Safety Pilot - Logging Instrument Time - Who is PIC?

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FlaplessDork
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:ummmm ... that's how I got my initial group 3 instrument rating, all those years ago - logging PIC under the hood, with a safety pilot in the right seat whom was NOT qualified to teach IFR.

At first, the DOT inspector doing my initial ride didn't want to count those hours towards my 40 instrument, and he maintained that I didn't have the experience for the instrument rating. I respectfully requested he look it up, and after talking to his boss's boss, the Inspector agreed with me that I was right and he was wrong, and that experience surely did count.

Not sure what else you want from me. CARs are very clear, and so is my experience on this very subject with Transport.

You want to people to do something different than the CARs, and that's fine with me. But it's simply not required - my initial instrument rating is the proof of that.
I'm saying its open still for interpretation. Your experience is proof of varying opinions. In my experience I've seen things get passed by on license applications before, I've seen multiple interpretations on CARs from various inspectors, and I've seen things enforced incorrectly. It seems to vary from region too. My point is the jury is still open on it. It is still open for argument.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Tim »

as I mentioned, it's part of the MFC syllabus. every time i recommended someone for an IFR flight test i used this time towards the 40 hrs.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

It is still open for argument
No. To summarize:

-- FD says all instrument time for IFR must be dual from "qualified person".

On the other side, we have:
-- CAR 421.46 clearly states EXPERIENCE not TRAINING for 40 hrs instrument, and explicitly states ONLY 15 hrs instrument required from "qualified person",
-- Hedley,
-- Transport (Hedley's initial group 3 IFR),
-- KK7,
-- Tim (MFC).

Hmmmm.

Feel free to do or say whatever you want at your school. You're CFI, you're God there, you can make all your instructors and students wear pink tu-tu's if you want. You can tell your students that they need 100 hours instrument time for an initial instrument rating. Why would I care? But don't pretend that's what the CARs say.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by mcrit »

Guys,
I think what you are looking for is in the AIM not the CARs.
http://www.tc.gc.ca/eng/civilaviation/p ... 67.htm#3-7
3.7.4 Instrument Flying Practice

(a) When licensed pilots are engaged in instrument flying practice with an appropriately qualified pilot, only the designated pilot-in-command may be credited with pilot-in-command flight time.

(b) The pilot undertaking instrument practice with an appropriately qualified pilot, if not the designated pilot-in-command, may be credited with dual flight time.

(c) The safety pilot, if not the designated pilot-in-command, may be credited with co-pilot flight time if the certificate of airworthiness requires a co-pilot on the type of aircraft being used.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Big Pistons Forever »

FlaplessDork wrote:
Hedley wrote:You are reading something into the CARs that is simply not there.
It is there.

Read CAR 425.21
(9) A person who conducts flight training toward the issuance of an instrument rating shall be the holder of a Commercial Pilot Licence or an Airline Transport Pilot Licence, have an instrument rating and:

(a) have a flight instructor rating; or

(b) have experience of not less than 500 hours pilot-in-command flight time, of which:

(i) not less than 100 hours shall be on the applicable aircraft group, and

(ii) in the case of Group I aircraft, not less than 10 hours shall be on the type of multi-engine aeroplane used for the training
You can do it, you just can't do it towards the instrument rating. But then again why would you want to? The instrument time for the other licenses and ratings is specifically under the dual requirements.

If you're up there training yourself its still training, and you need to meet Part 4 requirements to conduct training.

my 02 cents

Since "skybaron" the original poster who started this thread asked about logging time for refresher training the issue of experience vs training for the issue of
initial IFR rating is irrelevant.

Assuming we are talking about light aircraft operations, the only thing that matters is that there can only be one pilot who logs PIC time. That can be either the guy doing the refresher training or the safety pilot, but not both. If the safety pilot is also an instructor he/she could log either nothing or PIC with the other person logging dual.

With respect to the 40 hours required for the initial rating, as Hedley points out the CAR should be read literally. If they do not say "training" then training should not be implied. However just because you can do something does not necessarily mean you should. The point of the exercise is to learn how to fly IFR and past the IFR flight test. You should IMO do this with a planned program of simulator and aircraft training. My personal experience is that most people need a cumulative total of 40 (or more) hours of training in order to become competent at flying IFR. I personally would discourage students practicing on their own with a safety pilot because they are likely to practice the wrong way of doing something rather than the right way. It seems to me if you are already incurring the expense of flying the aircraft you might as well also pay a bit more for the instructor and get more value from the flight. But if you are a skygod and learned everything you need to know to pass the ride in your 5 hours of PPL instrument training and 15 more hours of IFR training then I guess go fill your boots flying on your own with a safety pilot.

Ps RE the AIM: Unless the paragraph heading includes a CAR's reference , which this one does not then, it is "information" not "direction" and thus not binding on the pilot
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:FD says all instrument time for IFR must be dual from "qualified person".
You are misquoting me. I have said from the beginning that you can credit instrument experience towards the IFR. The argument has never been about whether the time can be credited.
FlaplessDork wrote:You can do it, you just can't do it towards the instrument rating.
The argument is whether you can conduct solo training for the specifically for IFR. My argument is that if you are self training on with specific intent for the instrument rating it falls under CAR 425.21 which states that a person conducting training must be qualified. Flight training is not necessarily only a dual activity.

By your own admission you said you were self taught IFR, aka conducting your own flight training. Now you can argue can that your time was not towards the instrument rating and that could be the workaround. Who's to say what you actually did, but you can't ignore CAR 425.21.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

The argument is whether you can conduct solo training for the specifically for IFR
No, it is not. CAR 421.46 clearly says that 40 hours of instrument EXPERIENCE is required for an initial instrument rating.

You have decided to deliberately mis-interpret that as your own definition of "solo training" and thus suck in CAR 425.21, which is where your argument goes off the rails.

There is a simple difference between EXPERIENCE and TRAINING which you are having difficulty comprehending.

If CAR 421.46 didn't explicitly require 15 hours from a "qualified person", I can perhaps see some confusion. But there is no confusion - it explicitly requires 15 hours, not the 40 hours that you are deliberately and incorrectly asserting, perhaps for your own purposes of generating revenue hours.

Don't mis-understand me - at your FTU, as CFI you are God. What you say, goes. However, just because you have different (possibly higher) standards, DOES NOT make them the CARs, and the rest of us, outside your FTU, do not have to respect your policy decisions.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:
The argument is whether you can conduct solo training for the specifically for IFR
No, it is not. CAR 421.46 clearly says that 40 hours of instrument EXPERIENCE is required for an initial instrument rating.

You have decided to deliberately mis-interpret that as your own definition of "solo training" and thus suck in CAR 425.21, which is where your argument goes off the rails.

There is a simple difference between EXPERIENCE and TRAINING which you are having difficulty comprehending.

If CAR 421.46 didn't explicitly require 15 hours from a "qualified person", I can perhaps see some confusion. But there is no confusion - it explicitly requires 15 hours, not the 40 hours that you are deliberately and incorrectly asserting, perhaps for your own purposes of generating revenue hours.

Don't mis-understand me - at your FTU, as CFI you are God. What you say, goes. However, just because you have different (possibly higher) standards, DOES NOT make them the CARs, and the rest of us, outside your FTU, do not have to respect your policy decisions.
Define experience and training.

Again you misquote me. My argument has never been about crediting hours but the definition of when you are training and when you are not. I say its training if the intent is to practice skills for the IFR and therefore it falls under CAR 425.21. If its structured into a syllabus its classified as training. If you are practicing skills on your own with the intent of obtaining a rating you are in essence creating your own training syllabus. I've agreed from the beginning it can be argued either way. The truth is until something goes wrong and somebody sues, or there is enforcement action relating to this particular issue this debate will not be settled. The CARs are open to interpretation.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

I say its training if the intent is to practice skills for the IFR and therefore it falls under CAR 425.21
I say it's EXPERIENCE as per CAR 421.46. If you don't believe me, call whomever your want at Transport and ask them.

CAR 421.46 does NOT say 40 hrs from a "qualified person". It says 15, despite what you might think.

I find the motive suspicious, when an instructor tells you that the regulations require more instruction than they actually do. I have seen many students "milked" by instructors before, and it offends me.
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Last edited by Hedley on Wed Feb 09, 2011 12:22 pm, edited 1 time in total.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:
I say its training if the intent is to practice skills for the IFR and therefore it falls under CAR 425.21
I say it's EXPERIENCE as per CAR 421.46. If you don't believe me, call whomever your want at Transport and ask them.

CAR 421.46 does NOT say 40 hrs from a "qualified person". It says 15, despite what you might think.
I've agreed with this from the start. Define when it is considered training and when it is not. When does CAR 425.21 apply in your opinion?
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

When does CAR 425.21 apply in your opinion?
CAR 425.21 applies for the 15 hours as explicitly required by CAR 421.46(2)(b)(ii)(C).

This is really very simple. I don't see any wiggle room here. Again, call whomever you wish at Transport, and go with their answer.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:CAR 425.21 applies for the 15 hours as explicitly required by CAR 421.46(2)(b)(ii)(C).

This is really very simple. I don't see any wiggle room here. Again, call whomever you wish at Transport, and go with their answer.
In my opinion it applies anytime there is training conducted specifically for the instrument rating. I don't see where is holds a 15 hour condition to it.

A pilot obtained 35 hours of instrument experience during there PPL/CPL from a person that wasn't instrument rated. Under the CAR's they would require an additional 15 hours from a qualified individual who held the instrument rating. This is why the regulation is what it is. It allows you to take credit from instrument experience obtained from previous sources when applying for the license to which a minimum of 15 must be provided by the qualified person. It is silent on training. CAR 425.21 mentions training for the instrument rating and the requirements. As soon as I tell someone to go "learn IFR on your own" 425.21 is being broken. Now if I tell them to practice VOR tracking on your own to "be a better at flying at night" you can take credit. Thats how you can work around it and CYA at the same time.

Its the very reason why MFC according to Tim allows it only if its not towards the instrument rating.
Tim wrote:you don't need an instrument rating to be a safety pilot for someone who is notworking towards a inst rating. moncton flight college routinely sends students to act as safety pilots with other students for solo instrument practice. in fact, it's part of the syllabus.
Soon as you designate a flight as part of an instrument rating syllabus, CAR 425.21 needs to be met. There's still lots of flexibility here, and you can still save people a lot of money, but you are now certain you are CYA.

Discussion is a good thing as it gets people thinking but the topic has been beaten to death. I'm also tired of having my character attacked because my opinion varies from yours. I'm done.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

I'm also tired of having my character attacked
I'm not attacking your character. What I'm smelling is an instructor milking students, and I'm afraid I don't tolerate that kind of unethical behaviour very well.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

Hedley wrote:I'm not attacking your character. What I'm smelling is an instructor milking students, and I'm afraid I don't tolerate that kind of unethical behaviour very well.
You're making assumptions, and yes it is an attack on my character when you have never met me. I no longer instruct, but my students will attest that I would bent over backwards for them. Many still call me with their questions. You've resorted to throwing sticks and stones when I all have done is have a debate. Not once have I used mockery or made assumptions on your character during this debate.
Hedley wrote:I have seen many students "milked" by instructors before, and it offends me.
Hedley wrote:Don't mis-understand me - at your FTU, as CFI you are God
Hedley wrote:perhaps for your own purposes of generating revenue hours.
Hedley wrote:Feel free to do or say whatever you want at your school. You're CFI, you're God there, you can make all your instructors and students wear pink tu-tu's if you want. You can tell your students that they need 100 hours instrument time for an initial instrument rating. Why would I care? But don't pretend that's what the CARs say.
Hedley wrote:Please feel free to do whatever makes you happy. If you think wearing a purple hat keeps the elephants away, who am I to argue with your logic?
All assuptions and do nothing to further your position. Quite frankly its low, unprofessional and childish and have made me loose complete respect for you.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

made me loose complete respect for you
You're wrong again - that's "made me lose complete ..."

As you point out, though, the most important thing in aviation isn't facts, it's feelings.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Dagwood »

I've noticed that if I don't agree with Hedley, it means he knows something I have yet to learn. :prayer:

Now back to our regularly scheduled programing. :mrgreen:
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by KK7 »

I'm surprised this is still an argument considering how I think the CARs are pretty well spelled out on this issue.

I'm with BPF that the 40 hours instrument experience should be more weighted towards dual with a qualified person rather than on your own, but that doesn't change what the CARs says. If someone with 40 hours experience wants to try out the flight test, and asks me to recommend them, and my flying with them proves to me that they are competent, I would have no choice but to recommend even if the 40 hours isn't all training as per the CARs, but 15 hours with a qualified person, 5 hours with an instructor, and a total of 40 hours instrument experience. But of someone came to me asking me to put together a training plan for them, I would suggest like BPF that they do 40 hours training. Not because of milking, but because I feel this will produce a better IFR pilots. I'm not speaking of qualified people (ie instructors with little IFR experience) who may or may not provide poorer quality instruction than someone practicing on their own.

Anyways, if anyone thinks, despite the CARs being pretty clear, that the 40 hours instrument experience must be completely training and not any experience outside of this, then I can only conclude that they consider the 45 hour PPL requirement to involve 45 hours of dual and no solo practice at all. If one can learn to fly with some solo practice, which I consider to be a very key component of ab initio training, then why not IFR?
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Hedley »

I'm surprised this is still an argument considering how I think the CARs are pretty well spelled out on this issue
Indeed. At this point, I am beginning to suspect that Flapless Dork is in fact a highly skilled troll, laughing his @ss off at me. If so, ya got me, buddy.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by FlaplessDork »

KK7 wrote:Anyways, if anyone thinks, despite the CARs being pretty clear, that the 40 hours instrument experience must be completely training and not any experience outside of this, then I can only conclude that they consider the 45 hour PPL requirement to involve 45 hours of dual and no solo practice at all. If one can learn to fly with some solo practice, which I consider to be a very key component of ab initio training, then why not IFR?
Read 425.21(2), which states that a permit holder can conduct self-training without being an instructor and 401.19 which places further limitations on the student pilot permit specifically.

The argument has never been about the hours being credited. Both opinions allow for equal flexibility on obtaining the hours.

The argument is if a flight is designated as a training flight for the purpose of obtaining an instrument rating does it fall under CAR 425.21 and when is a flight considered a training flight for the purpose of obtaining an instrument rating.

I don't believe its as black and white as Hedley claims. I shared my opinion, and will admit to the possibility of being wrong, however nothing yet has changed my opinion.
Hedley wrote:
I'm surprised this is still an argument considering how I think the CARs are pretty well spelled out on this issue
Indeed. At this point, I am beginning to suspect that Flapless Dork is in fact a highly skilled troll, laughing his @ss off at me. If so, ya got me, buddy.
You are just as guilty as I am.
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Re: Safety Pilot - Logging Instrument Time - Who is PIC?

Post by Les Habitants »

Wow...the disrespect here baffles me

Flapless is simply stating that, while it is not strictly against the CARs, if you were to go flying on your own under the hood with a safety pilot in the right seat of your 172 for the purpose of brushing up on your instrument skills for you're IR, it could easily be misinterpreted as "training." If there is ONE thing that I have learned about insurance companies, it's that they will go to great lengths to save a mighty dollar. I wouldn't put it past whoever it is covering your insurance to argue the point Flapless makes, that your flight was for the purpose of trainingfor your IR (whether YOU call it training or not), and therefore, because you did not have a properly qualified training pilot in the right seat, your insurance is void.
It's a grey area, and all Flapless is arguing here, is that it's his proposition to avoid "flirting" with that grey area, so that if there ever was an investigation, he is going to be able to put concrete evidence behind his arse that he was following the CARs by the book.
He's just covering his arse, and it's just his opinion. Frankly, I agree 100% with him, and there is no need to attack him for that.

Hedley, you're throwing low blows and showing a complete lack of class. You are COMPLETELY misinterpreting Flapless here, and being completely hypocritical. It's behaviors like that that too many pilots who "think they are all that" display that make me ashamed to be apart of the industry
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