On 02/10/06 08:54, Gary Drescher wrote:
"Mark Hansen" wrote in message
...
When flying in VMC and using a view limiting device, the safety pilot
is considered a required crew member, and as such can decide to act
as PIC or SIC.

Correct. And because the flight is construed to require multiple crew
members, the safety pilot (if acting as PIC) can log PIC time (in addition
to the sole manipulator doing so), according to 61.51e1iii.

However, I would think this is not the case when flying
in IMC, as the safety pilot must be PIC (because the pilot flying is
not IMC current).

In the IMC scenario, there is no safety pilot, and there is only one
required crew member (the PIC). Under those circumstances, merely acting as
PIC does not entitle the pilot to log PIC time (acting as PIC is not one of
the three conditions listed in 61.51e1 as the *only* conditions that allow
PIC time to be logged).

Nonetheless, the FAA has reportedly said that a pilot acting as PIC (even
when just one crewmember is required) can log PIC time if the sole
manipulator does not or cannot.

Thank you, Gary. This is certainly very clear, although it is not what
I previously understood. I wonder if the Chief Counsel simply hasn't been
asked this specific case:

- IMC conditions
- Pilot flying is not IMC current
- Pilot flying is sole manipulator of the controls, and thus logs PIC
- Pilot not flying is acting PIC (required because the pilot flying is
not IMC current) and so logs PIC

Perhaps what is confusing me is that I thought that any pilot "acting"
as PIC was entitled to log the time as PIC. Your statement to the contrary,
above, is the first time I've ever heard that.

Thanks again - this is a great discussion!


If this is covered by one of the Chief Counsel written opinions, can
you please provide a reference to it?

That's certainly a reasonable question, but they're not readily available as
far as I know; they circulate mainly as Usenet chain mail. So my own policy
when a purported Chief Counsel opinion flatly contradicts the FARs is just
to follow the FARs.

--Gary




--
Mark Hansen, PP-ASEL, Instrument Airplane
Cal Aggie Flying Farmers
Sacramento, CA