Safety pilot, IFR flight, and PIC time

7 Answers

1. 
   

   
   

   Chris Polek on Jun 04, 2014

   Florent,
   My interpretation of the Regulations 61.51 (e)(iii) and specifically the statement about required by regulation. Your friend my log PIC time while you are under the Hood as long as he is appropriately rated for the airplane you are flying and has a current medical. Also 91.109 spells out Simulated Instrument and Safety Pilot requirements. He may log PIC time while you are under the hood but since you will be on an IFR flight plan any actual conditions you encounter he can not log the PIC time since he is no longer required crew. He can also not log the cross country time since the interpretation of the cross country logging requires a landing. Only if one of you had a CFI and was giving instruction could you both log the cross country time. The type of flight plan doesn’t matter in my opinion just the actual weather conditions.

   So to recap you can log PIC simulated instrument cross country time and your safety pilot can log pic flight time only while you are under the hood logging your simulated time and you list him in your log book as your safety pilot and I would suggest your safety pilot list you as who he was acting as safety pilot for.

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2. 
   

   
   

   Florent Barale on Jun 04, 2014

   Thanks Chris for your interpretation. I read several articles in this website about who can log PIC time, cross country time, and the difference betweem IMC/VMC, and I agree with your interpretation based on all that I read.
   The only thing I had a doubt was the flight plan part (i.e. VFR/IFR part), since I had two contradictory thoughts in my mind:
   1) The safety pilot acting as PIC would need to be current and rated on every part of the flight, hence the IFR part, hence he needs an instrument rating and cannot log PIC time under IFR if he’s not, and
   2) To me it would be silly to fly under simulated instrument under the hood on a VFR cross country flight: What route would you follow, a fictional VOR route invented by you just for the flight? So in that sense, the safety pilot doesn’t need to be instrument rated for an IFR flight.

   From the regs and your answer, it makes sense that the VFR/IFR flight plan part doesn’t matter.
   But it is the exact definition of “acting as PIC” that I’m looking for that will for sure solve my questioning.
   In other words, my question is: To “act as PIC” under an IFR flight as a safety pilot, do you need to be instrument rated (knowing that the one under the hood is instrument rated and current)?
   Thanks again for your answer.

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3. 
   

   
   

   Mark Kolber on Jun 04, 2014

   In other words, my question is: To “act as PIC” under an IFR flight as a safety pilot, do you need to be instrument rated (knowing that the one under the hood is instrument rated and current)?

   Yes. The key is the words “to act as PIC.”

   That phrase is not about logging flight time; it’s not about whether you are acting as a safety pilot; it’s not about you are flying the airplane or not; it’s not about which seat you are sitting in or even whether you are sitting in any control seat at all (the captain of a Part 121 remains captain/PIC during a bathroom break). It’s a universal statement about being “”the person who…Has final authority and responsibility for the operation and safety of the flight;” [FAR 1.1]

   If the concept that the person with “final authority and responsibility” for a flight under IFR has to have an instrument rating isn’t obvious enough, 61.3(e) makes it pretty clear.

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4. 
   

   
   

   Florent Barale on Jun 04, 2014

   Thanks Mark for your point. Indeed, FAR 61.3(e) is pretty clear. Thus, to act as PIC under IFR, one need an instrument rating.
   Thus, for my scenario, we must be VFR for my friend to log PIC as a safety pilot.

   But if I want to log PIC cross country under simulated instrument under the hood in VFR, can I do a VFR cross country under the hood?
   By looking at FAR 61.51(g)(1), I only need “to operate the aircraft solely by reference to instruments under actual or simulated instrument flight conditions”, nothing states that it must be IFR. So to me I can do it in VFR.

   But it seems awkward to me to do a VFR cross country under the hood and log simulated instrument flight conditions, even if technically it is legal.
   I don’t think that the purpose of simulated instrument flight conditions is to maintain a course and an altitude under VFR; it doesn’t sharpen your IFR skills at all (or just a little).

   Any thoughts?

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5. 
   

   
   

   Wes Beard on Jun 04, 2014

   You should go back to the definition of cross country in the FARs.

   ——–
   Cross-country time means—

   (i) Except as provided in paragraphs (ii) through (vi) of this definition, time acquired during flight—

   (A) Conducted by a person who holds a pilot certificate;

   (B) Conducted in an aircraft;

   (C) That includes a landing at a point other than the point of departure; and

   (D) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point

   ———

   On your VFR flight are you using dead reckoning, pilotage and electronic navigation aids? Most likely. How great would it be to plan a flight and then fly it using only a heading indicator and time. Challenging but to me quite fun.

   For the safety pilot to log PIC time he is stating in his logbook that he was the legal “acting” pilot in command and has all the rights and legal obligations of such a flight. If he is not able to accept an IFR flight plan (due to no instrument rating) he cannot accept one. You will need to plan the flights VFR.

   My concern would be that the safety pilot is stating in their logbook that they were the legal “acting” pilot in command when they log PIC time. Hence, if there is an accident, incident or airspace violation, the FAA will undoubtedly go after the safety pilot who was simply just sitting there. I’d rather log SIC time personally.

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6. Best Answer
   
   

   
   

   Mark Kolber on Jun 04, 2014

   Simulated instrument flight only requires you be under the hood. You can certainly increase the instrument challenge for yourself, even without ATC calling the shots. The only real “loss” is that of IFR en route procedures. You can, for example, look at places like FltPlan.com and choose a route that mimics a real ATC clearance. You an include a practice approach at your destination and decide you are going to go missed and do a different approach to the same airport (or divert to another), and not brief the new approach until in the missed approach hold. Maybe even cover the AI and DG and do one of them partial panel. You can even enlist ATC assistance by utilizing Flight Following and ask for practice approaches.

   In so many parts of the country this is done every day, under VFR, during instrument training and as self-proficiency exercises. All it takes is some thought, procedural knowledge, and a little imagination. And the benefits can be tremendous.m

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7. 
   

   
   

   Florent Barale on Jun 04, 2014

   Thank you Mark and Wes. I didn’t think about all these possibilities. My friend might not even need PIC time, but total time, so SIC is also a possibility. Thanks again.

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