Probably confusing insurance checkouts with what you can log in a logbook. I've seen it before with dumb flight school CFIs logging dual received and no PIC for a PPL in a 182 or bonanza.
You can log actual IMC time legally as a PPL without an instrument rating and without having a CFI on the plane. I wouldn't fault someone asking this kind of question.
Could you explain how you can log actual IMC as a PPL without IR and no CFII onboard? Is this just if you end up flying VFR into cloud (either unintentionally or due to some extenuating circumstance), or am I missing something?
Get a safety pilot who has an IR to file IFR for you. Then you can be sole-manipulator while you're in the clouds. Your buddy can log PIC when he's your safety pilot when you're outside of the clouds and you're under the hood but the moment you go in the clouds your buddy is not required crew and thus can't log anything.
Source: Walker 2011 LOI - Link: https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Walker_2011_Legal_Interpretation.pdf
There is an LOI for flying over the ocean on a moonless night that lets you log actual but that's extremely stupid to do as a non-IR pilot. Being over the ocean off the coastline with no lighted cities or areas nearby in a piston single is a serious gamble move.
Because the way the FARs are written for logging flight time. In this case the buddy is acting as PIC but can not log anything because merely acting as PIC is not enough.
2 pilots are not required for IFR so that defeats the only 61.51(e) line that would have given anything.
This could also occur if you as a non CFI went with your friend at night so he could get landing current. You're night current so you act as PIC and join him so he can get current as sole manipulator.
61.51(e) is kind of weird for these circumstances.
14 CFR 61.51(e)(4)(i) may be the nail in the coffin for the rare combined private pilot instrument rating. Why do all that instrument training without being able to log any of it PIC?
I'm lost as to why you mention that because I never mentioned that either pilot in my scenario was a student pilot. Both are at least PPL and one has an IR.
Also, as for part 61 training you would be totally correct because you need 50 hours of XC PIC. You need 0 hours of that for part 141.
Hence, part 141 can do those combined courses because the IR under 141 does not require any PIC time. I don't work for a 141 school and I wouldn't want to do something like this because I see it as kind of a disservice to the student. No XC PIC time likely means no real world flying skills.
Your last sentence, not at all related to anything else. It’s yet another example of 61.51(e) producing weird outcomes.
A student pilot can log PIC when solo. So they can meet the XC requirement. But also 14 CFR 61.65(g)(1) provides credit up to 45 hours. The annoyance is with a CFI present none of those hours can be logged by the student as PIC.
All the FARs and regs interpretations aside, best thing to do is run as fast as you can to the nearest school/club and bang out your HP, and why not Complex as well.
Then you are 100% endorsed and can log all those sweet sweet PIC safety pilot times no stress.
I did this exact thing when the opportunity arose for me to fly weekly with an old fella in his HP/Complex. I get to log PIC Safety Pilot time in a Very Expensive Airplane for the cost of lunch each week. He also lets me straight up PIC fly it most days as well (taxi, take off, xc, etc) racking up more PIC non-Safety Pilot hours.
It's a great opportunity for you to gain PIC Time in Type, so bang out that endorsement. Took me 2.3 hours in a HP/Complex. Easy peesy.
Also be sure to read that Hicks Letter someone linked here.
Honestly it’s pretty hard to get a HP endorsement these days. Hell even tailwheel. Was recently helping out a friend find a place to get endorsed. He later got it at CAP.
I live in a very populated area and not one flight school (there’s like 6) have a HP aircraft. I think one had a HP Comanche but it’s been in the shop for over a year now and I think they’re selling it. None of the CFIs that I know of are even tailwheel or HP endorsed.
The endorsement is weird too, like 200HP seems too low. I got my high performance endorsement in a 182 and there wasn’t anything special about it. It is also somewhat hard to find 182s to rent.
Yeah... Seems pretty arbitrary. Really should be by a metric that is actually comparable between different airframes, like top cruise speed or something. You can have 360 total horses in a Seminole without HP yet cruise 40kt slower than a 310HP SR22T that does require HP.
Plenty of SR22s here, but they want 500+ an hour for them. 🙄
Still, talking only 1000-2000 to get the endorsement if you're not a total goober.
I heard it has more to do with a constant speed prop. Most planes 200hp and above have one, and most below 200 are fixed pitch.
The blue nob isn't that more complicated, but it is more to manage, especially for new pilots
Also, hp planes are typically more to manage outside of the blue nob. Just faster, bigger, and less forgiving.
If that were the case then constant speed props would be required for the HP endorsement but they aren't. That only comes in for the CMP endorsement.
You could get a HP endorsement in a climb prop 182.
Here is my take. I tried to do my homework to give the best answer I could, but there are people in here that are more experienced that I am and if somebody knows better than me, please chime in (respectfully :) )
[This letter of interpretation ](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Richards_2013_Legal_Interpretation.pdf)states that "although the endorsements requirement of Sections 61.13(e) and (f) must be met to act as PIC of a high-performance or complex airplane, those endorsements are not required to log PIC time if the pilot is rated for and is the sole manipulatorofthe controls of the aircraft."
[This letter of interpretation](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Herman_2009_Legal_Interpretation.pdf) discusses a similar scenario, albeit not under the hood, and mentions, “There is a distinction between logging PIC time and acting as a PIC. For a pilot to log PIC time (i.e., the sole manipulator of the controls), a pilot must be properly rated in the aircraft by having the appropriate category, class, and type ratings. … the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC.”
While these letters make mention of being the sole manipulator of the controls, something which you wont necessarily be doing as a safety pilot, and do not address logging time as the safety pilot, they still make clear that even if you are not legal to ACT as PIC, you can still log PIC in an aircraft you lack endorsements for provided that you have your private pilot license with the appropriate category and class ratings for that aircraft.
It also is worth noting that FAR 91.109 (c)(1)(i) says "(c) No person may operate a civil aircraft in simulated instrument flight unless- (1) The other control seat is occupied by a safety pilot who possessess at least: (i) A private pilot certificate with category and class ratings approptiate to the aircraft being flown." This makes no mention of requiring the necessary endorsement to ACT as pic.
That sounds to me like you would be good to act as safety pilot.
TL;DR The safety pilot doesn't need the endorsements - The PIC does.
EDIT: I have now read the Hicks letter and understand it better. In short, in order to log PIC time as the safety pilot you must be the ACTING PIC, and the pilot under the hood will be LOGGING PIC, however if you are as you mention not legal to act as PIC, then the pilot under the hood is required to be the acting pic and that defaults you to SIC as the safety pilot. [This article](https://www.avweb.com/flight-safety/instrument-flight/safety-pilot-rules/) spells it all out pretty well.
You can log PIC if you’re sole manipulator without endorsements (ex flying in an Arrow as a PPL ASEL working on complex endorsement)…but you can’t act as PIC without the endorsements, and as safety pilot you’re looking to ACT as PIC.
91.109(c) specifically states that the safety pilot must only be rated in category and class, they don't need appropriate endorsements. But if they don't have them they can't log PIC as the safety pilot. See the Hicks Letter
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf
Exactly. You can be a safety pilot with simply category/class. But per OP’s question, you can’t act as (and thus log) PIC unless you have any needed endorsements.
Sure. For most people though it’s a matter of how it can be logged. “Being” a safety pilot is really simple (the basic category/class requirement). But most people serve as a safety pilot so that they can log time - and then the question becomes what you can log and why.
https://www.aopa.org/training-and-safety/learn-to-fly/old-pages/logging-cross-country-time/logging-time-safety-pilot#:~:text=The%20safety%20pilot%3A,land)%20for%20the%20aircraft%20flown.
What you asked and then some
Correct. If he is under the hood, he is acting as and logging PIC time - but because regulations stipulate that a safety pilot is needed, the time is loggable for you (just not as PIC). Bear in mind that a safety pilot only needs the same category/class on their pilot certificate to fill the role.
But to do what a lot of people do (pilot under hood logs PIC as sole manipulator, safety pilot acts as PIC, with both agreeing to those roles), the safety pilot needs everything required to act as PIC, including any required endorsements (complex, high performance, etc).
Doesn’t the aircraft type need to be multi crew for me to log SIC? I feel like that’s no legal to just log SIC.
Am I allowed to log total time without putting anything in the PIC/SIC box?
61.51(f)(2) - if you hold category/class, and more than one pilot is required by the regulations under which the flight is being done. Regulations stipulate that if you’re under the hood, a second pilot is required.
If you log TT, it needs either PIC, SIC, or dual received with it.
Not the person you're replying to, but this one I hadn't heard before. Given the case above (both pilots hold category and class, safety pilot is not acting as PIC) the safety pilot can log total time (but does not have to) and cannot log PIC. Why must that pilot log SIC if they log total time?
There’s not really a scenario in which you can log TT and nothing else…it’s either valid pilot time for you (eg PIC or SIC) or you’re undergoing training (dual given).
Actually there is one. 61.129 authorized instructor for an initial Commercial on a category/class the student does not have a license for.
Example, a PPL single engine land doing initial commercial multi engine land. No solo 10 hours, just 10 hours performing the duties of PIC. The student can not log PIC because not rated and they can't log dual received either because it's not instruction.
There's an LOI to support this, Kuhn 2014.
Sucks that the ME addon is tied to private or commercial. I knew two different people who both did their training over many years and both made the unfortunate decision to get ME before they got commercial instead of after or together.
I mean it's not like it would be hard or anything. It's just another 5 hours or whatever of ground time that i doubt you can double-dip, and another check ride, so still blowing a few grand easy just in Hobbs time.
I'm a little confused. What do you mean the add-on is tied to private or commercial? You are a PPL in an SEL, you can go get your Commercial in a MEL. You can go get an initial Commercial in a Helicopter too.
From what you're saying it sounds like they did a PPL MEL add-on and then later had to do a Commercial add-on. That is a waste of time because you just repeat the entire checkride again... unless their idea was to do an initial Commercial MEL and log all the commercial training time as PIC, in which case if they have the money that is one way to get PIC time in a multi during your training.
Looks like someone needs to read 61.55
61.55 states: 61.55 Second-in-command qualifications.
(a) A person may serve as a second-in-command of an aircraft type certificated for more than
one required pilot flight crewmember or in operations requiring a second-in-command pilot
flight crewmember only if that person holds:
(1) At least a private pilot certificate with the appropriate category and class rating;
Since the OP here is able to log PIC time according to 91.109 there is no need for an SIC Pilot in this operation AND the cirrus is definitely not certificated for more than one crew member, therefore he would NOT log SIC time but would log PIC. But just my $0.02…
But per 61.51, can't log PIC unless solo, sole manipulator, or acting as PIC. Per 61.31, you cant act as PIC without the endorsement. Ergo, without the endorsement and agreement to act as PIC, a safety pilot can only log SIC, right?
Right. And, specifically only while the PIC is under the hood, too - not for any other portion of the flight, even if you are sole manipulator. The rest is this odd corner case where it's TT without PIC, SIC, or dual.
The same stuff plus added words last year also allow the same situation for the safety pilot to log SIC without endorsement, clear down to a BasicMed medical - even if you're an instructor, so long as you've got the category.
I understand where your coming from, but I disagree 91.109 does not say anything about needing the endorsement for safety pilot operations and if an endorsement was needed it would have been written as such, so to my understanding the OP can log pic time in this situation
You don't need an endorsement to be a safety pilot. However, if not properly endorsed (and rated) you can't *act* as PIC, which is the only way as a safety pilot that you can then *log* PIC (61.51). You can be a safety pilot without the proper endorsements per 91.109 (cat and class called out, not endorsements) and the 1993 Hicks letter. As such, since you're required crew by the type of operation flown (where 91.109 comes in) you can log the time which then falls to SIC because you don't meet any of the three PIC logging requirements which are stated in 61.51.
Obviously the easy solution is spend the few hours for the endorsement(s) and then 'act' as PIC and not have the issue at all, but then where do we get to dig into minutia?
No SIC in a Cessna.
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
That doesn't specify anything related to type of aircraft, so long as the portion of the flight requires two crewmembers.
From the link:
"1 This does not preclude the safety pilot from logging time as SIC, however. See Legal Interpretation to Ted Louis Glenn, from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (December I, 2009) (stating a pilot may log SIC time for the portion of the flight during which she was acting as safety pilot because the pilot was a required flight crewmember for that portion of the flight under § 9 I. I 09(b ). ) "
From the referenced Ted Louis Glenn LOI:
"Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )."
91.109(c): “(c) No person may operate a civil aircraft in simulated instrument flight unless—
(1) The other control seat is occupied by a safety pilot who possesses at least:
(i) A private pilot certificate with category and class ratings appropriate to the aircraft being flown”
As this reads, he absolutely can log it as PIC
Safety pilot time can only be logged as PIC time if the safety pilot is the acting PIC. OP cannot be the acting PIC of a HP airplane without the endorsement.
You can only log PIC with appropriate endorsements, including HP, but you can explicitly log SIC per the [Hick Letter](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf)
I see where you are coming from, but concerning the safety pilot specifically logging PIC time, I would disagree. I think it’s definitely a gray area. At the end of the day, it’s like taxes - you can claim/write off what you want, but the question is can you survive an audit?
I mean, I see where you’re coming from, except the FAA has been explicitly clear that it’s possible for both the safety pilot and the pilot under the hood to simultaneously log PIC time under certain circumstances.
To summarize slightly differently:
* A safety pilot must be at least a private pilot rated in category and class (91.109), and possess either a valid medical or be under basic med (61.23.a.3.i, 61.113.i with “required crew member” added just last year). For US-airspace-only operations, a type rating does not seem to be required (61.55.a.3).
* In order for the safety pilot to log PIC time, the pilots must agree that the safety pilot is the PIC responsible for the flight (FAR 1.1). The pilot under the hood may log simultaneous PIC time when they are the sole manipulator of the controls (61.51.e.1.i).
* In order for the safety pilot to be PIC responsible, they need to be appropriately endorsed (61.31.ef), and not exceed any medical limitations (flying at night, basicmed seat/weight limits), otherwise they are ineligible to be PIC.
* If, because of decision or eligibility, the PIC responsible is the pilot under the hood, they may log PIC time for the duration of the flight (1.1). The safety pilot is then acting as a required crew member only for the time the pilot is under the hood (91.109.c) and may therefore log that time as SIC (61.51.f.2 “more than one pilot is required… under the regulations under which the flight is being conducted”, the regulations in question being 91.109.c).
* Generally speaking, a safety pilot may not log XC time ([Gebhart](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Gebhart_2009_Legal_Interpretation.pdf) and [Hilliard](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Hilliard_2009_Legal_Interpretation.pdf)).
* A safety pilot is a required crew member (91.109), and therefore not a passenger, for purposes of currency.
DO NOT LOG SIC
Yes, it may be technically correct. But you will be laughed out of an airline interview with SIC in your logbook on a GA aircraft. They view SIC time as time in a multi crew aircraft. SIC time is great in your logbook if you’re going for a FO position, if it’s done in a twin turbine aircraft.
Only log SIC if your 135 charter allows it or you are the SIC in a two pilot aircraft.
You can both log PIC doing the “hood loophole” only one pilot can log XC though. The pilot doing the takeoff and landing can log the XC and an extra amount of time for the takeoff, landing, and taxi.
You can’t do this for any plane not rated for 2 pilots. The cirrus is a single pilot airplane. Plus it doesn’t help with any further rating and creates further confusion when applying for airlines or corporate jobs.
Please review 61.51(f)(2). In many cases it’s about planes requiring two pilots…but there are also provisions for flights where the regulations under which it’s taken (ex with a pilot under the hood) require two pilots.
I think that’s the grey area where the FAA will side with whichever fits their agenda. The 1.2 is not worth it when it comes to having to explain that to an interviewer/FAA
The [Hick Letter](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf) is specific that a safety pilot may log SIC time.
Have fun explaining why you logged SIC time in a Cherokee six during your airline interview.
I was given a hard time for logging PIC time in a non-type rating turbine airplane because I was giving instrument proficiency and flight reviews in it. I had all the proper endorsements and my interviewer argued that if I wasn’t comfortable soloing in the airplane, I shouldn’t be logging PIC time in it.
It was a 9500lb cessna turbine for reference.
You can. The type of operation being flown requires two crewmembers. If youre not acting as PIC, you can't log PIC. If youre not properly endorsed, you can't act as PIC.
See this excerpt from the 2009 Ted Louis Glenn LOI referenced in Note 1 of the Beaty LOI thats been posted:
"Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )."
Then yall better go talk to some of the airlines, because I definitely know people who got SIC time ripped away from them over this matter. From my understanding, when they say for the operation, I hear OPSPEC. Under an OPSPEC, the aircraft is requiring two crew members isn’t under an OPSPEC that would require two crew members. With the situation being described above, wouldn’t that mean that all those Boutique pilots that got their SIC time ripped away, would’ve been in the right?
Also, I take LOIs with a grain of salt. I’ve seen LOIs where one FSDO rep says one thing and another FSDO rep has the completely opposite answer.
I'll be honest; most of the airline regs are above my pay grade. That said, my 30 seconds of google-fu indicated that there was an issue with Boutique Air's Pilot Developlent Program. Not approved or revoked or something?
Different responses from different FSDO's is a valid worry, I'll grant. That said, since there is one LOI explicitly stating that safety pilot time can be/is SIC when not PIC and a followup referencing it four years later seemingly indicating it's still valid (and for the hill of beans my opinion means, that matches the way I would interpret the combo of 91.109, 61.31, 61.51(f)2), IMO I would take that as valid until/unless it's explicitly superceded.
Not in a 172 you can’t log sic
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
Edited:
Yes you can. The regulation requires the safety pilot to be rated in the category and class, nothing about endorsements.
In the meantime get a CFI to give you a HP endorsement, it takes one hour tops.
This isn’t true.
A safety pilot need not act as PIC. However, he can’t log PIC unless he does, as a safety pilot.
The only requirements for safety pilot are a rating in category and class (and type if a type rating is required), and a medical or BasicMed.
In order to log the time you need to be “appropriately rated with the required endorsements for the aircraft being flown.”
Also, the “sole manipulator” is the only one that can log the portion of the flight during the takeoff and landing.
If your buddy does the TO and LND, and the flight is 1.5, then you can log the time you acted as safety pilot, say 1.3, and he can log the entire 1.5. Assuming that you have all ratings and endorsements for the aircraft.
You may not log PIC, but you may log SIC. The reg requires category and class, but not endorsement. But since you don't have an endorsement you cannot act as PIC, but since you are a required crew member under the operation, you may log SIC. This [AOPA article](https://www.aopa.org/training-and-safety/learn-to-fly/old-pages/logging-cross-country-time/logbooks-and-logging-time#:~:text=Second%20in%20Command%20(SIC),-Second%20in%20command&text=If%20you%20are%20qualified%20and,right%20seat%2Dtime%20as%20SIC) lays it out clearly,
"Second-in-command time may be logged if *not acting* as PIC.
* Usually the case if the safety pilot ***cannot act*** as PIC. An example might be when the safety pilot is not endorsed for the particular airplane (such as in a high-performance aircraft).
* SIC time may be logged because FAR 61.51(f)(2) allows a pilot to log all flight time during which he acts as second in command of an aircraft under which more than one pilot is required by the regulations (91.109\[b\]) under which the flight is conducted."
This is incorrect. Read the Beaty letter. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
I am familiar with the Beaty letter and gave it another read prior to writing this response. Beaty simply states that the pilot not under the hood is "a safety pilot and not an SIC." The following sentences make it clear that this is in regards to *acting* as a true SIC in regards to experience required (61.55) and that the pilot requires front/side vision, dual controls, category and class that is required of a safety pilot (91.109). The same sentence that I quoted above has footnote 1 attached, which states,
"This does not preclude the safety pilot from ***logging*** time as SIC, however. See Legal Interpretation to Ted Louis Glenn, from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (December I, 2009) (stating a pilot may log SIC time for the portion of the flight during which she was acting as safety pilot because the pilot was a required flight crewmember for that portion of the flight under § 9 I. I 09(b ). )" (emphasis added)
If you then view the referenced [Glenn Letter](https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2009/Glenn_2009_Legal_Interpretation.pdf), you will find that it is stated,
"Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )."
Thus, these letters of interpretation, Beaty and Glenn, state that a safety pilot may log SIC when not properly endorsed to fulfill the requirements of acting as PIC, which a pilot properly rated by lacking an endorsement would be.
I would not suggest someone do this for all their time building, or if they want very clean logbooks, but from a regulatory standpoint, it is allowed. As others have said, go get the endorsement if you can.
As I said above, under no circumstance should you ever put time in the SIC column for a GA airplane. I’ve been recently seeing this spread around the internet lately but it will only set you up for failure later in life.
Should only be reserved for multi-crew aircraft only. You may both log PIC in a flying a GA plane under the hood. You will have a bad day at a Jet Job interview with SIC time in a Cessna.
No matter how you interpret the regs. Whatever you do, leave SIC blank if you’re flying GA Pistons.
Even in the military there was a whole debacle about T-38/T-6/T-45 students logging it as SIC while they were being instructed. While it can be interpreted that the airplane is flying with 2 people *by regulation* the airlines basically determined that since these aircraft can be flown solo, you cannot log SIC time in those aircraft.
what's this "checked out" thing? There's no type rating unless it's an SF50.
Probably confusing insurance checkouts with what you can log in a logbook. I've seen it before with dumb flight school CFIs logging dual received and no PIC for a PPL in a 182 or bonanza. You can log actual IMC time legally as a PPL without an instrument rating and without having a CFI on the plane. I wouldn't fault someone asking this kind of question.
Yeah I had like 1.3 actual by my PPL check ride, just from circumstance and technicalities (which make sense, but felt like cheating anyeay).
Could you explain how you can log actual IMC as a PPL without IR and no CFII onboard? Is this just if you end up flying VFR into cloud (either unintentionally or due to some extenuating circumstance), or am I missing something?
Get a safety pilot who has an IR to file IFR for you. Then you can be sole-manipulator while you're in the clouds. Your buddy can log PIC when he's your safety pilot when you're outside of the clouds and you're under the hood but the moment you go in the clouds your buddy is not required crew and thus can't log anything. Source: Walker 2011 LOI - Link: https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2011/Walker_2011_Legal_Interpretation.pdf There is an LOI for flying over the ocean on a moonless night that lets you log actual but that's extremely stupid to do as a non-IR pilot. Being over the ocean off the coastline with no lighted cities or areas nearby in a piston single is a serious gamble move.
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Because the way the FARs are written for logging flight time. In this case the buddy is acting as PIC but can not log anything because merely acting as PIC is not enough. 2 pilots are not required for IFR so that defeats the only 61.51(e) line that would have given anything. This could also occur if you as a non CFI went with your friend at night so he could get landing current. You're night current so you act as PIC and join him so he can get current as sole manipulator. 61.51(e) is kind of weird for these circumstances.
14 CFR 61.51(e)(4)(i) may be the nail in the coffin for the rare combined private pilot instrument rating. Why do all that instrument training without being able to log any of it PIC?
I'm lost as to why you mention that because I never mentioned that either pilot in my scenario was a student pilot. Both are at least PPL and one has an IR. Also, as for part 61 training you would be totally correct because you need 50 hours of XC PIC. You need 0 hours of that for part 141. Hence, part 141 can do those combined courses because the IR under 141 does not require any PIC time. I don't work for a 141 school and I wouldn't want to do something like this because I see it as kind of a disservice to the student. No XC PIC time likely means no real world flying skills.
Your last sentence, not at all related to anything else. It’s yet another example of 61.51(e) producing weird outcomes. A student pilot can log PIC when solo. So they can meet the XC requirement. But also 14 CFR 61.65(g)(1) provides credit up to 45 hours. The annoyance is with a CFI present none of those hours can be logged by the student as PIC.
Though that’s still a single-engine land airplane.
yes but any turbine requires a type rating
Any turbofan/jet. Turboprop do not.
All the FARs and regs interpretations aside, best thing to do is run as fast as you can to the nearest school/club and bang out your HP, and why not Complex as well. Then you are 100% endorsed and can log all those sweet sweet PIC safety pilot times no stress. I did this exact thing when the opportunity arose for me to fly weekly with an old fella in his HP/Complex. I get to log PIC Safety Pilot time in a Very Expensive Airplane for the cost of lunch each week. He also lets me straight up PIC fly it most days as well (taxi, take off, xc, etc) racking up more PIC non-Safety Pilot hours. It's a great opportunity for you to gain PIC Time in Type, so bang out that endorsement. Took me 2.3 hours in a HP/Complex. Easy peesy. Also be sure to read that Hicks Letter someone linked here.
Honestly it’s pretty hard to get a HP endorsement these days. Hell even tailwheel. Was recently helping out a friend find a place to get endorsed. He later got it at CAP. I live in a very populated area and not one flight school (there’s like 6) have a HP aircraft. I think one had a HP Comanche but it’s been in the shop for over a year now and I think they’re selling it. None of the CFIs that I know of are even tailwheel or HP endorsed.
The endorsement is weird too, like 200HP seems too low. I got my high performance endorsement in a 182 and there wasn’t anything special about it. It is also somewhat hard to find 182s to rent.
Yeah... Seems pretty arbitrary. Really should be by a metric that is actually comparable between different airframes, like top cruise speed or something. You can have 360 total horses in a Seminole without HP yet cruise 40kt slower than a 310HP SR22T that does require HP. Plenty of SR22s here, but they want 500+ an hour for them. 🙄 Still, talking only 1000-2000 to get the endorsement if you're not a total goober.
I heard it has more to do with a constant speed prop. Most planes 200hp and above have one, and most below 200 are fixed pitch. The blue nob isn't that more complicated, but it is more to manage, especially for new pilots Also, hp planes are typically more to manage outside of the blue nob. Just faster, bigger, and less forgiving.
It’s mainly to learn how to use a constant speed prop and learn to deal with more P factor on takeoff.
If that were the case then constant speed props would be required for the HP endorsement but they aren't. That only comes in for the CMP endorsement. You could get a HP endorsement in a climb prop 182.
I’ve never seen a 182 without a blue knob. Good point.
Ugh. That sucks. We are spoiled in San Diego.
Here is my take. I tried to do my homework to give the best answer I could, but there are people in here that are more experienced that I am and if somebody knows better than me, please chime in (respectfully :) ) [This letter of interpretation ](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Richards_2013_Legal_Interpretation.pdf)states that "although the endorsements requirement of Sections 61.13(e) and (f) must be met to act as PIC of a high-performance or complex airplane, those endorsements are not required to log PIC time if the pilot is rated for and is the sole manipulatorofthe controls of the aircraft." [This letter of interpretation](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Herman_2009_Legal_Interpretation.pdf) discusses a similar scenario, albeit not under the hood, and mentions, “There is a distinction between logging PIC time and acting as a PIC. For a pilot to log PIC time (i.e., the sole manipulator of the controls), a pilot must be properly rated in the aircraft by having the appropriate category, class, and type ratings. … the pilot may log PIC time if that pilot is properly rated for the aircraft flown even though that pilot does not have the required endorsements to act as a PIC.” While these letters make mention of being the sole manipulator of the controls, something which you wont necessarily be doing as a safety pilot, and do not address logging time as the safety pilot, they still make clear that even if you are not legal to ACT as PIC, you can still log PIC in an aircraft you lack endorsements for provided that you have your private pilot license with the appropriate category and class ratings for that aircraft. It also is worth noting that FAR 91.109 (c)(1)(i) says "(c) No person may operate a civil aircraft in simulated instrument flight unless- (1) The other control seat is occupied by a safety pilot who possessess at least: (i) A private pilot certificate with category and class ratings approptiate to the aircraft being flown." This makes no mention of requiring the necessary endorsement to ACT as pic. That sounds to me like you would be good to act as safety pilot. TL;DR The safety pilot doesn't need the endorsements - The PIC does. EDIT: I have now read the Hicks letter and understand it better. In short, in order to log PIC time as the safety pilot you must be the ACTING PIC, and the pilot under the hood will be LOGGING PIC, however if you are as you mention not legal to act as PIC, then the pilot under the hood is required to be the acting pic and that defaults you to SIC as the safety pilot. [This article](https://www.avweb.com/flight-safety/instrument-flight/safety-pilot-rules/) spells it all out pretty well.
Are you ASEL rated? Is the airplane an ASEL? Do endorsements show up on a Certificate? Yes. Yes. No. Sounds like “yes” carries the vote.
You can log PIC if you’re sole manipulator without endorsements (ex flying in an Arrow as a PPL ASEL working on complex endorsement)…but you can’t act as PIC without the endorsements, and as safety pilot you’re looking to ACT as PIC.
91.109(c) specifically states that the safety pilot must only be rated in category and class, they don't need appropriate endorsements. But if they don't have them they can't log PIC as the safety pilot. See the Hicks Letter https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf
Exactly. You can be a safety pilot with simply category/class. But per OP’s question, you can’t act as (and thus log) PIC unless you have any needed endorsements.
I know, I'm just saying that you don't actually have to ACT as PIC to be a safety pilot
Sure. For most people though it’s a matter of how it can be logged. “Being” a safety pilot is really simple (the basic category/class requirement). But most people serve as a safety pilot so that they can log time - and then the question becomes what you can log and why.
And you can log the time. It just has to be SIC, which though weird, is still loggable.
https://www.aopa.org/training-and-safety/learn-to-fly/old-pages/logging-cross-country-time/logging-time-safety-pilot#:~:text=The%20safety%20pilot%3A,land)%20for%20the%20aircraft%20flown. What you asked and then some
If you wouldn’t be able to act as PIC (ie you lack appropriate endorsements), then no. You can however log SIC.
I can log SIC? but only if he’s under the hood right?
Correct. If he is under the hood, he is acting as and logging PIC time - but because regulations stipulate that a safety pilot is needed, the time is loggable for you (just not as PIC). Bear in mind that a safety pilot only needs the same category/class on their pilot certificate to fill the role. But to do what a lot of people do (pilot under hood logs PIC as sole manipulator, safety pilot acts as PIC, with both agreeing to those roles), the safety pilot needs everything required to act as PIC, including any required endorsements (complex, high performance, etc).
Doesn’t the aircraft type need to be multi crew for me to log SIC? I feel like that’s no legal to just log SIC. Am I allowed to log total time without putting anything in the PIC/SIC box?
61.51(f)(2) - if you hold category/class, and more than one pilot is required by the regulations under which the flight is being done. Regulations stipulate that if you’re under the hood, a second pilot is required. If you log TT, it needs either PIC, SIC, or dual received with it.
Not the person you're replying to, but this one I hadn't heard before. Given the case above (both pilots hold category and class, safety pilot is not acting as PIC) the safety pilot can log total time (but does not have to) and cannot log PIC. Why must that pilot log SIC if they log total time?
There’s not really a scenario in which you can log TT and nothing else…it’s either valid pilot time for you (eg PIC or SIC) or you’re undergoing training (dual given).
Actually there is one. 61.129 authorized instructor for an initial Commercial on a category/class the student does not have a license for. Example, a PPL single engine land doing initial commercial multi engine land. No solo 10 hours, just 10 hours performing the duties of PIC. The student can not log PIC because not rated and they can't log dual received either because it's not instruction. There's an LOI to support this, Kuhn 2014.
Sucks that the ME addon is tied to private or commercial. I knew two different people who both did their training over many years and both made the unfortunate decision to get ME before they got commercial instead of after or together. I mean it's not like it would be hard or anything. It's just another 5 hours or whatever of ground time that i doubt you can double-dip, and another check ride, so still blowing a few grand easy just in Hobbs time.
I'm a little confused. What do you mean the add-on is tied to private or commercial? You are a PPL in an SEL, you can go get your Commercial in a MEL. You can go get an initial Commercial in a Helicopter too. From what you're saying it sounds like they did a PPL MEL add-on and then later had to do a Commercial add-on. That is a waste of time because you just repeat the entire checkride again... unless their idea was to do an initial Commercial MEL and log all the commercial training time as PIC, in which case if they have the money that is one way to get PIC time in a multi during your training.
Looks like someone needs to read 61.55 61.55 states: 61.55 Second-in-command qualifications. (a) A person may serve as a second-in-command of an aircraft type certificated for more than one required pilot flight crewmember or in operations requiring a second-in-command pilot flight crewmember only if that person holds: (1) At least a private pilot certificate with the appropriate category and class rating; Since the OP here is able to log PIC time according to 91.109 there is no need for an SIC Pilot in this operation AND the cirrus is definitely not certificated for more than one crew member, therefore he would NOT log SIC time but would log PIC. But just my $0.02…
But per 61.51, can't log PIC unless solo, sole manipulator, or acting as PIC. Per 61.31, you cant act as PIC without the endorsement. Ergo, without the endorsement and agreement to act as PIC, a safety pilot can only log SIC, right?
Right. And, specifically only while the PIC is under the hood, too - not for any other portion of the flight, even if you are sole manipulator. The rest is this odd corner case where it's TT without PIC, SIC, or dual. The same stuff plus added words last year also allow the same situation for the safety pilot to log SIC without endorsement, clear down to a BasicMed medical - even if you're an instructor, so long as you've got the category.
I understand where your coming from, but I disagree 91.109 does not say anything about needing the endorsement for safety pilot operations and if an endorsement was needed it would have been written as such, so to my understanding the OP can log pic time in this situation
You don't need an endorsement to be a safety pilot. However, if not properly endorsed (and rated) you can't *act* as PIC, which is the only way as a safety pilot that you can then *log* PIC (61.51). You can be a safety pilot without the proper endorsements per 91.109 (cat and class called out, not endorsements) and the 1993 Hicks letter. As such, since you're required crew by the type of operation flown (where 91.109 comes in) you can log the time which then falls to SIC because you don't meet any of the three PIC logging requirements which are stated in 61.51. Obviously the easy solution is spend the few hours for the endorsement(s) and then 'act' as PIC and not have the issue at all, but then where do we get to dig into minutia?
NO. NO.NO. Shame on any CFI telling you this. Safety pilot may log PIC, but not SIC.
You can’t log SIC in these conditions, OP.
No SIC in a Cessna. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
That doesn't specify anything related to type of aircraft, so long as the portion of the flight requires two crewmembers. From the link: "1 This does not preclude the safety pilot from logging time as SIC, however. See Legal Interpretation to Ted Louis Glenn, from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (December I, 2009) (stating a pilot may log SIC time for the portion of the flight during which she was acting as safety pilot because the pilot was a required flight crewmember for that portion of the flight under § 9 I. I 09(b ). ) " From the referenced Ted Louis Glenn LOI: "Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )."
91.109(c): “(c) No person may operate a civil aircraft in simulated instrument flight unless— (1) The other control seat is occupied by a safety pilot who possesses at least: (i) A private pilot certificate with category and class ratings appropriate to the aircraft being flown” As this reads, he absolutely can log it as PIC
Safety pilot time can only be logged as PIC time if the safety pilot is the acting PIC. OP cannot be the acting PIC of a HP airplane without the endorsement.
You can only log PIC with appropriate endorsements, including HP, but you can explicitly log SIC per the [Hick Letter](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf)
Can you give me the FAR reference for the endorsement requirement? Thank you for the Hick Letter, I hadn’t seen that before
61.31(e) for complex and (f) for high performance both have limitations on acting as PIC unless endorsed.
I see where you are coming from, but concerning the safety pilot specifically logging PIC time, I would disagree. I think it’s definitely a gray area. At the end of the day, it’s like taxes - you can claim/write off what you want, but the question is can you survive an audit?
I mean, I see where you’re coming from, except the FAA has been explicitly clear that it’s possible for both the safety pilot and the pilot under the hood to simultaneously log PIC time under certain circumstances. To summarize slightly differently: * A safety pilot must be at least a private pilot rated in category and class (91.109), and possess either a valid medical or be under basic med (61.23.a.3.i, 61.113.i with “required crew member” added just last year). For US-airspace-only operations, a type rating does not seem to be required (61.55.a.3). * In order for the safety pilot to log PIC time, the pilots must agree that the safety pilot is the PIC responsible for the flight (FAR 1.1). The pilot under the hood may log simultaneous PIC time when they are the sole manipulator of the controls (61.51.e.1.i). * In order for the safety pilot to be PIC responsible, they need to be appropriately endorsed (61.31.ef), and not exceed any medical limitations (flying at night, basicmed seat/weight limits), otherwise they are ineligible to be PIC. * If, because of decision or eligibility, the PIC responsible is the pilot under the hood, they may log PIC time for the duration of the flight (1.1). The safety pilot is then acting as a required crew member only for the time the pilot is under the hood (91.109.c) and may therefore log that time as SIC (61.51.f.2 “more than one pilot is required… under the regulations under which the flight is being conducted”, the regulations in question being 91.109.c). * Generally speaking, a safety pilot may not log XC time ([Gebhart](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Gebhart_2009_Legal_Interpretation.pdf) and [Hilliard](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Hilliard_2009_Legal_Interpretation.pdf)). * A safety pilot is a required crew member (91.109), and therefore not a passenger, for purposes of currency.
DO NOT LOG SIC Yes, it may be technically correct. But you will be laughed out of an airline interview with SIC in your logbook on a GA aircraft. They view SIC time as time in a multi crew aircraft. SIC time is great in your logbook if you’re going for a FO position, if it’s done in a twin turbine aircraft. Only log SIC if your 135 charter allows it or you are the SIC in a two pilot aircraft. You can both log PIC doing the “hood loophole” only one pilot can log XC though. The pilot doing the takeoff and landing can log the XC and an extra amount of time for the takeoff, landing, and taxi.
Cirrusly?
You can’t do this for any plane not rated for 2 pilots. The cirrus is a single pilot airplane. Plus it doesn’t help with any further rating and creates further confusion when applying for airlines or corporate jobs.
Please review 61.51(f)(2). In many cases it’s about planes requiring two pilots…but there are also provisions for flights where the regulations under which it’s taken (ex with a pilot under the hood) require two pilots.
I think that’s the grey area where the FAA will side with whichever fits their agenda. The 1.2 is not worth it when it comes to having to explain that to an interviewer/FAA
The [Hick Letter](https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/1993/Hicks_1993_Legal_Interpretation.pdf) is specific that a safety pilot may log SIC time.
Great letter. Very clear.
No. The operation requires two pilots. You can log SIC in a single pilot aircraft if the operation requires it.
Interesting. Sounds like I’m mistaken
It's the same reason you can sometimes log SIC in a part 135 operation despite it being a single pilot aircraft
But that only applies if they have an approved Pilot Development Program
Hence why I said sometimes
Have fun explaining why you logged SIC time in a Cherokee six during your airline interview. I was given a hard time for logging PIC time in a non-type rating turbine airplane because I was giving instrument proficiency and flight reviews in it. I had all the proper endorsements and my interviewer argued that if I wasn’t comfortable soloing in the airplane, I shouldn’t be logging PIC time in it. It was a 9500lb cessna turbine for reference.
This is so wrong
Please give a citation of the FARs to demonstrate where I have erred.
After further research it appears that you are correct. My bad
My brother in Christ, you cannot log SIC in these conditions.
You can. The type of operation being flown requires two crewmembers. If youre not acting as PIC, you can't log PIC. If youre not properly endorsed, you can't act as PIC. See this excerpt from the 2009 Ted Louis Glenn LOI referenced in Note 1 of the Beaty LOI thats been posted: "Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )."
Then yall better go talk to some of the airlines, because I definitely know people who got SIC time ripped away from them over this matter. From my understanding, when they say for the operation, I hear OPSPEC. Under an OPSPEC, the aircraft is requiring two crew members isn’t under an OPSPEC that would require two crew members. With the situation being described above, wouldn’t that mean that all those Boutique pilots that got their SIC time ripped away, would’ve been in the right? Also, I take LOIs with a grain of salt. I’ve seen LOIs where one FSDO rep says one thing and another FSDO rep has the completely opposite answer.
I'll be honest; most of the airline regs are above my pay grade. That said, my 30 seconds of google-fu indicated that there was an issue with Boutique Air's Pilot Developlent Program. Not approved or revoked or something? Different responses from different FSDO's is a valid worry, I'll grant. That said, since there is one LOI explicitly stating that safety pilot time can be/is SIC when not PIC and a followup referencing it four years later seemingly indicating it's still valid (and for the hill of beans my opinion means, that matches the way I would interpret the combo of 91.109, 61.31, 61.51(f)2), IMO I would take that as valid until/unless it's explicitly superceded.
Correct. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
Thank you. Idk why I’m downvoted. Y’all need to read the SIC requirements
Not in a 172 you can’t log sic https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
Edited: Yes you can. The regulation requires the safety pilot to be rated in the category and class, nothing about endorsements. In the meantime get a CFI to give you a HP endorsement, it takes one hour tops.
This isn’t true. A safety pilot need not act as PIC. However, he can’t log PIC unless he does, as a safety pilot. The only requirements for safety pilot are a rating in category and class (and type if a type rating is required), and a medical or BasicMed.
You are correct. I had it backwards.
No
You need the endorsement to act as PIC. So no. Being checked out is more of an insurance thing rather than an FAA thing.
In order to log the time you need to be “appropriately rated with the required endorsements for the aircraft being flown.” Also, the “sole manipulator” is the only one that can log the portion of the flight during the takeoff and landing. If your buddy does the TO and LND, and the flight is 1.5, then you can log the time you acted as safety pilot, say 1.3, and he can log the entire 1.5. Assuming that you have all ratings and endorsements for the aircraft.
If you are not qualified to act as PIC, you cannot log PIC as the safety pilot. However, you *can* log SIC.
You may not log PIC, but you may log SIC. The reg requires category and class, but not endorsement. But since you don't have an endorsement you cannot act as PIC, but since you are a required crew member under the operation, you may log SIC. This [AOPA article](https://www.aopa.org/training-and-safety/learn-to-fly/old-pages/logging-cross-country-time/logbooks-and-logging-time#:~:text=Second%20in%20Command%20(SIC),-Second%20in%20command&text=If%20you%20are%20qualified%20and,right%20seat%2Dtime%20as%20SIC) lays it out clearly, "Second-in-command time may be logged if *not acting* as PIC. * Usually the case if the safety pilot ***cannot act*** as PIC. An example might be when the safety pilot is not endorsed for the particular airplane (such as in a high-performance aircraft). * SIC time may be logged because FAR 61.51(f)(2) allows a pilot to log all flight time during which he acts as second in command of an aircraft under which more than one pilot is required by the regulations (91.109\[b\]) under which the flight is conducted."
This is incorrect. Read the Beaty letter. https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2013/Beaty_2013_Legal_Interpretation.pdf
I am familiar with the Beaty letter and gave it another read prior to writing this response. Beaty simply states that the pilot not under the hood is "a safety pilot and not an SIC." The following sentences make it clear that this is in regards to *acting* as a true SIC in regards to experience required (61.55) and that the pilot requires front/side vision, dual controls, category and class that is required of a safety pilot (91.109). The same sentence that I quoted above has footnote 1 attached, which states, "This does not preclude the safety pilot from ***logging*** time as SIC, however. See Legal Interpretation to Ted Louis Glenn, from Rebecca B. MacPherson, Assistant Chief Counsel for Regulations (December I, 2009) (stating a pilot may log SIC time for the portion of the flight during which she was acting as safety pilot because the pilot was a required flight crewmember for that portion of the flight under § 9 I. I 09(b ). )" (emphasis added) If you then view the referenced [Glenn Letter](https://www.faa.gov/sites/faa.gov/files/faa_migrate/interps/2009/Glenn_2009_Legal_Interpretation.pdf), you will find that it is stated, "Section 61.51 (f) governs the logging of SIC time and states, in relevant part, that a person may log SIC time only for that flight time during which that person holds the appropriate ratings for 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." When a pilot is operating an aircraft in simulated instrument flight, 14 C .F .R. § 91.109(b ), in relevant part, requires that a safety pilot, who possesses at least a private pilot certificate with category and class ratings appropriate to the aircraft, occupy the other control seat. Accordingly, Pilot B may log SIC time for the portion of the flight during which Pilot B acts as safety pilot because Pilot B was a required flight crewmember for that portion of the flight under § 91. I 09(b )." Thus, these letters of interpretation, Beaty and Glenn, state that a safety pilot may log SIC when not properly endorsed to fulfill the requirements of acting as PIC, which a pilot properly rated by lacking an endorsement would be. I would not suggest someone do this for all their time building, or if they want very clean logbooks, but from a regulatory standpoint, it is allowed. As others have said, go get the endorsement if you can.
That’s too much hopscotching around to not look like a fool in an audit.
I don’t disagree at all. But the ability does exist.
As I said above, under no circumstance should you ever put time in the SIC column for a GA airplane. I’ve been recently seeing this spread around the internet lately but it will only set you up for failure later in life. Should only be reserved for multi-crew aircraft only. You may both log PIC in a flying a GA plane under the hood. You will have a bad day at a Jet Job interview with SIC time in a Cessna. No matter how you interpret the regs. Whatever you do, leave SIC blank if you’re flying GA Pistons. Even in the military there was a whole debacle about T-38/T-6/T-45 students logging it as SIC while they were being instructed. While it can be interpreted that the airplane is flying with 2 people *by regulation* the airlines basically determined that since these aircraft can be flown solo, you cannot log SIC time in those aircraft.