Originally Posted by
JohnBurke
Not true. 14 CFR 91.109(C) requires a safety pilot when the pilot manipulating the controls is wearing a view limiting device (simulated instrument flight). The purpose of the safety pilot is see and avoid. See and avoid is a requirement whether IMC or VMC, whether IFR or VFR. The pilot manipulating the controls is still vision-restricted whether in a cloud, or not. So long as the pilots vision is obscured, a safety pilot is required.
This is technically correct, and I explained it poorly.
The gotcha exists when the pilot flying cannot resist the temptation to log IMC while in the clouds. In that case it becomes very difficult to justify logging hood and SP time.
But the FSDO's in FL used to be hard-over on this issue. They basically would not tolerate any SP time logging in IMC...I suppose they made the reasonable assumption that neither the hood nor SP was required in actual. You might win the battle with the NTSB appeals board, but my recommendation would be don't fight this one. In this case I agree with the feds...is anyone REALLY going to leave the hood on in actual? Really? I'd call BS on that.
If you're building SP time in AZ, should be no worries...
Also...be careful about logging XC time as SP. The SP is not a required crewmember during T/O and landing, and cannot log any XC requiring a landing. I'm not sure about ATP XC time.