Simulated IFR Training

11 Answers

1. 
   

   
   

   Lance on Jan 27, 2011

   The way that it was explained to me by Phoenix FSDO is that as long as you are both rated and current to fly the aircraft as PIC then you may both log PIC.  The person under the hood being the sole manipulator of the controls may log PIC, while the person not under the hood is responsible for the safety of the flight and acts as PIC.  However, any part of the flight that one pilot is not under the hood the person flying the single pilot aircraft typically becomes the pilot responsible for the safety of the aircraft, therefore that time is only logged by the person flying.

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2. 
   

   
   

   skyboyCFI on Jan 27, 2011

   Technically, a safety pilot is not necessarily the ‘acting’ PIC. They are really a required crew member. Most experts will argue that it’s actually SIC time for the safety pilot. Still time but not PIC. This is one of the many ambiguous subjects. Some FAA guys says, only log time while the other pilot is under the hood. When the hood comes off, they are no longer required and the time stops for the safety pilot. Even though the flight may continue.

   If the acting pic and manipulator of control pic can both log, then hood or not, two people can log by just saying, hey friend, I’ll fly, you be acting pic, we both log, according to the reasoning quoted to Lance (above) by the FDSO. But we both know that doesn’t fly. (no pun intended).

   An FAA examiner said in a seminar I attended, if a pilot takes a non-pilot flying and let’s them fly for fun, technically, the pilot cannot log the time his friend is flying.

   Again, ambiguous confusion. Gotta love the regs. :-p

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3. 
   

   
   

   Wesley Beard on Jan 27, 2011

   FAR 61.51(e)(iii) Logging of PIC Time:
   When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted;
    
   It’s perfectly legal to have both pilots log PIC time when one pilot is under the hood.  Notice the wording above though, the safety pilot who logs PIC time is stating under this regulation that he is the legal pilot in command.  This means they are responsible for the other pilots actions.  If you don’t want to be legally responsible for those mistakes, you can log SIC time per 61.51(f)
    
   The legal pilot in command must have a medical and be current.  The safety pilot only needs to have a medical.  It’s possible for the legal pilot in command and the safety pilot to be the same pilot meaning the pilot flying doesn’t need to have a medical or be current.
    
   There are other discussions on this forum that go more in depth on this topic.

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4. 
   

   
   

   skyboyCFI on Jan 27, 2011

   Wesley, the term ‘legal’ pic is improper. There are only two pic classifications. ‘Acting’ pic and pic manipulator of controls. Not to argue about semantics. But you are spot on in clarifying that the safety pilot must accept ‘acting’ pic responsibility to log as pic, otherwise it’s SIC time.

   But as before mentioned, there are allot of experts that say only log the time the hood is on.

   A similar issue was covered in a FAA legal opinion about two pilots in a tail wheel, one without a tail wheel endorsement, both can log time if non-endorsed pilot flies and endorsed pilot is ‘acting’ pic. See:

   http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/Herman.pdf

   With this legal opinion, I’d argue that at any time two pilots fly together if one just says, I’ll be acting pic you fly the plane, then both of us can log the time. But I doubt the FAA would agree to that one :-p.

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5. 
   

   
   

   Wesley Beard on Jan 27, 2011

   The term “legal pilot in command” is only used to emphasize who will be blamed for any airspace infractions, incidents or accidents.  Reference 91.3.  In a legal setting, the legal (acting) pilot in command will be held responsible.
    
   You and I agree that once the hood comes off, only the sole manipulator of the controls can log PIC time.  I will typically make a remark in my logbook that the actual total time of the flight was 1.4hrs even though I logged 1.2hrs of PIC/SIC and 1.2hrs of total time.  However, if the safety pilot logs PIC time for the flight and the other pilot is landing (visually I hope) the safety pilot is still the legal (acting) pilot in command even though they can’t log it.
    
   Unless both pilots agree (preferably in writing) beforehand that the sole manipulator becomes the legal (acting) pilot in command once the hood comes off, the safety pilot will still be the legal (acting) pilot in command.  Most of this stuff is academia, meaning it is a good discussion but will rarely come into play in real life.  One day it may come into play though and I hope these issues have been worked out beforehand.

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6. 
   

   
   

   Matthew Waugh on Jan 27, 2011

   So I agree that both can log PIC, one under the sole manipulator clause and the other one under the acting as PIC clause. The reason it only works when there is a hood in play is that (with the exception of instructors, I think) you need to be a required crew member to log anything. So 2 buddies flying together, there’s only one required crew member – one person has to wear a hood, THEN you’ve got 2 required crew members.
    
   There’s no ambiguity about this – people’s beliefs may not align, but some people believe in Santa Clause, some don’t, doesn’t make his (her) existence true one way or another.
    
   The other factor to consider is insurance and/or rental agreements. They may be specific about acting PIC requirements and location, so make sure you understand them. It’s all fun and games until you’re crawling out the the wreckage, and then you suddenly find somebody else owns your house.

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7. 
   

   
   

   skyboyCFI on Jan 27, 2011

   Wesley, I do agree with your last comments. The term ‘acting’ still remains an important term.

   Read the following for additional interesting FAA legal interpretation somewhat related.

   http://www.faa.gov/about/office_org/headquarters_offices/agc/pol_adjudication/agc200/interpretations/data/interps/2009/Herman.pdf

   Wesley is very correct, it’s a good discussion. It is how we all continue to learn. With an openmind, happy & safe flying!!

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8. 
   

   
   

   Kent Shook on Jan 27, 2011

   Whoa, Skyboy – Where in the Herman interpretation do you read anything that says BOTH pilots may log PIC in a lacking-endorsement scenario? That simply is not true, and the interpretation does not say anything of the sort.
    
   In the case of simulated instrument time, the reason both may log PIC is due to 91.109(b)(1), which requires a second pilot (the safety pilot). There is no requirement for two pilots to be aboard when one of them simply lacks an endorsement; thus in the case addressed in the Herman interpretation does not apply to the question that was asked here.
    
   There are two possible answers to the original question posed by Dan here:
    
   Scenario 1) The safety pilot is fully qualified to act as pilot in command and will be acting as pilot in command as agreed upon before the flight.
   * Pilot Flying logs PIC time for the entire duration of the flight by virtue of FAR 61.51(e)(1)(i).
   * Safety Pilot logs PIC time only for the duration of time where the Pilot Flying was under the hood by virtue of FAR’s 61.51(e)(1)(iii) and 91.109(b)(1).
    
   Scenario 2) The Pilot Flying is fully qualified to act as pilot in command and will be acting as pilot in command as agreed upon before the flight.

   * Pilot Flying logs PIC time for the entire duration of the flight by virtue of FAR 61.51(e)(1)(i).

   * Safety Pilot logs SIC time only for the duration of time where the Pilot Flying was under the hood by virtue of FAR’s 61.51(f)(2) and 91.109(b)(1).

   Period, end of story. (I wish – This has got to be the most-asked, most argued-over question in aviation despite reasonably clear regulations as well as existing FAA interpretations.)

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9. 
   

   
   

   skyboyCFI on Jan 27, 2011

   Re-read the Herman legal opinion/interpretation. If does say both pilots can log time. The ‘acting’ pilot logs time. He is ‘required’ as the only pilot fully qualified in the aircraft. The manipulator of controls is qualified as a SE pilot and can log time under that rule. Re-read the puppy (maybe a couple times). :-p

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10. 
    

    
    

    Wesley Beard on Jan 28, 2011

    I took SkyBoy’s use of the FAA document as confirmation as there are only two types of PIC’s listed in the regulations.  Those that log PIC time and those that act as pilot in command.  My use of the term “legal pilot in command” is technically incorrect and I should strive to use the proper term whenever possible.
     
    In any regard, I think we answered the question sufficiently enough to consider the topic closed.

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11. 
    

    
    

    skyboyCFI on Jan 28, 2011

    I don’t wanna close it though. 😉

    Just kidding. :-p

    Seriously, what was the original question.

    Like maggot said in another post. All is good, we can only benefit from disagreements. Nobody knows everything (but me). :-). Jk

    Flying High!! A mile high 😉

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