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Old 09-21-2009, 04:54 PM   #1  
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Default Logging SFTY Pilot Time

My friend and I went for a cross country here in south florida a few months ago. The total time was about 2.5 and he was the PIC. But me, however, acted as a safety pilot for about 0.9 of the total trip, so I logged 0.9 PIC time. My question is: Should I log it also as x-country time or not?

Its been a while since I made that flight, but today I was checking my logbook to make sure everything was alright and now Im not sure how should I log it. By the time I made that flight, I didn't log it as X-Country time... only PIC time.

Anyone knows?
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Old 09-21-2009, 07:15 PM   #2  
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Yes, you can log it as XC and/or night (but not IMC obviously).
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Old 09-22-2009, 03:27 AM   #3  
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Not Sure about logging as a X/C: Read below

Your letter presents an example to illustrate your questions. In the example, Pilot A and
Pilot B, who both are rated in the aircraft, take a flight between two airports that are
separated by 187 nautical miles. As agreed to prior to the flight, Pilot A flies the aircraft and
Pilot B acts as the PIC. Although the flight is conducted in visual meteorological
conditions, Pilot A operates the aircraft in simulated instrument flight with Pilot B acting as
a safety pilot. The total flight time is 2.2 hours and the total simulated instrument time is 2.0
hours. Your letter asks how much PIC flight time and cross-country flight time can be
logged by Pilots A and B.
Section 61.51(e) governs the logging of PIC time and states, in relevant part, that a sport,
recreational, private, or commercial pilot may log PIC time for the time during which that
pilot is "the sole manipulator of the controls of an aircraft for which the pilot is rated or has
privileges" or "acting as pilot in command of an aircraft on which more than one pilot is
required under ... the regulations under which the flight is conducted."
In your example, Pilot A may log the entire flight (2.2 hours) of PIC flight time because that
pilot was the sole manipulator of the controls for the entire flight. Pilot B may log the
portion of the flight during which Pilot A operated in simulated instrument flight and Pilot B
acted as the safety pilot (2.0 hours) because Pilot B was a required flight crewmember for
that portion of the flight under 14 C.F.R. 91.109(b).
Section 61.65 requires, in relevant part, that an applicant for an instrument rating log 50
hours of cross-country flight time as pilot in command. Cross-country time is defined in 14
C.F .R. 61.1 (b)(3)(ii) as time acquired during a flight conducted in an appropriate aircraft
that "includes a point oflanding that was at least a straight-line distance of more than 50
nautical miles from the original point of departure" and that "involves the use of dead
2
reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to
navigate to the landing point."
A safety pilot provides a visual reference to the ground and other aircraft during the portion
ofthe flight when the pilot manipulating the controls is flying with a view-limiting device.
As discussed above, the safety pilot is a required flight crewmember for only a portion of the
flight. Section 61.65(d) contemplates that only the pilot conducting the entire flight,
including takeoff, landing, and en route flight, as a required flight crewmember may log
cross-country flight time. Because a safety pilot does not conduct the entire flight, a person
acting as a safety pilot for a portion of the flight may not log any cross-country flight time
for the flight. In your example, Pilot A may log the entire flight (2.2 hours) of cross-country
flight time because that pilot conducted the entire flight. However, Pilot B may not log any
cross-country flight time because that pilot was a required flight crewmember for only a
portion of the flight.
This response was prepared by Robert Hawks, an Attorney in the Regulations Division of
the Office of Chief Counsel and coordinated with the Certification and General Aviation
Operations Branch of Flight Standards Service. We hope this response has been helpful to
you. If you have additional questions regarding this matter, please contact us at your
convenience at (202) 267-3073.
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Old 09-22-2009, 08:48 AM   #4  
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Wow, that's unusual. This is the first situation I have ever heard of where required crewmembers cannot log conditions of flight.

I'm willing to bet that a lot of folks are in violation of this interpretation.
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Old 09-22-2009, 10:54 AM   #5  
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Quote:
Originally Posted by rickair7777 View Post
Wow, that's unusual. This is the first situation I have ever heard of where required crewmembers cannot log conditions of flight.

I'm willing to bet that a lot of folks are in violation of this interpretation.
It's been an issue of contention for quite a while. The defunct Part 61 FAQ, which goes back more than 10 years, also said the safety pilot couldn't log cross country.

In both cases, the analysis is a bit shaky, but that's what you get with a results-oriented opinion.
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Old 09-22-2009, 12:49 PM   #6  
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Same for me Rick. This was just handed to me last week and we all were under the impression that you could log it as X/C and PIC.

Need a Law degree to interpret half the regulations, lol..
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Old 09-22-2009, 12:57 PM   #7  
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Quote:
Originally Posted by FlynPoPo View Post
Same for me Rick. This was just handed to me last week and we all were under the impression that you could log it as X/C and PIC.

Need a Law degree to interpret half the regulations, lol..
And that is why half of the regs don't use much common sense it would seem. If it gets this complicated, and people are relying on interpetations of the rules from the different FSDOs, it is no wonder that people are unknowingly in violation (or are they???) This isn't the only case in which I have heard that asking different FSDOs or even the FAA will garner you a variety of answers.
Thanks for the info in any case.d

USMCFLYR
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Old 09-22-2009, 02:54 PM   #8  
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I have all 400 plus pages of the old FAQs printed out (don't laugh, it makes good reading on those long XCs with a stiff headwind) and there are countless situations where just about everyone could be in violation of the FAA's conventional wisdom. Its actually informative and the answers are fairly well reasoned in contrast to about 99% of everything else from the Feds. I actually referenced a section today with our DPE to clear up a students logbook matter and the FSDO agreed. While not official legal interpretations, its sure beats saying "well I did it this way because someone on APC said I could." I'm sad they don't maintain it anymore.

I'd have to agree that cross country time doesn't apply when acting as safety pilot. The airplane might go from point A to point B but that has no bearing on what sole purpose and responsibility of a safety pilot is.
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Old 09-22-2009, 03:58 PM   #9  
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Alright thanks guys!! Then my logbook entries were correct!

Very Helpful!
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Old 09-22-2009, 04:33 PM   #10  
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Quote:
Originally Posted by ebuhoner View Post
My friend and I went for a cross country here in south florida a few months ago. The total time was about 2.5 and he was the PIC. But me, however, acted as a safety pilot for about 0.9 of the total trip, so I logged 0.9 PIC time. ?
I don't think that anyone responded to the PIC part.

In the scenario as you posted it, you can't log PIC time either. Logging PIC as a safety pilot is based on 61.51(e)(1)(iii) "is acting as pilot in command of an aircraft on which more than one pilot is required..."

IOW, in order to log PIC as a safety pilot, you need to be acting as PIC. You say in your post that the other pilot was the PIC, not you.

So you can't log PIC although, if you want, you may log the time as SIC under 61.51(f)(2)
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