A good pilot is always learning -- how many times have you heard
this old standard throughout your flying career? There is no truer
statement in all of flying (well, with the possible exception of
"there are no old, bold pilots.") It's part of what makes aviation
so exciting for all of us... just when you think you've seen it
all, along comes a scenario you've never imagined.
Aero-News has called upon the expertise of Thomas P. Turner,
master CFI and all-around-good-guy, to bring our readers -- and us
-- daily tips to improve our skills as aviators, and as
representatives of the flying community. Some of them, you may have
heard before... but for each of us, there will also be something we
might never have considered before, or something that didn't
"stick" the way it should have the first time we memorized it for
the practical test.
It is our unabashed goal that "Aero-Tips" will help our readers
become better, safer pilots -- as well as introducing our
ground-bound readers to the concepts and principles that keep those
strange aluminum-and-composite contraptions in the air... and allow
them to soar magnificently through it.
Look for our daily Aero-Tips segments, coming each day to you
through the Aero-News Network. Suggestions for future Aero-Tips are
always welcome, as are additions or discussion of each day's tips.
Remember... when it comes to being better pilots, we're all in this
A reader asks:
If an instrument rated safety pilot
files an IFR flight plan on a VMC day, can the student instrument
pilot legally log simulated instrument time while under the hood?
Should the flight enter IMC, what are the ramifications?
Let's look at some assumptions for the specific scenario
- The IFR-rated (and presumably current) "safety pilot" is not an
Instrument Instructor (CFII) but otherwise is fully current and is
acting as Pilot-in-Command (PIC).
- The "student instrument pilot" (SIP) is certificated as a
Private or Commercial pilot and current to carry passengers in the
make and model airplane flown.
- By "logging" the time the reader means logging it for purposes
of meeting the experience requirements for the Instrument rating
(as opposed to logging for "diary purposes").
If those assumptions are correct, here's what the Federal Air
Regulations have to say about logging simulated instrument
61.51(g), Logging instrument
- A person may log instrument time only for that flight time when
the person operates the aircraft solely by reference to instruments
under actual or simulated instrument flight conditions.
- For the purposes of logging instrument time to meet the recent
instrument experience requirements of Sec. 61.57(c) of this part,
the following information must be recorded in the person's
- The location and type of each instrument approach accomplished;
- The name of the safety pilot, if required.
"Safety pilots", however, are addressed in FAR 91.109(b), which
No person may operate a civil aircraft in simulated instrument
- 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.
- The safety pilot has adequate vision forward and to each side
of the aircraft, or a competent observer in the aircraft adequately
supplements the vision of the safety pilot.
Back to the scenario
From this reading of the regulations, then, it appears that:
- Assuming the assumptions are correct, the SIP can indeed log
simulated instrument time for that time the airplane is in visual
conditions and the SIP is sole manipulator of the controls, flying
solely by reference to instruments.
- It might be construed that upon entering IMC the regulatory
provision for Safety Pilot no longer exists, because there is not
"adequate vision forward and to each side of the aircraft."
However, adequate might be satisfied by simply being able to see
out in IMC. This is a regulatory "grey area" (IMC pun
intended)…I'd be interested in input from the FAA or other
in-the-know persons on this.
My read on this, however, is that "safety pilot" is a
designation intended for flight in visual conditions. Barring
informed information to the contrary, I feel that the SIP can log
simulated instrument time in VMC, but once the flight enters IMC
the PIC should take over the controls as the SIP can't log the time
anyway. Save the "Actual" time for flight with a
Thanks, reader, for your question, and for your patience
waiting for the answer to appear in print.
Aero-tip of the day: Get an official FAA
ruling before gambling on "grey area" interpretations of the
Federal Air Regulations.