Can a safety pilot log X-CTY time?

[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.