Logging 2nd in command as safety pilot

[Bernoulli]

Have any of you logged second in command for being a safety pilot in an aircraft requiring only one pilot? It looks like 61.55a says you cant, but then there is an exception... (paragraph D, #4 of 61.55 which seems to say it's ok if "designated as a safety pilot for purposes required by 91.109(b)." Have any of you built time this way and is it legit in the eyes of future airline employers?

 

[abev107]

I was recently thinking about the same thing. Perhaps someone more familiar can post their knowledge. In the mean time I found this that may answer our questions.

http://www.awp.faa.gov/new/fsdo/art_pilot.htm

 

[501261]

Knowing how screwed up the FAR's are I'm sure it’s legal to log SIC in a C150, just like its legal for 3 people to log PIC in an Aztec. Personally I'd much rather log the 3-way PIC than SIC in a C150, because it doesn't stick out nearly as bad.

Sure, under FAR 61.51(f.2) combined with 61.55(d.4) you can log SIC in a C150.

In the real world however, if I was looking to hire you, and saw C150 SIC time, I'd probably laugh you out the door. Seriously, if you went and logged time like this, I'd have to question all the other hours you logged, and quite frankly there are simply too many pilots out there that I don't have to question about the "quality" of hours logged!

If your gonna be a safety pilot and log it, at least get a CFI so that you can log it as dual given!

 

[TAG2]

It's been a long time for me but from what I remember, I think as a safety pilot you can actually log PIC. You are rated (I hope) in the aircraft and required to be there. The pilot flying also logs PIC as "sole manipulator of the controls".

 

[reaperman]

Bernoulli,

61.55 does not apply to single pilot aircraft. When simulated instrument conditions occur, a single pilot aircraft does not then come under 91.55 because its certificate does not change.

All the time logging answers are at DOC's.

 

[501261]

Reaper, even old DOC says you can log SIC, see his example 12

FAR 61.55 d 4 does apply to single pilot airplanes!

 

[dogg]

Bernoulli, If you must log it then I suggest making a new column in your log book that is tiitled "safety pilot" and keep track of it but do not include it in any total. Likewise if you are logging sim time or ftd time, make a seperate column and log it but do not include it in total time either. Employers want your total time to represent the total time that you were flying the airplane or that you were a required crewmember because the airplane required it.....it will just make life easier at that first interview.

 

[eriknorth]

I'm kinda new at all of this, but looking at the regs, I see a dispute. 61.51 paragraph f does say that you must be qualified as per 61.55, but it says that they must be qualified AND occupy a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate. Part (2) of f also says that more than one pilot must be required for the flight. I think it's pretty cut and dry from the word "AND" that SIC can only be logged for a flight that REQUIRES more than one crewmember. A 150 definately doesn't require more than one.
I just work here.

 

[Mitsipilot]

Like TAG2 said, I have always been under the impression that you can log this as PIC time. Why wouldn't you be able to?

 

[TXCAP4228]

I'm kinda new at all of this, but looking at the regs, I see a dispute. 61.51 paragraph f does say that you must be qualified as per 61.55, but it says that they must be qualified AND occupy a crewmember station in an aircraft that requires more than one pilot by the aircraft's type certificate. Part (2) of f also says that more than one pilot must be required for the flight. I think it's pretty cut and dry from the word "AND" that SIC can only be logged for a flight that REQUIRES more than one crewmember. A 150 definately doesn't require more than one.
I just work here.

91.109 says that a safety pilot is required. Therefore, the you are a required crewmember, even in a 150. - not required because of the type certificate, but because the FAR says that a safety pilot is required for the operartion.

All that being said, if you are rated in the category and class, I think you can log it PIC. 61.51 and 91.109 are operative here.

 

[eriknorth]

Yes PIC for sure. That's what many flight schools base their training programs on. When they advertise 100 hours of multi time or the like, you end up flying something like 50 PIC and 50 safety pilot (logging PIC). I am pretty sure about the SIC thing though, and how you can't log that in a 150. Call a FSDO and I'll bet they'll agree.

 

[eriknorth]

So if you are training in a Cessna, and you are a safety pilot for someone under the hood, how would you log it?

 

[TXCAP4228]

Deftone, I see what you're saying but I disagree completely.

.....you probably can get away with it. But think about it. Why do you want to log time where your not flying, not teaching, and not required to occupy that seat.

You ARE required to occupy that seat if the other pilot wears a view limiting device. 91.109.

Now, because you are REQUIRED under the regs, you may log the time as PIC under 61.51.

If there were a midair or something happened, the SAFETY PILOT would be liable too. Don't think that the fed's wouldn't go after the safety pilot too.

 

[TXCAP4228]

I negelected to mention before and I want to make it clear, I would not log SIC as a safety pilot, I would log PIC. 61.51.

 

[bozz66]

Here is the explanation off of Doc's FAR page:

"The right-seat pilot of a small trainer may simultaneously be the PIC and the "safety pilot" for a FAR 91 instrument training flight. Since safety pilots are required flight crewmembers, under FAR 91.109(b), the flight requires two pilots, and this PIC is now acting as PIC of an aircraft requiring more than one pilot. "

Notice it says "Acting as PIC" You can't log it as PIC.

Now an example of what a safety pilot can log:

A private pilot (Pilot "A"), with an airplane, single-engine land rating, wishes to log some simulated instrument time in a Cessna 172. The pilot enlists the help of another (same rating) private pilot (Pilot "B") who agrees to act as a safety pilot for Pilot "A". Pilot "A" is the pilot-in-command for the flight as agreed between the two pilots. Pilot "A" flies the airplane (is the sole manipulator of the flight controls) for the entire flight, and spends all but 0.3 hours of the 1.5 hour flight "under the hood".

Pilot "A" logs 1.5 hours PIC flight time, with 1.2 hours of "simulated instrument" time.

Pilot "B" logs 1.2 hours of SIC time, since Pilot "B" was only required for the time when Pilot "A" was under the hood.

This represents no change from the old rules.

Here is the link to Doc's site
http://www.propilot.com/

 

[eriknorth]

Flame away, but if "Doc" says to log it SIC, then he's an idiot. I get my information clarified not only from the FARs, but from the Feds as well. I use this board and the internet only as a supplementary tool for learning, and I make sure that what I learn is backed up. Two officials from the ATL FSDO have confirmed that PIC can and is logged by the safety pilot and the pilot under the hood.

 

[bozz66]

Two officials from the ATL FSDO have confirmed that PIC can and is logged by the safety pilot and the pilot under the hood.

I'm looking at my FAR's Explained book by Kent S. Jackson and for 61.51, under FAA Chief Counsel Opinions( note it says opinions ) it says that" if the pilots 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, then the safety pilot may log all of 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 61.51."

So Erik, your FSDO guys are right only if you agree to let the safety pilot be the acting PIC. At least that's how I read it.

I think you're being a little swift in your judgement of "Doc". He most certainly is not an idiot. He has a massive knowledge of the regualtions and he is always more than happy to help anyone that might have a question. He has a disclaimer on his site that explains that he is not a lawyer and that his interpretations are just that, his interpretations . They don't hold water more than anybody elses, including the FSDO's! Deftone is right, if they aint Legal Council, then you're just guessing like the rest of us

 

[eriknorth]

read the book and think for yourself.

That's my whole point, is that I am reading it and thinking for myself. Much of the stuff that I read on this board I agree with, but will play devil's advocate with another view for the sake of learning. If one can make points on a subject from any angle, it is clear that he knows it, and that is what I strive for, is more aviation knowledge. I am not trying to insult doc. I know that I am pretty green and that someone of his caliber has a lotof knowledge and wisdom. However, I don't believe you have to be a deity to interpret a couple of paragraphs. Once again, no offense to doc, but everything that I have learned on this, and everyone I ask, goes against what he says on this subject. I'm pretty sure there is not supposed to be room for so much gray area. Who has the final say, anyway. If it lies in the PIC, then I don't see why we shoot down other pilots acting in such a manner and rely on some other source. Help me with this.

 

[cjh]

I can't believe this is STILL an issue

Whether two pilots can log simultaneous time in a single pilot aircraft, when the issue is a safety pilot's time, has absolutely nothing to do with the type certification of the aircraft. It has everything to do with 61.51(e)(1)(iii). 61.51, the ONLY reg which controls logging, specifically states that a pilot CAN log PIC time when ACTING as PIC for a flight "under the regulations under which the flight is conducted". The complete text is copied below. The regulation that makes this a two pilot requirement is 91.109 which requires a safety pilot for simulated instrument flight. See 91.109(b)(1), again copied below for reference.

Note that for the safety pilot to log PIC time, he must be ACTING as PIC, which means he must be qualified to do so. That includes currency and endorsements issues as well as being rated in the aircraft. If he is not qualified to act as PIC, or simply does not wish to, then he can still log SIC time, again under the provisions of 61.51(e)(1)(iii).

Doc most certainly does support this position, as does the AFS-640 board. Copies of opinions from each are also listed below.

----------------------------
61.51 Pilot logbooks.
(e) Logging pilot-in-command flight time. (1) A recreational, private, or commercial pilot may log pilot-in- command time only for that flight time during which that person --

(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated;

(ii) Is the sole occupant of the aircraft; or

(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.

--------------------------
91.109 Flight instruction; Simulated instrument flight and certain flight tests.
(b) No person may operate a civil aircraft in simulated instrument flight unless --

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.


---------------------------
Doc's opinion from Doc's FAR Pages. (I picked one. He has written on this subject, confirming the above, NUMEROUS times.)

"Since FAR 91.109(b) requires a safety pilot when flying under simulated instrument conditions, the operation now requires two pilots. Therefore, right seat (PIC and safety pilot) may log PIC time under FAR 61.51(e)(1)(iii).

[Edited for non relevance.] However, as soon as the foggles come off, right seat (PIC) time-logging privileges grind to a sudden halt because no provisions in FAR 61.51 allow him to log time.

FYI: If left seat had remained PIC [ again edited due to non relevance] then right seat (safety pilot) would only have been able to log SIC time. [Remainder edited due to non-relevance.]

I hope this helps!

Regards,

Doc"

--------------------------
And finally, the AFS-640 board's opinion on the subject.

QUESTION: In the December 1997 edition of "AOPA PILOT," specifically page 22, "AOPA ACCESS," the question was asked: "If I am flying as a safety pilot, can I log that time as pilot in command?" AOPA's answer is: "Yes. There had been talk during the rewrite process of changing this to specify only second-in-command time, but the final rule left logable safety pilot
PIC time intact. Requirements remain being rated in category and class. You are allowed to log safety pilot PIC time because your eyes are required for aircraft safety and therefore you become
a required crew member. The pilot under the hood can also log PIC time as 'sole' manipulator of the controls." §61.51(f)(2) seems pretty clear about safety pilots logging SIC rather than PIC time. What does AOPA know that we don't???

ANSWER: Yes, the time can be logged as PIC. Reference §61.51(e)(1)(ii): The safety pilot, who meets the qualifications set forth in §91.109(b) may log it as PIC time because §61.51(e)(1)(ii) states, in pertinent part, ". . . the regulations under which the flight is conducted. Note, we say "may" but he "may" prefer to log it as SIC time. Your understanding is probably based on the preamble discussion on page 16250, middle column, of the Federal Register (62 FR 16250; April 4, 1997). We would highly recommend that you also read the preamble discussion on page 16250, first column, of the Federal Register (62 FR 16250; April 4, 1997).
Reference §61.51(e)(1)(i): The other pilot manipulating the controls, and who meets the qualifications set forth in §91.109(a)(2) and (b)(3)(ii) may log it as PIC time because §61.51(e)(1)(i) states, in pertinent part, "Is the sole manipulator of the controls of an aircraft for which the pilot is rated;"
{q&a-95}

QUESTION: Is it true that a qualified pilot can log pilot-in-command time for all flight time during which he acts as a required safety pilot per 14 CFR §91.109?

ANSWER: Yes, the safety pilot can log the time as PIC time in accordance with §61.51(e)(ii) which states ". . . regulations under which the flight is conducted."

---------------------------
So there you have it.

Whether it's a good idea to have a lot of safety pilot time in your logbook is another issue. Whether this type of flight time is the equivalent to single pilot IFR flight time is also debatable. If you are a person who builds a lot of time flying safety pilot you probably answer "yes" to both of these issues. Personally, I think it's of marginal benefit, certainly not good to have a lot of it, and is not even a close second to being the PF. However, the regs say you can log it, and that's the issue in this thread. Legally, you CAN log it.

 

[T-REX]

urgggg

I go with what the FSDO says:

http://www.awp.faa.gov/fsdo/las_vegas/art_pilot.htm

Plus, the whole SIC C150 looks funny!