What's wrong with logging SIC time?
 

I've been hearing a lot about why you should never log SIC time unless the aircraft requires more than one crew member, but to me it sounds like you can log SIC time in other circumstances too. For example, when a pilot is acting as a safety pilot and has the correct category and class certification, but is unable to log PIC due to lack of an endorsement (complex, high performance, etc). Technically, that safety pilot is a required crew member. Would there be any issues with logging SIC time if this were the case?


Jim

61.51 (f) Logging second-in-command flight time. A person may log second-in-command time only for that flight time during which that person:
(1) Is qualified in accordance with the second-in-command requirements of §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.

Huh...
 

According to FAR's explained you may log SIC time while acting as a safety pilot. I was always told SIC only applied to multi-crew airplanes. FAR's Explained is not a FAA publication so I would probably check with your FSDO (or the FSDO that gives you the answer you want).

You can log PIC time, you just can't act as PIC. There is a difference.

You can also log whatever you like. Your logbook is yours to what you like with. As long as you can show currency, you can log whatever you choose.

Potential employers consider PIC as the person who has the ending responsibility for the flight. Same reason SIC time in a King Air or cabin class twin doesn't go well when applying for a better job.

Ask people who did 135 charter in King Airs or CJs and logged SIC, or the King Air guys who logged PIC on the legs they flew in 90s/200s (though they had no PIC training on the aircraft). It doesn't often go over well in an interview or on an application.

There are just too many situations out there to cover with blanket statements, but this might be good general advice. It certainly depends on the operation and the rules/regulations (opsecs) that the crew and aircraft are operating under the direction of during flight. I log SIC time, though I am PIC/single pilot qualified, even when I am flying. I understand that I could be logging PIC time, but all of my PIC time up to this point as been when I have
been "the person who has the ending responsibility for the flight." as you say DirectTo. This method would not work for everybody, but as he also says - your logbook is yours to log time in as you wish - just be able to explain it and justify it when you interview.

USMCFLYR

Well, I'm not even a commercial pilot yet so I wouldn't rack up too many hours doing this. I'm asking primarily because I'm wondering if I should spend the extra $1000 for complex and high performance endorsements on my certificate so I can log some safety pilot time provided I find some rich guy with a 182 or a Bonanza that needs a safety pilot. But, if I can manage to log SIC time toward my CPL without spending the extra grand for the endorsements I'd probably just do that. I don't know, what do you think would be the best course of action?

This whole thing is just a way to keep me flying and boost my TT on a tight budget.

I just got off the phone with the FSDO. After a lengthy time on hold, they say it OK to log SIC time in an aircraft if you are the safety pilot, even if you cannot be PIC due to lack of endorsements as long as you have category and class. I guess that answers my question.

I'm amazed! You actually managed to get someone on the phone who gave the correct answer.

Be wary of answers given by a FSDO, especially over the phone. They are notorious for being incorrect. You just got lucky this time.

BTW, you will often hear that you should never log this or that when the regs say you can. Despite the title of this section of the forum, you'll find that a lot of folks answer this kind of question based on (a) what they personally think you should log or (b) based upon a perception of what the airlines would like you to do.

You're asking about logging time that the FAA permits you to log to meet the FAA's time requirements for FAA certificates. No reason not to log legit time toward the 250 generic flight hours needed for the commercial.

Dude, I'm just going to change your emplasis:About 20 years of FAA Chief Counsel interpretations make it clear that for logging PIC and SIC purposes, the safety pilot required under 91.109 make flight under the hood with a safety pilot a flight in which "more than one pilot is required under the regulations under which the flight is being conducted."

A couple of problems here...

- Local FSDO's are not always right.

- There are many regulatory grey areas, and other FSDOs may not agree with your FSDO. Actually odds are very high they will disagree.

- Employers have their own standards, and may not be familiar with all regulatory fine print. The average airline interviewer would probably NOT accept SIC in a light ASEL under part 91. Thye might not even give you the opportunity to explain, they might just hire someone else. Even if they do discuss it with you, the last thing you want is to be on the defensive, with your integrity (or intelligence) in question arguing some fine point of regulation. Trust Me. If you want to be a career pilot, you need to cater to what the employers are looking for...they are the ones who hire you, not the FAA.

If you really want a definitive answer, you need to write the FAA legal folks in Washington. They will send you a latter addressing your specific question, and such a letter would over-ride any rogue FSDO or local clown inspector.

Actually this question has been answered by FAA legal before (see NoyGonnaDoIt's post), you can search for it on their website.

In your shoes I would get the endorsements and just log it is PIC just to avoid confusion down the line. You'll need those endorsements eventually anyway.

...and for educational purposes and to see how far back some of this goes,

No endorsements needed to act as a safety pilot:
http://www.faa.gov/about/office_org/...991/Rizner.rtf

For the logging rules for safety pilots as SIC or as PIC:
http://www.faa.gov/about/office_org/...1993/Hicks.rtf

If you don't like old stuff, there's stuff from 2009 and 2010 dealing mostly with cross country scenarios (safety pilots may not log cross country time toward requirements) that restate some of the basic rules.

You don't need those endorsements to log the Safety Pilot PIC time; you only need those endorsements to act as a PIC in those types of aircraft. It might benefit you (both financially and operationally) if you did some research so you understand the difference between acting as a PIC and logging PIC time.

Yes you do. Read the reg and the FAA's interpretations. You need to be acting as PIC to log PIC as a safety pilot.

==============================
61.5(e) Logging pilot-in-command flight time.

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights-
***
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted;
==============================

If you think there's another part of 61.51 that applies to safety pilot logging PIC, please point it out.

It's been a while since I have done any instruction but it seems to me that based on the FARs and backed up by the first letter you do not need to have the endorsements if you were acting as a safety pilot and therefore logging SIC time.
However according to the second letter, if both pilots agreed ahead of time that the safety pilot would act as PIC (and therefore log PIC time) then he/she would need the endorsements.

If you really don't want to attract attention by having SIC time in a single engine piston, get the endorsements.

Thanks for the links, NoyGonnaDoIt, answers a lot of questions.

IMO, if you're talking about logging 10ish SIC safety pilot hours towards your commercial, do it. At current aircraft rental prices that can save you $1000, I find it difficult to believe that 500, 1000, 1500, etc, hours down the road some airline is going to fault you for for logging 10 hours or so of perfectly legal SIC time in a 182 to help you obtain the commercial cert. Now if you show up to an interview with a significant percentage of time as SIC in a single pilot plane that is a different story.

As for the endorsements, you will need the complex endorsement for commercial anyways. The high performance may not hurt to have down the road. If you can spare the money I would get them. You never know if you will be able to find one of these people who is willing to just let you fly them around on a couple $100 hamburger runs and log the PIC time outright.

I've logged some SIC time in single pilot planes under 135 that required an SIC, and I found it to be valuable experience. It does not comprise a significant percentage of my total time, and if airlines want to subtract it from my total time then I'm fine with that. It gave me different types of experience (actual, bad wx, icing, turbine, high alt ops) that I can't get beating the pattern with a student. If anything it made me a more well-rounded pilot and instructor. I realize the airlines frown upon it, but logging it is the only proof I have that I have this kind of experience, and its some hours that may come in handy for getting my ATP or insurance minimums for some job down the road. I would suggest to anyone that has the opportunity to get some hours as SIC for a 135 to do so. Just remember its not going to get you an airline job, and if you show up to an interview with 1000 hours and 100+ of it is SIC in a King Air 90 then that may not look so good.

You got it. Here's what's going on:

The first letter only answers the question, "do you have to have the endorsements to act as a safety pilot." (no) It doesn't attempt to answer the question of (a) whether the SP is PIC or SIC or something else, nor (b) how you log the time.

The second question answers the logging question and tells us the same thing 61.51 does. If a pilot in a required 2-pilot crew (in this case, the safety pilot) is acting as PIC, he may log the time as PIC. If not acting as PIC, he may log the time as SIC.

Neither one goes on to say the (hopefully) obvious: To act as PIC, you need to be qualified to act as PIC in the aircraft and the operation - ratings, endorsements, currency, etc.

Misunderstanding occurs when you don't break down the question into its parts. A lot of people get "a safety pilot may log PIC time" somewhere along the way and think it's a universal. It's not; like any other multi-pilot situation, it depends on their roles and what they are doing. Start doing that (assuming it's important to you) and even those weird 2-pilots-log-PIC scenarios begin t make some kind of sense.

Screw it, I'm just gonna go ahead and do it. There's no way I'm getting more than 20 hours out of it anyway, and if I do happen to find some guy who will let me fly his 182 around then I'll just get the damn endorsement. I'm looking to fly ANG initially, not airline. I appreciate the help you guys gave me.

Jim

If its only a few hours, why take a chance of having it being a subject scrutinized on a later interview (military or civilian)?

It's all about the risk vs. reward calculation. Demonstrate good judgement in they eyes of a future evaluator.

How does one demonstrate good judgment by not following the rules and avoiding the logging of legitimate flight time?

Or (and I always ask this one :) ) is it that future employers also avoid following the rules and avoiding the use of FAA requirements?

Logging SIC at a 135 operation should be completely acceptable to airline employers assuming that the legs were 135 (not 91), the 135 OPSPEC authorizes it, and you had the required training, checkrides, and currency.

Where people get in trouble is when all of those conditions are not met.

You're going to get a complex/HP endorsement eventually, right? So... why not get that now and log the safety pilot time as legit PIC?

I am asking this because I am not a CFI and don't know the answer and not trying to be a smart ars.

How do CFIs log time? For example you have a student with a private that signs for the plane at the FBO and is the person at the controls. The instructor is say.... doing a BFR or refresher training or something. Something that wouldn't require them to be in the aircraft and the student could be flying alone.

I know the student would be the PIC because they signed for the A/C and also are the one at the controls. What does the CFI log? Is dual given a form of PIC when you are a CFI?

Anytime you're giving instruction you are logging PIC (at least no exceptions jump out to me). The student is flying, logging PIC (sole manipulator), but as CFI you're technically responsible for the airplane and the flight, and you're also qualified to log PIC.

Now, on a lot of airline apps they look as dual given as seperate from 'regular' PIC, but that's a different matter.

But you ARE required to be there for this type of flying.
If the CFI isn't there - then the training isn't being conducted.

USMCFLYR

Using this reasoning, the Safety Pilot is requireded to be there then because without a safety pilot no one is under the hood. Correct?

Like all logging flight time questions, your starting point is FAR 61.51.

CFIs log PIC when giving instruction under 61.51(e)(3).

Yep, it really is that simple. Don't have to talk about being "required" or "being responsible" or any of the other irrelevant things that sound nice as a reason. Just a rule that tells you when you can log time.

That is my understanding, but I've never done the safety pilot thing or looked into it much except for reading threads on this board.
There are MANY dedicated threads on here though dealing with the safety Pilot issue.

USMCFLYR

The logic is that IMC is a condition of flight (like night) so it can be logged by all pilot crewmembers.

Approaches and landings are held to different standards.

Also as specified in the written rules (although the approaches are not as clear as the ladnings)

I just had an interview for a regional and the interviews not only frowned upon my nearly 300 hours of SIC in a C208 for a 135 EAS provider of SCHEDULED service, he told me I couldn’t count it towards my total time and was now LESS than 1400TT…with it, I was at 1640.

Talk about a kick in the teeth…

The FSDO said I CAN count it, as long as I didn’t engage the autopilot…

…screw this industry with all the different interpretations…

It’s like the bible…EVERYBODY has a different translation.

They are a private business. They can require anything they want. The only "standard" is just that. The FAA does not regulate what businesses do in this respect. If they want to only count Space Shuttle time, they can do just that unfortunately.

What Airline was that????