Logging Safety Pilot Time?

[pgcfii2002]

Is it permissable as PIC...since under the FAR's the Safety Pilot is a required crewmember?

 

[avbug]

This subject gets covered a lot. A little effort with the search engine should net you more than you wanted to know.

 

[midlifeflyer]

Try this (it's mine but what the heck):

"May a Safety Pilot Log PIC Time?"
http://www.midlifeflight.com/faq/faq.php?s=2#8

 

[pgcfii2002]

Thanks

 

[flyboyike]

The problem with all these "kinda PIC but not really" situations is that, regardless of what the FAA considers PIC, what matters is what an airline will accept as such. I'm not aware of a carrier that would let you count safety pilot time. It seems to me most of them will count PIC only if:

1. You signed for the airplane.
2. You gave instruction in the airplane.
3. You received instruction in the airplane.

I would add that I don't see how it would make much difference. In my nearly 1300 hours, I probably have all of 8-11 hrs as safety pilot. Hardly worth worrying about, IMHO.

 

[AC560]

I'm not aware of a carrier that would let you count safety pilot time.

I know two guys flying for Skywest who did 90% of their multi-time this way.

When they rewrite part 61 I hope they change PIC under it to something more clear. It is highly retarded right now imho (for a lot of reasons not just the safety pilot, sole manipulator, etc. stuff).

 

[727gm]

Logging time as a Safety Pilot IS lame.

The regulation requiring a safety pilot is not written for the benefit of shameless time-builders, but to encourage practice and proficiency by those flying under the hood.

Just sit there and keep your head on a swivel, and appreciate good work that CFII's have done in making instrument pilots. And when you need some practice, maybe the other fellow will act as safety pilot for you.

 

[midlifeflyer]

When they rewrite part 61 I hope they change PIC under it to something more clear.

It =is= clear. Been clear for a lot of years. Wasn't changed when they revised Part 61 10 years ago and there's nothing that changes it in the current proposed revision.

You just don't like it. That's a different issue.

 

[Amish RakeFight]

I wanna be a safety pilot when I grow up!

....Bestest job in the whole world Mommy!

 

[nosehair]

I wanna be a safety pilot when I grow up!

....Bestest job in the whole world Mommy!

Nothin' to it, Sonny ! Just get your CFI.

 

[AC560]

It =is= clear. Been clear for a lot of years.

No it isn't because if it was the #1 topic on these and other forums wouldn't be can I log PIC as a regional F/O, can I log PIC as a safety pilot, or can I log PIC as sole manipulator; my buddy logs PIC as a safety pilot; the 2 instructors in the back seat each log PIC for giving us each dual; and because it was a moonless night we all logged it as actual.

This weekend take a poll at your airport ask some random questions on what is legal and isn't legal to log. Then get back to me on whether the regulations are clearly written or not, being able to understand something (which most people don't anyways) does not make it clear.

there's nothing that changes it in the current proposed revision.

The definition of cross country would be one thing listed in the proposed changes which would effect logging. They also want to broaden 61.59 to include an "incorrect" entry in a logbook as opposed to a "fraudulent" entry as a basis for suspension or revocation of a certificate. Along with a slew of other things most of which will make it worse rather then better.

AOPA specifically wrote in their comments on the proposed rule changes.

"AOPA Members continue to have questions on appropriately logging PIC time. AOPA suggests that a matrix be added to Part 61.51(e), Logging pilot-in-command flight time, outlining the conditions under which a pilot may log PIC time, including time spent acting as a safety pilot."

You just don't like it.

I don't like it either. We should not have two distinctly different definitions for PIC which we currently do in the FAR's. There should be a clear definition of when you can log actual IFR, when you can log PIC, etc. Because while I can read the legal opinions (and the fact several people have had to write for rulings further indicates the lack of clarity) and I have a good grasp of what is and what isn't allowable it took a lot of time and effort to get there that could have been expended better doing something else.

 

[avbug]

No it isn't because if it was the #1 topic on these and other forums wouldn't be can I log PIC as a regional F/O, can I log PIC as a safety pilot, or can I log PIC as sole manipulator; my buddy logs PIC as a safety pilot; the 2 instructors in the back seat each log PIC for giving us each dual; and because it was a moonless night we all logged it as actual.

This weekend take a poll at your airport ask some random questions on what is legal and isn't legal to log. Then get back to me on whether the regulations are clearly written or not, being able to understand something (which most people don't anyways) does not make it clear.

What you have here is not ambiguous regulation, but lazy pilots who expect to learn by osmosis. The regulation is quite clear on the topic.

Can you log PIC as a regional F/O? Yes, if you're rated in the aircraft...but the question arises as to weather you should. The issue of legality should be something you were taught as a student pilot. If you still don't know it, that's your fault. It's spelled out in the regulation.

Can you log PIC as a safety pilot? The answer is very clear, but again, lazy pilot syndrome means that many won't lift a finger to get educated, and then complain about it being too hard to understand. Again, refer back to my comments above; use the search engine here. Read the regulation. It's not a grey area at all.

Can you log PIC as sole manipulator? Clearly yes, if you're rated in the aircraft...and it's spelled out VERY clearly in the regulation...something every student pilot should have been taught. If you don't understand it, you need to be re-educated on the basics.

Your buddy logs PIC as safety pilot...but is he the PIC? If not, he can't log it as PIC. The instructors in the back seat are idiots. As are those in the front for going along with it. You log instrument...it matters not a whit if you are in simulated or actual conditions. How many pilots does it take for you four to screw in a lightbulb, anyway? Sounds like a poor joke in progress.

Take a poll at the local airport? Question lazy pilots about their understanding of the regulation they haven't taken the time to learn, and thus make a truly scientific determination as to how well the regulation is written, or any degree of ambiguity therein? Why not just flip a coin? The test will be just as intelligent. Truth is that when pilots profess to ignorance of the regulation, they're professing to ignorance. You can stop right there, because that's the heart of the problem. Not the regulation.

We should not have two distinctly different definitions for PIC which we currently do in the FAR's.

There has only ever been one definition of pilot in command in the regulation. Logging flight time for the purposes of meeting the recency of flight experience requirements, or experience requirements for a certificate or rating is another matter. Logging time doesn't make one the PIC; the definition of PIC hasn't changed, nor has the responsibility thereof.

The FAA purposely applied the regulation regarding logging of PIC as it did, following considerable public comment, for good reason. Circumstances exist under which one may not be the PIC in an airplane, but may be fulfilling the role and is therefore justified in logging the time. Such an example is one who is rated in the airplane (category and class), but needs a minimum experience in the airplane to qualify for insurance purposes. The individual may not be allowed by the operator to act as PIC, but may still log PIC by fulfilling all the appropriate duties and conducting all the appropriate actions under the supervision or tutelage of a qualified pilot who is acting as PIC...and therefore log enough time legitimately to qualify for insurance, for a job, for a certificate or rating, to instruct in the aircraft, etc. The regulation thus written has eased the economic burden on the general aviation pilot while recognizing that even though the pilot may not be the actual PIC for the flight, he or she may have taken all the steps, made all the decisions, conducted the flight, operated the aircraft, etc...and therefore has good reason and justification for logging the time as PIC. Bottom line,the regulation makes sense, and it's to your benifit.

There should be a clear definition of when you can log actual IFR, when you can log PIC, etc.

The regulations are quite clear on those topics.

Because while I can read the legal opinions (and the fact several people have had to write for rulings further indicates the lack of clarity) and I have a good grasp of what is and what isn't allowable it took a lot of time and effort to get there that could have been expended better doing something else.

If you're flying for a living, learning and knowing the regulation is part of your job. Don't want to do it? Go find different work. The regulation set forth by the FAA is among the shortest regulation in the Code of Federal Regulations. Ever look at the tax law?

The regulation was intentionally designed to be a living document, subject to change, to expansion, and to adapt to changing requirements in the real world. Legal opinions show the way the regulation is applied by the Administrator, and are of value, as are specific ALJ rulings (case law), and Federal Register preambles...all of which are applicable, defensible, and relevant to understanding the regulation.

Remember that ignorance of the law is never an excuse.

 

[midlifeflyer]

No it isn't because if it was the #1 topic on these and other forums wouldn't be can I log PIC as a regional F/O, can I log PIC as a safety pilot, or can I log PIC as sole manipulator; my buddy logs PIC as a safety pilot; the 2 instructors in the back seat each log PIC for giving us each dual; and because it was a moonless night we all logged it as actual.

"I don't understand" or "I don't have the knowledge" is not the definition of unclear. All of those questions you just mentioned, from an FAR standpoint, have had unvarying official answers for decades.

 

[midlifeflyer]

Take a poll at the local airport? Question lazy pilots about their understanding of the regulation they haven't taken the time to learn, and thus make a truly scientific determination as to how well the regulation is written, or any degree of ambiguity therein? Why not just flip a coin? The test will be just as intelligent. Truth is that when pilots profess to ignorance of the regulation, they're professing to ignorance. You can stop right there, because that's the heart of the problem. Not the regulation.

Heck, take a poll of pilots walking up to a Cutlass to explain the workings of the constant speed prop or the landing gear and you might find that those systems are "unclear" by the definition of some folks here.

But I don't fault anyone for confusion on the regs. The FAA did, after all, end up taking a phrase "pilot in command" and using it in two different ways - as meaning the person who is the pilot in charge of the flight ("real" or "acting" PIC) and as a shorthand for various pilot functions that permit the accumulation of a certain category of time that the FAA uses to determine qualifications for certificates, ratings, and currency ("paper" or "logged" PIC time).

Unfortunately (except for online forums that have in recent years broadened the knowledge base), most student pilots are not exposed to the difference between real and paper PIC. That's mostly because their CFIs weren't exposed to it either.

 

[AC560]

"I don't understand" is not the definition of unclear.

Unclear
c.1300, "not easy to understand," from un- (1) "not" + clear (adj.). Cf. M.Du. onclaer, Du. onklaar, Ger. unklar, O.N. uklarr, Dan. uklar, Swed. oklar. Of persons, in sense of "uncertain, doubtful," it is recorded from 1671. Uncleared is recorded from 1637 in ref. to debts, 1772 in ref. to land.

Heck, take a poll of pilots walking up to a Cutlass to explain the workings of the constant speed prop or the landing gear and you might find that those systems are "unclear" by the definition of some folks here.

Hand those pilots an operating manual for a Cutlass, then ask them the question on the workings of the constant speed prop or landing gear after they have read it. I would suspect that the vast majority would be quickly able to provide the correct answer.

Take a copy of part 61 and ask what is the maximum amount of people who can log PIC on a flight. I suspect that the vast majority would not be able to provide the correct answer.

This isn't entirely a matter of ignorance it is a matter of poorly written regulations (imho) which make it difficult for both students, pilots, and instructors to understand. Though clearly it is a matter where I will have to part ways with you and Avbug. I hope you took the time to send your thoughts to the FAA prior to the May 8th deadline.

 

[midlifeflyer]

Take a copy of part 61 and ask what is the maximum amount of people who can log PIC on a flight. I suspect that the vast majority would not be able to provide the correct answer.

I'll have to disagree with you. A lot of folks will not be able to read that book and understand the workings of that Cutlass. I still haven't a clue how to read a wiring diagram without getting a headache. Ever see a student pilot try to use those performance charts or an E6B without instruction? Or figure out that "maneuvering speed" is not the speed at which it's easy to maneuver or that "controllability" does not mean how easy it is to keep the aircraft under control?

But sit me down with someone who understands those diagrams and can teach, and the chances are they would become clear, even to me. (I'll admit to the laziness that AvBug describes.)

Same with With the logging rules, sit down with a classroom with the same people and review the official FAA interpretations of the same stuff, and you'll have people who understand (assuming, of course, that they want to). My experience is that the body or rules and regulations that govern a regulated activity are not the easiest to understand. Like that wiring diagram, regulese is not normal English. To some extent the stilted language with the sub-paragraphs and reliance on references and definitions and concepts that may appear elsewhere takes a bit of effort.

But really, once you understand that the word "only" has been consistently interpreted as both a necessary and a sufficient condition, how unclear is

==============================
A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges
==============================

The misunderstanding of this pretty simple sentence seem to be a bunch of "buts," "unlesses," "excepts" and other concepts that people keep reading into it, not the language of the regulation itself. I guess "clarity" is in the eye of the beholder.

BTW, although I agree with AvBug that there is some history to the reasons it was done this way (which, based on an email I received this week, may go back to at least 1929!), I won't argue with your desire to change it. If you want to force a private pilot heading to an instrument rating to fly 50 hours of cross country as a real PIC and not be able to count instructional cross countries he flies with his II, go for it. Or, if you want to stop a pilot from using time that she has acted as a safety pilot to help meet the technical Part 61 requirements for getting a commercial certificate or the technical Part 135 time requirements if she lucks out and gets a chance to fly for a small cargo operator, by all means petition the FAA to change things.

 

[nosehair]

All of those questions you just mentioned, from an FAR standpoint, have had unvarying official answers for decades.

Another way of saying that is, "Tha FAA has been trying to write clarifying official answers for all these years, ...and still, regular people have much difficulty understanding and applying the regulation about logging PIC."

You guys who answer that this 61.51 is clear have been living in a vacuum too long.

Yeah, it's crystal clear to you.

But it's very obvious that it is not clear to most people. The test to make that determination is the actual understandability of the language in the working field.

It took me a lot of back-and-forth with this issue; First, the reading of the words P-I-C within a regulation would seem to be addressing the PIC, so all the words in the regulation would seem, to the uninitiated mind, to apply to a pilot who is in command.

In other words, "Here is what must be happening for you, the PIC, to log it as PIC..(i)(ii)(iii)"

Next is the mis-understanding of the term "rated".

In most of the cases, when you think of a pilot being "rated", it means he is "rated" (fully authorized) to act as PIC.

The definition of "Rating" in FAR 1.1 is: "Rating means a statement that, as a part of a certificate, sets forth special conditions, priveleges, or limitations."

The camp that wants to log PIC for every minute they are on the controls of an airplane they are not capable of being the PIC of, wants to interpret this to say rating means what's stamped on your certificate.

The camp that believes that PIC hours should reflect exactly that; PIC time as defined in 1.1 interprets "rated" to mean complying with all regulations concerning priveleges and limitations of the pilot certificate which are set forth in regulations, such as complex, high performance, etc. In other words, the pilot who logs PIC should be performing the duties of PIC under supervision of an instructor, and that instructor is attesting that this pilot is performing at PIC level during the flight.

See the lack of clarity?

 

[AC560]

==============================
A sport, recreational, private, or commercial pilot may log pilot-in-command time only for that flight time during which that person is the sole manipulator of the controls of an aircraft for which the pilot is rated or has privileges
==============================

The misunderstanding of this pretty simple sentence seem to be a bunch of "buts," "unlesses," "excepts" and other concepts that people keep reading into it, not the language of the regulation itself. I guess "clarity" is in the eye of the beholder.

So if I am an ATP I can no longer log PIC flying a C172 under part 91?

(2) An airline transport pilot may log as pilot-in-command time all
of the flight time while acting as pilot-in-command of an operation
requiring an airline transport pilot certificate.

 

[Doc Holiday]

61.167 (a)

A person who holds an airline transport pilot certificate is entitled to the same privileges as those afforded a person who holds a commercial pilot certificate with an instrument rating.

 

[SSDD]

The problem with the FAR's is not so much that they are unclear, but rather that people are always trying to find ways to get around them.

 

[avbug]

Next is the mis-understanding of the term "rated".

Misunderstanding only by those who won't lift a finger to help themselves. Rated clearly means category and class, and where appropriate, a type rating.

An endorsement is not, and has never been, a rating. An endorsement is not necessary to be "rated" in the airplane, helicopter, etc. Category, class, and where appropriate, type, as spelled out in the regulation.

SSDD hit the nail on the head. People hear what they want to hear, and get upset when they don't hear enough of what they want to hear, or hear it in the way they want to hear it.

What we have are lazy pilots who won't lift a finger to educate themselves. Ignorance is no excuse.

But it's very obvious that it is not clear to most people. The test to make that determination is the actual understandability of the language in the working field.

Only when that test is applied agains those who have made an effort to understand. Most are too lazy to do so, and therefore invalidate understanding of the regulation in the field as a legitimate test of it's clarity.

So if I am an ATP I can no longer log PIC flying a C172 under part 91?

There is nothing written in the regulation that might suggest such a thing. You read into it what you want to read into it, hear what you want to hear, and thus fail to understand what is written in plain English.

Often understanding the regulation means understanding more than one sentence at a time. That's your problem in this case.

I would suspect that the vast majority would be quickly able to provide the correct answer.

This is a discussion of facts and points of law. Not what you would "guess."

"I don't understand" or "I don't have the knowledge" is not the definition of unclear.

Well put.

 

[A Squared]

and you'll have people who understand (assuming, of course, that they want to).

The problem with the FAR's is not so much that they are unclear, but rather that people are always trying to find ways to get around them.

BINGO!!!!!!

There's a huge part of the problem. Example: Logging SIC time in a single pilot aircraft. It's really clear. The SIC has to be required by the regulations Ther's nothing vauge or ambiguous about that. Yet there are leigons of young pilots who insist that it's legal to log SIC in a single pilot aircraft if the insurance policy requires it.

The problem here is not that the regulation is unclear. Every native english speaker with an IQ higher than thier inseam measurment knows that an insurance policy isn't a regulation. It's difficult to get more clear than that. But they *want* it to mean something different, desperatly, so badly that they can taste it. I mean they really, really, really want the reg to mean somethign different, so thay halucinate (can't think of a better word) that it is somehow "unclear" what is meant by "regulation", and imagine that it could include "insurance policy".

This is an example of a really clear regulation that is very frequently "misunderstood" because it conflicts with someone's desired reality.

Now you take a reg that requries a little more effort, say you have to look at a specific definition on another page, or you have to read two different regulations together to get the full meaning, and add to that the overwhelming desire for the regulation to mean what you wnat it to mean, not what it actually means, and the "misunderstanding" gets that much easier.

 

[AC560]

This is a discussion of facts and points of law. Not what you would "guess."

No it is a discussion whether the facts and laws are written clearly. My opinion and that of one of the largest pilot organizations is they are not. You happen to disagree and feel that it is an issue of laziness and stupidity. Certainly ignorance of the law isn't an excuse but the law should make an effort to simple in both its meaning and description.

 

[flyboyike]

I know two guys flying for Skywest who did 90% of their multi-time this way.

Did they actually tell Skywest that's how the logged it or did they just call it PIC and Skywest didn't bother to check?

 

[Amish RakeFight]

Did they actually tell Skywest that's how the logged it or did they just call it PIC and Skywest didn't bother to check?

The pilots who log PIC as safety pilot are complying with the part 91 law. Although the person logging hood time can log PIC, they also have to list the safety pilots name as required by the regs. Clearly it is obvious as to how one gained their ME time in this fashion. Not true the other way around. The safety pilot logging PIC need not make a record of who the pilot was to satisfy FAA requirements. Therefore if they log PIC in said ME as safety pilot, then it technically need not go further. If Skywest requires clraification as to how the ME time was obtained, then they have a right to if they use this information in their hiring decisions. Other than that, there is no reason for the applicant to disclose how they obtained XX amount of ME time as PIC other than the standard entries such as day, A/C type, duration, etc. The FAA affords this condition of PIC logging by the safety pilot. As a reminder as well, this is a choice made between the two pilots. The safety pilot may also elect to log this time as SIC.

 

[flyboyike]

The pilots who log PIC as safety pilot are complying with the part 91 law.

I'm not denying that.

there is no reason for the applicant to disclose how they obtained XX amount of ME time as PIC other than the standard entries such as day, A/C type, duration, etc. The FAA affords this condition of PIC logging by the safety pilot.

True enough, but do you suppose Skywest would have accepted that time as PIC, had those applicants disclosed it was safety pilot stuff?

 

[AC560]

True enough, but do you suppose Skywest would have accepted that time as PIC, had those applicants disclosed it was safety pilot stuff?

Was written in their log books that way, it is legal PIC whether Skywest looked at their books or not I have no idea. The time was legally logged though which is more then most do (lot of pencil whipping going on out there).

 

[Amish RakeFight]

True enough, but do you suppose Skywest would have accepted that time as PIC, had those applicants disclosed it was safety pilot stuff?

Depends on how desperate they are for pilots. Right now most are struggling to fill classes as is well known.

Although I've never been invited to participate in the hiring process, I'm confident in stating that they have some inkling of just where the multiengine minimums they are seeing come from. Many of the aspiring regional pilots (who are almost invariably low time pilots w/o 121) find it quite difficult to come by ME time easily and thus have to acquire it any way they can.

What's more important is how this safety pilot PIC time was spent. Many here have quickly discounted the role of the safety pilot, yet as having been a practicing CFII and safety pilot prior, I know for a fact that one can gain a good amount of knowledge and experience by simply sitting there and doing the job they are required to do.

 

[midlifeflyer]

Depends on how desperate they are for pilots.

It also depends on what they tell you in the information accompanying the application. I have seen more than one discussion referring to applications with instructions to include only certain types of PIC time.