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PostPosted: Wed Dec 03, 2008 12:47 pm 
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Location: Livermore, CA
I've got what might be a silly question...

I have a neighbor who is an ATP-rated pilot for a foriegn freight carrier who said he would love to be my safety pilot for IFR currency flights. Apparently long haul flights over the Pacific in a 747 just aren't cutting it for him and he is itching to get back in something more macho such as a C172 or Warrior. ;-)

He is a US citizen and has a US license, and is current as far as his job goes (completes check flights every 6 months), but neither of us really knew with 100% certainty whether he is qualified to serve as my safety pilot.

I would assume so, but figured it doesn't hurt to ask. Anyone know?

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PostPosted: Wed Dec 03, 2008 3:27 pm 
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Location: SF Bay Area, California
Hi PilotBrad. My guess is that he probably isn't right now. I'm predicating that on the belief that he hasn't flown a single in a while.

Safety Pilot regulations start at 91.109:

Quote:
91.109 (b): 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.


I'm sure your friend qualifies here - provided he has an ASEL Private rating or higher. Who knows, he could have skipped it and got his private in a multi and can't even legally fly singles.

91.109 makes a safety pilot a "required pilot flight crewmember". Now on to 61.3 which tells us what is required to be a "pilot in command" or "required pilot flight crewmember":

Quote:
61.3: Requirement for certificates, ratings, and authorizations.

(a) Pilot certificate. A person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of a civil aircraft of U.S. registry, unless that person--
(1) Has a valid pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. ...
...
(c) Medical certificate. (1) Except as provided for in paragraph (c)(2) of this section, a person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of an aircraft, under a certificate issued to that person under this part, unless that person has a current and appropriate medical certificate that has been issued under part 67 of this chapter, or other documentation acceptable to the Administrator, which is in that person's physical possession or readily accessible in the aircraft.


So, valid flight certificate and medical - he'll have these covered too as long as he's ASEL. Now for the fun part - does he need "recent flight experience"? On to 61.57.

Quote:
61.57: Recent flight experience: Pilot in command.

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and--
(i) The person acted as the sole manipulator of the flight controls; and
(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel.
(2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act as a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are carried on board the aircraft, other than those necessary for the conduct of the flight.


This says that in order to be PIC or (I'm admittedly stretching the wording a little) a required flight crewmember, he needs to have done 3 takeoffs and landings in a single engine aircraft. This is where your friend probably doesn't qualify right now. So, have him do those three takeoffs and landings in a single.

Next question: can he do it with you on board? I'd say probably not, but I think this is still a bit of a gray area. You'll see that 61.57(a)(2) says that no persons may be on board other than those necessary for the conduct of the flight. I've heard the argument that YOU as a CURRENT single engine pilot are required simply because he's not current (and has a "passenger") until he's done his three landings.

But if you want to entirely avoid gray areas - which I'm guessing you do since you asked this question - have him go for a flight by himself or with a CFI. And if he hasn't really flown a small single for a long time, he might need a CFI to help him out for the first couple of times. Big iron pilots have this nasty tendency to flare at 60 feet AGL. :)


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PostPosted: Thu Dec 04, 2008 3:28 am 
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Joined: Tue May 13, 2008 9:35 pm
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PilotBrad wrote:
I've got what might be a silly question...

I have a neighbor who is an ATP-rated pilot for a foriegn freight carrier who said he would love to be my safety pilot for IFR currency flights. Apparently long haul flights over the Pacific in a 747 just aren't cutting it for him and he is itching to get back in something more macho such as a C172 or Warrior. ;-)

He is a US citizen and has a US license, and is current as far as his job goes (completes check flights every 6 months), but neither of us really knew with 100% certainty whether he is qualified to serve as my safety pilot.

I would assume so, but figured it doesn't hurt to ask. Anyone know?


I am going to make an assumption here that you want your friend to safety for you in a single engine land plane. Two questions

1. Does your friend have a single engine land rating on his certificate?

2. Does your friend have a current medical?

If the answer to both is "Yes" then he can act as your safety pilot. Period. He does not need to be current as long as you are. That means YOU are the PIC and must be current and qualified in all respects. Go fly and have fun! :)


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PostPosted: Thu Dec 04, 2008 3:47 am 
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Landis wrote:
Hi PilotBrad. My guess is that he probably isn't right now. I'm predicating that on the belief that he hasn't flown a single in a while.


And your "guess" would be wrong.

Quote:
Safety Pilot regulations start at 91.109:

Quote:
91.109 (b): 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.


I'm sure your friend qualifies here - provided he has an ASEL Private rating or higher. Who knows, he could have skipped it and got his private in a multi and can't even legally fly singles.

91.109 makes a safety pilot a "required pilot flight crewmember". Now on to 61.3 which tells us what is required to be a "pilot in command" or "required pilot flight crewmember":

Quote:
61.3: Requirement for certificates, ratings, and authorizations.

(a) Pilot certificate. A person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of a civil aircraft of U.S. registry, unless that person--
(1) Has a valid pilot certificate or special purpose pilot authorization issued under this part in that person's physical possession or readily accessible in the aircraft when exercising the privileges of that pilot certificate or authorization. ...
...
(c) Medical certificate. (1) Except as provided for in paragraph (c)(2) of this section, a person may not act as pilot in command or in any other capacity as a required pilot flight crewmember of an aircraft, under a certificate issued to that person under this part, unless that person has a current and appropriate medical certificate that has been issued under part 67 of this chapter, or other documentation acceptable to the Administrator, which is in that person's physical possession or readily accessible in the aircraft.


So, valid flight certificate and medical - he'll have these covered too as long as he's ASEL. Now for the fun part - does he need "recent flight experience"? On to 61.57.


You were fine up until this point. So far you have quoted the regs that are required for a safety pilot. Notice that there are no currency requirements contained in the above regulations. That is because none are necessary.

Where you fell down, so to say is in the following regulation:

Quote:
Quote:
61.57: Recent flight experience: Pilot in command.

(a) General experience. (1) Except as provided in paragraph (e) of this section, no person may act as a pilot in command of an aircraft carrying passengers or of an aircraft certificated for more than one pilot flight crewmember unless that person has made at least three takeoffs and three landings within the preceding 90 days, and--
(i) The person acted as the sole manipulator of the flight controls; and
(ii) The required takeoffs and landings were performed in an aircraft of the same category, class, and type (if a type rating is required), and, if the aircraft to be flown is an airplane with a tailwheel, the takeoffs and landings must have been made to a full stop in an airplane with a tailwheel.
(2) For the purpose of meeting the requirements of paragraph (a)(1) of this section, a person may act as a pilot in command of an aircraft under day VFR or day IFR, provided no persons or property are carried on board the aircraft, other than those necessary for the conduct of the flight.


This says that in order to be PIC


Lets stop right here for now. Notice the section is titled "Recent flight experience: Pilot in command." It does NOT apply to anyone other than the PIC. It does NOT apply to the safety pilot.

Quote:
or (I'm admittedly stretching the wording a little) a required flight crewmember,


Yeah, quite a stretch because, as I said, it ONLY applies to the PIC. The rest of the paragraph is irrelevant.

What follows is getting into a whole different set of currency requirements.
Quote:
Next question: can he do it with you on board? I'd say probably not, but I think this is still a bit of a gray area.


No gray at all.

Quote:
You'll see that 61.57(a)(2) says that no persons may be on board other than those necessary for the conduct of the flight.


You left out a rather important point. The section says that no person may ACT AS PIC ... That is a rather important distinction.

Quote:
I've heard the argument that YOU as a CURRENT single engine pilot are required simply because he's not current (and has a "passenger") until he's done his three landings.


As long as YOU are current, YOU may allow a non current pilot be "sole manipulator of the controls" to gain his landing currency. Nothing wrong, or against regulations in this.

Quote:
But if you want to entirely avoid gray areas - which I'm guessing you do since you asked this question - have him go for a flight by himself or with a CFI.


Nothing wrong with that advise, but in the context of safety pilot, unnecessary.

Quote:
And if he hasn't really flown a small single for a long time, he might need a CFI to help him out for the first couple of times. Big iron pilots have this nasty tendency to flare at 60 feet AGL. :)


Hmm. I sort of resent that remark.

:mrgreen:


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PostPosted: Thu Dec 04, 2008 12:31 pm 
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Joined: Thu Feb 14, 2008 5:10 pm
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Location: Livermore, CA
Wow, thanks guys... Great stuff!

A little more info on him...
He is ASEL rated, and has a current medical. He learned in GA aircraft, then got hired by the regionals to fly an RJ, then recently as an FO on the 747.

He's not current in ASELs, and since it's not my A/C he's not going to get current with me as PIC. He'll need an instructor for that. ;-)

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PostPosted: Thu Dec 04, 2008 6:10 pm 
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PilotBrad wrote:
He's not current in ASELs, and since it's not my A/C he's not going to get current with me as PIC. He'll need an instructor for that. ;-)


Good idea. But the bottom line point is that he does not need to be current to act as your safety pilot.


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PostPosted: Fri Dec 05, 2008 11:22 am 
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Joined: Sun Oct 21, 2007 6:35 am
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Location: SF Bay Area, California
Greg is right. If your friend is going to be SIC he doesn't need to be current. I was thinking in terms of both pilots logging PIC time (you as sole manipulator of the controls, the friend as the acting PIC). This is the normal case when both people are trying to build time, but your friend probably doesn't really care about being PIC or logging PIC. You will be both "acting PIC" and "PIC as sole manipulator" and your friend will be SIC as a required crew member.

Good info from AOPA (members link) at http://www.aopa.org/members/files/topics/sftyplt.html

As for the Recent Flight Experience and there being "no gray at all", I'm glad that Greg is able to see through all of the different interpretations and come out completely black and white. But there are different interpretations and the FAA/NTSB has been known in the past to go against the most commonly held interpretations among the community. While I agree that the most common interpretations of 61.51 and 61.57 allow a non-current pilot to log PIC for recency purposes while another current pilot acts as PIC (logging nothing), I wouldn't say that there is no gray here or that the FAA/NTSB will never interpret this differently.

Should we go into logging XC as Safety Pilot next? :)


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PostPosted: Fri Dec 05, 2008 7:46 pm 
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Landis wrote:
While I agree that the most common interpretations of 61.51 and 61.57 allow a non-current pilot to log PIC for recency purposes while another current pilot acts as PIC (logging nothing), I wouldn't say that there is no gray here or that the FAA/NTSB will never interpret this differently.


61.51(e) is pretty black and white. And the FAA has enough rulings on that to make it pretty clear. What they do in the future is of no concern at THIS time.


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PostPosted: Wed Dec 10, 2008 11:51 am 
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Joined: Thu Feb 14, 2008 5:10 pm
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Location: Livermore, CA
Thanks again guys. Your comments agree with my original thinking regarding the FARs. Strange as it may seem, I let the fact that he is an ATP somehow cause undue concern.

He won't be logging any of the time. I just want him to sit there and keep his hands in his lap and his mouth shut. That is, unless I am about to hit something. :P

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