Safety pilot "flight time"

On Sun, 28 Jan 2007 18:58:32 -0500, bsalai wrote:

Ron Rosenfeld wrote:
On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen
wrote:

But ... and I hadn't considered this until now... you would still log the
entire flight time as "total flight time" even though the amount of time
logged under PIC, SIC or both is less than the total.

That's what I thought I had written.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Are you sure about logging the second in command time?

YES



61.51 says:

...
(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.

In both cases, it seems to require that the time be in an aircraft that
requires more than one pilot by the aircraft's type certificate.

That isn't the case in any of the aircraft I fly as safety pilot, so,
I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
log it as something else?

Brad

Reread 61.51(f)(2) carefully: "...more than one pilot is required under
the type certification of the aircraft ***or the regulations under which
the flight is being conducted***.

91.109(b)(1) is the regulation that *requires* a safety pilot when the
pilot flying is operating the aircraft in simulated instrument flight.

Hence "the regulations under which the flight is being conducted" requires
more than one pilot.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Ron Rosenfeld wrote:
On Sun, 28 Jan 2007 18:58:32 -0500, bsalai wrote:

Ron Rosenfeld wrote:
On Tue, 23 Jan 2007 07:05:16 -0800, Mark Hansen
wrote:

But ... and I hadn't considered this until now... you would still log the
entire flight time as "total flight time" even though the amount of time
logged under PIC, SIC or both is less than the total.
That's what I thought I had written.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)
Are you sure about logging the second in command time?

YES


61.51 says:

...
(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.

In both cases, it seems to require that the time be in an aircraft that
requires more than one pilot by the aircraft's type certificate.

That isn't the case in any of the aircraft I fly as safety pilot, so,
I'd say if you are not PIC, you can't log the time as SIC. Maybe you can
log it as something else?

Brad

Reread 61.51(f)(2) carefully: "...more than one pilot is required under
the type certification of the aircraft ***or the regulations under which
the flight is being conducted***.

91.109(b)(1) is the regulation that *requires* a safety pilot when the
pilot flying is operating the aircraft in simulated instrument flight.

Hence "the regulations under which the flight is being conducted" requires
more than one pilot.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

Absolutely, thanks.

Brad

"Ron Rosenfeld" wrote in message
...

Legal opinion citation:

June 22, 1977 to Mr. Thomas Beane

...
Also, a pilot, rated in category and class (e.g.
airplane single-engine) could, as the pilot who "Has final authority
and responsibility for the operation and safety of the flight" log PIC
time if another pilot, not appropriately rated, was actually
manipulating the controls of the aircraft.
...

=============================

He actually notes three instance under which the non-manipulating pilot
may
log PIC time:

1. More than one pilot required under type certificate.
2. More than one pilot required under regulations (e.g. safety pilot)
3. Pilot manipulating not appropriately rated.



I wonder what regulation the lawyer bases #3 on.

He says "rated", meaning has the appropriate ratings on his pilot
certificate. I wonder if that is what he intended, or if he intended
"qualified", which to me would include endorsements, currency and medical.
Seems like the intent must have been if the pilot manipulating was not
qualified as PIC, then the one not manipulating but acting as PIC could log
PIC. But regardless, he said "rated", and we have to take it as written, if
we accept the opinion as valid.

Anyway, that opinion from the chief counsel's office is very interesting.

On Mon, 29 Jan 2007 09:48:17 -0600, "Stan Prevost"
wrote:


"Ron Rosenfeld" wrote in message
.. .

Legal opinion citation:

June 22, 1977 to Mr. Thomas Beane

...
Also, a pilot, rated in category and class (e.g.
airplane single-engine) could, as the pilot who "Has final authority
and responsibility for the operation and safety of the flight" log PIC
time if another pilot, not appropriately rated, was actually
manipulating the controls of the aircraft.
...

=============================

He actually notes three instance under which the non-manipulating pilot
may
log PIC time:

1. More than one pilot required under type certificate.
2. More than one pilot required under regulations (e.g. safety pilot)
3. Pilot manipulating not appropriately rated.



I wonder what regulation the lawyer bases #3 on.

He says "rated", meaning has the appropriate ratings on his pilot
certificate. I wonder if that is what he intended, or if he intended
"qualified", which to me would include endorsements, currency and medical.
Seems like the intent must have been if the pilot manipulating was not
qualified as PIC, then the one not manipulating but acting as PIC could log
PIC. But regardless, he said "rated", and we have to take it as written, if
we accept the opinion as valid.

Anyway, that opinion from the chief counsel's office is very interesting.



It's an old opinion (1977), and I've not seen that question addressed
recently. However, I don't have a problem accepting "rated" as
differentiated from "qualified to act as PIC".

I guess I would put that in the same category as being able to log PIC if a
"pilot" with "no" ratings (e.g. your kid sister) were manipulating the
controls.
Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

"Ron Rosenfeld" wrote in message
...

It's an old opinion (1977), and I've not seen that question addressed
recently.

I don't think the opinions die of old age unless the underlying regulations
change, and I would think it could be relied upon unless rescinded. I
haven't gone back to the old part 61 and compared.

However, I don't have a problem accepting "rated" as
differentiated from "qualified to act as PIC".


Nor do I. He said "rated", and as I said, we have to accept what he said.
I was just speculating that the actual intent might have been different.

I guess I would put that in the same category as being able to log PIC if
a
"pilot" with "no" ratings (e.g. your kid sister) were manipulating the
controls.

I agree, except that you are not allowed to log PIC during the time the kid
sister is manipulating the controls, except perhaps under this legal
opinion.

I agree, except that you are not allowed to log PIC during the time the kid
sister is manipulating the controls, except perhaps under this legal
opinion.

I call baloney.

"Dave Butler" wrote in message
...

I agree, except that you are not allowed to log PIC during the time the
kid sister is manipulating the controls, except perhaps under this legal
opinion.

I call baloney.

You call what baloney?

Stan Prevost wrote:
"Dave Butler" wrote in message
...
I agree, except that you are not allowed to log PIC during the time the
kid sister is manipulating the controls, except perhaps under this legal
opinion.
I call baloney.

You call what baloney?

That one is not allowed to log PIC during the time the kid sister is
manipulating the controls.

On 01/30/07 07:36, Dave Butler wrote:
Stan Prevost wrote:
"Dave Butler" wrote in message
...
I agree, except that you are not allowed to log PIC during the time the
kid sister is manipulating the controls, except perhaps under this legal
opinion.
I call baloney.

You call what baloney?

That one is not allowed to log PIC during the time the kid sister is
manipulating the controls.

The regs are specific in this area, and I agree with Stan. Here they
a

(e) Logging pilot-in-command flight time.
(1) A sport, recreational, private, or commercial pilot may log
pilot-in-command time only for that flight time during which
that person

(i) Is the sole manipulator of the controls of an aircraft for
which the pilot is rated or has privileges;

(ii) Is the sole occupant of the aircraft; or

(iii) Except for a recreational pilot, is acting as pilot in command
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.

When our Pilot is letting his kid sister operate the controls and fly the
airplane, which one of those three apply to the pilot? He's not the sole
manipulator of the controls, he's not the sole occupant, and the aircraft
does not require more than one pilot.

Now I would guess that every pilot in this situation is logging the time as
PIC, but the statement was that a strict interpretation of the regulations
do not allow it (except that now, the legal opinion provides a way, in that
it allows for an exception if the person operating the controls is not
"rated").


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

"Mark Hansen" wrote in message
Now I would guess that every pilot in this situation is logging the time
as
PIC, but the statement was that a strict interpretation of the regulations
do not allow it (except that now, the legal opinion provides a way, in
that
it allows for an exception if the person operating the controls is not
"rated").



Maybe allows a way. The continued effectivity of the opinion would have to
be researched. As Dr. Rosenfeld said, it is old. Part 61 underwent a major
rewrite since that opinion, and the basis for the opinion may have changed.