Safety Pilot Time
Safety pilot is required by §91.109(c) when one pilot is utilizing a view limiting device for simulated instrument time. So, when might you use it? The original intention is to obtain the required instrument currency for instrument rated pilots. However, it can be used to build experience for both pilots. Be cautious however when logging the time, especially if you are using the time towards a certificate or rating. In some instances, you may not log some of the time. Let’s take a look.
The most common reason for splitting time is to build PIC time. PIC time is required for both the instrument rating and commercial pilot certificate. Both the instrument and commercial when conducted under part 61 requires 50 hours of PIC cross-country time. Let’s say Pilot A and Pilot B are planning a cross-country. Pilot A plans to fly from Airport 1 to Airport 2 under the hood. Pilot B plans to act as a safety pilot per §91.109(c). At Airport 2 they plan to switch roles. Pilot A conducts the takeoff from Airport 1, dons the hood, then makes the landing at Airport 2. Both pilots log PIC time and cross-country time. Is this legal?
Well…..We will assume both are private pilots ASEL and current. Under §91.109(c) No person may operate a civil aircraft in simulated instrument flight unless—
The other control seat is occupied by a safety pilot who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft being flown.
So, in order for Pilot A to log the simulated instrument time they require a safety pilot. Check.
Now let’s look at what is required to log cross-country. In part §61.1 cross-country means
(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under §61.101 (c), time acquired during a flight—
(A) Conducted in an appropriate aircraft;
(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and
(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.
In our scenario we will say the pilots went 100nm. It would appear that they both could log cross-country PIC. Here is the rub. (B) states a landing must be made. Since Pilot B did not make the landing they cannot log cross-country time. They can log PIC time when they are required by §91.109(c) to act as a safety pilot but they do not meet the requirements of §61.1 for cross-country time. If the flight from Airport 1 to Airport 2 took 2 hours to complete here is how the logging might break down:
Pilot A Pilot B
2.0 PIC 1.7 PIC
1.7 Sim Inst 0 Sim Inst
2.0 Cross-Country 0 Cross-Country
Notice pilot B cannot log the whole flight. I was generous with .3 less but the reality is there is run-up, takeoff and landing. As an examiner this is a quick item to check. If you only log 1 landing (assuming the other pilot flew back) but logged the whole flight…red flag. Cross-country logged for both legs but only 1.7 Sim Instrument…red flag.
What if the pilots switch mid-flight who is manipulating the controls, or both do a takeoff at the departure? DO NOT DO IT! In this case neither one of the pilots will qualify for cross-country time since neither conducted a takeoff or landing 50 nm from the departure point. (See Glenn Interp)
Aviation is expensive, or everyone would do it. When it comes to flight training everyone wants to save money. However, if it is substantial (as would be in this case assuming this is how these pilots logged all 50 cross-country hours they would have only really flown 25 hours of logable cross-country time) then it is probably not legal.
The FAA Chief Counsel has put out several Legal Interpretations on the subject. Here is a link to two notable Interpretations. Gebhart Glenn
Tailwinds,
Lance
