other manner of logging as required crew members, then each may log the conditions of flight...night, instrument, etc.

You don't understand this, brightspark?

Okay smarta$$

You said that a safety pilot can log instrument time as well. Being in IMC would disqualify the need for a safety pilot. Therefore he/she is unable to log any of the flight time, let alone instrument. What you described was a single pilot operation...

 

[regionalcap]

The safety pilot is only required for the purposes of simulated instrument flight. I would agree that the safety pilot is not required for actual instrument flight therefore doesn't log actual instrument conditions.

 

[avbug]

You said that a safety pilot can log instrument time as well. Being in IMC would disqualify the need for a safety pilot.

That would make you wrong on two counts.

First, I said nothing about IMC, but we'll address it anyway. You made the assumption that I stipulated IMC, whereas I did not. The FAA has held that one need not be in instrument meteorological conditions in order to be in instrument conditions. The FAA has held that any circumstance requiring the use of intruments to maintain control of the aircraft, to include a moonless night over water or flight between cloud layers, constitutes instrument conditions. Further, the FAA has held that one who does not posses an instrument rating may log instrument time under such conditions...without ever being in IMC.

So far as the necessity of a safety pilot while in IMC...you're wrong there, too. So long as the pilot flying wears a view limiting device, is under a hood or a cockpit blackout device, or is otherwise prevented from seeing and avoiding other traffic, the safety pilot is required. The safety pilot's primary duty is seeing and avoiding other traffic (further reinforced by the subsequent requirements under 91.109 for additional observers where necessary to see traffic where the safety pilot's field of view may be obscured).

The requirement to see and avoid does not go away in IMC, nor in instrument conditions. As you have just learned, IMC and instrument conditions are not necessarily the same thing. A safety pilot is required so long as the flight engages in simulated instrument flight. That the flight may actually require instruments to maintain control does not negate the fact that one pilot may be wearing a view limiting device or otherwise constrained from the ability to see and avoid other traffic, or the fact that he or she has no choice due to artificial means of restricting his or her vision outside the cockpit, but to fly by reference to instruments.

The truth is, a pilot may be in instrument conditions and not in IMC, and a pilot may require a safety pilot while flight in instrument conditions or IMC.

What you described was a single pilot operation...

I described no such thing. Perhaps you're not so bright. Your comprehension does lack, somewhat. Try again.

 

[midlifeflyer]

There's stuff in this discussion that is not in dispute. There is stuff that is arguable.

That two pilots may log PIC at the same time, in or outside the training environment is based on FAA Chief Counsel opinions going back about 25 years. The analysis is simple: if a pilot fits into one of the cubbyholes created for logging PIC in 61.51, he or she may log PIC, no matter who else can also. OTOH, if you don't fit into one of those boxes, you can't log it, even if you are the "real" PIC.

That both the safety pilot and the flying pilot may log PIC in simulated instrument conditions (if the safety pilot is the one acting as PIC) is, according to FAA Chief Counsel opinion going back at least 15 years, one of those situations in which both pilots fit into 61.51 PIC cubbyholes. That one is based on the interplay between 61.51 and 91.109, making the flight a 2-required pilot operation (don't bother telling me there are holes in the analysis - I know).

One can rant and rave and yell that their silly or unfair, but they are what they are - established FAA policy.

IMO, still open are two of the other questions that have been discussed here. One is the interesting question about whether the safety pilot is still a required crewmember when the flight goes into IMC. I happen to agree with AvBug on that one. 24 years ago, the FAA Chief Counsel said, "'Simulated' instrument conditions occur when the pilot's vision outside of the aircraft is intentionally restricted, such as by a hood or goggles." I don't see anything in the definition, or in the 91.109 requirement that talks about the weather outside. But I guess it's arguable, if for no other reason than FAA interpretations are based, not only on the words of the regulations but often on the policy the reg was based on.

The other is the safety pilot cross country issue, and that one is because of what I mentioned earlier - the orphaned Part 61 FAQ said no, and I'm aware of a regional counsel opinion that punted the issue to Flight Standards.

 

[Amish RakeFight]

If one really wants the acting PIC as a safety pilot time and has an imperative to log it as x-ctry, then do a touch-and-go before the manipulator lands the plane.

I too have heard that one may log instrument time in VMC when there is no visible horizon or on a moonless night over rural terrain.

 

[midlifeflyer]

If one really wants the acting PIC as a safety pilot time and has an imperative to log it as x-ctry, then do a touch-and-go before the manipulator lands the plane.

You sound like you read the old FAQ. But if you did, you know that Lynch's analysis was purely result-oriented - I don't want it to count so it doesn't. So if it's really the rule, the touch & go and the destination is probably not enough.

Now, if you do a touch & go at =both= the departure and the destination so that both pilots...

 

[Amish RakeFight]

Good point. I forgot about the takeoff!

 

[nosehair]

So long as the pilot flying wears a view limiting device, is under a hood or a cockpit blackout device, or is otherwise prevented from seeing and avoiding other traffic, the safety pilot is required.

Additionally, I teach zero-zero take-offs, with the pilot under the hood from 'brakes off', and I teach flying the glideslope to touchdown. I personally want to be able to land in zero zero if it becomes necessary, and I teach this emergency skill to all my instrument students. Of course, I'm a CFI and can log all the time anyway, but everyone should not think that all training is PTS-minimum-oriented. Some pilots are actually training to a higher standard.