Logging Safety/ Cross Country

[JRSLim]

Here's my question
I know that the FARs indicate we can log pic for safety pilot since we act as a req'd crew member.

But...
If we are safety pilot, and the plane goes to another airport and makes a landing during an approach (so the pilot gets X-copuntry) but we never touch the controls, do we log X-country?

My opinion would be no, except that since the FARs say we are PIC, then that might make it yes.


Thanks
Shaun

 

[Booker]

Here's my question
I know that the FARs indicate we can log pic for safety pilot since we act as a req'd crew member.

Only if you're also acting as PIC. See 61.51(d)(iii)

But...
If we are safety pilot, and the plane goes to another airport and makes a landing during an approach (so the pilot gets X-copuntry) but we never touch the controls, do we log X-country?

From the AFS-600 FAQ:

The pilot performing the take-off & landing, i.e., conducting flight in an appropriate aircraft per the definition of cross-country, is the person acquiring the cross-country credit. A safety pilot can not possibly log 100% of a flight since during visual operations [takeoff, landing, etc.] the safety pilot services are not required. The person that acts as safety pilot is no more than a passenger during the VFR portions of the flight. There is no logic, common sense or regulatory provision for a passenger, even a part time safety pilot, to log cross-country flight time.

My opinion would be no, except that since the FARs say we are PIC, then that might make it yes.

I don't think they say that.

 

[midlifeflyer]

This is one of those weird anomalies in the logging regulations that get some people's dander up.

Notice that the group of cross country definitions in 61.1(b)(3) all begin with "time acquired during a flight" that meets certain requirements. Missing are words and phrases you see in some of the other regulations that indicate "sole manipulation or some specific type of piloting participation.

So we're left with a regulation that defines cross country time as time that is acquired during a flight that meets cross country requirements rather than a regulations that says time that is acquired by, for example, being the manipulator of the controls on a flight, or performing landings during a flight.... or even conducted by the pilot seeking to log the time

If you read him enough, John Lynch, who writes the FAQ, has an unfortunate tendency to get blustery on certain issues that he feels strongly about, and it clouds the clarity of some of his opinions. (That probably started the time he made an incorrect statement on the FAQ about logging, a reader wrote to FAA Legal and Lynch had to issue a correction).

But what it comes down to is that if you have the right to log some kind of time under FAR, and the time occurs during the course of a cross country flight, you may log that time as cross country time.

So, in the safety pilot as PIC situation, for example, the same amount of time that the Safety Pilot may log as PIC (the time during which the flying pilot is under the hood) during a cross country flight, may also be logged as cross country time.

(If you think a safety pilot logging SIC time in a 152 is silly, how about also logging it as cross country?)

BTW, from time to time the question comes up about why the Commercial certificate requires solo cross country flights. It's there to meet ICAO requirements, but I think the general ability to log cross country when not flying is at least part of the reason why the commercial time is specified as "solo".

 

[dmspilot00]

Hey, I was thinking the same thing, but it seemed no one else was.

The FAQ says "The person that acts as safety pilot is no more than a passenger during the VFR portions of the flight. " But the regulation defines cross-country time as "time acquired during a flight...that includes a point of landing..."

Just because the safety pilot is no longer required when the person under the hood takes his foggles off for landing wouldn't mean that the flight just ends for the SP. It is still the same flight.

As far as logging SIC cross-country, the instrument rating specifies 50 hours cross-country PIC time, so obviously the FAA considered that you can log cross-country without being PIC.

If the FAA wanted only the person who performed the t/o and landing to log XC, they should have said so. Notice also the word "only" appears nowhere in the definitions for XC time, which appears a lot under other regulations involving types of time and logging time. It doesn't say you have to make the landing, and it doesn't even say you have to be the one who is using dead reckoning, piotage, etc.

The FAQ is wrong from time to time. I remember one issue that it was clearly dead wrong on, but I forget which one. Maybe it was the one where a reader wrote to them, how long ago did that happen?

 

[midlifeflyer]

The FAQ says "The person that acts as safety pilot is no more than a passenger during the VFR portions of the flight. "
Just because the safety pilot is no longer required when the person under the hood takes his foggles off for landing wouldn't mean that the flight just ends for the SP. It is still the same flight.

Maybe I wasn't that clear, but I agree with the FAQ on this point. The safety pilot/PIC can only log cross country time to the extent that she can log some other piloting time; not more. When the reg says "time acquired" I'm pretty sure that it means "time that's countable for something" not "time sitting around" (althouhg I'd love to log some xc PIC in a 757 next time I take United to the East coast).

Bear in mind that a lot of the complexity of the FAR logging rules is because they are based on FAA =policy= decisions on what time should be counted for certificate and rating purposes. In this case, the policy is to permit a pilot who perfroms an important crew function (safety pilot) to get a logging benefit for the time that she is performing those functions.

So, for example, SP (safety pilot) and FP (flying pilot) go on a 50+ NM cross-country together. The SP is acting as PIC. The total flight takes 2 hours. FP flies visually most of the way, but does 1/2 hour under the hood. So SP may log 1/2 hour PIC. SP may also log 1/2 XC, not more. That's the piloting time that she accrued during the xc flight.

As far as logging SIC cross-country, the instrument rating specifies 50 hours cross-country PIC time, so obviously the FAA considered that you can log cross-country without being PIC. But it would be pretty useless.

Not necessarily. There are a whole bunch of definitions at work here and remember that FAR definitions may not be the same as normal English. For example, among other things Part 135 requires a certain amount of cross country "flight time". Well, FAR1 defines "flight time as "Pilot time that commences when an aircraft moves under its own power for the purpose of flight and ends when the aircraft comes to rest after landing" In turn, 61.1 defines "pilot time" as "that time in which a person...Serves as a required pilot flight crewmember" So, at least theoretically, that .5 SIC cross country time in the 152 can apply to Part 135 requirements. The pilot might even get the job if the interviewer can stop laughing long enough!

The FAQ is wrong from time to time. I remember one issue that it was clearly dead wrong on, but I forget which one. Maybe it was the one where a reader wrote to them, how long ago did that happen?

It was a while back. The issue was whether a pilot without a high performance endorsement could log PIC time in a high performance airplane. Lynch said no, despite over 20 years of consistent FAA legal opinions to the contrary. Someone wrote to FAA legal and FAA legal sent a letter to Lynch, who issued a correction. If I'm not mistaken, it's Q&A-256. It now has only text from the FAA legal opinion. It used to have Lynch's original answer and the correction, but if you read it you can see that the answer is in response to something that was there before.

 

[dmspilot00]

The total flight takes 2 hours. FP flies visually most of the way, but does 1/2 hour under the hood. So SP may log 1/2 hour PIC. SP may also log 1/2 XC, not more. That's the piloting time that she accrued during the xc flight.

I did understand what you were saying. I guess I just went a little overboard, so sorry about that.

When I mentioned the flight not ending when the foggles were taken off, I wasn't trying to say that you could log XC for the entire flight; just that it would be wrong to say you couldn't log ANY XC because you did not perform the landing or act as a crewmember during the landing. Since the regs say "during a flight" and "includes a landing," it's not like just because the safety pilot stops being a crewmember before landing, that the flight ceased or the landing did not happen. That is what I meant.

When I quoted the FAQ as saying "The person that acts as safety pilot is no more than a passenger during the VFR portions of the flight. " I was noting that this is the FAQ's rationalization for the safety pilot not being able to log ANY cross-country time AT ALL...because the safety pilot is a passenger during the landing.

I still don't see anything funny about logging SIC in a 152, unless it was a large amount of time or if it didn't count toward any certificate/rating. But, I wouldn't like make a SIC column in my log book and add it into all the totals from that page on, or include it in LearJet SIC time or something. I would just put it under total time and write in the remarks that it was SIC.

As far as the FAQ being wrong, I think it was something along those lines.