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Subject:Re: Logging time as safety pilot
From:Eric W. Seelig
Date:Thu Aug 24 12:35:57 2000
I *love* these threads!

Ill take a stab at it...

Bill McHugh wrote:
> Pilot "A" is rated single engine land, no instrument, complex, or
> high-performance ratings. Pilot "B" is rated single engine land, instrument,
> complex and high-performance, but is not a CFI. Pilot B asks pilot A to fly
> as his safety pilot while he shoots some practice instrument approaches in a
> complex, high-performance aircraft under the hood in visual meteorological
> conditions.
>
> Questions:
>
> (1) Can pilot A legally fly as pilot Bs safety pilot?

Sure. 91.109(b) says that when doing simulated instrument work,
the other seat must be occupied by a safety pilot who has to have
at least a private certificate with the appropriate category and
class ratings (in this case, airplane, single-engine, land). It
says nothing about endorsements, so the fact that the airplane is
complex and high perf does not matter.

> (2) If so, can pilot A log the time?

Yes. As others will surely point out, he can log whatever he
wants...using it for a rating/certifite is another matter.

> (3) If so, how should the time be logged?

He may log it as SIC. 61.51(f)(2) says that he can log SIC
because he holds the appropriate category and class ratings and
because he is a required crew member under the regulations under
which the flight is being conducted (91.109(b)). Again, there is
no mention of endorsements.

He may NOT log it as PIC because according to 61.51(e)(1)(iii), in
order to log PIC time in a flight requiring more than one pilot, he
must be ACTING as PIC for that flight. Legally, since he does not
have the endorsements for complex and high perf, he may not ACT as
PIC and, in this case, that means he may not LOG PIC.

> (4) What are the above answers if the weather is IMC?

He can still fly along as the safety pilot. He still may not log
PIC because he cannot ACT as PIC...in this case, not only because
he lacks endorsements, but also because the flight will be
conducted under IFR, and he may not act as PIC under IFR...recall
that acting as PIC is a requirement for logging PIC in this case.
He may certainly still log SIC when the airplane is VMC since he
is certainly a required crew member. I dont know about time the
airplane spends in the clouds. If the airplane is IMC, and the pilot
is wearing a hood, is the second pilot still required? Does it still
count as simulated instrument? Not sure on this one.

It is interesting to note that although "A" may not log PIC as the
safety pilot, he could very legally log PIC under the hood as the
"sole manipulator" of an aircraft for which he is rated (no mention
of endorsements). He could, of course, not ACT as pic, so the
safety pilot would have to act as PIC, and would NEED the complex
and high perf endoresements.

And to further complicate things, even if we throw away the hoods:
If both A and B hold private certificates, A with an instrument
rating and B with complex/high perf endoresements, they could not
head off into the clouds on an IFR plan because NEITHER of them
could legally act as PIC...

Eric
(who hopes he didnt botch anything too badly while flipping back
and forth between several windows on his slow computer here at
work)

P.S. Here are the FARs I cited:

91.109
(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.
(2) The safety pilot has adequate vision forward and to each side of
the
aircraft, or a competent observer in the aircraft adequately
supplements the
vision of the safety pilot; and
(3) Except in the case of lighter-than-air aircraft, that aircraft
is
equipped with fully functioning dual controls. However, simulated
instrument
flight may be conducted in a single-engine airplane, equipped with a
single,
functioning, throwover control wheel, in place of fixed, dual controls
of the
elevator and ailerons, when--

61.51
(e) Logging pilot-in-command flight time. (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;
< SNIP (ii) >
(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.

61.51
(f) Logging second-in-command time. A person may log second-in-
command flight time only for that flight time during which that person:
< SNIP (1) >
(2) Holds the appropriate category, class, and instrument rating (if an
instrument rating is required for the flight) for the aircraft being
flown,
and more than one pilot is required under the type certification of the
aircraft or the regulations under which the flight is being conducted.


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