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4 Answers

Safety pilot in an LSA

Asked by: 4105 views
FAA Regulations, Instrument Rating, Light Sport Aircraft

Here's one I haven't been able to find any discussion on...


Imagine  you have a pilot who holds a private pilot certificate, has a valid drivers license, and has recently completed a flight review. However, this pilot's medical certificate has expired (not revoked or denied). In other words, a pilot who is current and able to exercise the privileges of a Sport Pilot but not medically current to exercise the privileges of a Private Pilot.


91.109(c)(1) states that for flying in simulated instrument conditions, the other control seat must be occupied by a safety pilot who "possesses at least a private pilot certificate" and 61.3(c) is commonly cited as requiring that the safety pilot, as a required crewmember, must have a current medical.


My question is, can the hypothetical pilot I've described serve as the safety pilot in an LSA? My conclusion is yes because he holds a private pilot certificate, but need only be exercising privileges of a sport pilot to be a required crewmember in an LSA. This would lead to being able to use the sport pilot medical exemption found in 61.3(c)(2)(v).

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4 Answers

  1. Best Answer

    Mark Kolber on Mar 31, 2014

    I’m pretty sure the answer is no because 91.109(c) tells us explicitly that being a safety pilot is a private pilot privilege. And one exercising a private pilot privilege is required to have a medical. Note also that one exercising sport pilot privileges is precluded from acting as a required crewmember, another problem.

    This is an issue that is discussed periodically since, as things currently stand, even a sport instructor can’t put a student under the hood.

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  2. Wes Beard on Mar 31, 2014


    Just because the airplane is an LSA that doesn’t necessarily mean the operation automatically falls under the sport pilot rules. You must also comply with the privileges and limitations of a sport pilot.

    61.315(c)(13) requires the pilot in command to maintain visual reference to the surface. How can the pilot in command do that wearing a hood?

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  3. Kris Kortokrax on Mar 31, 2014

    If the safety pilot acts as the PIC, he can keep visual reference.
    Not really that different than if I put a Student pilot under the hood during training for a Private pilot certificate.

    The real question is whether the DC lawyers say that possession of a private pilot certificate would allow the operation with a driver’s license or if you need a medical certificate because you need to exercise the privileges of a private pilot certificate.

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  4. Brent on Apr 01, 2014

    Wes, in my hypothetical situation, only the safety pilot would be exercising the privileges of a sport pilot. The pilot under the hood, who I didn’t describe in the OP, would be medically current and exercising the privileges of a private pilot, so 61.315(c)(13) would not apply. However, I think Mark’s point that a sport pilot can’t be a required crewmember per 61.315(c)(19) would definitively preclude someone attempting to exercise the privileges of a sport pilot from being a safety pilot.

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