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.
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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.
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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.
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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"
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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."
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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.
