Post deleted by Doug Taylor

mrivc211

Well-Known Member
Re: Question about time.

Under no circumstances can two people log PIC time. For a while people were in arguement about whether the safety pilot of someone flying under the hood can log it as PIC, the FAA recently put out something and put that to rest. But I know people still do it anyways. But an answer to your question is that its the sole manipulator of the aircraft. No where in the regs does it say you have to sit in the left seat to be PIC. You can sit left or right seat. Hope that helps.
 

Derg

Cap, Roci
Staff member
Re: Question about time.

Actually, the pilot in command of the aircraft.

I don't mean to be a smart ass, but that's really the answer.

You're both not PIC, per se. You're both 'eligible' to fly at PIC, but there can only be one 'sole manipulator' of the controls at one time.

There is, however a debatable 'loophole' around the one PIC at a time rule. If one pilot is under a 'hood' and the other pilot acts as a safety pilot. It's in the grey area and is the subjet of many lengthy discussions but I think the Feds put their foot down recently, I can't remember.

I absolutely do not recommend having an inordinate amount of safety pilot time logged in your logbook when it comes to interviewing at an airline or taking a checkride down at the FSDO.
 

pilot602

If specified, this will replace the title that
Re: Question about time.

Can someone post a link or reference to the "FAA decision/putting it's foot down" in regards to the loggin of PIC/Safety pilot time?

I haven't heard anything about it.
 

pilot602

If specified, this will replace the title that
Re: Question about time.

Out of curiosity I did a quick search on FAA.gov and came up with this. This same article has been posted on various FSDO web sites and this particular copy (they are all identical) was dated 9/26/2002.

[ QUOTE ]
LOGGING PILOT-IN-COMMAND TIME

by Al German

Proper logging of PIC time is a favorite subject of CFI’s sitting around these rainy days. And that’s not unusual since in the FAA’s own words in the Federal Register "The FAA acknowledges there has been confusion in the past regarding the logging of pilot-in-command time by these pilots and that inconsistent policy opinions have been issued by the FAA". In researching the subject FAR Parts 61 & 91, the Federal Register comments issued during the major revision to Part 61 in August 1997, "Federal Aviation Regulations Explained" published by Jeppesen, and various other aviation monthly publications were reviewed.

First lets be clear: who is, or can be, pilot-in-command (PIC) and who may log PIC time are two separate issues and are only sometimes related.

FAR Part 1 defines the pilot-in-command as follows: "Pilot-in-command means the person who:

1. Has the final authority and responsibility for the operation and safety of the flight;
2. Has been designated as pilot-in-command before or during the flight; and
3. Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight."


Part 91.3 expands those comments making it clear that anything that happens during the flight is the sole responsibility of the pilot-in-command.

According to the Federal Register there are only three ways a private or commercial pilot can properly log pilot-in-command time.

1. When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated.
2. When the pilot is sole occupant of the aircraft.
3. When the pilot is acting as pilot-in-command of an aircraft for which more than one pilot is required under the regulations under which the flight is conducted.


Far Part 61.51 "Pilot logbooks" covers the logging of pilot time and section (e) addresses logging PIC time.

A private or commercial pilot may log PIC time if that person is "the sole manipulator of the controls of an aircraft for which the pilot is rated" [61.51 (e)(1)(i)]

Thus a non-instrument rated pilot taking instrument flight instruction, if rated in the aircraft, may log PIC based on the "sole manipulator of the controls" rule. Since there is nothing in the rules that addresses meteorological conditions, the pilot may log PIC while in the clouds. This is supported by FAA chief counsel opinions [Federal Regulations Explained-Jeppesen].

A private or commercial pilot may log PIC time when "acting as pilot-in-command of an aircraft on which more than one pilot is required under the - - - - regulations under which the flight is conducted". [61.51 (e)(1)(ii)]

Normally, a safety pilot, required by regulations, who scans for traffic for a pilot flying under simulated instrument conditions is not pilot-in-command and thus logs second-in-command. However, if the two pilots agree that the safety pilot is designated pilot-in-command, the safety pilot/pilot-in-command may log PIC since he is the pilot responsible for the operation and safety of the aircraft. The pilot flying is "sole manipulator of the controls for which the pilot is rated"" and may also log PIC. Therefore, two private pilots may log PIC under these conditions. However, the safety pilot/pilot-in-command must realize that anything that occurs during the flight is his responsibility. Airspace violations, non-compliance with ATC instructions, near mid air collision, and runway incursions on the ground are all now charged to the safety pilot. A recent article in a monthly aviation publications discussed a flight where there was a violation and the two pilots disagreed who was pilot-in-command.


However, two pilots may not simultaneously log PIC when one pilot is sole manipulator of the controls and the other is acting as pilot-in-command if the regulations governing the flight do not require more than one pilot.

"An airline transport pilot may log as PIC time all of the flight time while acting as pilot-in-command of an operation requiring an airline transport certificate." [61.51 (e)(2)] Previous regulations allowed a situation where three pilot (one an ATP) could log PIC simultaneously when conducting an operation which did not require an airline transport pilot. This is no longer allowed under the August 1997 revision.

A flight instructor may log PIC "while acting as a authorized instructor". No change to previous regulations.

A student pilot can now log PIC. That’s new, and since there is no restriction, your logbook can be updated so that all student solo time prior to August 4, 1997 may be logged as PIC. When an instructor is aboard, since the student is not rated in the aircraft, flight instruction is still logged as dual not PIC.

Then there are some unusual situations which occur. A private pilot flying with his friend (a CFI or ATP) aboard as a passenger. What is the status of the CFI or ATP who is obviously a more senior pilot with more experience than the private pilot? The regulations don’t address this situation, but the courts may find that the more senior pilot has some or all the responsibility for the operation or safety of the flight.

In summary, the person who is pilot-in-command may log PIC, others may also log PIC depending in the circumstances.


[/ QUOTE ]

You can see the "actual" article here: http://www.awp.faa.gov/fsdo/art_pilot.htm

Unless something new has been released (and very, very recently) safety pilot PIC time is still "legal."
 

flyitup

Well-Known Member
Re: Question about time.

It seems like this debate comes up about once a week, and we never really agree on anything... Let's just agree to disagree and be done with it...

Good work on that article by the way 602...
 

pscraig

Well-Known Member
Re: Question about time.

[ QUOTE ]
I absolutely do not recommend having an inordinate amount of safety pilot time logged in your logbook when it comes to interviewing at an airline or taking a checkride down at the FSDO.


[/ QUOTE ]

What amount is inordinate, in proportion? Some flight schools have a lot of the program logged as safety pilot.
 

skypilot

New Member
Re: Question about time.

Posted this on the Ari-Ben thread..Maybe it should go here?

I know there has been a lot of talk about looking PIC time as safety pilot, and would like to relate a story. I'm currently in a multi-engine time building program at a local FBO. Last October when testing for my instrument rating the DE saw I had a some hours for the 50 hour x-country time using the 2 pilot PIC method. He did not like this at all and was about to tell me to go home. Understand that the DE is a fair guy and I had tested with him before. Also, he is a former Eastern Airline pilot and NTSB investigator.

The DE totally disagreed with 2 pilots logging PIC time. It was a Sunday afternoon and he called one of his buddy's at the FSDO that also agreed with him that this was illegal. The DE then went on the Internet and to this link: http://afs600.faa.gov/srchFolder.asp?Category=640OtherFAQ&lev2=DPE


After reading the below from the WORD document, he reluctantly tested me. He still didn't agree or like the idea, but this was all he had to go on.

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} And this answer has been reviewed by the FAA’s Washington HQ Chief Counsel Office (AGC-240), and they have agreed with this answer.
{Q&A-273}

Anyhow, I've logged about 20 hours like this and recently found a MEI, II to share time with.
 

A320_DUDE

Well-Known Member
Re: Question about time.

So the way I understand it....If I'm under the hood w/ a CFI as a safety pilot,we can both log it as PIC time? Am I wrong?
 

davetheflyer

New Member
Re: Question about time.

From Pilot602's excellent post:

[ QUOTE ]
However, two pilots may not simultaneously log PIC when one pilot is sole manipulator of the controls and the other is acting as pilot-in-command if the regulations governing the flight do not require more than one pilot.



[/ QUOTE ]

It looks like the safety pilot loophole is out the window. I always thought that SIC time would be more appropriate anyway.
 

Kingairer

'Tiger Team' Member
Re: Question about time.

[ QUOTE ]
Under no circumstances can two people log PIC time

[/ QUOTE ]

Thats not true either. For example a CFI giving dual to a commercial student. Both can log PIC.

As for logging PIC as a safety pilot, come on, dont try to cheat the system, logging time as a safety pilot is almost worthless. I wouldnt log more then 5 hours of safety pilot, and since i wouldnt log more then 5 hours, i wouldnt log it at all b/c its not worth having that in there for an extra 5 hours of flight time.
 

pilot602

If specified, this will replace the title that
Re: Question about time.

Dave,

When one pilot is under the hood a second pilot is required:

Per FAR Sec. 91.109, sec. (b) No person may operate a civil aircraft in simulated instrument flight unless --

(1) The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

Which means that FAR 61.51, (e) (1) A recreational, private, or commercial pilot may log pilot-in- command time only for that flight time during which that person --
(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated;
(ii) Is the sole occupant of the aircraft; or
(iii) Except for a recreational pilot, is acting as pilot in command 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. ...

kicks in because 91.109 requires the safety pilot to be there and if the safety pilot is agreed by both pilots to be the acting PIC he or she can then log that time as PIC. If the safety pilot is indeed the acting PIC he or she becomes completely responsible for any and all infractions, incidents and or acidents that the pilot under the hood may comit. Which is the exact reason this is not "cheating" the system.

The pilot under the hood logs PIC because he or she is "(i) Is the sole manipulator of the controls of an aircraft for which the pilot is rated[;]."

If the safety pilot does not want to be the acting PIC, the pilot under the hood then becomes the PIC and the safety pilot - because he or she is required to be there - would then log SIC. The pilot under the hood, the PIC in this scenario, would then be completely responsible for any and all infractions, incidents and or acidents that the he or she may comit.

Hence the ability to log SIC/PIC depends on who the acting PIC is. So, in effect the "loophole" is not out the window - it's re-enforced by this article.

[ QUOTE ]
However, two pilots may not simultaneously log PIC when one pilot is sole manipulator of the controls and the other is acting as pilot-in-command if the regulations governing the flight do not require more than one pilot.

[/ QUOTE ]

This applies to two rated, pilots flying in one aircraft neither of which is under the hood. Or, an ATP riding along with a private and trying to log PIC time when he hasn't touched the controls at all during the flight.
 

braidkid

New Member
Re: Question about time.

Ok, this thread has me bothered. I think this is such an important thread to everyone on this board because safety time simply saves us money. I can go buy 100 hours of multi (which seems to be the norm insurance companies are requiring) and split it with someone else under the hood for $5k. Or I can go buy 100 on my own for $10k. As far legality is concerned, safety time is 110% legitimate according to the FAR's.
Another thing that bugs me is the talk of safety time being worthless and not qualifying in terms of experience. Flyitup and I recently flew to Las Vegas splitting the time, one of us under the hood and one of us as safety pilot. I can not tell you how much we BOTH learned from the experience. Even flying right seat just watching everything going on and helping with the radios from time to time felt as if we were both learning on the same level. There is a lot of negative talk toward legal safety time on this board even from Doug. If I were an employer and saw an applicant with 1000 hours and no safety time and an applicant with 1500 and 500 of those hours safety time you better believe I'm going to take the guy with the safety time. Safety time, in my opinion based on my own experiences, is a very powerful learning experience and it saves us peons with no multi time and only enough time to swab the decks tons of money.
Ok, I'm going to step off my soap box now...
 

Brandon

New Member
Re: Question about time.

My personal opinion is the person who is responsible for the flight and who will take the heat if there is an accident is the PIC and may log that time as PIC. That is the only time that goes in the PIC column in my logbook.
I guess what it comes down to is just log what you want, but I sure don't want to have to defend my logbooks when I am interviewing for a job, just because the FARs say it's okay doesn't mean that someone who thinks its cheating has to hire you anyways. The FARs also say I can jump in an airplane and take off in 0-0 but that doesn't mean it's a good idea.
And after that interview, if you get put in the sim with 1000 hours in the logbook, you better shoot approaches like someone who has been doing it for 1000 hours, and not like someone who just sat there and watched.

Yeah, you may learn something by being safety pilot, but no more than you'd learn if the pilot flying was looking out the windows and you were just a front seat passenger.
 

I_Money

Moderator
Re: Question about time.

>>My personal opinion is the person who is responsible for the flight and who will take the heat if there is an accident is the PIC and may log that time as PIC.<<

If the aircraft is involved in a mid-air the safety pilot would get a ribbing.
 

davetheflyer

New Member
Re: Question about time.

cime_sp and pilot602,

I was referring to the logging of PIC vs. SIC time for safety pilot duties. It used to be legal for both pilots to log PIC in that circumstance.
 
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