The Answer
If it is legal for you to log it you can if you would like.
Source:
FREQUENTLY ASKED QUESTIONS
14 CFR, PART 61
ARRANGED BY SECTION
MAINTAINED BY ALLAN PINKSTON
PILOT EXAMINER STANDARDIZATION TEAM, AFS-640
Contact: Allan Pinkston phone: (405) 954 - 6472
E-Mail:
[email protected]
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."
{Q&A-88}
Source AOPA:
http://www.aopa.org/members/files/topics/sftyplt.html
If you are a member.
Logging Time: Safety Pilot
A safety pilot is required by FAR 91.109(b) when the other pilot is "under the hood". The safety pilot:
* must be at least a private pilot. 91.109(b)(1)
* must be rated for the category and class (airplane, single-engine land) of the aircraft flown. 91.109(b)(1)
* must have a current medical. as a required flight crewmember, the safety pilot must have a current medical certificate. 61.3(c)
* must occupy the other control seat (normally the right or "co-pilot's" seat). FAR 91.109(b)(1)
Logging flight time
* Pilot "under-the-hood"
o may log pilot-in-command time while sole manipulator of the controls. FAR 61.51(e)(1)(i).
* Safety Pilot.
o Pilot-in-command time may be logged if acting as PIC.
+ The two pilots must agree that the safety pilot is the acting PIC.
+ PIC time may be logged only while the other pilot is "under-the-hood".
+ PIC time may be logged because FAR 61.51(e)(1)(iii) allows certificated pilots to log PIC when acting as PIC of an aircraft on which more than one pilot is required by the regulations (91.109(b)) under which the flight is conducted. A safety pilot is required for "hood work."
o Second-in-command time may be logged if not acting as PIC.
+ Usually the case if the safety pilot cannot act as PIC. An example might be when the safety pilot is not endorsed for the particular airplane (such as in a high-performance aircraft).
+ SIC time may be logged because FAR 61.51(f)(2) allows a pilot to log all flight time during which he acts as second-in-command of an aircraft under which more than one pilot is required by the regulations (91.109(b)) under which the flight is conducted.
Other considerations
* Summary of logging PIC. Both pilots may log PIC time if the safety pilot is the acting pilot-in-command. FAR 61.51(e) allows both the sole manipulator of the controls and the acting PIC to log PIC time.
* Acting as PIC. The safety pilot should not take the role as acting PIC lightly. What if the aircraft is involved in an accident, incident, or violates an FAR?
* High-performance aircraft. AOPA has a letter of interpretation that states the safety pilot does not have to have a high-performance "sign-off" to act as safety pilot. However, some FAA divisions may interpret the regulations differently. Prudence suggests that the safety pilot be endorsed for high-performance aircraft and thoroughly familiar and current in the aircraft.
* Recording flight. AOPA suggests that both pilots include in their logbook the name of the other pilot. This may assist you if the FAA ever questions the logged time.
A single-yoke aircraft may not be used unless:
* the single-engine airplane is equipped with a single throwover control wheel,
* the safety pilot determines the flight can be conducted safely, FAR 91.109(b)(3)(i)
* the person manipulating the controls is at least a private pilot rated for the category and class of the aircraft being flown. FAR 91.109(b)(3)(ii)
