Free safety pilot - I'll come to you

[NJMac]

I got a quote for a $240k hull value Ovation and the price was a fair amount more than I expected.  I've got about 250 hrs M20E time but no HP.  The insurance said many brokers wouldn't quote me but the one that did offered it at $8500 for the year.  

Since I'm a man of many thoughts, always finding a better way, I figured I would whore myself out to anyone who needs a safety pilot in an M20R so that I can build my time in Make/Model such that they'll love me more when I finally buy mine.  

@Parker_Woodruff is there a better way that my sleepy brain has not come up with yet? 

[mike_elliott]

to log the time as PIC, you and the other pilot have to agree before hand you are the PIC. This opens you up to potential liability exposure without insurance coverage. Just something to think about

 The relevant FAR is 61.51, and the relevant sections are (e) (i) and (e) (iii).

[daytonabch04]

$8500 is crazy.  I had no Mooney time, about 5 hrs of HP and RG before the purchase of my Bravo.  My hull was 240k as well and was only quoted around 3300 with about 325 hrs TT.  I would say shop it around as best as you can..

[midlifeflyer]

6 minutes ago, mike_elliott said:

to log the time as PIC, you and the other pilot have to agree before hand you are the PIC. This opens you up to potential liability exposure without insurance coverage. Just something to think about

 The relevant FAR is 61.51, and the relevant sections are (e) (i) and (e) (iii).

You also need your HP endorsement to log it as PIC

[Bob - S50]

1 minute ago, mike_elliott said:

to log the time as PIC, you and the other pilot have to agree before hand you are the PIC. This opens you up to potential liability exposure without insurance coverage. Just something to think about

 The relevant FAR is 61.51, and the relevant sections are (e) (i) and (e) (iii).

I don't think it's quite that straight forward.

If NJMac has a Class 3 physical he can act as a required crew member and can thus be a safety pilot.  In that case, any time the other pilot is under the hood, NJ can log PIC time and so can the pilot manipulating the controls.

If NJ only has Basic Med, he cannot legally act as a Safety Pilot unless they do what you stated and designate NJ as PIC even though the other pilot will be doing the flying.  However, that may or may not be an issue with the owner's insurance.

Or I may be wrong.  Here's a link to AOPA:

Safety Pilot PIC Time

[midlifeflyer]

1 minute ago, Bob - S50 said:

I don't think it's quite that straight forward.

You are right. There are multiple issues in the scenario.

What is the time in type the insurer is looking for? Undifferentiated "flight time," PIC time, or something else? That's leaving out the proficiency issue, the whole reason for the time in type requirement.

Assuming PIC time, you have both the pilot warranty and need to have the HP endorsement issues to deal with.

[mike_elliott]

19 minutes ago, Bob - S50 said:

I don't think it's quite that straight forward.

If NJMac has a Class 3 physical he can act as a required crew member and can thus be a safety pilot.  In that case, any time the other pilot is under the hood, NJ can log PIC time and so can the pilot manipulating the controls.

If NJ only has Basic Med, he cannot legally act as a Safety Pilot unless they do what you stated and designate NJ as PIC even though the other pilot will be doing the flying.  However, that may or may not be an issue with the owner's insurance.

Or I may be wrong.  Here's a link to AOPA:

Safety Pilot PIC Time

According to AOPA, it is exactly as I have stated:

From your link, Bob:

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."

[Parker_Woodruff]

4 hours ago, NJMac said:

I got a quote for a $240k hull value Ovation and the price was a fair amount more than I expected.  I've got about 250 hrs M20E time but no HP.  The insurance said many brokers wouldn't quote me but the one that did offered it at $8500 for the year.  

@Parker_Woodruff is there a better way that my sleepy brain has not come up with yet? 

I've got username amnesia...did I quote this to you?  Unless we are talking age 70+ or recent losses, the price sounds steep...but I'd need to look at the file....

[NJMac]

1 hour ago, Parker_Woodruff said:

I've got username amnesia...did I quote this to you?  Unless we are talking age 70+ or recent losses, the price sounds steep...but I'd need to look at the file....

Negative.  Unless you're Kristen at BWI?  She just found a 2nd option for $4500 annually. That's pretty much what I had expected.  I'm happy to connect with you though. 

[Parker_Woodruff]

1 hour ago, NJMac said:

Negative.  Unless you're Kristen at BWI?  She just found a 2nd option for $4500 annually. That's pretty much what I had expected.  I'm happy to connect with you though. 

That's the pricing I had in mind.  Just depends on who you want to work with.  You have to give it time for some of these carriers to respond...they don't all throw out a quote automatically.

[ragedracer1977]

8 hours ago, midlifeflyer said:

You also need your HP endorsement to log it as PIC

Since when? 

You only need to be rated in category and class. 

A brand new PPL without even a complex endorsement can log PIC as a Safety pilot in a brand new acclaim.

Edited January 5, 2021 by ragedracer1977

[midlifeflyer]

2 hours ago, ragedracer1977 said:

Since when? 

You only need to be rated in category and class. 

A brand new PPL without even a complex endorsement can log PIC as a Safety pilot in a brand new acclaim.

Nope. He can act as safety pilot in the Acclaim, but cannot log PIC.

Since forever. The rules and the official interpretations of the rule have been clear and consistent for decades, 

A pilot only needs to be rated in category and class in order to act as a safety pilot.

A safety pilot may act as PIC or not act as PIC. 

in order to log PIC, the safety pilot must be acting as PIC. That's  what the logging rule says, 

In order to act as PIC in a high performance airplane, a pilot must...

[Hank]

31 minutes ago, midlifeflyer said:

Nope. He can act as safety pilot in the Acclaim, but cannot log PIC.

Since forever. The rules and the official interpretations of the rule have been clear and consistent for decades, 

A pilot only needs to be rated in category and class in order to act as a safety pilot.

A safety pilot may act as PIC or not act as PIC. 

in order to log PIC, the safety pilot must be acting as PIC. That's  what the logging rule says, 

In order to act as PIC in a high performance airplane, a pilot must...

That's not what the Examiner said when I bought my Mooney a month after my PPL ride. Category and Class is what he said my safety pilot needed, and all of 'em logged time (just not landings . . . ).

[carusoam]

NJ,

Did you get a feeling for how many hours you want to have to slay this dragon?

The challenge I think I am seeing...

1) You want to get transition training... to cover all the differences that come with the much higher HP and added weight... in the long body...  engine outs, Full flap Go arounds... (things that all MSers should get exposed to with a knowledgeable CFI...) 

2) It isn’t much different than your current experience... just more...

3) Riding along at altitude would be extremely similar to your current experience... not very helpful, but the speed difference is a bunch of fun... 

4) Each time I changed planes... there was a 1amu extra insurance cost that first year... that went away the second year...

I tried to negotiate away the extra 1amu... like getting the TT prior to taking ownership...  but, couldn’t find a way to make that happen...

5) Work with Parker to find out what the true cost of coverage on your new bird is with no LB time... then see what it would be if you were in year two with 100 more hours...

Go LB!

-a-

[midlifeflyer]

1 hour ago, Hank said:

That's not what the Examiner said when I bought my Mooney a month after my PPL ride. Category and Class is what he said my safety pilot needed, and all of 'em logged time (just not landings . . . ).

He was wrong. Or you misunderstood. Maybe he said, "they can log time." They can. Just not PIC time,

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Herman - (2009) Legal Interpretation.pdf

Learning moment. Don't just read the answer. Understand why it's the answer.

[NJMac]

I'm glad I asked this question since apparently this topic is mis understood by many.  

@carusoam my assumption was that if I picked up 25 hours that I could show in make/model (from being a safety pilot), that the insurance would like me just a little bit more and lower their rates.  Maybe that was a poor assumption, I dunno. These safety pilot hours were not to replace the insurance transition training but to pad my experience resume that they use for underwriting. 

[midlifeflyer]

30 minutes ago, NJMac said:

this topic is mis understood by many.  

It is. Pretty much the same as the logging rules in general.

 Many get only as far as "the FAA says I can log PIC time as a safety pilot" and stop there, without getting to "if I meet the requirements for safety pilots and the requirements for both acting as and logging PIC."

But your question is not necessarily answered by that. When an insurer asks for time in type the question is, what kind off time in type are they looking for? Is it sitting there as merely a passenger for all the takeoffs and landings and logging the time watching someone else fly under the hood?

[PaulM]

3 hours ago, NJMac said:

I'm glad I asked this question since apparently this topic is mis understood by many.  

@carusoam my assumption was that if I picked up 25 hours that I could show in make/model (from being a safety pilot), that the insurance would like me just a little bit more and lower their rates.  Maybe that was a poor assumption, I dunno. These safety pilot hours were not to replace the insurance transition training but to pad my experience resume that they use for underwriting. 

What you can do is find a mooney person who wants to fly places with you (Lunch, etc)... and you are the pilot under the hood.   Then you can log PIC as the sole manipulator of the controls, but the owner is the FAA legal PIC.. (and gets to log the time too).   That is category and class only.

When I have flown under the hood in my plane, either the right seater is a CFI, and the flight is under instruction.  Or the right seater cannot log anything as they can't be PIC under my insurance (listed or open pilot warranty). 

When I transitioned to my M20M I told the insurer I had 150+ complex hours, and they wrote me a policy with no transition requirements.   I then re-read the statement and they only asked for Make.. not Make & Model.. so I told them I had 145 of those hours in a M20J... and the price went down.

I still did 2 days of transition training in San Antonio. 

My current insurer wants Make&Model for the open pilot warranty.

[midlifeflyer]

2 hours ago, PaulM said:

What you can do is find a mooney person who wants to fly places with you (Lunch, etc)... and you are the pilot under the hood.   Then you can log PIC as the sole manipulator of the controls, but the owner is the FAA legal PIC.. (and gets to log the time too).   That is category and class only.

Unless there's something preventing it in, that's true. You don't even have to be under the hood (unless the pilot monitoring wants to log the time too).  

I know of pilots who grabbed a qualified CFI for insurance-required dual (and to gain proficiency in the airplane) and then used a qualified friend to act as PIC for the rest of the time requirement. 

[Vance Harral]

2 hours ago, midlifeflyer said:

You don't even have to be under the hood (unless the pilot monitoring wants to log the time too).  

Which leads to the interesting situations where even though a flight is legal and there is an acting PIC, no one may log PIC time.

[midlifeflyer]

1 minute ago, Vance Harral said:

Which leads to the interesting situations where even though a flight is legal and there is an acting PIC, no one may log PIC time.

There's really only one of those - an unrated person as sole manipulator - and there is an unpublished, unverified Chief Counsel opinion letter addressing it, the infamous 1977 Beane  interpretation (reproduced below). I first came across it  in the old Usenet days. It was passed along by an FAA staffer who said it was found in some papers, but I have never found it in any regularly-available source, including the multi-volume $5,000+/year Federal Aviation Decisions: Chief Counsel Interpretations and  Civil Penalty Decisions reference used by aviation lawyers (fortunately, that's the hardcopy version which is probably rarely used these days). The closest I ever came to verifying it was some correspondence with the former lawyer who wrote most of the 1970s and 1980s Chief Counsel logging interpretations. His response was, "I really don't remember it, but it sounds like me."

The underlining is mine...

And yes, the fundamental difference between "logging" and "acting" we  still argue about really were answered that long ago.

June 22, 1977

Mr. Thomas Beane

Dear Mr. Beane:

This letter is in response to your recent letters to the FAA Flight Standards Service and to the Chief Counsel inquiring about the logging of pilot-in-command (PIC) time by an airman whenever he is not the sole manipulator of the controls.

Section 1.1 of the Federal Aviation Regulations defines Pilot in Command as:

Pilot in command means the person who:

(1) Has 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.

Section 61.51(c)(2) of the Federal Aviation Regulations provides, in pertinent part:

(2)  Pilot-in-Command flight time.

(I)  A private or commercial pilot may log as pilot in command 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 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.

A pilot may log PIC time in accordance with Section 61.51(c)(2)(I) when he is not actually "flying the airplane", if the airplane is one on which more than one pilot is required under its type certificate or under the regulations under which the flight is conducted and he is acting as PIC. Also, a pilot, rated in category and class (e.g. airplane single-engine) could, as the pilot who "Has final authority and responsibility for the operation and safety of the flight" log PIC time if another pilot, not appropriately rated, was actually manipulating the controls of the aircraft.

It should be noted that more than one pilot may log PIC time for the same flight time.  For example, one pilot receiving instruction  may log PIC time in accordance with paragraph (c)(2)(I) for the time he is designated PIC, and another pilot may log PIC time in accordance with (c)(2)(iii) for the same time during which he is actually giving flight instruction.

We hope that we have satisfactorily responded to your inquiry on the proper logging of PIC time.

Sincerely,

ORIGINAL SIGNED BY EDWARD P. FABERMAN

for NEIL R. EISNER Acting Assistant Chief Counsel Regulations & Enforcement Division Office of the Chief Counsel -

[Vance Harral]

5 minutes ago, midlifeflyer said:

and there is an unpublished, unverified Chief Counsel opinion letter addressing it, the infamous 1977 Beane  interpretation (reproduced below)

Thanks for the post.  The interpretation in the opinion letter is not unreasonable.  But as you note, it doesn't seem to be published anywhere definitive, which makes it of dubious legal value.

Even if it were, it only addresses the case where a "pilot, not appropriately rated" is the sole manipulator.  I'm not sure what that's intended to mean.  If it means "whoever is holding the controls, regardless of their certificate/ratings, or lack thereof", then it covers all bases.  If it actually means "a person who holds a pilot certificate, but is not appropriately rated", then it doesn't cover the most common case I use as an example: a pilot who is not an instructor may legally allow a non-pilot passenger who doesn't even hold a student pilot certificate, to try their hand at flying the airplane.  Probably happens dozens of times a day every single day across the country.  I know of no mechanism which permits the acting PIC to log PIC time in that scenario.

Most acting PICs in that scenario incorrectly log the time anyway, and I don't really have any heartburn about it.  It's just an interesting thing to point out, and fills out the complete set of logging permutations I use when discussing PIC logging.  Namely that:

1. you can act as PIC and be entitled to log PIC (makes sense)
2. you can not act as PIC and not be entitled to log PIC (seems obvious)
3. you can not act as PIC and still be entitled to log PIC (as sole manipulator, most common case being under the hood with the pilot monitoring acts as PIC)
4. you can act as PIC and not be entitled to log PIC (the case we're discussing here)

[midlifeflyer]

Vance, I take "not appropriately rated" at face value withou reading a lot of extra stuff into it. A private pilot ASEL, a private glider pilot, and a non pilot all fit the definition in a twin. 
 

FWIW, I wrote a comment in the letter a few years ago.

The Unofficial, Unvarnished, and Totally Made-Up Truth About the Beane "Only Rated Pilot On Board" Opinion
(The names have been changed to protect the innocent and guilty alike)

One day the lawyers at the FAA went out drinking after work and started talking about the logging rules (hey, they're lawyers; you were expecting them to talk about something interesting?). One of them said, call him Joe, said, "Can a pilot log PIC time if he lets his dog fly the airplane?"

Betty, who was a real stickler for strict readings, replied, "No. Since the dog had its paws on the controls, the pilot wasn't the 'sole manipulator of the controls.' So he can't log anything."

Peter rolled his eyes and said, "I know these rules are a bit convoluted, but really! That is the stupidest thing I ever heard! OF COURSE the pilot can log the flight! He's the ONLY ONE who can!"

"So what?" said Betty. That's what the reg says!"

"Oh BULL!" he said, "The guys who wrote 61.51 couldn't cover EVERY possible situation. A flight in which NO ONE can log PIC is ridiculous.

Fortunately, in addition to being sensible, Peter really knew his stuff. "There's a rule of law that's been around for a long, long time. It applies to both statutes and regulations." Peter continued, "'An interpretation that would lead to an absurd or unreasonable result should be avoided.' A flight on which NO ONE can log PIC is absurd."

The others had to agree.

 

[tmo]

So let me get this straight - our dogs can now log PIC? Can @201er's parrot?

[201er]

2 hours ago, midlifeflyer said:

Betty, who was a real stickler for strict readings, replied, "No. Since the dog had its paws on the controls, the pilot wasn't the 'sole manipulator of the controls.' So he can't log anything."

Didn't the FAA write a letter of interpretation that you can be sole manipulator of the controls without manipulating the controls? Flipping the autopilot from the off to on position is enough.

"The FAA considers a pilot's use and management of the autopilot to be the equivalent of manipulating the controls, just as one manages other flight control systems, such as trim or a yaw dampener. The autopilot system's sophistication does not affect a pilot's responsibility to manipulate and manage all control systems, including an autopilot, appropriately. Therefore, a pilot may log PIC flight time as the sole manipulator of the controls for the time in which he or she engages an autopilot."

 

23 minutes ago, tmo said:

So let me get this straight - our dogs can now log PIC? Can @201er's parrot?

Therefore, if the parrot is flying the plane and you flip the bird, you can still log PIC.