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Posted
6 hours ago, Mcstealth said:

I am also training IFR

And you didn't ask your instructor to explain this to you?? Pilots I get, but I can't comprehend their could be a CFI-II that doesn't know this stuff very well. It's likely its going to come up on your practical oral exam.

Posted
On 1/29/2022 at 10:38 AM, Mcstealth said:

I was asked by an IFR student to safety pilot on a VFR day, so that pilot could practice approaches under the hood. That pilot told me I could log that time as PIC..? 

I asked a couple of other pilots about logging the time and they were split in their thinking in what the regs said. 

I have not looked that hard, yet, into the book but I am going to figure it out. 

Does anyone know the song and verse?

As you can tell from the varied responses here, your confusion is not a rookie mistake . . . .

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Posted
4 hours ago, kortopates said:

And you didn't ask your instructor to explain this to you?? Pilots I get, but I can't comprehend their could be a CFI-II that doesn't know this stuff very well. It's likely its going to come up on your practical oral exam.

A question about regulatory requirements for logging flight time can be a teachable moment - reinforcing the need to check the regs, and getting the student in the habit of staying up to date on changes.

Imo it's perfectly acceptable for the instructor and the student to review the regs together, and potentially review interpretation letters as needed to cover specific use cases.

I have a pretty decent understanding of the regs, but far from perfect, and my standard answer to any non-trivial reg question is "let's get the book."

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Posted
21 hours ago, PeteMc said:

Not sure if you meant earliest or latest, but I did find the interpretation and learned something new.  However... your statement that they log SIC is just as incorrect as my statement.  Incorrect in that it did not include both the PIC and SIC options.  

I thought I did include both when I wrote

On 1/30/2022 at 7:16 AM, midlifeflyer said:

the Safety Pilot may log SIC if not acting as PIC.

 

Posted
19 hours ago, PeteMc said:

I didn't realize this had been made an option until @midlifeflyer pointed it out.  (Out of curiosity I still want to go back and see when it changed.)

Logging SIC  was discussed in the earliest safety pilot logging interpretation I know, back in 1993. There's a reason I give references in my regulatory articles. I don't expect anyone to take my word for it. 

Posted
12 hours ago, kortopates said:

And you didn't ask your instructor to explain this to you?? Pilots I get, but I can't comprehend their could be a CFI-II that doesn't know this stuff very well. It's likely its going to come up on your practical oral exam.

Even DPEs are not immune. Slightly different issue. There is a well-known DPE and author who insisted during a podcast that an instrument pilot could not regain currency by flying under IFR in actual with a current pilot acting as PIC. Continued to resist it even when confronted with FAA interpretations saying you could. 

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Posted
47 minutes ago, midlifeflyer said:

Logging SIC  was discussed in the earliest safety pilot logging interpretation I know, back in 1993.

Wait...  You're going from a 1933 interpretation?  Then you *may* not be correct.  I thought you were talking about something in the last few years that changed things.

I believe a later interpretation confirmed you should not log SIC based on "Single Pilot Certification" of the aircraft.  Which is why I've never heard of logging SIC in a Mooney or any GA plane flying Part 91.  

I'll try to do some digging, but maybe someone else here can cite where they said not to log SIC.  I know that everything I've read about Safety PIC always states PIC and says not SIC, but the ones that might reference the FAA interpretation may not be easily accessible online.   

Posted
17 minutes ago, PeteMc said:

I believe a later interpretation confirmed you should not log SIC based on "Single Pilot Certification" of the aircraft.  Which is why I've never heard of logging SIC in a Mooney or any GA plane flying Part 91.  

No, there is no later interpretation saying you should not log SIC as a safety pilot.  The basis for logging SIC is not "certification of an aircraft" Read the logging SIC regulation. Safety pilot logging SIC has exactly the same regulatory basis as logging PIC: "more than one pilot is required under the... regulations under which the flight is being conducted."

You may be thinking of the 2013 Beatty letter which says that safety pilots are nor really "acting" as an SIC (and therefore do not need to meet 61.55 requirements), although they are permitted to log it as such.

You or me never hearing of something is not the test of whether it exists. 

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Posted

I choose not to log time when asked to be the safety pilot even when in another M20J just like mine, just a different year model. I only log time when I’m under the hood and sole manipulator and do not log safety pilot time. I do log the information of my safety pilot in the remarks. 
 

I understand that I can legally log PIC time when I’m acting as safety pilot if the proper agreement is made, and that there are reasons for others to log this. But for me there is just no benefit as an IFR rated owner operator who is not logging time to gain ratings or become a commercial pilot. 

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Posted
31 minutes ago, midlifeflyer said:

No, there is no later interpretation saying you should not log SIC as a safety pilot. 

So I'm again back to now knowing something I should have known all along...  OR.. Oh wait!  I just forgot, yeah that's it!!!  :lol:

I did find a number of articles that debunk logging SIC, but then I also found a number of articles that also talk about logging SIC and why.  And a lot of those were in publications I try to read....  So I'll chock it up to just being set in my ways and probably originally leaned you should log PIC. 

Getting comfortable with always doing it the same way "just because" can really bite you in the A** sometimes!  :wacko:

Posted (edited)
1 hour ago, PeteMc said:

So I'm again back to now knowing something I should have known all along...  OR.. Oh wait!  I just forgot, yeah that's it!!!  :lol:

I did find a number of articles that debunk logging SIC, but then I also found a number of articles that also talk about logging SIC and why.  And a lot of those were in publications I try to read....  So I'll chock it up to just being set in my ways and probably originally leaned you should log PIC. 

Getting comfortable with always doing it the same way "just because" can really bite you in the A** sometimes!  :wacko:

"May" means a choice.  Some care about the extra hours since they count for certain things, including total flight time for certain certificates and ratings. Other don't care about it at all. Some just log it because the flying pilot needs to put the safety pilot's name in their logbook, so it's kind of a cross-verification if a question comes up. Others just log it as safety pilot time but don't bother with the SIC. entry.

Many debunking articles are about careers. Airlines are historically not impressed with safety pilot time , PIC or SIC. And then, of course, there are the "it shouldn't be that way so I've decided it isn't" crowd.

And, of course, you should log PIC as opposed to SIC, but only if you are entitled to.

Edited by midlifeflyer
Posted

All you guys who think that being safety pilot means you can log PIC, be careful! Although all Mooney M20s are airplanes, not all airplanes are M20s.

Here are some scenarios to illustrate:

Two private pilots own their own Mooneys. First pilot is complex rated and flies an M20J. Second is complex and HP rated and flies an M20R.

M20J pilot asks M20R pilot to be safety pilot in his M20J. They agree that M20R pilot acts as PIC and Safety Pilot. M20J Pilot and M20R pilot log PIC time.

Now they switch planes.

M20R pilot asks M20J pilot to be safety pilot in his M20R. M20J pilot does not have HP endorsement. Therefore M20J pilot CANNOT be PIC. M20R pilot is under the hood and acting PIC. M20J pilot is safety pilot. M20R pilot logs PIC. M20J pilot can't log PIC (but can log SIC).

Take it a step further, now they switch seats.

M20J pilot flies the M20R. M20R owner has to act as PIC as M20J pilot does not have HP endorsement. M20J pilot logs PIC as sole manipulator of the controls. If M20J pilot is under the hood and M20R pilot is PIC and safety pilot, M20R pilot logs PIC as well. If M20J pilot is not under the hood while flying the plane, then only M20J pilot logs PIC. Despite not having HP endorsement.

The safety pilot has to be qualified and acting as PIC in order to log PIC. The pilot flying under the hood only needs to be rated in category and class.

Posted
All you guys who think that being safety pilot means you can log PIC, be careful! Although all Mooney M20s are airplanes, not all airplanes are M20s.
Here are some scenarios to illustrate:
Two private pilots own their own Mooneys. First pilot is complex rated and flies an M20J. Second is complex and HP rated and flies an M20R.
M20J pilot asks M20R pilot to be safety pilot in his M20J. They agree that M20R pilot acts as PIC and Safety Pilot. M20J Pilot and M20R pilot log PIC time.
Now they switch planes.
M20R pilot asks M20J pilot to be safety pilot in his M20R. M20J pilot does not have HP endorsement. Therefore M20J pilot CANNOT be PIC. M20R pilot is under the hood and acting PIC. M20J pilot is safety pilot. M20R pilot logs PIC. M20J pilot can't log PIC (but can log SIC).
Take it a step further, now they switch seats.
M20J pilot flies the M20R. M20R owner has to act as PIC as M20J pilot does not have HP endorsement. M20J pilot logs PIC as sole manipulator of the controls. If M20J pilot is under the hood and M20R pilot is PIC and safety pilot, M20R pilot logs PIC as well. If M20J pilot is not under the hood while flying the plane, then only M20J pilot logs PIC. Despite not having HP endorsement.
The safety pilot has to be qualified and acting as PIC in order to log PIC. The pilot flying under the hood only needs to be rated in category and class.

And this is why we can never get anything done…


Sent from my iPhone using Tapatalk Pro
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Posted
11 minutes ago, Marauder said:


And this is why we can never get anything done…
 

Ok, for anyone who can't understand the rules as they are written, just don't log PIC time as safety pilot.

You could open yourself up to a can of worms in the event your logbook is reviewed. Or you could bear responsibility for a violation committed by the hooded pilot while you are acting as PIC.

Posted (edited)
2 hours ago, 201er said:
Ok, for anyone who can't understand the rules as they are written, just don't log PIC time as safety pilot.
You could open yourself up to a can of worms in the event your logbook is reviewed. Or you could bear responsibility for a violation committed by the hooded pilot while you are acting as PIC.


And don't forget the insurance liability when something bad happens…


Sent from my iPhone using Tapatalk Pro

Edited by Marauder
Posted
On 1/29/2022 at 8:38 AM, Mcstealth said:

I was asked by an IFR student to safety pilot on a VFR day, so that pilot could practice approaches under the hood. That pilot told me I could log that time as PIC..? 

I asked a couple of other pilots about logging the time and they were split in their thinking in what the regs said. 

I have not looked that hard, yet, into the book but I am going to figure it out. 

Does anyone know the song and verse?

Getting back to your original question, I'm guessing the situation is that you ARE able to fly as PIC in your fellow student's training airplane?  That means you have to have your PP certificate, current medical, passenger (and night if appropriate) currency.  I'm guessing his plane doesn't require you to have a complex or high power endorsement, but I suppose I could be wrong.  I'm guessing his plane doesn't require you to have a type rating (I can't imagine I'm wrong).

That means that you're legally able to log PIC for the time you are safety pilot and he/she is under the hood.  Whether you actually want to is a whole other question--see the legal and insurance concerns above.

It also should be EXPLICITLY discussed before every flight when you're flying with any other pilot as a routine.  My CFII drilled this into me, and every lesson (and every BFR and casual flight since) starts with a discussion of who is ACTUALLY the PIC and when.  

If you can't act as PIC in his/her SEL airplane (say you don't have the proper endorsement or current medical), you still can BE a safety pilot for someone as long as you have a PP SEL certificate.  You can forgo the current medical, currencies and endorsements.  I think you don't need a type rating either, but someone will correct me if I'm wrong. 

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Posted
5 minutes ago, jaylw314 said:

If you can't act as PIC in his/her SEL airplane (say you don't have the proper endorsement or current medical), you still can BE a safety pilot for someone as long as you have a PP SEL certificate.  You can forgo the current medical, currencies and endorsements.  I think you don't need a type rating either, but someone will correct me if I'm wrong. 

You do need a current medical to be safety pilot.

 

61.23 a3ii Must hold at least a third-class medical certificate When exercising the privileges of a flight instructor certificate and acting as the pilot in command or as a required flightcrew member, except when operating under the conditions and limitations set forth in § 61.113(i);

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Posted

And that also means no basic med either to be a safety pilot .. which the FAA should correct to allow…

-Don

Posted
48 minutes ago, 201er said:

You do need a current medical to be safety pilot.

 

61.23 a3ii Must hold at least a third-class medical certificate When exercising the privileges of a flight instructor certificate and acting as the pilot in command or as a required flightcrew member, except when operating under the conditions and limitations set forth in § 61.113(i);

Oops, my bad!

Posted (edited)
49 minutes ago, hammdo said:

And that also means no basic med either to be a safety pilot .. which the FAA should correct to allow…

-Don

Although if you have BasicMed, you could legally be safety pilot if you are the PIC (assuming the insurance and legal issues are agreed on!)

Edited by jaylw314
  • Like 2
Posted

You CAN be a safety pilot while on Basic Med.

You CAN log PIC as a safety pilot.

There are instances where you can't do either of those.

Those stating the absolutes to the contrary still don't understand the regs.

 

Posted

I attached the pdf for it... 

what got me was the 3rd class medical and required flight crew in one of the regs...  a basic med pilot needed to be PIC 'all the time' from takeoff to landing as it were.

https://pilot-protection-services.aopa.org/news/2017/september/01/basicmed-and-safety-pilots

https://www.eaa.org/eaa/news-and-publications/eaa-news-and-aviation-news/news/11-24-2021-faa-proposes-allowing-basicmed-for-safety-pilots#:~:text=November 24%2C 2021 – The FAA,pilots under simulated instrument conditions.

November 24, 2021 – The FAA is proposing to fix a technicality in the Federal Aviation Regulations that prevents pilots flying under BasicMed from operating, in most cases, as safety pilots under simulated instrument conditions. The fix is included in a recently released notice of proposed rulemaking (NPRM) that requires commercial balloon pilots to hold second-class medicals, to fulfill a Congressional mandate implemented after a high-profile accident several years ago.

When the FAA created BasicMed in 2017, it directly copied the law passed by Congress that required the agency to do so. While this allowed for an expedient rulemaking process, the rulemakers took the congressional language literally that only pilots in command (PICs) could utilize the new program. This meant that other required flight crew members, most notably safety pilots who are required to be on board while the PIC is using a view-limiting device, still needed to have at least a third-class medical certificate.

The new language changes instances of “pilot in command” in the rule to “pilot in command or required flight crew member.” This allows any required crew, including safety pilots, to use BasicMed.

“This is a long-overdue fix to an illogical technicality in the rule,” said Tom Charpentier, EAA government relations director. “While it is unfortunate that it comes together with a Congressional mandate that increases regulatory burden on commercial balloon operators, we are pleased that the FAA took the opportunity to fix BasicMed as part of its regulatory compliance with Congress."

So, you can see where I was confused about acting as a safety pilot under basic med


-Don

 

 

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