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9 Answers

Can instrument student log hood time as PIC provided flying with a qualified safety pilot

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Instrument Rating

Actually the title asks the entire question.

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9 Answers

  1. Best Answer


    Ron Klutts on May 18, 2018

    What does 61.51(e) say about who can log PIC time? Are you rated in the aircraft? Could you log PIC time if not under the hood? Does having the hood matter? I could answer the question but I’m teaching you to fish vs giving you the fish. You’ll need to understand the FAR’s for the check ride anyway.

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  2. Airknocker on May 18, 2018

    Thanks, Ron.

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  3. KDS on May 18, 2018

    Yes, but it can get more complicated and more misunderstood after that regarding what the safety pilot can log and what qualifications the safety pilot has to have.

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  4. Mark Kolber on May 19, 2018

    KDS, most of the “more complicated” is us, not the rules.

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  5. KDS on May 19, 2018

    What was that line you used before that made me chuckle? Something like “as you can clearly see”. This one has a similar ring.

    In the case of the safety pilot being qualified or not and what to log, I believe much of that comes from legal interpretations instead of regulations. Then AFAIK, there is no legal opinion on one point and that is does the safety pilot have to be current in landings to act as safety pilot. My understanding is no they don’t, but that comes from talking with an FAA manager, not from anything I’ve read. I know that if it’s in writing anywhere that you would be the man to know about it, so if you can point me to something in writing, I’d appreciate it.

    However, as was the case in my “chuckle comment” in another question / thread, I’ll bet you’ll agree with me that few pilots could pass a test on questions about who can be a safety pilot and what can they log when.

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  6. John D Collins on May 20, 2018

    KDS,

    In most cases, the regulations mean what they say and say what they mean. Here is the relevant regulation for logging second in command time:

    “(f) Logging second-in-command time. A person may log second-in-command flight time only for that flight time during which that person:

    (1) Is qualified in accordance with the second-in-command requirements of Sec. 61.55 of this part, and occupies a crewmember station in an aircraft that requires more than one pilot by the aircraft’s type certificate; or
    (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.”

    This can be reduced to the following edit by removing the non applicable sections:

    “(f) Logging second-in-command time. A person may log second-in-command flight time only for that flight time during which that person:

    (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 regulations under which the flight is being conducted.”

    So assuming the safety pilot is a private pilot, single engine land, no instrument rating, and only flown in a Cessna 172, and is not current to carry passengers during day or night acting as PIC, he may sit right seat in a Pilatus 910 and if he is the lookout, can log second in command time at night on a flight operated under VFR. The pilot under the hood must be current and fully qualified to act as PIC for the flight.

    He will need to hold at least a third class medical as well because he would be a required crew member according to 91.109 (c) and 61.3(c)

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  7. Mark Kolber on May 20, 2018

    In most cases, the regulations mean what they say and say what they mean.

    True for the most part, but particularly in the safety pilot area, ass KDS points out, a lot of it is based on interpretation.

    Yes, the requirements for currency (or the lack of currency) are right in the rules, as is the need for a medical (other than the anomaly created by the BasicMed statute), but if you want to have some fun, try analyzing the safety pilot’s authority to log PIC when acting as PIC – strictly interpretation and not in the rules.

    If you think 61.51(e)(1)(iii) covers it, and want a small regulatory headache, consider whether you can, as PIC, let a pilot with no medical, or better yet, no pilot certificate at all, fly the airplane under the hood.

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  8. Mark Kolber on May 20, 2018

    KDS, I think most of the confusion on safety pilot requirements comes down to a misunderstanding on the difference between a safety pilot who is acting as PIC and a safety pilot who is not acting as PIC.

    A safety pilot who is not acting as PIC doesn’t have to meet any PIC requirements. Landing currency, flight review currency, HP, complex and tailwheel endorsements, for example, are PIC requirements. So a safety pilot who is not acting as PIC doesn’t have to meet them.

    OTOH, 91.109(c) says a safety pilot is at least a private pilot who is a required crewmember. As required crew, 91.23 says the safety pilot has to meet the applicable medical requirement regardless of acing or not acting as PIC.

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  9. KDS on May 20, 2018

    Wise and correct comments from both John and Mark.

    Allow me to throw one more example out for the group. That is the logging of flight time. I would be willing to bet that the overwhelming majority of flight instructors log flight time based on what is read from the Hobbs meter at the end of a lesson. Normally, the two are the same, but there are times when the aircraft does not move for a long time after engine start.

    However, the good news is that the regulation includes the word “intentional” in regards to falsification. If it didn’t, there are very few who would not be a violator.

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