Splitting Multi PIC time? legit or not?

[Ralph]

Again, the FAA cleary shows it a-ok to do this, and like I said before and as we saw with the example above, some moron did take it a bit too far, but I would be shocked if anyone ever made a stink over a few safety pilot PIC hours. And like I said before, unless you crash or show up to an ATP checkride as a 300 hour pilot with 1300 hours of safety pilot time its not likely anyone will every know or care.

For the FAA’s take which is of course NOT a rule and as such is an interpretation that can change. See the page below;

http://afs600.faa.gov/srchFolder.asp?Category=640OtherFAQ&lev2=DPE

which has a link that reads…

FAQ 14 CFR Part 61 [Adobe Acrobat]
Subject: Part 61 Frequently Asked Questions with change #18 dated 12/05/2002. This is the FAA Flight Standards Service 14 CFR Part 6...
Modified: 12/12/2002 11:23:36 PM [5377k]
http://av-info.faa.gov/data/640otherfaq/pt61-18.pdf

See page 64 of the PDF file which reads in part as follows:

“QUESTION: I have two instrument students who wish to build time to credit for the 50 hours of cross-country PIC time required for the instrument and commercial certificates. They intend to fly cross-country flights together, trading off legs with one flying as safety pilot and the other manipulating the controls while under the hood. I've counseled them that the safety pilot may log the time as PIC only for the duration the manipulating pilot was under the hood and can not count the flight as cross-country towards the instrument and commercial rating requirements. Is it acceptable for the safety pilot PIC time to count towards these specific cross-country requirements?

ANSWER: Ref. § § 61.1(b)(3)(ii), §61.51(e)(1)(iii); NO. Your advice is good. 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. {Q&A-536} “

You can also see page 89 which reads as follows.

“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 crewmember. 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}

If you would like to see AOPA's take on the matter go to http://www.aopa.org/members/files/topics/sftyplt.html

It reads in part as follows.

Pilot "under-the-hood"

may log pilot-in-command time while sole manipulator of the controls. FAR 61.51(e)(1)(i).

Safety Pilot.

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."

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.

 

[labbats]

Wow, great answers.

I'm still pretty fresh on this board (see join date), so was unaware I was asking dated questions. Apologies.

Getting the plane will not be the issue. We are both employed by a company whose multi plane we achieved our multi-instrument ticket in, so we can check it out to ourselves at our convinience. The issue lies in the ramifications of splitting the time. Herein lies the problem, and a split in the responses. Both the other CFI and myself have about 20 hours multi time in this specific airplane, however, none of which is PIC. We want to cost effectively achieve 15 hours PIC time in a familiar aircraft to qualify for an MEI ticket. It seems this is legal, but from a couple responses, it may come back to bite me with our current career path minefielded with insurance minimums and qualifications that pick apart my logbook. We both are very honest with our logbooks, and would only log safety pilot time when foggles are on, but this seems a moot point to those in charge (insurance adjustors).

I just find it frustrating that my career is balanced upon multi-PIC time, yet it costs more than anyone can handle to pay out for 100-200 hours alone. So you go the MEI route, but you pay your dues, which come in monetary form too.

 

[midlifeflyer]

Both the other CFI and myself have about 20 hours multi time in this specific airplane, however, none of which is PIC.

Here's part of the issue. Sometimes the issue is FAA-legal and other times it's what an employer or insurer wants.

For the moment, let's leave aside what an employer or insurer may want. That is going to vary. So we'll stick with what is clearly legal under the FAR. Let's also assume for the moment that this airplane does not require a type-rating. (If it does, it might change the picture)

First of all, are you saying that all of these 20 hours is time that you accumulated before you received the multi-rating on your pilot certificate? The reason I ask is that, from an FAR perspective, PIC time may be =logged= whenever you are the only person flying an airplane that you are rated for. If any of these hours were accumulated =after= you received your multi-engine rating, those hours properly belong in the PIC column of your logbook.

We want to cost effectively achieve 15 hours PIC time in a familiar aircraft to qualify for an MEI ticket. It seems this is legal, but from a couple responses, it may come back to bite me

If the purpose is to log the required number of PIC hours to qualify you under the FAR for the MEI, then you are absolutely entitled to use the FAR definition of loggable PIC time.

The use of safety pilot time as PIC time is not a loophole. It's not stretching the FAR. It's not sneaking around behind someone's back. It represents an FAA policy decision about what it will allow pilots to count toward certificate, rating, and currency requirements.

BTW, I'm not sure that this has been specifically said, but I am also assuming that you are using "safety pilot" in the sense of either acting as a safety pilot when the pilot flying the airplane is under the hood. If you're using the phrase "safety pilot" in some other sense, then none of the following applies.

Here's the simplest scenario:
1. You are both rated in the aircraft.
2. You are both current for the purpose of acting as PIC with passengers on board.
3. You both agree that whoever is acting as safety pilot is also acting as PIC during that portion of the flight when the flying pilot is under the hood.

The Flying Pilot (FP) may log as PIC all of the time that the FP is the only one flying the airplane.

The Safety Pilot (SP) may log as PIC all of the time, and =only= the time, that the FP is under the hood.

That's it. Period. perfectly legitimate.

Employers understand that pilots build time by utilizing the FAR definition of PIC time in order to meet minimum FAA requirements for something. The problem arises when the employer tries to ascertain the =quality= of that PIC time and the applicant tries to make the sows ear of being a lookout in a Cessna 152 into the silk purse of significant PIC experience.

 

[bobbysamd]

Splitting time - valuable or not?

I agree with JimNTexas; the case is interesting, but is distinguished from the original poster's proposition. Among other things, the two pilots in the revocation case had falsified logbooks, which, in and of itself, is wrong. Also, they mirrored something like 200 flights between them.

From a legal standpoint, as pointed out above, as long as there are agreements about who would be PIC and who is safety pilot, there should be no problems. However, I feel that the long and short of it is how potential employers would view the time. As Midlifeflyer noted, employers want quality time. Employers know that pilots are desperate for multi time. They probably would disregard all but a few hours of safety pilot time. You have to look at it from the employability standpoint and not necessarily what is or what is not legal.

Good luck with whatever you decide to do.

 

[midlifeflyer]

Re: Splitting time - valuable or not?

As Midlifeflyer noted, employers want quality time. Employers know that pilots are desperate for multi time. They probably would disregard all but a few hours of safety pilot time. You have to look at it from the employability standpoint and not necessarily what is or what is not legal.

FWIW, I'll add one more note to this. You need to look at the issue from =both= an FAA and employability perspective. They're not mutually exclusive.

Let's take it out of safety pilot as PIC issues. More to cross country. For Part 135 qualification purposes, the cross country time may be basic point-to-point cross country: any flight involving a landing at another airport that you didn't bump into by accident, no matter what the distance. So you've got all these hours of flying to the airport with the great restaurant that's 10 NM away. Do you bother to log them?

Obviously, no employer is going to be impressed with this cross country time. But consider this scenario: You are a young CFI working at an FBO that does some night cargo operations. The FBO operator knows you, likes you, and is confident in your piloting skills. One of the regular pilots is going on vacation and you're offered the job of subbing. If all you count is the 50+ NM type of cross country, you're just shy of meeting the overall Part 135 cross country requirements, and you're really far off on the night cross country requirement. If you count point-to-point cross country, you meet them. The employer in this situation doesn't care that the cross country time was to the airport 5 NM away; she only cares that the local FSDO won't come banging on the door with a 135 violation.

Now, I'm not in the aviation industry, so you can take this with a grain of salt, but I can't imagine that aviation is so different than any other form of business. My take is that there's a big difference between having data and presenting it. You log what it is legitimate to log, but you present it in a way that is appropriate for the situation.

Not talking about falsifying or hiding the information. When going for the FedEx interview, there's a big difference between "I've got 1500 hours of cross country time" and "I've logged all of my cross countries to meet Part 135 requirements, but a lot of them were real short trips. I've broken out the ones I think are significant and they total...."

Ah! The advantages of electronic logbooks.

 

[bobbysamd]

Legal x-c time v. not logging it

For Part 135 qualification purposes, the cross country time may be basic point-to-point cross country: any flight involving a landing at another airport that you didn't bump into by accident, no matter what the distance. So you've got all these hours of flying to the airport with the great restaurant that's 10 NM away. Do you bother to log them?

But consider this scenario: You are a young CFI working at an FBO that does some night cargo operations. The FBO operator knows you, likes you, and is confident in your piloting skills. One of the regular pilots is going on vacation and you're offered the job of subbing. If all you count is the 50+ NM type of cross country, you're just shy of meeting the overall Part 135 cross country requirements, and you're really far off on the night cross country requirement. If you count point-to-point cross country, you meet them. The employer in this situation doesn't care that the cross country time was to the airport 5 NM away; she only cares that the local FSDO won't come banging on the door with a 135 violation . . . . .

And the pilot in question got the chance because he/she met the requirements, fair and square (And took a 135 ride with the FAA, who would have checked his/her credentials and issued him/her a 135 letter!). As opposed to logging multi time questionably.

I would, and did, log this kind of cross-country time. As long as it meets the definition, i.e. is legal, logged accurately, and follows the spirit of the reg, there's nothing wrong with it. One rung on the ladder for many career pilots is ferrying aircraft for customers, friends and others. I ferried aircraft many a time in CAP, and logged all my time. Employers will see that you have cross-country time, but will be more interested in how much was IFR.

There are freight pilots in California who fly cross-country, but on very short flights. Many of them graduate to the bigger iron in time without problems.

Cross-country time seems to be a less sensitive issue than building that all-important and hard-to-build multi time. On the other hand, everyone is sooooo desperate to build multi hours, and to build them in a hurry, because they are so hard to build and so vital for the career. That's why the multi time-building issue is so controversial, and why so many try to contrive the time.