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5 Answers

Logging PIC while not IFR current in IMC with “Safety Pilot” who is current

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FAA Regulations

Situation: Pilot A and Pilot B are both instrument rated private pilots for ASEL aircraft. Pilot B is both instrument current and proficient. Pilot A's instrument currency just lapsed, so he brings Pilot B along with him as a "safety pilot" during the grace period between 6 and 12 months to regain currency. They file IFR, and they happen to enter actual IMC conditions during their approaches for currency. Can pilot A log PIC during these approaches? Pilot A is the sole manipulator of the controls, but only pilot B is the only pilot legally current.

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5 Answers



  1. John D Collins on Jul 18, 2021

    Pilot B must act as PIC to file IFR or to enter any IMC. I assume pilot B is not an instructor. Pilot A is a passenger, but is rated for the aircraft category and class. Pilot B is also the safety pilot for the time Pilot A is practicing under the hood. Pilot A can log any of the time they are the sole manipulator of the controls and if under the hood and in VFR or IFR conditions, pilot A can log instrument time and count any approaches. Pilot B can also log the time as PIC while acting as the safety pilot. Pilot A can also log the time in actual conditions and although pilot B is acting as PIC, there are no provisions in the regulations requiring a safety pilot, so Pilot B can’t log that time. Pilot B can’t log the time Pilot A is not under the hood, such as taxi, takeoff, and landing.

    All this is covered in various FAA General Counsel opinions. This is one of many:

    https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Speranza%20-%20(2009)%20Legal%20Interpretation.pdf

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  2. AviatorTrevor88 on Jul 18, 2021

    Hi John. I’m still a little confused. I did mention both pilots are private pilots, so yes, neither is an instructor.

    So, in this case, where pilot A is the sole manipulator of the controls but *not* IFR current, you’re saying they can log PIC while in actual IMC but that pilot B cannot? Even though pilot B is the only pilot onboard legally current to fly in IMC?

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  3. John D Collins on Jul 19, 2021

    AviatorTrevor88,

    Yes. Pilot A is rated in the category and class of aircraft. 61.51(1.)(e.)(i) describes the basis for Pilot A logging the time as PIC. 61.51(b)(3) describes the conditions of flight that are logged in the entry. Pilot B is ACTING ACTING ACTING as PIC and is legally responsible for the safety of the flight. ACTING as PIC and LOGGING PIC are two totally different issues. It is unfortunate that the FAA uses the same term PIC in conjunction with ACTING as they do with LOGGING, it might be less confusing if ACTING as PIC, was termed ACTING as AIRCRAFT COMMANDER, but it is what it is. LOGGING PIC is described in 61.51 and ACTING as PIC is described in 61.3 and currency is described in 61.57. To file IFR or operate under IFR, Pilot B must ACT as PIC to file and fly under IFR.

    The aircraft only requires a single pilot. A second pilot is required by 91.107 as a safety pilot when the pilot flying is under the hood. Technically the pilot under the hood is a passenger since they can’t ACT as PIC. However, since pilot A holds a category and class rating for the aircraft, they are permitted to log PIC. There is no requirement for Pilot A to have a current medical or to be current in any way and they don’t need an endorsement such as a complex, high performance, or tail wheel.

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  4. Mark Kolber on Jul 20, 2021

    Trevor, John is absolutely correct. Logging PIC by a private pilot who is the sole manipulator of the controls only requires that the pilot be rated in aircraft category and class (and type if a jet).

    In your example, someone on board must be rated and current to be responsible for the flight (acting as PIC). Doesn’t matter it it’s an instrument rated and current private pilot or a CFI.

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  5. Mark Kolber on Jul 20, 2021

    Article on the difference between acting as PIC and logging flight time.
    https://www.ifr-magazine.com/system/logging-vs-being-pic/

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