safety pilot ?'s

[Helihead]

91.109 ... says you need a safety pilot to conduct simulated instrument right .... but where can I find out that the safety pilot can log the time as PIC but not as cross country ... ohh yeah and if he logs the time as PIC if something goes wrong is it his fault?? since he/she would be the PIC.. I cant seem to find it 61.51?? any one want to help me out please ....oh and do both pilots log PIC and the safety pilot subtracts like .2 or for each approch or what?

[Superman]

61.51 and 61.55 covers it. If you are a Private or Commercial pilot then you need to log your safety pilot time as SIC. You are a required crewmember, but not acting as PIC, just along for the ride. The only way I know that you could log it as PIC is if you were a CFII.

 

Logging and acting as PIC are two totally different things

 

Fly Safe

Clark

[RockyMountainPilot]

If the safety pilot elects to be PIC then yes, they are responsible for the safety of the flight. They log PIC because they are acting PIC on a flight that requires more than one pilot as per the regulations. The pilot flying logs PIC because they are sole manipulator of the controls. If the safety pilots does not want to be PIC, then they are SIC and log it as such. The pilot flying is then acting as PIC. Whoever is ACTING as PIC is responsible for the safety of the flight. It doesn't matter who is logging the time. If you are letting your friend, who is rated, fly the aircraft and you are acting as PIC, they can log PIC because they are sole manipulator, but you can NOT log PIC. If they screw up, you are responsible.

[Helihead]

ok heres a unrelated question ... could you log SIC on a vfr flight in a 206 if two pilots are not needed...some one was talking about oil companies hiring SIC for bell 206 that didnt have to have 2 pilots... is that true or possible?

[RockyMountainPilot]

ok heres a unrelated question ... could you log SIC on a vfr flight in a 206 if two pilots are not needed...some one was talking about oil companies hiring SIC for bell 206 that didnt have to have 2 pilots... is that true or possible?

 

No, you can not log SIC because an SIC is not required as per the regulations or the type certificate. So, you may be the SIC for the company, but you can only log PIC when you are sole manipulator of the controls. They might swap controls so that each pilot gets to log some PIC.

[Jeff]

No, you can not log SIC because an SIC is not required as per the regulations or the type certificate. So, you may be the SIC for the company, but you can only log PIC when you are sole manipulator of the controls. They might swap controls so that each pilot gets to log some PIC.

 

If the company's operations manual requires a two-pilot crew, then the SIC can log SIC time. In a Part 135 operation, the flight crew must comply with the company's operations manual; therefore, the ops manual's requirement for a two-pilot crew constitutes "...or the regulations under which the flight is operated."

[RockyMountainPilot]

If the company's operations manual requires a two-pilot crew, then the SIC can log SIC time. In a Part 135 operation, the flight crew must comply with the company's operations manual; therefore, the ops manual's requirement for a two-pilot crew constitutes "...or the regulations under which the flight is operated."

 

I am not to sure about this. Do you have a reference?

 

Edit: After doing a bit of googling, I would have to agree with you. An OPSpecs does constitute as regulatory for that operation.

Edited July 8, 2007 by RockyMountainPilot

[Helihead]

thanks for clearing that up for me

[Gomer Pylot]

Ops Specs are entirely regulatory, and you can have certificate action taken against you by the FAA for failure to comply with Ops Specs even though the action might not be in contravention to any FAR. Once the FAA signs off on Part 135 Ops Specs, they become an extension of Part 135, and compliance is mandatory. They can help or hurt, depending on what they say. For instance, the company I used to work for had in its ops specs that a flashlight operated off 2 AA batteries was sufficient for night flight. That helped, because a helicopter isn't going to be flying for 5 or 6 hours without electrical power. Two hours is about as long as a flight can usually last, and the requirement for D cell flashlights is simply ridiculous, especially with modern LED lights. The company I work for now doesn't have that in writing, so there is a big MagLite stuck in a box in the cockpit, never used, because it has to be there for night flights. My AA LED light puts out more light for a lot longer, and is far more useful, so that's what I use, but the silly BFL has to be carried along as ballast.

 

I don't know if anyone's ops specs require an SIC in 206s, and I doubt if they will, because they will only be used by one or two customers, as a customer requirement, not an ops spec requirement. I expect that those SICs will be logging the time in any case.

[joker]

In addition to what Gomer and Jeff are saying, (and not wishing to sound like a pompous ass - as was recently accused!) here is the legal interpretation on this subject; a reference that RMP was looking for.

 

Note: FAR references are old..but general gist still stands.

 

I hope it helps.

 

Joker

 

March 26, 1992

 

 

Mr. Michael G. Tarsa

 

 

Dear Mr. Tarsa:

 

Thank you for your letter of April 3, 1991, in which you ask questions about logging pilot in command (PIC) and second in command (SIC) time when operating under Part 135 of the Federal Aviation Regulations (FAR). We apologize that staff shortages, regulatory matters, and interpretation requests received prior to yours prevented us from answering your questions sooner.

 

Your letter presents the following scenario: a Part 135 certificate holder conducts operations in multiengine airplanes under instrument flight rules (IFR). The operator has approval to conduct operations without an SIC using an approved autopilot under the provisions of FAR 135.105. The operator has assigned a fully qualified pilot, who has had a Part 135 competency check, to act as SIC in an aircraft that does not require two pilots under its type certification. Although FAR 135.101 requires an SIC for Part 135 operations in IFR conditions, the autopilot approval is an exception to that requirement.

 

You correctly state that while the SIC is flying the airplane, he can log PIC time in accordance with FAR 61.51©(2)(i) because he is appropriately rated and current, and is the sole manipulator of the controls. Additionally, he has passed the competency checks required for Part 135 operations, at least as SIC.

 

You then ask two questions. The first asks whether the pilot designated as PIC by the employer, as required by FAR 135.109, can log PIC time while the SIC is actually flying the airplane. The answer is yes.

 

FAR 1.1 defines pilot in command:

 

(1) Pilot in command means the pilot responsible for the operation and safety of an aircraft during flight time.

 

 

FAR 91.3 describes the pilot in command:

 

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

 

There is a difference between serving as PIC and logging PIC time. Part 61 deals with logging flight time, and it is important to note that section 61.51, Pilot logbooks, only regulates the recording of:

 

(a) The aeronautical training and experience used to meet the requirements for a certificate or rating, or the recent flight experience requirements of this part.

 

FAR 61.51© addresses logging of pilot time:

 

(2) Pilot in command flight time. (i) A recreational, private, or commercial pilot may log pilot in command time only that flight time during which that pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or when the pilot is the sole occupant of the aircraft, or, except for a recreational pilot, when 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.

 

(ii) An airline transport pilot may log as pilot in command time all of the flight time during which he acts as pilot in command.

 

(iii) (omitted).

 

(3) Second in command flight time. A pilot may log as second in command time all flight time during which he acts as second 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.

 

As you can see, there are two ways to log pilot in command flight time that are pertinent to your question. The first is as the pilot responsible for the safety and operation of an aircraft during flight time. If a pilot is designated as PIC for a flight by the certificate holder, as required by FAR 135.109, that person is pilot in command for the entire flight, no matter who is actually manipulating the controls of the aircraft, because that pilot is responsible for the safety and operation of the aircraft.

 

The second way to log PIC flight time that is pertinent to your question is to be the sole manipulator of the controls of an aircraft for which the pilot is rated, as you mention in your letter. Thus, a multiengine airplane flown under Part 135 by two pilots can have both pilots logging time as pilot in command when the appropriately rated second in command is manipulating the controls.

 

We stress, however, that here we are discussing logging of flight time for purposes of FAR 61.51, where you are keeping a record to show recent flight experience or to show that you meet the requirements for a higher rating. Your question does not say if the second pilot in your example is fully qualified as a PIC, or only as an SIC. This is important, because even though an SIC can log PIC time, that pilot has not qualified to serve as a PIC under Part 135.

 

An example of this difference is FAR 135.225(d), which raises IFR landing minimums for pilots in command of turbine powered airplanes flown under Part 135 who have not served at least 100 hours as PIC in that type of airplane. Served and logged are not the same in this context, and no matter how the SIC logs his time, he has not served as a PIC until he has completed the training and check rides necessary for certification as a Part 135 PIC.

 

Approval for single pilot operations with use of an operative approved autopilot system under FAR 135.105 gives an operator an additional option in the conduct of operations. It does not mandate that all future flights be conducted in that manner. The operator can elect to fly trips with two pilots, as is otherwise required for flight in IFR conditions under FAR 135.101, using the second in command instead of the autopilot.

 

Your second question asks if, under the circumstances given above, the SIC can log time as SIC when the designated pilot in command is flying the aircraft. The answer is yes, as long as the certificate holder is using the SIC as a crewmember instead of exercising the autopilot authorization. In other words, the certificate holder elects not to conduct an IFR flight using the single pilot with a functioning autopilot option, but rather conducts an IFR flight using two qualified pilots. The two pilots are then "required by the regulations under which the flight is conducted", FAR 61.51©(3), and the assumption is that the second pilot (SIC) will function as a required crewmember, and SIC time may validly be logged. However, if for some reason another qualified pilot "rides along" and does not function as a crewmember, then second in command time may not be validly logged.

This interpretation has been prepared by Arthur E. Jacobson, Staff Attorney, Operations Law Branch, Regulations and Enforcement Division; Richard C. Beitel, Manager. It has been coordinated with the Manager, Air Transportation Division, and the Manager, General Aviation and Commercial Division, Flight Standards Service.

 

We hope this satisfactorily answers your questions.

 

Sincerely,

 

 

Donald P. Byrne

Assistant Chief Counsel

Regulations and Enforcement Division

Edited July 9, 2007 by joker