"safety pilot time"?!?!

[CaptO'Brien]

Well i suppose if you just went in your log book and started writting down times that you never flew or were aboard an aircfaft at the time when your logbook got the once over for your ATP you have the risk of being caught for falsifying your times....but if the time is logged in a legit way under the safety pilot scheme (which im assuming is legit considering what people are saying/flight schools using it for licensing purposes) then when your log book gets say spot checked and they check into it you are in the clear.....

Also has anyone gone to Ari ben or a school who does the same type of training/logging methods (ATP??) and gone onto somewhere like cathay?

Thanks for all the responses

 

[AC560]

but if the time is logged in a legit way under the safety pilot scheme (which im assuming is legit considering what people are saying/flight schools using it for licensing purposes) then when your log book gets say spot checked and they check into it you are in the clear

If I log it as PIC and my buddy logs it as PIC unless they slap our two log books next to each other they are never going to know. Not that I am advocating this but if people feel the need to bulk up their log book with grey hours they shouldn't bother with convoluted schemes.

 

[A Squared]

If I log it as PIC and my buddy logs it as PIC unless they slap our two log books next to each other they are never going to know. Not that I am advocating this but if people feel the need to bulk up their log book with grey hours they shouldn't bother with convoluted schemes.

I realize that you're speaking rhetorically, and that you're not actually advocating this, but if you have an accident or an incident, while you both are in the airplane, the FAA may very well slap your logbooks down side by side and compare. I beleive that this is how they caught these guys:


http://www.ntsb.gov/o_n_o/docs/AVIATION/4008.PDF

Notice that the penalty is revoction. Also bear in mind that it can be a pretty benign incident which triggers a logbook review. I personally know of pilots who have been requested to present thier logbooks for review in the case of incdents like a runway departure due to a blown tire, which absolutley no damage to the aircraft or airport facilities, and no appearence of pilot non-proficiency.

 

[CaptO'Brien]

oh man now im more confused....so those guys in that article logged safety pilot time and its illegal? or is it just because they didnt make a note in their logbook stating that for 50% of the time they were acting as safety pilot and just stated that they were PIC the whole time with no mention of the safety pilot.

What part of the FAR's states that it is ok to log safety pilot time? can it be counted as multi PIC and TT or what does it count towards?

I truly only want to log things legally and dont want to be tampering and parker pening my logbook to get myself ahead, however i do want to represent myself as best as possible by logging getting the most out of what measly time i do have...because we all know the person i will be competing with in an interview will have done the same.

This is why i am asking these questions before i partake in using the safety pilot system to get myself extra multi time when i would have to spend the money anyways. If i can get 50 hours multi PIC and have fun doing it for the same cost or less than it would cost me to do the 50 PIC on at C-172 and its all legal why wouldnt i? I just need to know the legallity of it and of course in this industry there will always be conflicting answers.

Am i going to have my license revoked for doing this? is it legal? can i get my ATP if they spot checked this time in my log book?

I guess lots of people are using this method to build their time so i thought i would use it to...but surely i dont want to use it if its going to screw me over.

Thanks again for your helpful responses!
Capt O'B

 

[AC560]

I realize that you're speaking rhetorically, and that you're not actually advocating this, but if you have an accident or an incident, while you both are in the airplane

I think the key point is there are no short cuts in life and if you try to take one the consequences can be severe. There are lots of opprtunities for people to build legitimate time as opposed to looking for the loop holes. I always like your posts A Squared, you always sum up the point well.

PS My log book and flight bag got stolen out of my car the day before that accident, I can only give the FAA my total time. Again if you feel the need to cheat, don't be stupid (though generally I guess stupid people are the ones who feel the need to cheat the most).

 

[sqwkvfr]

What's it to be? Hours or experience?

I know what Skywest is gonna say if apply with my 38 hours of multi time.

 

[A Squared]

oh man now im more confused....so those guys in that article logged safety pilot time and its illegal? or is it just because they didnt make a note in their logbook stating that for 50% of the time they were acting as safety pilot and just stated that they were PIC the whole time with no mention of the safety pilot.

Well, not exactly. They weren't using the "safety pilot" excuse. They were "giving each other flight instruction". It's just a variation of the same theme. It's a justfication for both guys taking credit for the same flight time. This is not illegal in itself, but they did not log it as dual given and dual received, they just each logged the same time as "PIC". This is the basis of the falsification charge. Presumably, if you were playing the safety pilot game, and you didn't log it as such, you both just logged it as PIC with no explanation, you could be the subject of the same falsification charges.

Is it legal to log Safety pilot as PIC time? yes it is, according to a 1992 interpretation from the FAA's Chief Counsel. The opinion letter is posted below. In order to do that the safety pilot must be designated the actual PIC of the flight. Personally, it appears to me that this interpretation violates both the letter and the spirit of the regulations. If you read 61.51(e)1 and 2 together it appears that a plain english reading of the words would prohibit anyone who is not an ATP holder, in an operation requiring an ATP (121 captain, etc), from logging PIC time when they are not actually manipulating the controls.

But, how I read the regulation is of course, irrelevant. The Chief Counsel has issued an interpretation, and you are persumably safe following it's guidance.

So if it's legal, wht's the problem?

OK. let's be honest about what is going on, It's a loophole, an aparently legal loophole, to justify logging pilot time when you were not piloting an airplane. You were sitting there, watching for traffic, yet it's entered in your logbook as if you were flying the airplne, and you present it as an indication of your piloting experience, which it is not. Sure, there are things to be learned from being a safety pilot, if you approach it with that mindset, just like there are things to be learned by working on the ramp, and things to be learned by helping a mechanic work on airplanes and things to be learned by sitting in a non-crew seat and observing an experienced pilot or crew operate. None of these things are actually piloting though, yet many would present the "safety pilot" time as time that they piloted an airplane as PIC, because there's a loophole which allows that.

Maybe a different way of explaining it is to look at the "giving dual" dodge.

Let's say that you're a multi-eingine instructor. You give 50 hours of no-$hit multi engine instruction. You're taking students who have never flown a multi engine airplane and you're teaching them to do that, correcting thier mistakes, preventing them from losing control of the airplane, walking them through drag demos, demonstrating manuvers, helping them refine thier technique toward a checkride.

Is that 50 hours legit PIC time? Absolutely, and by most measures, valuable experience.

Now, change the scenario. You and a MEI buddy buy 100 hours of block time in a twin, and you fly off that time, back and forth, over and over. First You "instruct" him for an hour, then he "instructs" you for an hour, then you "instruct" him for an hour, then he "instructs" you for an hour ... back and forth , on and on. At the end of the 100 hours, you have 50 hours that you did fly the airplane, but your logbook shows 100 hours of PIC time. That other 50 hours, when he was flying, is that really legitimate flight time? well.... no, it's not. Let's be honest, you were really not giving each other instruction, you were using "instruction" as an excuse to take credit for time you didn't fly.

So to take that back to the safety pilot issue: Is the your "safety pilot" time more like the first case, or legitimate instruction, or is it like the second case, a loophole to log more time than you'd be otherwise entitiled to log? I'd say that in most cases, it's just a rationalization for logging time that you wouldn't be otherwise entitiled to log.

As a personal; preference, I would prefer my PIC time in my logbook to match the time I actually was Pilot in Command.

You don't end up with that by "splitting" time via the "safety pilot" dodge or "giving each other dual" dodge. In those cases you end up with "time when I wasn't actually piloting, but I can't be prosecuted for claiming it"



The Chief Counsel Interpretation:

October 30, 1992


Mr. David M. Reid


Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the logging of pilot in command (PIC) time under the Federal Aviation Regulations (FAR).

In your letter you ask four questions. First, you ask whether there are "any circumstances when, during a normal flight, two Private Pilots may simultaneously act as (and therefore log the time as) Pilot In Command?" The answer is two private pilots may not simultaneously act as PIC but they may, under certain circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC time. PIC, as defined in FAR 1.1, means the pilot responsible for the operation and safety of an aircraft during flight time. FAR 61.51 deals with logging PIC flight time, and it provides that a private or commercial pilot may log as PIC time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR 61.51 only regulates the recording of PIC time used to meet the requirements toward a higher certificate, higher rating, or for recent flight experience.

Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51. Enclosed please find two prior FAA interpretations concerning logging of PIC time. We hope that these will be of further assistance to you.

In your second question you ask "how shall two Private Pilots log their flight time when one pilot is under the hood for simulated instrument time and the other pilot acts as safety pilot?" The answer is the pilot who is under the hood may log PIC time for that flight time in which he is the sole manipulator of the controls of the aircraft, provided he is rated for that aircraft. The appropriately rated safety pilot may concurrently log as second in command (SIC) that time during which he is acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i). Enclosed please find a prior FAA interpretation concerning the logging of flight time under simulated instrument flight conditions. We hope that this interpretation will be of further assistance to you.

In your third question you ask "during instrument training, how shall a VFR Private Pilot log the following flight time: Pilot In Command time, Simulated Instrument time, and Actual Instrument time, when that pilot is... A)...under the hood? B)...in actual instrument conditions? C)...under the hood in actual instrument conditions?" The answer is the VFR private pilot may log all of the flight time you described as PIC flight time under FAR 61.51(c)(2)(i) if he was the sole manipulator of the controls of an aircraft for which he is rated. Under FAR 61.51(c)(4) the pilot may log as instrument flight time only that time during which he operates the aircraft solely by reference to instruments, under actual or simulated instrument flight conditions. Please note that the FARs do not distinguish between "actual" and "simulated" instrument flight time. Enclosed is a prior FAA interpretation concerning the logging of instrument flight time. We hope this interpretation will further assist you.

Finally you ask "does FAR 61.57 affect how the VFR Private Pilot shall log Pilot In Command time during instrument training, either before or after meeting the 6/6/6 requirement, and if so, how?" FAR 61.57 does not affect how a pilot logs PIC time during instrument training; FAR 61.51(c)(2) and (4) govern logging of instrument flight time. FAR 61.57(e) provides currency requirements for acting as PIC under instrument flight rules (IFR) or in weather conditions less than the minimums for visual flight rules (VFR). Enclosed please find a prior FAA interpretation on instrument flight time and FAR 61.57(e). We hope this interpretation will further assist you.

We hope this satisfactorily answers your questions.

Sincerely,


Donald P. Byrne
Assistant Chief Counsel
Regulations Division

 

[CaptO'Brien]

Ok thanks A SQ that is making more sense...I figured that it was a loophole in the system..now i need to decide between doing my conversions for cheaper and logging 50 hours multi by using the loophole or doing them for more expensive, not getting much multi, but then at least my logbook reflects everybit of PIC time i have actually been true PIC...the decisions...

i kinda wish this loophole didnt even exsist because then i wouldnt have to compete against people who have just bought 200 hours of multi by sitting right seat of a light twin...and the regionals would have to lower their multi requirements because not enough people would meet the multi requirements to fill their seats.

Guess i gotta figure these things out before i make my decision...Thanks for your help guys/girls

Cpt O'B

 

[PDH]

A couple of more things to consider--when logging safety pilot time, be certain that the pilot flying the aircraft is wearing a view limiting device.

Secondly, taxiing, takeoff, and anytime below DH does not require a safety pilot.

Thirdly, any time spent in the clouds or less than VFR mins does not require a safety pilot as you are already on an Instrument Flight Plan. The safety pilot and pilot manipulating the controls will not log the same PIC time for each flight.

 

[Amish RakeFight]

Sadly, many a pilot has advanced their career this way.