RCFlyer

SIC time cannot be logged. It is quite clear right here:

This is the only case that SIC can be logged under a Part 91 flight. No exceptions. Chief Counsel has no basis for stating that the Safety Pilot would be able to act or log the flight as an SIC.

Obviously, further clarification should be sought.

NoyGonnaDoIt

Please do. You're welcome to tell the arm of the FAA that is responsible for interpreting the regs that its wrong.

RCFlyer

You're a friendly fellow aren't you?

First of all, we have two different interpretations from the FAA. One that says you can log and act as PIC with the flying pilot, and one that says you can log and act as SIC only. The interpretation you referenced is much older than the PIC interpretation.

As far as the written regulations are concerned, not the interpretations from counsel, it would be in violation to log or act as SIC in an aircraft that does not require an SIC pilot. 61.51(f)(2) only gets you out of the currency and training requirements to fly as safety pilot in a 2-pilot aircraft.

BTW, there is no "precedence" in the world of regulation. Interpretation is subject to change at any time the administrator feels it should change.

Element94

Hey guys...

Lots of lurking on these forums in the past few years, not a lot of posting...but, having recently done a significant amount of research on these matters (with chief council interpretations, aviation lawyers, and AOPA), I'll add in whatever understanding or justification was provided for me:

14 C.F.R. 61.51(f)(2) states: 14 C.F.R. 91.109(b) in relevant part states:

Thus, the safety pilot is considered a required flight crewmember for the "regulations under which the flight is conducted." (91.109 - Simulated Instrument Flight). Nowhere in 91.109 does it state that the safety pilot must be acting as PIC.

If the safety pilot was acting as PIC, then s/he would log time under 61.55(e)(iii), as they satisfy the relevant requirements for that regulation.

If the pilot manipulating the controls chooses to act as PIC, as defined in 14 C.F.R. 1.1, then the safety pilot would log the flight time during which they performed duties as a required flight crew member under 61.55(f)(2), or, as SIC.

There was a fantastic post in another aviation forum a few weeks ago on this very matter...I'll see if I can try to dig it up.

From a pragmatic standpoint, however, it's legal semantics. As long as you're properly qualified to act as PIC in that aircraft, I don't think it would particularly matter whether you log the time as SIC or PIC. The qualifications for acting as such are the same, and joint legal responsibility (not to mention insurance or legal liability) would jointly lie between the two crew members.

MEMpilot

Its always been pretty clear a safety pilot can legally log PIC time. I don't understand what the fuss is about.

I was going to post the Rod Machado reference prior, so here it goes...

Rod Machado's Learn to Fly Page

NoyGonnaDoIt

Which also says that in ordre to log PIC the safety pilot must act as PIC. Quite correct. And talks about the safety pilot logging SIC.

Riddle me this:

How can you log PIC as safety pilot based on a reg that says:
==============================
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. 61.51(e)(1)(iii)
==============================

and not log SIC under a reg that says:

==============================
and more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is being conducted. 61.51(f)(2)
==============================

MEMpilot

Eh, FARs can become as murky as the US constitution...have you noticed?

The precedent is that one may log PIC time as a safety pilot. Just accept that.

You are acting as pilot in command on an aircraft on which more than one pilot is required under the type certification or the regulations under which the flight is conducted (this one needs a bit of explanation) To understand item #3 you must understand the difference between logging PIC and acting as the PIC. Keep in mind that FAR 91.109(b)1 wisely requires that a safety pilot be on board if the person flying is operating under simulated instrument conditions. Yes, I think this is a good rule, too. The regulations also require that one person on board the aircraft always act as PIC. This will be the person who is legally responsible for the operation of that aircraft. The person acting as the pilot in command can obviously log this time as PIC. On the other hand, the regulations also allow an additional person to log PIC if that person does something that generates experience of sufficient value. Here's an example.
Suppose you and a friend both have private pilot certificates with airplane, single-engine-land ratings. Let's also say that each of you is legally qualified to act as the legal PIC (meaning that you are both current, have current medicals, etc., etc.). Both of you hop into a Cessna 172 for a flight. Your friend wears a view-limiting device and is the sole manipulator of the flight controls while you act as the safety pilot.
In this instance, if your friend elects to act as the legal PIC as well as be the sole manipulator of the flight controls, then he alone logs the flight time as PIC while you log the time as second in command (SIC). [This is also the example where, if the airplane is either complex or high performance, and if you don't have a complex or high performance endorsement, then you can still act as safety pilot and log it as SIC since you're not acting as (the legal) PIC.]
On the other hand, you may elect to act as the safety pilot as well as the legal PIC while your friend is the sole manipulator of the controls. If so, then you can log the time as PIC and your friend can also log the time as PIC. Do you see why this is? Being the safety pilot doesn't mean you can automatically log the time as PIC. You must be willing to act as the legal PIC (as well as the safety pilot) to log this time as PIC. Since your friend is the sole manipulator of the controls, he gets to log PIC time as well. If anything goes wrong in this scenario, you're the one whose ticket will be on the line.
Here's another commonly asked question regarding the information above. Suppose you and the same friend go flying in that same Cessna 172 and no one wears a view-limiting device. Is there any situation where both of you log the time as PIC?
Sorry, but there's absolutely no way this can happen.
Yes, I realize that some folks suggest it's possible for both pilots to simultaneously log all the flight time as PIC here but the FAA doesn't seem to think so (and they are the folks who count in this instance). The only condition where these two pilots can log PIC is when one pilot is operating under simulated conditions as stated above.

NoyGonnaDoIt

I do. I never suggested otherwise.

But only if the safety pilot is the one acting as PIC as every source cited in this thread indicates (including the information you bolded in your post).

Foxy

I find it surprising that people are still debating this when there is a consensus view among the aviation press, the FAA spokespersons (spokespeople?!), and every FSDO rep I've seen quoted.

* You can log PIC as Safety Pilot, if:

1. A safety pilot is required by the regulations, and:
2. You are acting as the legal PIC, responsible for the safe outcome of the flight, during that portion of time when the 'Sole Manipulator' PIC is, er, solely manipulating the controls in simulated instrument flight*.

* You can log SIC (And only SIC) as Safety Pilot, if:

1. A safety pilot is required by the regulations, and:
2. You are not acting as the legal PIC, responsible for the safe outcome of the flight.

As to the initial question, I do not know the answer, but somebody did, and posted it. But as to this followup about logging PIC versus SIC for safety pilot time-- this is something we all should know and agree upon. All I'm doing here is re-stating what several others have said and trying to make it as clear as possible.
(But then, that's probably the goal of those who wrote the regs in the first place, and look where that got us..)

-Fox
*- Obviously, who is "legally" PIC needs to be agreed upon beforehand, and has oodles of considerations- Insurance, legal liability, responsibility.. and in the event of an accident, violation or incident, the FAA may decide that the person asleep in the back seat was the real PIC, so all bets are off. But as far as logging time, it's pretty straightforward: If you agreed before the flight that you were responsible for its safe outcome, then you may log PIC. If you did not, then you should (And are authorized to by the regulations above to) log SIC.

USMCFLYR

Good post Fox and you make it seem very clear - thanks.
Question though - - I'm use to signing for an airplane. The person who signs for the airplane is the AC Commander (mil PIC in this case) That person is the one who is responsible for the safe outcome of the flight as you say in the above bolded.
Back when I was flying GA - I thought I remembered signing for the aircraft too from the flight school. Is this not common? Did I remember wrong? How is this handled in your experience now? In this case - the private pilot who signed for the C-152 would fit the bill as you describe above. So if the safety pilot wanted to log that time as PIC then he would need to be the one to sign the plane out. Correct?
I did talk to some corporate pilots a while back and asked them the question about *signing* for the aircraft and they looked at me like I had sprouted horns.
It certainly wasn't the black and white that i am accustom too right now!

USMCFLYR