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.
