Time logging follow-up

[James Carlson]

We had a lot more discussion about logging time than I expected.  I'd
like to clear some things up about this topic, if possible.  (Otherwise,
this is just fodder for next month's meeting.)

First, on logging SIC time: my memory was wrong here.  You certainly can
log SIC time while serving as a safety pilot.  The key words are in
61.51(f)(2):

  (f) Logging second-in-command flight time. A person may log
      second-in-command time only for that flight time during which that
      person:
    (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.

The key part there is the "or the regulations" phrase.  As a safety
pilot, you're a required crewmember, so you can log it as SIC time.  As
Russ pointed out, this may be a good option as you don't have the same
responsibility as SIC as you do when acting as PIC.

Second, on logging PIC time in aircraft for which you're not rated.
There was some discussion about this during the meeting, but I do not
believe that this is legal.  The issue here is about logging PIC time
while under the hood with an appropriately rated safety pilot on board.
The rule says this:

  When the pilot is the sole manipulator of the controls of an aircraft
  for which the pilot is rated, or has sport pilot privileges for that
  category and class of aircraft, if the aircraft class rating is
  appropriate;

The "or" part is set off by commas.  The rest says "aircraft for which
the pilot is rated if the aircraft class rating is appropriate."  The
definition of that "aircraft class" is from FAR 1.1:

  (1) As used with respect to the certification, ratings, privileges,
      and limitations of airmen, means a classification of aircraft
      within a category having similar operating characteristics.
      Examples include: single engine; multiengine; land; water;
      gyroplane; helicopter; airship; and free balloon; and

The part that may be confusing here is 61.129(b)(4), which allows time
spent "performing the duties of PIC" to be "credited" towards the
rating.  But this does not allow this time to be logged as PIC.  If
you're not rated, you can't log PIC time unless you're solo in the
aircraft.  (And being solo and unrated in a multi-engine aircraft is
somewhat rare.)


Some references provided by Russ Kelsea:

https://www.faa.gov/news/safety_briefing/2016/media/novdec2016.pdf
 (see page 16)

https://www.aopa.org/training-and-safety/learn-to-fly/logging-cross-country-time/logging-time-safety-pilot

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/data/interps/2012/trussell%20-%20(2012)%20legal%20interpretation.pdf

-- 
James Carlson         42.703N 71.076W         <carlsonj at workingcode.com>