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Logging PIC under IFR and in Actual IMC for Non-Instrument Rated Pilots

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James Cummiskey

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Aug 12, 2001, 10:33:52 AM8/12/01
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Scenario: One non-instrument rated pilot and one instrument rated pilot are
in a cockpit. Neither are CFIs.

Both pilots can log PIC (with the other simulataneously logging SIC) in
simulated instrument conditions under VFR in VMC. However, two questions:

Question 1: Can the non-instrument rated pilot log PIC time (as sole
manipulator) on an IFR flight plan while under the hood in VMC conditions?

Question 2: If the answer to Question 1 is "Yes," can the non-instrument
rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
actual IMC?

If the answer to either question is "Yes," what does the instrument rated
pilot log (if anything) while the non-instrument pilot is logging PIC time
under these conditions?

It the answer to either question is "No," than does the instrument pilot log
the flight time as both Instrument and PIC time even though he is NOT the
sole manipulator (the non-instrument rated pilot is flying the plane on an
IFR flight plan)?


Mark Kolber

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Aug 12, 2001, 2:54:27 PM8/12/01
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On Sun, 12 Aug 2001 14:33:52 GMT, "James Cummiskey"
<cumm...@home.com> wrote:

>Scenario: One non-instrument rated pilot and one instrument rated pilot are
>in a cockpit. Neither are CFIs.
>
>Both pilots can log PIC (with the other simulataneously logging SIC) in
>simulated instrument conditions under VFR in VMC.

Actually, in simulated instrument conditions, it is possible for
both to simultaneously log PIC.

>However, two questions:
>
>Question 1: Can the non-instrument rated pilot log PIC time (as sole
>manipulator) on an IFR flight plan while under the hood in VMC conditions?

Yes.

>
>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>actual IMC?
>

Yes

>If the answer to either question is "Yes," what does the instrument rated
>pilot log (if anything) while the non-instrument pilot is logging PIC time
>under these conditions?

Nothing


Of course, in this scenario, the instrument rated pilot is the one who
must act as PIC.


The simple rule is this:

Acting PIC = responsible for the flight
Logging PIC = sole manipulator of the controls.

Exceptions (I think this is all of them, but there may be more)

1. Pilots acting as PIC in an operation requiring more than one
crewmember may log PIC.

2. ATP in Part 121 operations.

3. CFI giving instruction.
-
Mark Kolber
APA, Denver, Colorado
www.midlifeflight.com
=========
email? replace "spamaway" with "mkolber

Ron Rosenfeld

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Aug 12, 2001, 3:04:42 PM8/12/01
to
On Sun, 12 Aug 2001 14:33:52 GMT, "James Cummiskey" <cumm...@home.com>
wrote:

>Scenario: One non-instrument rated pilot and one instrument rated pilot are


>in a cockpit. Neither are CFIs.

I will assume both are rated in the airplane, and meet all requirements to
act as PIC in VFR conditions. Furthermore I will assume that the aircraft
does not require more than one pilot by it's type certificate; so that the
only reason for two pilots would be the safety pilot requirements of
91.109.

>
>Both pilots can log PIC (with the other simulataneously logging SIC) in
>simulated instrument conditions under VFR in VMC. However, two questions:
>

No they cannot.

Either may log PIC as the actual PIC.
The pilot manipulating the controls may log PIC as the sole manipulator.

Only the safety pilot may log SIC (and then only if he is not also logging
PIC).

I am not aware of any circumstances where the safety pilot could log PIC
time and the pilot manipulating the controls log SIC time.

>Question 1: Can the non-instrument rated pilot log PIC time (as sole
>manipulator) on an IFR flight plan while under the hood in VMC conditions?

Yes.

>
>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>actual IMC?

Yes.

>
>If the answer to either question is "Yes," what does the instrument rated
>pilot log (if anything) while the non-instrument pilot is logging PIC time
>under these conditions?

If it is agreed before the flight that the instrument rated pilot will be
the actual PIC, then he may log PIC time while he is acting as safety
pilot. Otherwise, he may log SIC time while acting as safety pilot.

According to my interpretation of the regulations, since a safety pilot is
required only in VMC, the IR pilot could only log pilot time in VMC. In
IMC, two pilots would not be required, and since the IR pilot is not
manipulating the controls (and is not a CFI), he could not log PIC time.
Furthermore, since a safety pilot is not required in IMC, he could not log
SIC time.

Note the use of the terms IMC and VMC. The type of flight plan is
irrelevant.

>
>It the answer to either question is "No," than does the instrument pilot log
>the flight time as both Instrument and PIC time even though he is NOT the
>sole manipulator (the non-instrument rated pilot is flying the plane on an
>IFR flight plan)?
>
>
>

Best,

Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

James Cummiskey

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Aug 12, 2001, 5:40:02 PM8/12/01
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> >Both pilots can log PIC (with the other simulataneously logging SIC) in
> >simulated instrument conditions under VFR in VMC. However, two
questions:
> >
>
> No they cannot.

Sorry, it would have been more precise for me to say "either" vice "both."
It wasn't exactly clear what I meant by my statement (although I think the
previous poster understood).

> Yes.
> Yes.

Well, I appreciate these answers, but could someone please provide a source
citation if available? I couldn't find anything pertinent in the FARs or
other
regulations. Here's my issues:

3-2-1.b and 91.173 says "No person may operate a plane in controlled
airspace under IFR unless that person has filed an IFR flight plan." I
believe that one can't legally file an IFR flight plan and receive a
clearance into controlled airspace (whether VMC or IMC) unless instrument
rated (except for the CFI scenario). Hence, the instrument rated pilot must
have filed the original flight plan (and he must have put his name in the
PIC block on the flight plan--although interestingly, whenever I get a
pop-up clearance, or a TEC routing, they don't ask for my name--go figure).

However, I think what you're telling me is that the instrument rated pilot
can file the flight plan as PIC, but then he can legally choose to let the
non-instrument pilot do all the flying under an IFR flight plan (whether VMC
or IMC), thereby switching PICs. Are you then saying that since the
non-instrument rated pilot is logging the time as PIC, that this will make
the non-instrument rated pilot the legal PIC in the IFR/VMC and IFR/IMC
scenarios (in other words, if there's a problem, the non-instrument rated
pilot will be held accountable--even those he is not formally qualified to
fly under IFR). This doesn't make much sense to me.

> If it is agreed before the flight that the instrument rated pilot will be
> the actual PIC, then he may log PIC time while he is acting as safety
> pilot. Otherwise, he may log SIC time while acting as safety pilot.

So, you're saying that under VFR, the instrument rated pilot can log PIC
time even though he is not sole manipulator? Isn't this counter to FAR
61.51.e.1? If true, does the non-instrument pilot log SIC as the sole
manipulator during this segment of the flight?

> Note the use of the terms IMC and VMC. The type of flight plan is
> irrelevant.

Since a flight plan is REQUIRED under IFR (whether or not it is IMC or VMC),
I think it is wholely relevant. The issue is more whether an instrument
rated pilot can completely relinguish his PIC responsibility and authority
to a non intrument rated pilot in flight when operating under IFR
(especially so in IMC). If the instrument rated pilot is not relinquishing
the PIC responsiblity, then shouldn't be logging the PIC hours? Actually, I
think the best way to restate my question is this:

There are three different modes of logging instrument time: VFR (by
definition VMC), IFR/VMC, and IFR/IMC. Mode one (VFR) is simulated
instrument time, and either pilot can log PIC-instrument time as sole
manipulator, and the other pilot can log SIC-instrument time as safety
pilot. Modes two and three are distinctly different scenarios (e.g., you
don't use safety pilots in IFR/IMC). In mode two (IFR/VMC), what are the
rules for logging time (are there any differences from mode one)? In mode
three (IFR/IMC), what are the rules for logging time (see my issues
regarding legally relinguishing PIC authority/responsibility above)?

Other thoughts on this convoluted issue?

"Ron Rosenfeld" <ronros...@spamcop.net> wrote in message
news:sjjdnts9vm1bgfssd...@4ax.com...

James Cummiskey

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Aug 12, 2001, 6:08:01 PM8/12/01
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Just re-read Mark's and Ron's posts, and I now understand their points about
the VFR/VMC and IFR/VMC scenarios (either both pilots can simultaneously log
PIC time--one as legal PIC, and the other as sole manipulator OR the sole
manipulator can log PIC and the safety pilot can log SIC). The sole
manipulator pilot also logs simulated instrument time while under the hood;
the safety pilot does not. However, what is the source of this regulation
(that allows dual PIC logging)--I couldn't find it in the FAR/AIM?

Also, my question about whether an IFR pilot can legally relinquish his PIC
authority/responsibility in IFR/IMC is still a valid one. What is the
source of this regulation?

This has to be a FAQ--does a comprehensive one exist?

Thanks!

"James Cummiskey" <cumm...@home.com> wrote in message
news:SICd7.59603$A47.28...@news1.rsm1.occa.home.com...

Bob Moore

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Aug 12, 2001, 8:00:12 PM8/12/01
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Ron Rosenfeld <ronros...@spamcop.net> wrote:

>Note the use of the terms IMC and VMC. The type of flight plan is
>irrelevant.

Not really...anytime an Instrument Flight Plan is filed, there must be
an Instrument rated PIC. He need not manipulate the controls, but he
IS the PIC. It does not matter whether it is IMC or VMC, as long as
the IFR plan is filed and flown, the instrument rated pilot is the
PIC. If the non-instrument rated pilot is logging "PIC time" as the
sole manipulator of the controls, then the "real" PIC may not log
"PIC time", in fact, he logs nothing unless serving as safety pilot in
VMC conditions and then he may only log "SIC time" if the
non-instrument rated pilot is logging "PIC time" as the sole
manipulator of the controls.

Bob Moore
ATP ASMEL
CFI ASE-IA

James Cummiskey

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Aug 12, 2001, 8:34:25 PM8/12/01
to
Thanks, Bob--this makes much more intuitive sense to me (regarding an IFR
flight plan dictating that the legal PIC be the instrument rated pilot).
However, just to be clear, are you refuting the contention that when under
IFR/VMC, that BOTH pilots can log PIC time simultaneously (as they
theoretically can in VFR/VMC; i.e., the non-instrument rated pilot under the
hood as sole manipulator PIC, and the instrumented rated pilot as legal PIC
and safety pilot)?

Again, does anyone have a citation to something which definitively sorts all
this out?

Regards, Jim

"Bob Moore" <rmoo...@tampabay.rr.com> wrote in message
news:gMEd7.42833$iq1.7...@typhoon.tampabay.rr.com...

Bob Moore

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Aug 12, 2001, 8:29:47 PM8/12/01
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rmoo...@tampabay.rr.com (Bob Moore) wrote:
>Not really...anytime an Instrument Flight Plan is filed, there must be
>an Instrument rated PIC. He need not manipulate the controls, but he
>IS the PIC. It does not matter whether it is IMC or VMC, as long as
>the IFR plan is filed and flown, the instrument rated pilot is the
>PIC. If the non-instrument rated pilot is logging "PIC time" as the
>sole manipulator of the controls, then the "real" PIC may not log
>"PIC time", in fact, he logs nothing unless serving as safety pilot in
>VMC conditions and then he may only log "SIC time" if the
>non-instrument rated pilot is logging "PIC time" as the sole
>manipulator of the controls.

Whoops.... scratch the last sentence of that post. They may both log
PIC in that case.

Bob

Bob Moore

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Aug 12, 2001, 9:43:13 PM8/12/01
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"James Cummiskey" <cumm...@home.com> wrote:
>Thanks, Bob--this makes much more intuitive sense to me (regarding an IFR
>flight plan dictating that the legal PIC be the instrument rated pilot).
>However, just to be clear, are you refuting the contention that when under
>IFR/VMC, that BOTH pilots can log PIC time simultaneously (as they
>theoretically can in VFR/VMC; i.e., the non-instrument rated pilot under the
>hood as sole manipulator PIC, and the instrumented rated pilot as legal PIC
>and safety pilot)?

By this time you have seen my correction.....

Bob

Stuart King

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Aug 13, 2001, 1:14:10 AM8/13/01
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This makes good sense, the qualified pilot must be the PIC.

What about if its a high performance complex aircraft, and the
non-instrument rated pilot is sole-manipulator, does this change the
logging?

Just curious,
Stuart


"Bob Moore" <rmoo...@tampabay.rr.com> wrote in message

news:%bFd7.42962$iq1.7...@typhoon.tampabay.rr.com...

Larry Fransson

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Aug 13, 2001, 4:17:24 AM8/13/01
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In article <ktwd7.59454$A47.27...@news1.rsm1.occa.home.com>,
"James Cummiskey" <cumm...@home.com> wrote:

Not that I wish to jump into the middle of yet another of these
discussions, but this one caught my attention:

> Both pilots can log PIC (with the other simulataneously logging SIC)

Huh? You're either the pilot in command or the second in command. You
can't be both. You would be beside yourself!

Ron Rosenfeld

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Aug 13, 2001, 7:21:39 AM8/13/01
to
On Sun, 12 Aug 2001 22:08:01 GMT, "James Cummiskey" <cumm...@home.com>
wrote:

>Just re-read Mark's and Ron's posts, and I now understand their points about


>the VFR/VMC and IFR/VMC scenarios (either both pilots can simultaneously log
>PIC time--one as legal PIC, and the other as sole manipulator OR the sole
>manipulator can log PIC and the safety pilot can log SIC). The sole
>manipulator pilot also logs simulated instrument time while under the hood;
>the safety pilot does not. However, what is the source of this regulation
>(that allows dual PIC logging)--I couldn't find it in the FAR/AIM?

The following regulatory cites are backed up by written opinions from FAA
Chief Counsel:

The sole manipulator logs PIC time per 61.51(e)(1)(i):

(1) A recreational, private, or commercial pilot may log
pilot-in-command time only for that flight time during which that person--
(i) Is the sole manipulator of the controls of an aircraft
for which the pilot is rated;

The safety pilot "may" log PIC time, per 61.51(e)(1)(iii):

(iii) Except for a recreational pilot, is 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.

The pertinent phrase here has to do with "the regulations under
which the flight is conducted". That specific regulation is 91.109 which
requires the safety pilot.


>
>Also, my question about whether an IFR pilot can legally relinquish his PIC
>authority/responsibility in IFR/IMC is still a valid one. What is the
>source of this regulation?

I did not see any question about the IFR rated pilot relinquishing his PIC
authority/responsibility. He CANNOT.

However, he may not be able to LOG PIC time for the purposes of 61.51.

Understand that the FAA makes a distinction between ACTING as PIC and
LOGGING PIC. It is possible to ACT as PIC without being able to LOG it;
and it is possible to LOG PIC without being able to ACT as PIC.


>
>This has to be a FAQ--does a comprehensive one exist?

Below is a copy of an FAA Chief Counsel written opinion:

==================
Legal Interpretation # 92-52

October 30, 1992

Mr. David M. Reid

Dear Mr. Reid:

Thank you for your letter of June 12, 1992, concerning the
logging of pilot-in-command (PIC) time under the Federal Aviation
Regulations (FAR).

In your letter you ask four questions. First, you ask whether
there are "any circumstances when, during a normal flight, two
Private Pilots may simultaneously act as (and therefore log the
time as) Pilot-In-Command?" The answer is two private pilots may
not simultaneously act as PIC but they may, under certain
circumstances, simultaneously log PIC time.

There is a difference between serving as PIC and logging PIC
time. PIC, as defined in FAR 1.1, means the pilot responsible
for the operation and safety of an aircraft during flight time.
FAR 61.51 deals with logging PIC flight time, and it provides
that a private or commercial pilot may log as PIC time only that
flight time during which he is the sole manipulator of the
controls of an aircraft for which he is rated, or when he is the
sole occupant of the aircraft, or when he acts as PIC 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. It is important to note that FAR 61.51 only
regulates the recording of PIC time used to meet the requirements
toward a higher certificate, higher rating, or for recent flight
experience.

Therefore, while it is not possible for two pilots to act as PIC
simultaneously, it is possible for two pilots to log PIC flight
time simultaneously. PIC flight time may be logged by both the
PIC responsible for the operation and safety of the aircraft
during flight time in accordance with FAR 1.1, and by the pilot
who acts as the sole manipulator of the controls of the aircraft
for which the pilot is rated under FAR 61.51. Enclosed please
find two prior FAA interpretations concerning logging of PIC
time. We hope that these will be of further assistance to you.

In your second question you ask "[h]ow shall two Private Pilots
log their flight time when one pilot is under the hood for
simulated instrument time and the other pilot acts as safety
pilot?" The answer is the pilot who is under the hood may log
PIC time for that flight time in which he is the sole manipulator
of the controls of the aircraft, provided he is rated for that
aircraft. The appropriately rated safety pilot may concurrently
log as second in command (SIC) that time during which he is
acting as safety pilot.

The two pilots may, however, agree prior to initiating the flight
that the safety pilot will be the PIC responsible for the
operation and safety of the aircraft during the flight. If this
is done, then the safety pilot may log all the flight time as PIC
time in accordance with FAR 1.1 and the pilot under the hood may
log, concurrently, all of the flight time during which he is the
sole manipulator of the controls as PIC time in accordance with
FAR 61.51(c)(2)(i). Enclosed please find a prior FAA
interpretation concerning the logging of flight time under
simulated instrument flight conditions. We hope that this
interpretation will be of further assistance to you.

In your third question you ask "[d]uring instrument training, how
shall a VFR Private Pilot log the following flight time:
Pilot-In-Command time, Simulated Instrument time, and Actual
Instrument time, when that pilot is ... A) ... under the hood?
B) ...in actual instrument conditions? C) ... under the hood in
actual instrument conditions?" The answer is the VFR private
pilot may log all of the flight time you described as PIC flight
time under FAR 61.51(c)(2)(i) if he was the sole manipulator of
the controls of an aircraft for which he is rated. Under FAR
61.51(c)(4) the pilot may log as instrument flight time only that
time during which he operates the aircraft solely by reference to
instruments, under actual or simulated instrument flight
conditions. Please note that the FARs do not distinguish between
"actual" and "simulated" instrument flight time. Enclosed is a
prior FAA interpretation concerning the logging of instrument
flight time. We hope this interpretation will further assist
you.

Finally you ask "[d]oes FAR 61.57 affect how the VFR Private
Pilot shall log Pilot-In-Command time during instrument training,
either before or after meeting the 6/6/6 requirement, and if so,
how?" FAR 61.57 does not affect how a pilot logs PIC time during
instrument training; FAR 61.51(c)(2) and (4) govern logging of
instrument flight time. FAR 61.57(e) provides currency
requirements for acting as PIC under instrument flight rules
(IFR) or in weather conditions less than the minimums for visual
flight rules (VFR). Enclosed please find a prior FAA
interpretation on instrument flight time and FAR 61.57(e). We
hope this interpretation will further assist you.

We hope this satisfactorily answers your questions.

Sincerely,

/s/ Donald P. Byrne
Assistant Chief Counsel
Regulations Division

=====================

Ron Rosenfeld

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Aug 13, 2001, 7:28:40 AM8/13/01
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On Mon, 13 Aug 2001 00:00:12 GMT, rmoo...@tampabay.rr.com (Bob Moore)
wrote:

I disagree, but perhaps my writing was not clear. Let me try again:

For the purpose of the IR pilot LOGging PIC, the type of flight plan is
irrelevant.

He may only LOG PIC when the flight conditions are VMC (i.e. when a safety
pilot is required).

When flight conditions are IMC, no safety pilot is required, so the IR
pilot cannot log PIC while the nonIR pilot is manipulating the controls.

Of course, on an instrument flight plan, the IR pilot must ACT as PIC, he
just might not be able to LOG it. Don't forget, the original poster
specified that the IR pilot was NOT a CFI.

Ron Rosenfeld

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Aug 13, 2001, 7:29:19 AM8/13/01
to
On Mon, 13 Aug 2001 05:14:10 GMT, "Stuart King"
<stu...@nospam.KingFamily.spamx.Netnospam> wrote:

>This makes good sense, the qualified pilot must be the PIC.
>
>What about if its a high performance complex aircraft, and the
>non-instrument rated pilot is sole-manipulator, does this change the
>logging?
>
>Just curious,
>Stuart
>

No.

Ron Rosenfeld

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Aug 13, 2001, 7:30:18 AM8/13/01
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On Mon, 13 Aug 2001 01:17:24 -0700, Larry Fransson <lfra...@qwest.net>
wrote:


Perhaps with multiple personality disorder?

James Cummiskey

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Aug 13, 2001, 10:11:15 AM8/13/01
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Great post--thanks, Ron!

"Ron Rosenfeld" <ronros...@spamcop.net> wrote in message

news:5ddfntcaqftljagkb...@4ax.com...

Alexis Yushin

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Aug 13, 2001, 10:15:18 AM8/13/01
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Ron Rosenfeld <ronros...@spamcop.net> wrote:
>>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>>actual IMC?
>
> Yes.

Sounds like nonesense to me. How can you log PIC if you're not IR rated
on an instrument flight plan?


>>If the answer to either question is "Yes," what does the instrument rated
>>pilot log (if anything) while the non-instrument pilot is logging PIC time
>>under these conditions?
>
> If it is agreed before the flight that the instrument rated pilot will be
> the actual PIC, then he may log PIC time while he is acting as safety
> pilot. Otherwise, he may log SIC time while acting as safety pilot.
>
> According to my interpretation of the regulations, since a safety pilot is
> required only in VMC, the IR pilot could only log pilot time in VMC. In
> IMC, two pilots would not be required, and since the IR pilot is not
> manipulating the controls (and is not a CFI), he could not log PIC time.
> Furthermore, since a safety pilot is not required in IMC, he could not log
> SIC time.
>
> Note the use of the terms IMC and VMC. The type of flight plan is
> irrelevant.

I believe you're not allowed to file IFR flight plan if you dont have
the rating.

Alexis

Ron Natalie

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Aug 13, 2001, 10:46:53 AM8/13/01
to

Alexis Yushin wrote:
>
> Ron Rosenfeld <ronros...@spamcop.net> wrote:
> >>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
> >>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
> >>actual IMC?
> >
> > Yes.
>
> Sounds like nonesense to me. How can you log PIC if you're not IR rated
> on an instrument flight plan?
>

Because it is not necessary to be pilot in command to log it.

A private pilot can log PIC time:
1. When sole manipulator of the controls of an AIRCRAFT for which he
is rated.
2. When pilot in command of an operation requirng more than one pilot...

Having an instrument rating, currency, HP endorsements, etc.. are all
requirements on the pilot and command, not conditions for logging it under
#1. All you need to do is posess an appropriate aircraft rating and do
the flying to log PIC. You can have the real PIC in the right seat.

Being "In Command" is a different concept than working the controls.

James Cummiskey

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Aug 13, 2001, 11:15:29 AM8/13/01
to
Well, I think we're all in agreement here. Thanks to all for helping to
clear this up. Another related question (that happens virtually every day
here in SoCal):

Scenario: Two pilots take off in VMC at a Class D airport (surrounded by
Class E). One non-instrument rated pilot is flying the airplane, and the
other instrument rated pilot is in the right seat. The aircraft is on a
"IFR to VFR on-top" clearance. Field Elevation is 0 MSL. There is a
ceiling at 1000 AGL with tops at 2000 MSL. The sole manipulator is logging
PIC time, and the safety pilot as acting as the legal PIC. The pilot
penetrates the cloud deck and flies on top. At 2000 MSL, the sole
manipulator puts on his hood, and the airplane continues the climb.

Since the airplane is on an IFR clearance, the instrument rated pilot will
necessarily remain the legal PIC until the flight ends (or the IFR flight
plan is cancelled). The sole manipulator will log PIC time the entire time
he is flying the aircraft. However, per FAR 61.51.g., the sole manipulator
can only log the time as "Instrument" time when the pilot operates the
aircraft solely by reference to instruments.

Per 61.51(e)(1)(iii), the safety pilot can only log flight time when more
than one pilot is required. 91.109 requires that the safety pilot has
"adequate vision forward and to the side of the aircraft." (The implication
is that VFR conditions must prevail).

Issues/Questions:

(1) During the 1 minute climb to 1000 MSL and the cloud ceiling, flight
conditions are still technically IMC (1000 foot below clouds clearance is
not maintained). However, the sole manipulator cannot log instrument time
during this 1 minute, since he is not operating the aircraft solely by
reference to instruments. Moreover, the safety pilot is not logging any
time at all, since the sole manipulator has visual reference, and thus the
safety pilot is not required. Is this correct?

(2) If the sole manipulator wore a hood (a simulated zero-zero takeoff)
during the initial climb to 1000 MSL, he clearly would be able to log
instrument time, but would the safety pilot be able to log PIC time (after
all, conditions are NOT VMC). Indeed, is it even LEGAL for the sole
manipulator to be wearing a hood in these IMC conditions (since the safety
pilot doesn't have adequate visual reference to properly perform his
duties)?

(3) During the 2 minute climb from 1000 to 2000 MSL, flight conditions are
solid IMC. Hence, the sole manipulator can now log instrument and PIC time,
but the other pilot (still acting as legal PIC) cannot log ANY time (since
again, he is not required as a safety pilot). Is this correct?

(4) During the 1 minute climb from 2000 to 2500 MSL, flight conditions are
also technically IMC (since 500 foot above clouds clearance is not
maintained). Since the sole manipulator immediately puts onhis hood, he can
now log this time as instrument time. However, same questions as #2: It's
not technically VMC. Hence, can the safety pilot legally perform his duties
(and also log the time)?

The two minutes of flight time in question may not sound like a lot (but it
adds up if you do it every day). Thoughts?


"Ron Rosenfeld" <ronros...@spamcop.net> wrote in message

news:h4efnts0u744jo7pb...@4ax.com...

James Cummiskey

unread,
Aug 13, 2001, 11:19:19 AM8/13/01
to
Oops, please transpose the 500/1000 feet cloud clearance issues in my
scenario below (yup, it's 500 feet below and 1000 feet above)! It actually
makes it more interesting for the initial 1000 feet climb with the sole
manipulator wearing the hood scenario. Thanks!

"James Cummiskey" <cumm...@home.com> wrote in message

news:laSd7.61180$A47.28...@news1.rsm1.occa.home.com...

Bob Moore

unread,
Aug 13, 2001, 12:20:59 PM8/13/01
to
"James Cummiskey" <cumm...@home.com> wrote:
>(2) If the sole manipulator wore a hood (a simulated zero-zero takeoff)
>during the initial climb to 1000 MSL, he clearly would be able to log
>instrument time, but would the safety pilot be able to log PIC time (after
>all, conditions are NOT VMC). Indeed, is it even LEGAL for the sole
>manipulator to be wearing a hood in these IMC conditions (since the safety
>pilot doesn't have adequate visual reference to properly perform his
>duties)?

James, I think that you are confusing IMC and IFR. Under the stated
conditions, the plane was operating IFR in VMC.
IMC means operating IN the clouds, less than 1000'/3mi requires IFR,
but you may still be VMC (clear of clouds), much as one might be if
operating VFR in class "G" airspace (one mile and clear of clouds).

Bob Moore

The Globule

unread,
Aug 13, 2001, 4:52:34 PM8/13/01
to
On Sun, 12 Aug 2001 14:33:52 GMT, "James Cummiskey"
<cumm...@home.com> wrote:

Ok folks, here are the right answers and you better believe it if you
do not want to get busted by the FAA or an insurance company: yes,
they will check your logbook if you get involved in an accident and
wrong log book entries could be ground for revocation of your pilot
certificates or deny your claim (no money !).

To begin with, I consider unwise to practice instrument training in
VMC under an IFR flight plan if the instrument rated pilot is not
CFII. This could lead to serious misunderstanding about who is
responsible for the operation and safety of the flight and will
certainly put you in trouble should an incident arises (remember that
there is no more friends in these situations).

Basic rules: if none of the pilots is a CFI, only the sole manipulator
of the controls of the aircraft can log PIC (provided he/she meets
other requirements pertaining to the flight being conducted)
During the time the flying pilot is "under the hood" in VMC the non
flying pilot is acting as a safety pilot and is required to have at
least a private pilot certificate with appropriate category and class
ratings for the aircraft flown (ie: airplane single engine land).
During that time (and only during that time) the non flying pilot can
log SIC time as he/she is required by the regulation under which the
flight is being conducted (CFR14 - 91.109b).

>Scenario: One non-instrument rated pilot and one instrument rated pilot are
>in a cockpit. Neither are CFIs.
>
>Both pilots can log PIC (with the other simulataneously logging SIC) in
>simulated instrument conditions under VFR in VMC. However, two questions:
>
>Question 1: Can the non-instrument rated pilot log PIC time (as sole
>manipulator) on an IFR flight plan while under the hood in VMC conditions?

Answer to question 1 is Yes
The sole manipulator of the controls of an aircraft can log PIC time
if he/she has at least a private pilot certificate with appropriate
category and class ratings for the aircraft flown (ie: airplane single
engine land)

>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>actual IMC?

Answer to question 2 is No
Since the other pilot is not qualified as a CFI with an instrument
rating (CFII) the non qualified pilot is prohibited to be in control
of the aircraft in less than VFR meteorological conditions and
therefore cannot log pilot time (CFR14 - 61.3.e)

>If the answer to either question is "Yes," what does the instrument rated
>pilot log (if anything) while the non-instrument pilot is logging PIC time
>under these conditions?

He/she can log SIC time while the other pilot is flying "under the
hood" in VFR meteorological condition as he/she is acting as a safety
pilot

>It the answer to either question is "No," than does the instrument pilot log
>the flight time as both Instrument and PIC time even though he is NOT the
>sole manipulator (the non-instrument rated pilot is flying the plane on an
>IFR flight plan)?

The instrument rated pilot can log PIC time only when being the sole
manipulator of the controls and he/she can log instrument time while
in IMC. The non instrument rated pilot cannot log pilot time under
these conditions.

For your info, I am an active CFI, CFII, MEI, AGI, IGI and check pilot
for the Civil Air Patrol.


***************************************************************************************
Legal Warning: Anyone sending me unsolicited/commercial/junk/spam e-mail WILL be charged a US$500 proof-reading fee. Do NOT send unsolicited advertisements and do NOT add my e-mail address to your list(s):
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***************************************************************************************

macho...@nosoup4u.com

unread,
Aug 13, 2001, 5:18:33 PM8/13/01
to
I think ACROCFI's double-I brother has arrived.

On Mon, 13 Aug 2001 15:52:34 -0500, The Globule <no...@nowhere.com>
wrote:

James Cummiskey

unread,
Aug 13, 2001, 5:26:24 PM8/13/01
to
Bob, I don't think I agree. Visual Meteorological Conditions (VMC) and
Instrument Meteorological Conditions (IMC) are defined by the AIM as
"meteorgological conditions expressed in terms of visibility, distance from
cloud, and ceiling equal to or better than specified minima." In other
words, the standard minima needed for a particular class of airspace.
Hence, one can be in IMC, yet still be clear of clouds.

Simarily, VMC/IMC is a binary state. One can only be in one or the other at
any particular moment--not both.

The situation I described was clearly "IFR" the entire time (the aircraft
was on an IFR flight plan). However, if you buy this definition of VMC/IMC
above, IMC was clearly transitory. Here's a recap:

* Aircraft took off in VMC and climbed 500 feet.
* Since cloud layer ceiling started at 1000 feet, aircraft entered IMC at
500 feet (the airspace is D surrounded by E)
* Since cloud layer top ended at 2000 feet, aircraft exited IMC at 3000 feet
(assume > 3M visibility)

Hence, VMC -> IMC -> VMC.

The question is whether the safety pilot can log PIC time during the
clear-of-clouds IMC climb from 2000-3000 feet? In other words, can you
legally enter simulated instrument conditions in NON-VFR (i.e., "IMC")
conditions? Of course, in training, we do this all the time (put on our
hoods right after we climb clear of the cloud layer), but is it legal and
safe?

Consider the reason we have VFR cloud minima to begin with--to avoid the
possibility of another aircraft popping out from the cloud giving you
minimum time to react.

Thoughts?

"Bob Moore" <rmoo...@tampabay.rr.com> wrote in message

news:L7Td7.48949$iq1.8...@typhoon.tampabay.rr.com...

James Cummiskey

unread,
Aug 13, 2001, 5:40:39 PM8/13/01
to
Thanks for the comment. However, Ron R. posted the extract from the FAA
Legal Interpretation # 92-52 that seems to make it quite clear that the
instrument rated pilot can ALSO log PIC time when acting as the safety pilot
in VMC conditions on an IFR flight plan. Do you disagree with this?

> To begin with, I consider unwise to practice instrument training in
> VMC under an IFR flight plan if the instrument rated pilot is not
> CFII. This could lead to serious misunderstanding about who is
> responsible for the operation and safety of the flight

Don't think there's any possible misunderstanding if both pilots know the
rules. The instrument rated pilot will ALWAYS remain the LEGAL PIC the
entire time the aircraft is on the IFR flight plan (whether or not in IMC or
VMC). The non-instrument rated sole manipulator will log PIC time in
simulated instrument conditions, and the instrument rated safety pilot will
SIMULTANEOUSLY log LEGAL PIC time on an IFR flight plan in VMC (just as he
can on an VFR flight if he agrees to assume legal PIC responsibility for the
flight). Concur?

> Since the other pilot is not qualified as a CFI with an instrument
> rating (CFII) the non qualified pilot is prohibited to be in control
> of the aircraft in less than VFR meteorological conditions and
> therefore cannot log pilot time (CFR14 - 61.3.e)

Interesting. I agree that 61.3.e states that you can't act as PIC under IFR
or in non-VMC unless you are instrument rated. However, the issue is that
the instrument rated pilot is STILL the legal PIC in these conditions, and
thus 61.3.e doesn't strictly restrict another non rated pilot from being the
sole manipulator. Do you read it this way?

"The Globule" <no...@nowhere.com> wrote in message
news:9cagntc0bqfrpefr7...@4ax.com...

Bob Moore

unread,
Aug 13, 2001, 6:07:35 PM8/13/01
to
"James Cummiskey" <cumm...@home.com> wrote:
>Bob, I don't think I agree. Visual Meteorological Conditions (VMC) and
>Instrument Meteorological Conditions (IMC) are defined by the AIM as
>"meteorgological conditions expressed in terms of visibility, distance from
>cloud, and ceiling equal to or better than specified minima."

Well....I've been around a lot longer than the AIM, and I think
that it's wrong! :-) :-) If I can see the ground/horizon, I can't
log "instrument time" so I must be operating visually and there-
fore...VMC exists.....yes/no ????
Yes, you are correct about the AIM definition of VMC.....But..
Two pilots operating within sight of each other....no clouds,
but the visibility is two (2) miles. One pilot is at 1100' AGL in
class G airspace and is therefore VMC, the other pilot is 200'
above the first at 1300' AGL in class E airspace and is there-
fore IMC (needs 3 mi to be VMC). Doesn't make much sense
does it?

Bob

The Globule

unread,
Aug 13, 2001, 6:40:47 PM8/13/01
to
On Mon, 13 Aug 2001 21:40:39 GMT, "James Cummiskey"
<cumm...@home.com> wrote:


Well, there is a question in the CFI FAA written test about this issue
and the answer to that question is that the safety pilot has to log
SIC (CFR14 - 61.51.f) as it is required under the regulation in which
the flight is being conducted (CFR14 - 91.109.b) - Go figure !

Concerning the Legal interpretation # 92-52 it states that the
instrument rated pilot "may" log as PIC when acting as a safety pilot
which is the case when for example the flight is conducted under part
135; In this case one of the pilot has to be designated before the
flight begins as the Pilot in Command and will be PIC for and log PIC
time the entire duration of the flight. However, when the second in
command takes the controls, he/she can log PIC as well. I might be
wrong but I don't think this could be the case for a flight conducted
under part 91 unless a CFI is involved.


>Thanks for the comment. However, Ron R. posted the extract from the FAA
>Legal Interpretation # 92-52 that seems to make it quite clear that the
>instrument rated pilot can ALSO log PIC time when acting as the safety pilot
>in VMC conditions on an IFR flight plan. Do you disagree with this?
>
>> To begin with, I consider unwise to practice instrument training in
>> VMC under an IFR flight plan if the instrument rated pilot is not
>> CFII. This could lead to serious misunderstanding about who is
>> responsible for the operation and safety of the flight
>
>Don't think there's any possible misunderstanding if both pilots know the
>rules. The instrument rated pilot will ALWAYS remain the LEGAL PIC the
>entire time the aircraft is on the IFR flight plan (whether or not in IMC or
>VMC). The non-instrument rated sole manipulator will log PIC time in
>simulated instrument conditions, and the instrument rated safety pilot will
>SIMULTANEOUSLY log LEGAL PIC time on an IFR flight plan in VMC (just as he
>can on an VFR flight if he agrees to assume legal PIC responsibility for the
>flight). Concur?

In the perfect world this is true but in the real world when shit
happens nobody wants to assume the responsibility....
So my advise being: don't do it unless you're ready to go to court and
spend big bucks.

>
>> Since the other pilot is not qualified as a CFI with an instrument
>> rating (CFII) the non qualified pilot is prohibited to be in control
>> of the aircraft in less than VFR meteorological conditions and
>> therefore cannot log pilot time (CFR14 - 61.3.e)
>
>Interesting. I agree that 61.3.e states that you can't act as PIC under IFR
>or in non-VMC unless you are instrument rated. However, the issue is that
>the instrument rated pilot is STILL the legal PIC in these conditions, and
>thus 61.3.e doesn't strictly restrict another non rated pilot from being the
>sole manipulator. Do you read it this way?


It is true that the legal PIC would be the instrument rated pilot but
the non instrument pilot cannot legally be the only manipulator of the
controls of the airplane in IMC unless being under training given by a
qualified Instrument Flight Instructor.

Ron Rosenfeld

unread,
Aug 13, 2001, 10:22:03 PM8/13/01
to
On Mon, 13 Aug 2001 15:15:29 GMT, "James Cummiskey" <cumm...@home.com>
wrote:

>Well, I think we're all in agreement here. Thanks to all for helping to

Since the sole manipulator is doing this for practice, have him put on a
hood and then he can log instrument time, and the safety pilot can log SIC
or PIC time.

>
>(2) If the sole manipulator wore a hood (a simulated zero-zero takeoff)
>during the initial climb to 1000 MSL, he clearly would be able to log
>instrument time, but would the safety pilot be able to log PIC time (after
>all, conditions are NOT VMC).


>Indeed, is it even LEGAL for the sole
>manipulator to be wearing a hood in these IMC conditions (since the safety
>pilot doesn't have adequate visual reference to properly perform his
>duties)?

Yes it is legal. What do you mean by "adequate visual reference"? I don't
find that phrase in the relevant FAR's.

>
>(3) During the 2 minute climb from 1000 to 2000 MSL, flight conditions are
>solid IMC. Hence, the sole manipulator can now log instrument and PIC time,
>but the other pilot (still acting as legal PIC) cannot log ANY time (since
>again, he is not required as a safety pilot). Is this correct?

Technically, in my opinion, this is correct. Practically, WGAS?

>
>(4) During the 1 minute climb from 2000 to 2500 MSL, flight conditions are
>also technically IMC (since 500 foot above clouds clearance is not
>maintained). Since the sole manipulator immediately puts onhis hood, he can
>now log this time as instrument time. However, same questions as #2: It's
>not technically VMC. Hence, can the safety pilot legally perform his duties
>(and also log the time)?

I believe I used some incorrect terminology in previously describing when a
safety pilot is required. Rather than using VMC/IMC, I believe it would be
better to consider that a safety pilot is required when the safety pilot
would be of some benefit. A safety pilot usually is not required in IMC,
as the pilot flying could log instrument time even without a safety pilot.

However departing an airport, even one technically IMC but where it is
still possible to "see and avoid", a safety pilot would be required, if the
pilot flying is wearing a view limiting device. So this seems like an
exception.

It might not even be required for traffic avoidance, but for obstacle
avoidance. I departed BOS 22R today with a 1000' ceiling. As is usual, at
a fairly low altitude, I was given a right turn to 300° (this takes you up
the river between BOS and the city, and is a common instruction for small
a/c to get them quickly out of the way of larger a/c departing the same
runway). I would not want to do that under the hood without a safety
pilot, so as to ensure avoiding running into the control tower.

>
>The two minutes of flight time in question may not sound like a lot (but it
>adds up if you do it every day). Thoughts?

I think you're getting too nitpicky :-)).

Ron Rosenfeld

unread,
Aug 13, 2001, 10:27:18 PM8/13/01
to
On 13 Aug 2001 14:15:18 GMT, Alexis Yushin <ale...@forest.NLnetLabs.nl>
wrote:

>Ron Rosenfeld <ronros...@spamcop.net> wrote:
>>>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>>>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>>>actual IMC?
>>
>> Yes.
>
>Sounds like nonesense to me. How can you log PIC if you're not IR rated
>on an instrument flight plan?
>
>

It is FAA inspired nonsense, not necessarily applicable to the rest of the
world :-).

I'm guessing from your email address that you do not fly under FAA
regulations. Rest assured that the FAA differentiates between LOGging PIC
and ACTing as PIC. It is possible, under FAA regs, to be acting as PIC and
not be able to LOG it; it is also possible to be able to LOG PIC, even when
you are unqualified to ACT as PIC.


>>>If the answer to either question is "Yes," what does the instrument rated
>>>pilot log (if anything) while the non-instrument pilot is logging PIC time
>>>under these conditions?
>>
>> If it is agreed before the flight that the instrument rated pilot will be
>> the actual PIC, then he may log PIC time while he is acting as safety
>> pilot. Otherwise, he may log SIC time while acting as safety pilot.
>>
>> According to my interpretation of the regulations, since a safety pilot is
>> required only in VMC, the IR pilot could only log pilot time in VMC. In
>> IMC, two pilots would not be required, and since the IR pilot is not
>> manipulating the controls (and is not a CFI), he could not log PIC time.
>> Furthermore, since a safety pilot is not required in IMC, he could not log
>> SIC time.
>>
>> Note the use of the terms IMC and VMC. The type of flight plan is
>> irrelevant.
>
>I believe you're not allowed to file IFR flight plan if you dont have
>the rating.

That is true here, too. But there is no requirement that the person who
files the IFR flight plan actually be the pilot flying.

Best,

Ron Rosenfeld

unread,
Aug 13, 2001, 10:44:00 PM8/13/01
to
On Mon, 13 Aug 2001 15:52:34 -0500, The Globule <no...@nowhere.com> wrote:

>On Sun, 12 Aug 2001 14:33:52 GMT, "James Cummiskey"
><cumm...@home.com> wrote:
>
>Ok folks, here are the right answers and you better believe it if you
>do not want to get busted by the FAA or an insurance company: yes,
>they will check your logbook if you get involved in an accident and
>wrong log book entries could be ground for revocation of your pilot
>certificates or deny your claim (no money !).
>
>To begin with, I consider unwise to practice instrument training in
>VMC under an IFR flight plan if the instrument rated pilot is not
>CFII. This could lead to serious misunderstanding about who is
>responsible for the operation and safety of the flight and will
>certainly put you in trouble should an incident arises (remember that
>there is no more friends in these situations).

You are entitled to your opinion. Others disagree.

>
>Basic rules: if none of the pilots is a CFI, only the sole manipulator
>of the controls of the aircraft can log PIC (provided he/she meets
>other requirements pertaining to the flight being conducted)

This opinion of yours is contrary to FAA Chief Counsel legal opinion 92-52.

>During the time the flying pilot is "under the hood" in VMC the non
>flying pilot is acting as a safety pilot and is required to have at
>least a private pilot certificate with appropriate category and class
>ratings for the aircraft flown (ie: airplane single engine land).

He also needs a current medical.

>During that time (and only during that time) the non flying pilot can
>log SIC time as he/she is required by the regulation under which the
>flight is being conducted (CFR14 - 91.109b).

True.

>
>>Scenario: One non-instrument rated pilot and one instrument rated pilot are
>>in a cockpit. Neither are CFIs.
>>
>>Both pilots can log PIC (with the other simulataneously logging SIC) in
>>simulated instrument conditions under VFR in VMC. However, two questions:
>>
>>Question 1: Can the non-instrument rated pilot log PIC time (as sole
>>manipulator) on an IFR flight plan while under the hood in VMC conditions?
>
>Answer to question 1 is Yes
>The sole manipulator of the controls of an aircraft can log PIC time
>if he/she has at least a private pilot certificate with appropriate
>category and class ratings for the aircraft flown (ie: airplane single
>engine land)
>
>>Question 2: If the answer to Question 1 is "Yes," can the non-instrument
>>rated pilot log PIC time (as sole manipulator) on an IFR flight plan in
>>actual IMC?
>
>Answer to question 2 is No
>Since the other pilot is not qualified as a CFI with an instrument
>rating (CFII) the non qualified pilot is prohibited to be in control
>of the aircraft in less than VFR meteorological conditions and
>therefore cannot log pilot time (CFR14 - 61.3.e)

Again, this opinion of yours is contrary to FAA Chief Counsel legal
opinions.

Furthermore, what do you mean by "in control of the aircraft"? If you mean
"manipulating the controls", please give a citation of an FAR or legal
opinion. If you mean acting as Pilot in Command, I would agree with you.
However, this does not affect the legality of logging the flight.

>
>>If the answer to either question is "Yes," what does the instrument rated
>>pilot log (if anything) while the non-instrument pilot is logging PIC time
>>under these conditions?
>
>He/she can log SIC time while the other pilot is flying "under the
>hood" in VFR meteorological condition as he/she is acting as a safety
>pilot
>
>>It the answer to either question is "No," than does the instrument pilot log
>>the flight time as both Instrument and PIC time even though he is NOT the
>>sole manipulator (the non-instrument rated pilot is flying the plane on an
>>IFR flight plan)?
>
>The instrument rated pilot can log PIC time only when being the sole
>manipulator of the controls and he/she can log instrument time while
>in IMC. The non instrument rated pilot cannot log pilot time under
>these conditions.
>
>For your info, I am an active CFI, CFII, MEI, AGI, IGI and check pilot
>for the Civil Air Patrol.


Although you may teach safe flying, some of your interpretations of 14 CFR
Part 61 differ significantly different from written FAA legal opinions.
I'd rather go with the opinions of those enforcing the regulations.

By the way, do you have a real name?

Ron Rosenfeld

unread,
Aug 13, 2001, 10:52:52 PM8/13/01
to
On Mon, 13 Aug 2001 17:40:47 -0500, The Globule <no...@nowhere.com> wrote:

>On Mon, 13 Aug 2001 21:40:39 GMT, "James Cummiskey"
><cumm...@home.com> wrote:
>
>
>Well, there is a question in the CFI FAA written test about this issue
>and the answer to that question is that the safety pilot has to log
>SIC (CFR14 - 61.51.f) as it is required under the regulation in which
>the flight is being conducted (CFR14 - 91.109.b) - Go figure !
>
>Concerning the Legal interpretation # 92-52 it states that the
>instrument rated pilot "may" log as PIC when acting as a safety pilot
>which is the case when for example the flight is conducted under part
>135; In this case one of the pilot has to be designated before the
>flight begins as the Pilot in Command and will be PIC for and log PIC
>time the entire duration of the flight. However, when the second in
>command takes the controls, he/she can log PIC as well. I might be
>wrong but I don't think this could be the case for a flight conducted
>under part 91 unless a CFI is involved.
>

92-52 refers specifically to two "private pilots".

>

>
>It is true that the legal PIC would be the instrument rated pilot but
>the non instrument pilot cannot legally be the only manipulator of the
>controls of the airplane in IMC unless being under training given by a
>qualified Instrument Flight Instructor.


Where do you get that interpretation?

I know that's not the interpretation of the NE FSDO folk with whom I've
spoken.

I think it is unwise for an IR pilot to be sitting in the right seat during
an approach in IMC, with a non IR pilot in the left seat manipulating the
controls, unless the IR pilot has significant right seat experience. But
I've never seen any regulation that precludes me from allowing a non IR
pilot, or any person, from manipulating the controls regardless of the
weather conditions.

Mark Kolber

unread,
Aug 13, 2001, 11:53:11 PM8/13/01
to
On 13 Aug 2001 14:15:18 GMT, Alexis Yushin
<ale...@forest.NLnetLabs.nl> wrote:

>Sounds like nonesense to me. How can you log PIC if you're not IR rated
>on an instrument flight plan?

Because the non-IR pilot is the sole manipulator of the controls of an
aircraft for which the pilot is rated.

"Rated" in this case means having the proper "aircraft" ratings (i.e,
airplane single engine land)

This may well be a US-specific situation. The US FAR make a
distinction between the authority to ACT as PIC (be responsible for
the flight) and LOG PIC (put some flight experience numbers in a
logbook).


-
Mark Kolber
APA, Denver, Colorado
www.midlifeflight.com
=========
email? replace "spamaway" with "mkolber

The Globule

unread,
Aug 14, 2001, 2:55:56 AM8/14/01
to

You are right and I was wrong on this one. The non instrument rated
pilot can log PIC and instrument time during the time he is the only
manipulator of the controls and in IMC.
However, he/she cannot use this time as part of the training required
to obtain his/her flight instrument certificate.

Concerning the instrument rated pilot logging PIC (as he acts as PIC)
while another pilot (instrument rated or not) is actually flying the
aircraft is a "twist" of the "newly" formulated regulation I wouldn'd
consider for myself. But anyone is free to "cheat" the system I
guess...

Having a non instrument rated pilot flying an aircraft in IMC under
supervision of a pilot not qualified as an instrument flight
instructor is something I consider very unsafe. Accident reports shows
how easily qualified and experienced instrument flight instructors
can get in trouble, why taking a chance?

Having an aircraft going down on an IFR flight plan with a non
instrument rated pilot in the pilot seat and an instrument pilot not
qualified as a CFII in the right seat will get you very close
attention from the FAA and your insurance company. If you think you
can get away from either of them, I suggest you to reconsider this
very seriously.

Please fly safe (for yourself and others) and don't do anything
stupid: I'm in the air every other day ;-)

And yes, I have a real name which I do not expose on the internet or
usenet (I like my privacy)

All my best, The Globule.

James Cummiskey

unread,
Aug 14, 2001, 6:58:52 AM8/14/01
to
> However, he/she cannot use this time as part of the training required
> to obtain his/her flight instrument certificate.

Actually, 61.65.d.2.i states that you need 40 hours of actual or simulated
instrument time, but only 15 hours of this needs to be from an authorized
instructor. Hence, two private pilots can work together in simulated
condition in VMC to obtain 25 hours towards their instrument rating. A
private pilot can work with a
instrument rated non-CFI in IMC as well. Cheaper, and even could be more
effective (depending on the individuals and where they are in their
training). Considering the general abysmal quality of flight instruction
out there, one could even potentially receive better and more effective
training from a non-CFI rated instrument rated pilot sitting in the right
seat. There are many low-time CFIs who can't seem to teach at all. Give me
an experienced, competent non-CFI pilot who really enjoys teaching anyday.

> Concerning the instrument rated pilot logging PIC (as he acts as PIC)
> while another pilot (instrument rated or not) is actually flying the
> aircraft is a "twist" of the "newly" formulated regulation I wouldn'd
> consider for myself. But anyone is free to "cheat" the system I
> guess...

"Cheat the System?" Please. If you really are a CFI, this sounds more like
whining that there are viable alternatives to CFIs to obtain flight
instruction.

> And yes, I have a real name which I do not expose on the internet or
> usenet (I like my privacy)

Well, you can't expect anyone to take your claimed credentials seriously
(especially considering your propensity for getting things wrong).


"The Globule" <no...@nowhere.com> wrote in message

news:eudhnt4urft63l0lc...@4ax.com...

Bob Moore

unread,
Aug 14, 2001, 8:59:03 AM8/14/01
to
The Globule <no...@nowhere.com> wrote:

>You are right and I was wrong on this one. The non instrument rated
>pilot can log PIC and instrument time during the time he is the only
>manipulator of the controls and in IMC.
>However, he/she cannot use this time as part of the training required
>to obtain his/her flight instrument certificate.


Yes, the time cannot count toward the 15 hours of instruction required
to be given by an Authorized Instrument Instructor, but it DOES count
toward the total of 40 hours of actual or simulated instrument time
required by FAR 61.65 (d).

Bob Moore
ATP ASMEL 1450645
CFI ASE-IA IGI
Not hiding behind a phoney name!

William LeFebvre

unread,
Aug 14, 2001, 10:55:31 AM8/14/01
to
The Globule wrote:
> It is true that the legal PIC would be the instrument rated pilot but
> the non instrument pilot cannot legally be the only manipulator of the
> controls of the airplane in IMC unless being under training given by a
> qualified Instrument Flight Instructor.

I know of no such restriction. Please cite the regulation that you base
this on. If you can't then I will assume you are simply misinformed and
incorrect.

--
William "I actually put my name on my posts" LeFebvre
Mooney 4074H
w...@groupsys.com

Bob Moore

unread,
Aug 14, 2001, 11:57:37 AM8/14/01
to
William LeFebvre wrote:
William "I actually put my name on my posts" LeFebvre

You and me both, William, but if I passed out as much BS as some of
these guys (ACROCFI, Globule, etc) do, I don't think that I would use
my real name either. :-)

Bob Moore

The Globule

unread,
Aug 14, 2001, 12:54:32 PM8/14/01
to
On Tue, 14 Aug 2001 10:58:52 GMT, "James Cummiskey"
<cumm...@home.com> wrote:

>> However, he/she cannot use this time as part of the training required
>> to obtain his/her flight instrument certificate.
>
>Actually, 61.65.d.2.i states that you need 40 hours of actual or simulated
>instrument time, but only 15 hours of this needs to be from an authorized
>instructor. Hence, two private pilots can work together in simulated
>condition in VMC to obtain 25 hours towards their instrument rating. A
>private pilot can work with a
>instrument rated non-CFI in IMC as well. Cheaper, and even could be more
>effective (depending on the individuals and where they are in their
>training). Considering the general abysmal quality of flight instruction
>out there, one could even potentially receive better and more effective
>training from a non-CFI rated instrument rated pilot sitting in the right
>seat. There are many low-time CFIs who can't seem to teach at all. Give me
>an experienced, competent non-CFI pilot who really enjoys teaching anyday.

As you can read, I wrote "as part of the training required" and not
"as part of the instrument time required"

This is a good example on how easy it is to make a bad interpretation
of what we read.

In an effort to make the regulation easier to understand, the FAA
recently reformulated a lot of part 61 and 91 chapters (in the last
four years). My first answers were based on my knowledge of the
regulation at it has been for years. Ron arguments made me have a
closer look a the regulation as it is publish today and effectively,
he was right and I was wrong on some points we discussed.
I have no problem with that. I think we progress by sharing opinions
and challenging our minds.

>> Concerning the instrument rated pilot logging PIC (as he acts as PIC)
>> while another pilot (instrument rated or not) is actually flying the
>> aircraft is a "twist" of the "newly" formulated regulation I wouldn'd
>> consider for myself. But anyone is free to "cheat" the system I
>> guess...
>
>"Cheat the System?" Please. If you really are a CFI, this sounds more like
>whining that there are viable alternatives to CFIs to obtain flight
>instruction.

You're entitled to this opinion. But if one wants to teach in an
airplane and feels like he has the knowledge to do it why doesn't he
get a flight instructor certificate?

There is a big difference in the training a pilot as received to
become a private pilot and the training one has received to become a
CFI/CFII, experienced or not.

I would think that the training received from a CFI/CFII would be
better that the training received from a private pilot but you will
always find some exceptions and I'm sorry if you can't find a CFI good
enough to teach you.

>> And yes, I have a real name which I do not expose on the internet or
>> usenet (I like my privacy)
>
>Well, you can't expect anyone to take your claimed credentials seriously
>(especially considering your propensity for getting things wrong).

I feel like you are flaming me and I don't quite deserve it.

Please correct me if I'm wrong but you are the one who requested an
answer to your questions in the first place, aren't you?

Usenet is an open forum were people get information to do good and bad
things (think about your email being flooded with porn ads or your
name used by pedophile to sign their posts).
I'd rather use a nickname than having name and other personal
information used without my consent. You're free to use the name you
want, real or fake.
Matter of fact, why don't you give us your pilot certificate number
and your social security number so every one can be sure of who you
really are?

Please fly safely.

The Globule,
CFI, CFII, MEI, AGI, IGI <- believe it or not...

Steve Johnson

unread,
Aug 14, 2001, 5:36:40 PM8/14/01
to
The Globule wrote:

> This is a good example on how easy it is to make a bad interpretation
> of what we read.
> In an effort to make the regulation easier to understand, the FAA
> recently reformulated a lot of part 61 and 91 chapters (in the last
> four years). My first answers were based on my knowledge of the
> regulation at it has been for years. Ron arguments made me have a
> closer look a the regulation as it is publish today and effectively,
> he was right and I was wrong on some points we discussed.
> I have no problem with that. I think we progress by sharing opinions
> and challenging our minds.

> Please correct me if I'm wrong but you are the one who requested an


> answer to your questions in the first place, aren't you?
>
> Usenet is an open forum were people get information to do good and bad
> things (think about your email being flooded with porn ads or your
> name used by pedophile to sign their posts).
> I'd rather use a nickname than having name and other personal
> information used without my consent. You're free to use the name you
> want, real or fake.
> Matter of fact, why don't you give us your pilot certificate number
> and your social security number so every one can be sure of who you
> really are?
> Please fly safely.
> The Globule,
> CFI, CFII, MEI, AGI, IGI <- believe it or not...

I'd say Globule doesn't deserve flames. His post were cooperative and
when small errors were noted, he corrected himself.
God knows, trying to sort through FARS is a job in itself. Its sad when
fifty or more posts are necessary to try and understand any regulation
that should be crystal clear.
I also agree with him that usenet requires a degree of anonymous
presence.
Why anyone would want to post their personal information to millions of
potential viewers is beyond me.
Or, have you guys been lying about your real names, 'N' numbers,
ratings??

William LeFebvre

unread,
Aug 14, 2001, 5:39:42 PM8/14/01
to
Hello William,

I may very well be misinformed and incorrect.

I hope you don't mind me sharing some public information...

Name : LEFEBVRE, WILLIAM NEIL
Pilot's Address : 170 COLTON CREST DR
ALPHARETTA, GA, 30202-6769
FAA Region : Southern
Date of Medical : Jan, 2000
Class of Medical : 3
Expiration : Jan, 2003
Pilot Certificates : Private Pilot
Airplane Single Engine Land
Instrument Airplane


N-number : N4074H
Aircraft Serial Number : 24-1053
Aircraft Manufacturer : MOONEY
Model : M20J
Engine Manufacturer : LYCOMING
Model : I0360 SER A&C
Aircraft Year : 1980
Owner Name : SCHEINPFLUG LARRY R
Owner Address : 1725 KELLOGG SPRINGS DR
DUNWOODY, GA, 30338-6009
Registration Date : 21-Mar-2000
Airworthiness Certificate Type : Standard
Approved Operations : Normal

Please think a little further before flaming someone for being
cautious about their personal information.

I hope you will appreciate your name in the header of this message and
start to protect yourself more and flaming other less

The attached picture could have been child porn sent all over Usenet
with your name and email in the header.

The Globule "I actually put your name and much more on my posts"
Mooney 4074H
w...@groupsys.com

William LeFebvre

unread,
Aug 14, 2001, 5:42:15 PM8/14/01
to
Hello William,

Anything could have been posted over Usenet with your name and email
address in the header.

SuperCobra

unread,
Aug 14, 2001, 6:04:17 PM8/14/01
to
Ok, guys, started not to do this, but here goes:

My .02.

If I understand the Feds correctly, FAR 61.51 (f) Logging Second In Command
Flight Time states: A person may log SIC time during which that person: (1) Is
qualified in accordance with the SIC requirements of FAR 61.55 of this part,
and occupies a crewmember station in an aircraft that requires more than one
pilot by the aircraft's type certificate.

It goes on to number 2, but,that being stated, how can there even be an SIC in
the scenarios being discussed unless the plane is TC'd for 2 pilots?

Second: FAR 61.55 Second In command Qualifications (d) states: This section
(referring, I think to 61.55) does not apply to a person who is : (4)
Designated as a safety pilot for purposes required by FAR 91.109(b) of this
chapter.

Doesn't this say that you can't be SIC if you are a safety pilot?

Maybe I'm missing something, but enjoying the topic!!

Alan

Bob Moore

unread,
Aug 14, 2001, 6:44:55 PM8/14/01
to
Hey Bob !

Is that you? I'm not quite sure who you really are...
As one says: "On the internet, nobody knows you're a dog..."

May be this would fills the blanks...

Name : MOORE, ROBERT RAYMOND
Pilot's Address : 39820 US HIGHWAY 19 N LOT 256
TARPON SPRINGS, FL, 34689-8324
FAA Region : Southern
Date of Medical : Jun, 2000
Class of Medical : 3
Expiration : Jun, 2002
Pilot Certificates : Airline Transport Pilot
Airplane Single Engine Land
Airplane Multiengine Land
: Certified Flight Instructor
Airplane Single Engine
Instrument Airplane
: Ground Instructor
Advanced
Instrument
: Flight Engineer
Turbojet Powered

I'm sorry you retired from the airline business. I'm sure it is pretty
tough not to fly those big boys anymore.

As for our friend William I hope you will enjoy to your name and email
address in the header.

May be you should read his (oups!) I mean my post sent under his name

The Globule ;-)

Note: Do you mind if a keep a little privacy in my life?


On Tue, 14 Aug 2001 15:57:37 GMT, rmoo...@tampabay.rr.com (Bob Moore)
wrote:

> William LeFebvre wrote:

Bob Moore

unread,
Aug 14, 2001, 7:03:36 PM8/14/01
to

>Hey Bob !
>Is that you? I'm not quite sure who you really are...

That's me...and proud of it!

Bob Moore

Bob Moore

unread,
Aug 14, 2001, 7:09:21 PM8/14/01
to
, super...@aol.com (SuperCobra) wrote:
>If I understand the Feds correctly, FAR 61.51 (f) Logging Second In Command
>Flight Time states: A person may log SIC time during which that person: (1) Is
>qualified in accordance with the SIC requirements of FAR 61.55 of this part,
>and occupies a crewmember station in an aircraft that requires more than one
>pilot by the aircraft's type certificate.

You quoted paragraph one and should have quoted paragraph two which
goes on to say........"or the regulations under which the flight is
conducted". And in this case the regs require a second flightcrew
member.

Bob Moore
ATP ASMEL
CFI ASE-IA

William LeFebvre

unread,
Aug 14, 2001, 8:06:31 PM8/14/01
to
An anonymous coward wrote:
> Hello William,
>
> I may very well be misinformed and incorrect.
>
> I hope you don't mind me sharing some public information...

Perhaps I should sue you for fraud, since you impersonated me in a posting.

(Note to self: write letter to FAA regarding their pilot
database....although it is probably already too late). :-)

Of course, now if I see someone stalking my house I'll know who it is, Mr.
Globule Man.

> Please think a little further before flaming someone for being
> cautious about their personal information.

No flame intended. It is simply hard for me to give any credibility to
someone who hides behind a cloak of anonymity.

> I hope you will appreciate your name in the header of this message and
> start to protect yourself more and flaming other less

Hey bud, I was forging From addresses before you even knew what the Internet
or Usenet were. Don't try to point out the bleeding obvious to me. I am
very much aware of exactly what the protocols do and how they work. So,
quite frankly, I am unimpressed by your efforts. So you know how to use a
search engine and you know how to spoof headers. Big deal.

> The attached picture could have been child porn sent all over Usenet
> with your name and email in the header.

And it still could have been traced back to you, or at least the machine you
posted it from. Or didn't you know that? Unlike you, I don't have a
collection of kiddie porn to draw on for such nefarious activities.

--
William LeFebvre
Mooney 4074H
w...@groupsys.com

The Globule

unread,
Aug 14, 2001, 9:59:24 PM8/14/01
to
Dear Sir,

Retrieving information about you was made possible only because of
your lack of common sense about preserving your privacy.

All information I posted is public and I didn't impersonate you in my
post since I sign it with my nickname but merely tried to point out
why I keep a minimum of privacy as anyone should on public forum.

On the other hand, I am asking you to be very care full about your
declarations. I respect your integrity, so should you respect mine...

You are only degrading and disqualifying yourself by insulting me,
please behave like a gentlemen, not like a moron...

The Globule
MCSE

William LeFebvre

unread,
Aug 15, 2001, 1:07:28 AM8/15/01
to
The Globule wrote:
> All information I posted is public and I didn't impersonate you in my
> post

Yes you did. You forged a "From" line to make it look like the message was
from me. Your intent was, after all, to "prove" how easy it is to
impersonate another individual, correct? Then, in the same post, you
threatened me by saying how the post could have had "child porn" attached to
it. But yet you are surprised that I reacted in a negative way?
Interesting.....

> since I sign it with my nickname but merely tried to point out
> why I keep a minimum of privacy as anyone should on public forum.
>
> On the other hand, I am asking you to be very care full about your
> declarations. I respect your integrity, so should you respect mine...

Sir, I find it very difficult to respect the opinion of someone who is not
even willing to take personal responsibility for what he says. I respect
your right to retain anonymity. If you feel it makes you "safer" somehow,
then go right ahead. But opinions expressed anonymously just don't carry
much weight with me. Sorry, but that's just the way I am.

> You are only degrading and disqualifying yourself by insulting me,
> please behave like a gentlemen, not like a moron...

This is from the person who impersonated me and a fellow poster (apparently
just to prove a point), and who thought nothing of going out of his way to
post detailed information about me and a fellow poster on this newsgroup. A
gentleman would never have done such things.

Kevin Mac

unread,
Aug 15, 2001, 3:25:01 AM8/15/01
to

>I hope you don't mind me sharing some public information...

Globule, you have every right (and plenty of good reasons) to be
anonymous. Although he taunted you about your anonymity, you shouldn't
have taken the bait.

Your response to Mr. LeFebvre is really over the line. You sucker
punched him. A diplomat would have made the point to him more
discretely (like in a private email). Now he'll probably escalate this
pissing match by contacting your news group provider
news...@supernews.com.

Let's just drop this thread now and pretend it didn't happen. Let's
talk about flying!

Ron Natalie

unread,
Aug 15, 2001, 9:16:18 AM8/15/01
to

SuperCobra wrote:
>
>
> It goes on to number 2, but,that being stated, how can there even be an SIC in
> the scenarios being discussed unless the plane is TC'd for 2 pilots?
>

Because the rule says "or by the regulations under which the flight is
conducted." You can have SIC whenever the rules require two pilots. Now
this was primarily targetted at things like Part 135, the FAA has admitted
that simulated instrument flight also qualifies under this clause.

> Second: FAR 61.55 Second In command Qualifications (d) states: This section
> (referring, I think to 61.55) does not apply to a person who is : (4)
> Designated as a safety pilot for purposes required by FAR 91.109(b) of this
> chapter.
>
> Doesn't this say that you can't be SIC if you are a safety pilot?

No, it doesn't say that at all. It says that you don't have to meet
the qualifications requirements of 61.55 to act ass SIC safety pilot.

The Globule

unread,
Aug 15, 2001, 9:21:48 AM8/15/01
to

Again, this is public information....

I am not the one who jokes about and about people protecting their
privacy.

I might not should have done that but I hope that every one will be a
little more concerned about being caution on a public forum.

I really hope Mr. LeFevbre will think about it...

For me, this "pissing match" is over and Mr. LeFevbre should get over
it. (I got to go fly)

The Globule

SuperCobra

unread,
Aug 15, 2001, 9:48:44 AM8/15/01
to
>Because the rule says "or by the regulations under which the flight is
>conducted." You can have SIC whenever the rules require two pilots.


>Because the rule says "or by the regulations under which the flight is
>conducted." You can have SIC whenever the rules require two pilots. Now
>this was primarily targetted at things like Part 135, the FAA has admitted
>that simulated instrument flight also qualifies under this clause.

That explains it.

Thanks,
Alan

William LeFebvre

unread,
Aug 15, 2001, 9:58:49 AM8/15/01
to
The Globule wrote:
>
> Again, this is public information....
>
> I am not the one who jokes about and about people protecting their
> privacy.

You still don't get it. The joke wasn't about you protecting your privacy.
The joke was about you pretending to have credibility while hiding behind a
mask. If you choose to protect your privacy by hiding behind a cloak of
anonymity I have no problem with that. But don't expect your opinions to
carry much weight while you do so. And if that little joke in my sig
offended you then, quite honestly, you need to build up a thicker skin to
survive on Usenet!

> I might not should have done that

No you should not have done that. Here's an analogy, just because you know
how to break in to a computer system does that mean you should exercise that
knowledge? I think not.

> but I hope that every one will be a
> little more concerned about being caution on a public forum.
>
> I really hope Mr. LeFevbre will think about it...

I have thought about it, many times. I have been posting on Usenet forums
for over 15 years (since before rec.aviation or even rec.anything existed).
You are not telling me anything that I don't already know. There are lots
of people out there who already know me by name. What would be gained by
hiding now?

You keep insisting that everyone respect your choice to hide. Now I ask you
to respect my informed choice to remain known. Can we leave it at that?

Let's all forget about this and go log some PIC time!

David Brooks

unread,
Aug 15, 2001, 4:28:11 PM8/15/01
to
"Steve Johnson" <stjo...@yahoo.com> wrote in message
news:3B79A7...@yahoo.com...

>
> I'd say Globule doesn't deserve flames. His post were cooperative and
> when small errors were noted, he corrected himself.

I think you're letting him off too lightly. He expressed himself in a robust
way, which isn't bad, but tried to win the argument by waving his
qualifications ("For your info, I am an active CFI, CFII, MEI, AGI, IGI and
check pilot for the Civil Air Patrol") instead of referring to the facts.
That always raises flags in my mind. When he was called on it, he admitted
the errors, for which I'll give him credit, but excused himself by being
unfamiliar with the "new" regulations.

Which leads me to ask, what happened at his last few BFRs? Isn't that
supposed to be the place where you come up to date with the regs?

Then there was the whole forging incident...

Pity: he sounds like the kind of person I'd like on a personal level.

-- David Brooks, who works at Building 40 in Microsoft.

Peter Gozinya

unread,
Aug 15, 2001, 9:15:56 PM8/15/01
to
Whew...

Danger Will Robinson. Danger...

Pete

The Globule

unread,
Aug 15, 2001, 10:53:49 PM8/15/01
to
I'm aware of the new regulations but not perfect (still working on
it... :-)

Due to the complexity and interactions within chapters, reformulation
of regulations often allows "interpretations" which aren't always
intended by the regulator.

This has happened many times in the past and will unfortunately happen
in the future.

Here is one of many examples of this:

Following the 1996 FAA regulations, a commercial pilot with an
airplane rating could log PIC while receiving instruction in a
helicopter.
This PIC time was required to obtain a commercial helicopter add on.

Following the 1997 FAA regulations, it was not possible to log PIC
under the same conditions. Therefore, under strict interpretation of
the newly formulated regulation, it wasn't possible for a commercial
pilot with an airplane rating to obtain a commercial helicopter add on
without getting first a private helicopter pilot certificate allowing
him to log the PIC time required for the commercial rating.

Of course, this wasn't the intent for the regulator and the
formulation changed again in 1998, solving this issue.

There is often some differences between a legal interpretation of a
text meaning and its intended meaning. When I'm asked about issues
like this one, I try to give the best answer possible, considering
past and current formulations of the same regulation as well as being
conservative.

A few months ago, I had to answer the same question about SIC vs PIC
time while flying an IFR flight plan to one of my former instrument
student. My answer to him was that it was a "gray area" and I advised
him not to do it. My advise, being conservative, would remain the same
today, even if the legal interpretation says it is OK to do it.

If an incident occurs in IMC, no one will want to take the blame and
everyone will go to court (at least the survivors). The insurance
will deny the claim considering that training was given by a pilot not
qualified as an instructor or that the airplane was flown by a pilot
not instrument rated.

The FAA and insurance companies have more attorney's power than the
majority of us beside the fact that we are not able to subpoena a FAA
employee to testify in court as an expert: the FAA doesn't allow it.

Chances are that FAA and insurance company will win the trial...

And for what? saving a few bucks and log a few extra hours.

But this is a free country... Do want you want...

The Globule
(still anonymous)

On Wed, 15 Aug 2001 13:28:11 -0700, "David Brooks"
<d_w_b...@hotmail.com> wrote:

David Brooks

unread,
Aug 16, 2001, 1:01:10 PM8/16/01
to
Good reply. I take back my criticisms.

-- David Brooks

"The Globule" <no...@nowhere.com> wrote in message

news:c77mnt4d3n098ceok...@4ax.com...

SG

unread,
Aug 18, 2001, 8:21:29 PM8/18/01
to

If the flight is in a complex high performance airplane, does the safety pilot need
the complex and high performance endorsments?

From my reading I understand:

- No, if the safety Pilot acts as Second in Command
- Yes, if the Safety Pilot acts as Pilot in Command

Am I correct?

Thanks

-- SG

Ron Rosenfeld

unread,
Aug 18, 2001, 9:02:59 PM8/18/01
to
On Sat, 18 Aug 2001 17:21:29 -0700, SG <nos...@nospam.com> wrote:

>
>If the flight is in a complex high performance airplane, does the safety pilot need
>the complex and high performance endorsments?
>
>From my reading I understand:
>
>- No, if the safety Pilot acts as Second in Command
>- Yes, if the Safety Pilot acts as Pilot in Command
>
>Am I correct?
>

Yes

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