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Safety Pilot PIC Time - Answered

SR-20 Jens / Flickr

Did you check out our vote post yesterday on logging PIC time? It's a spin on the popular "safety pilot logging PIC" scenario that comes up often.

Here's the rundown:

You're a private pilot (non-instrument rated), and your friend invites you to ride along on a cross-country. He's a private pilot with an instrument rating, and he's flying his Cirrus SR-20 from Louisville, KY to Augusta, GA.
Both of you have current medicals, as well as the required takeoff/landing currency under FAR 61.57 for the Cirrus (Airplane Single Engine Land).
On the day of the flight, your friend files an IFR flight plan and the two of you take off for Augusta. The weather is clear across the entire route, and even though you're on an IFR flight plan, you're in VMC (visual meteorological conditions) the entire time.
Part of the way through the flight, your friend says he wants to practice some simulated instrument conditions "under the hood," and he asks you to be his safety pilot while he practices. You accept, and he flies for .9 hours with his foggles on. A few hours later, you land in Augusta, with a total flight time of 3.2 hours.
Can you both log PIC time for all or part of the flight?

Here's What You Said:

As of Monday night, 43 said both of you can log PIC for the entire flight, 244 said both of you could log PIC for the .9 hours when you acted as the safety pilot, and 126 said you can't log any PIC time - only your friend can log PIC.

What's The Deal With Two PICs?

There can only be one pilot-in-command (PIC). However, "acting" and "logging" are two different things. FAR 61.51 - Pilot Logbooks describes when you can log time, and section (e) covers PIC time. It says:

(1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights:
(i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate;
(ii) When the pilot is the sole occupant in the aircraft;
(iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted

(We're only including the relevant parts of the reg, and the bold emphasis is ours.)

So - your friend can log PIC because he's sole manipulator of the controls and is rated in the aircraft. How about you?

Simulated Instrument Flight

FAR 91.109 (c) says:

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 a private pilot certificate with category and class ratings appropriate to the aircraft being flown.

(Again, we're only including the relevant parts for this scenario.)

So, FAR 61.51 says you can log PIC time when you are acting as pilot-in-command and when more than one pilot is required by the regulations governing the flight. And FAR 91.109 says that when your friend's under the hood, another pilot - the safety pilot - is required. If the safety pilot is designated as the pilot-in-command, he or she can normally log the time as PIC.

What About The IFR Flight Plan?

But wait - there's a catch here. The flight's conducted on an IFR flight plan.

FAR 61.3 (e) explains when an instrument rating is required:

Instrument rating. No person may act as pilot in command of a civil aircraft under IFR or in weather conditions less than the minimums prescribed for VFR flight unless that person holds:
(1) The appropriate aircraft category, class, type (if required), and instrument rating on that person's pilot certificate for any airplane, helicopter, or powered-lift being flown;

(Again, we're only including the relevant parts and we're adding the bold emphasis.)

In This Case, You Can't Log PIC

That's the catch - you're on an IFR flight plan, which means you're flying under IFR. And, you don't have an instrument rating, so FAR 61.3 says you can't act as pilot-in-command.

You can still be the safety pilot, you just can't be the pilot-in-command. And that means you can't log PIC as the safety pilot. Even if the weather is clear, operating on an IFR flight plan still requires an instrument rating.

How could you have logged PIC? If you cancelled the IFR clearance, then you would have been flying VFR and could have acted as the PIC and a safety pilot. But, that's a lot of hassle to build .9 hours of PIC time.

Aleks Udris

Aleks is a Boldmethod co-founder and technical director. He's worked in safety and operations in the airline industry, and was a flight instructor and course manager for the University of North Dakota. You can reach him at

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