Safety pilot "flight time"

Thank you for posting the letter. I agrees with my position
IMHO. The question is whether you note the time as 61.51 or
1.1 time.

I wonder what cases have gone through in the past 14 years
to further clarify the issue?


"Bob Moore" wrote in message
46.128...
| Jim Macklin wrote
| Yes, please post the entire letter.
|
| How many times do we have to argue this issue?
| Every year?
|
| Here is the Chief Counsel decision on the matter:
|
| ---
| October 30, l992
|
|
| Mr. David M. Reid
|
|
| Dear Mr. Reid:
|
| Thank you for your letter of June 12, 1992, concerning the
| logging of pilot-in-command (PIC) time under the Federal
Aviation
| Regulations (FAR).
|
| In your letter you ask four questions. First, you ask
whether
| there are "any circumstances when, during a normal flight,
two
| Private Pilots may simultaneously act as (and therefore
log the
| time as) Pilot-In-Command?" The answer is two private
pilots may
| not simultaneously act as PIC but they may, under certain
| circumstances, simultaneously log PIC time.
|
| There is a difference between serving as PIC and logging
PIC
| time. PIC, as defined in FAR 1.1, means the pilot
responsible
| for the operation and safety of an aircraft during flight
time.
| FAR 61.51 deals with logging PIC flight time, and it
provides
| that a private or commercial pilot may log as PIC 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 PIC 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. It is important to note that FAR
61.51 only
| regulates the recording of PIC time used to meet the
requirements
| toward a higher certificate, higher rating, or for recent
flight
| experience.
|
| Therefore, while it is not possible for two pilots to act
as PIC
| simultaneously, it is possible for two pilots to log PIC
flight
| time simultaneously. PIC flight time may be logged by
both the
| PIC responsible for the operation and safety of the
aircraft
| during flight time in accordance with FAR 1.1, and by the
pilot
| who acts as the sole manipulator of the controls of the
aircraft
| for which the pilot is rated under FAR 61.51. Enclosed
please
| find two prior FAA interpretations concerning logging of
PIC
| time. We hope that these will be of further assistance to
you.
|
| In your second question you ask "[h]ow shall two Private
Pilots
| log their flight time when one pilot is under the hood for
| simulated instrument time and the other pilot acts as
safety
| pilot?" The answer is the pilot who is under the hood may
log
| PIC time for that flight time in which he is the sole
manipulator
| of the controls of the aircraft, provided he is rated for
that
| aircraft. The appropriately rated safety pilot may
concurrently
| log as second in command (SIC) that time during which he
is
| acting as safety pilot.
|
| The two pilots may, however, agree prior to initiating the
flight
| that the safety pilot will be the PIC responsible for the
| operation and safety of the aircraft during the flight.
If this
| is done, then the safety pilot may log all the flight time
as PIC
| time in accordance with FAR 1.1 and the pilot under the
hood may
| log, concurrently, all of the flight time during which he
is the
| sole manipulator of the controls as PIC time in accordance
with
| FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
| interpretation concerning the logging of flight time under
| simulated instrument flight conditions. We hope that this
| interpretation will be of further assistance to you.
|
| In your third question you ask "[d]uring instrument
training, how
| shall a VFR Private Pilot log the following flight time:
Pilot-In-
| Command time, Simulated Instrument time, and Actual
Instrument
| time, when that pilot is...A)...under the hood? B)...in
actual
| instrument conditions? C)...under the hood in actual
instrument
| conditions?" The answer is the VFR private pilot may log
all of
| the flight time you described as PIC flight time under FAR
| 61.51(c)(2)(i) if he was the sole manipulator of the
controls of
| an aircraft for which he is rated. Under FAR 61.51(c)(4)
the
| pilot may log as instrument flight time only that time
during
| which he operates the aircraft solely by reference to
| instruments, under actual or simulated instrument flight
| conditions. Please note that the FARs do not distinguish
between
| "actual" and "simulated" instrument flight time. Enclosed
is a
| prior FAA interpretation concerning the logging of
instrument
| flight time. We hope this interpretation will further
assist
| you.
|
| Finally you ask "[d]oes FAR 61.57 affect how the VFR
Private
| Pilot shall log Pilot-In-Command time during instrument
training,
| either before or after meeting the 6/6/6 requirement, and
if so,
| how?" FAR 61.57 does not affect how a pilot logs PIC time
during
| instrument training; FAR 61.51(c)(2) and
| (4) govern logging of instrument flight time. FAR
61.57(e)
| provides currency requirements for acting as PIC under
instrument
| flight rules (IFR) or in weather conditions less than the
| minimums for visual flight rules (VFR). Enclosed
| please find a prior FAA interpretation on instrument
flight time
| and FAR 61.57(e). We hope this interpretation will
further
| assist you.
|
| We hope this satisfactorily answers your questions.
|
| Sincerely,
|
| Donald P. Byrne
| Assistant Chief Counsel
| Regulations Division
|
|
|

On 01/22/07 15:00, Jim Macklin wrote:
Thank you for posting the letter. I agrees with my position
IMHO.

Are you saying that you believe the letter posted by Bob supports
your position?


The question is whether you note the time as 61.51 or
1.1 time.

What? You don't log 1.1 time. You either log your time as PIC or you don't.
1.1 describes the definition of PIC. 61.51 describes the requirements for
logging your time as PIC (among other things).

Oh my!


I wonder what cases have gone through in the past 14 years
to further clarify the issue?



--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

My question was actually what to put in the "flight duration" or "total
flight time" field of your logbook, if anything. For example, I have a
friend who wants to start his instrument rating. I want to fly with
him between his CFI lessons to let him practice and give tips. If I
can log "flight time" along with the "PIC" (when he's under the hood)
to get time towards a higher rating, that would be great. Should the
"flight time" be equal to the PIC (him under the hood)?

I think the FAA or AOPA should come out with a quick reference card for
this sort of thing!

Bob Moore wrote:
Jim Macklin wrote
Yes, please post the entire letter.

How many times do we have to argue this issue?
Every year?

kevmor wrote:

My question was actually what to put in the "flight duration" or "total
flight time" field of your logbook, if anything. For example, I have a
friend who wants to start his instrument rating. I want to fly with
him between his CFI lessons to let him practice and give tips. If I
can log "flight time" along with the "PIC" (when he's under the hood)
to get time towards a higher rating, that would be great. Should the
"flight time" be equal to the PIC (him under the hood)?




That's what nearly everybody does. Log what you fly and don't worry
about it.

On 01/22/07 17:02, kevmor wrote:
My question was actually what to put in the "flight duration" or "total
flight time" field of your logbook, if anything. For example, I have a
friend who wants to start his instrument rating. I want to fly with
him between his CFI lessons to let him practice and give tips. If I
can log "flight time" along with the "PIC" (when he's under the hood)
to get time towards a higher rating, that would be great. Should the
"flight time" be equal to the PIC (him under the hood)?

If you agree before the flight that you will be PIC while he is under
the hood, then you can log it as PIC for the time that he is under
the hood. If he remains PIC for the flight, then you can log as SIC
the time that he is under the hood.


I think the FAA or AOPA should come out with a quick reference card for
this sort of thing!

Well, that's probably true of a lot of areas. Also, there's a lot of
differing opinions here. The FAA does, from time to time, write legal
opinions on subjects where the FARs are not very clear. Bob Moore
was kind enough to post the results of one which is appropriate to
this discussion.


Bob Moore wrote:
Jim Macklin wrote
Yes, please post the entire letter.

How many times do we have to argue this issue?
Every year?





--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA

Thanks Mark, I think after reading pages and pages of this topic it's
starting to get clearer (especially the SIC/PIC difference). I can log
the time I put in the PIC or SIC column in the flight duration column,
right? So this could count towards the 250 hr. Commercial rating
requirement?

On Jan 22, 5:18 pm, Mark Hansen wrote:
On 01/22/07 17:02, kevmor wrote:

My question was actually what to put in the "flight duration" or "total
flight time" field of your logbook, if anything. For example, I have a
friend who wants to start his instrument rating. I want to fly with
him between his CFI lessons to let him practice and give tips. If I
can log "flight time" along with the "PIC" (when he's under the hood)
to get time towards a higher rating, that would be great. Should the
"flight time" be equal to the PIC (him under the hood)?If you agree before the flight that you will be PIC while he is under
the hood, then you can log it as PIC for the time that he is under
the hood. If he remains PIC for the flight, then you can log as SIC
the time that he is under the hood.



I think the FAA or AOPA should come out with a quick reference card for
this sort of thing! Well, that's probably true of a lot of areas. Also, there's a lot of
differing opinions here. The FAA does, from time to time, write legal
opinions on subjects where the FARs are not very clear. Bob Moore
was kind enough to post the results of one which is appropriate to
this discussion.



Bob Moore wrote:
Jim Macklin wrote
Yes, please post the entire letter.

How many times do we have to argue this issue?
Every year?--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA