Logging Safety Pilot Time?

[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.