Logging dual time on mutual flights

[Speedalive]

During flight training we did a number of mutual flights bombing around doing simulated ifr cross country flights. We were told that if we were acting as PM, we couldn't log the hours. I never thought twice about it, but I'm curious if there's a cars reference out there for why that is. If the PF was a PPL student working on his/her CPL/IFR and I were a mifr commercial pilot sitting right seat as PM/acting as safety pilot to keep us in VMC, could I have actually logged some of that time? If not, does it have to do with the C172 being certified as a single pilot airplane? I'd appreciate some clarification!

[PilotDAR]

A single pilot airplane (defined by its design, or national approval) requires one licensed pilot. There is no role for a second licensed pilot as a required crew member. If there is a second licensed pilot aboard, they are a passenger, no matter what their qualification. If the person flying is a student, the licensed pilot (either on board, or supervising) will be a licensed instructor, and there's still only one licensed pilot on board.

Thinking about it differently, if you presented time logged as a second pilot to TC in support of the next license or rating, what would you tell TC you were doing in a 172 in your capacity as a logging time a second pilot?

[photofly]

If the PF was a PPL student working on his/her CPL/IFR and I were a mifr commercial pilot sitting right seat as PM/acting as safety pilot to keep us in VMC, could I have actually logged some of that time?

PIlot Flying and Pilot Monitoring are concepts from multi-crew CRM, and don't apply to the Cessna 172. Secondly even in multi-crew scenarios PF and PM are nothing to do with who is PIC.

The only time two people can both log any kind of time in a 172 is when one is an instructor with the appropriate qualifications (doesn't have to be have an instructor rating under certain circumstances - one example that somewhat relevant to your example is CAR425.21(9)) and the other is a trainee and, importantly, engaged in being trained for the duration of the flight. Then the instructor is the PIC and the student logs "dual" time. This is different in the US, where multiple people can log PIC time, but this is not the US.

There is also no concept in Canada of a "safety pilot" (that's another US thing). It remains the PIC's responsibility to avoid traffic and weather, and there's no stipulation of the qualfications to be held by another person on board if the PIC needs assistance to do that. If you can train your dog to bark at clouds and other airplanes, use your dog. Assisting the pilot in that way doesn't make the other person a "required crew member"

To examine your example flight: In Canada a student pilot permit doesn't allow the privileges of carrying passengers, so the commercial pilot would be the only one qualified to be PIC. The student could log the flight as time towards a future instrument rating - requirement 421.46(2)(b)(ii)(C) - (even before they got their PPL) if the CPL in the other seat met the requirements of 425.21(9). In that case the student would log the flight as dual. It would be unusual though. This dual would not count towards the requirements of any solo or dual time towards their PPL - it would only be countable when they were adding up the required hours for their instrument rating, once they had a PPL.


If you were the CPL then you should have recorded the flight in your log as PIC. If and only if you met the requirements of 425.21(9) would the student be permitted to log anything, and then only as dual towards a future instrument rating, as I described.


I have to say the whole scenario seems very unusual though - there's no part of PPL training in Canada that involves unlicensed students practicing IFR cross countries. Was it some kind of TC-approved integrated course?

[Big Pistons Forever]

CAR 101 defines “Safety Pilot” as follows

safety pilot means a pilot who acts as a lookout for another pilot operating an aircraft in simulated instrument flight;

However as was pointed out in earlier posts this does not apply to the situation described in the original posts. The safety pilot described in the CAR is meant for persons who hold an instrument rating who want to practice IFR in VMC conditions without filing an IFR flight plan. This is most commonly used to maintain/regain IFR currrency

[Speedalive]

Perfect thanks! Makes sense to me.

[photofly]

The interesting thing about the definition of "safety pilot" in the CARs is that the only place the term appears in the regulations (as far as I can tell) is in the definition itself. To that extent, it's as useful as a defintion of "custard".

And the only place I can find it in the CARs Standards is in 428, as one of the duties of the Pilot Examiner.

Since there is no reference in any regulation to when a "safety pilot" is required, what qualifications they must have, or where their responsibilities begin or end, I don't think it helps us very much.

Does anyone have another reference where the phrase is used, that I missed?

[Big Pistons Forever]

The interesting thing about the definition of "safety pilot" in the CARs is that the only place the term appears in the regulations (as far as I can tell) is in the definition itself. To that extent, it's as useful as a defintion of "custard".

I would suggest the interesting thing about the safety pilot definition is it removes any ambiguity about who can be a safety pilot, you have to be a “pilot”, not a dog, and the duties are confined to when “simulated instrument flight” is being conducted.

There are many,many,many areas where the CAR’s are wrong/obsolete/contradictory/out of date or just plain silly, but you got to take the gimmes at face value

If you are an instructor and a student asks “What is the deal with this safety pilot thing?” You can say see CAR 101. If you are not doing what the CAR says, then you are not a “safety pilot” period.

[photofly]

I would suggest the interesting thing about the safety pilot definition is it removes any ambiguity about who can be a safety pilot, you have to be a “pilot”, not a dog, and the duties are confined to when “simulated instrument flight” is being conducted.

Well, I don't agree with you. There's a lot of ambiguity:

What kind of licence or permit does a safety pilot need to hold? Is a student pilot permit adequate?
Does a safety pilot need a current medical?
Does a safety pilot need to have a rating for the category or class or aircraft in which they act as safety pilot?
Can the holder of a pilot licence - balloon act as a safety pilot in a helicopter? Or vice versa?
Does a pilot need a night rating to act as a safety pilot at night?
Does a safety pilot need to meet the recency requirements of 401.05?
If I pay a safety pilot, is that considered to meet the test for "hire and reward" and do they need a Commercial (Safety) Pilot Licence?
Why is the privilege of acting as a "safety pilot" not listed in 401.26? Or any other section on privileges?


And that's just the start.

Which regulation (that I obviously missed) requires the presence of a "safety pilot", and under what circumstances? You can't haul someone up in front of a tribunal for breaking a "definition" - you need an actual regulation. So if my father in law (who is not a licensed pilot, but has eyes keener than a hawk) looks out for traffic while I practice holding patterns under the hood, which regulation have I broken?

[Big Pistons Forever]

Photo

Is this about the definition of “safety pilot” or the fact I pointed out you made an incorrect statement when you stated “There is no concept in Canada of a “safety pilot” ?

In any case the bottom line is simple. The original poster wanted to know if he/she could log the time when flying as a “safety pilot”. The answer as you very correctly pointed out is NO with the appropriate CAR’s reference provided.

I would say we are done here

[photofly]

Is this about the definition of “safety pilot” or the fact I pointed out you made an incorrect statement when you stated “There is no concept in Canada of a “safety pilot” ?

You're right! I have a reasonable knowledge of the regulations, but I haven't memorized all the definitions. Thank you for pointing out the definition of "safety pilot", whose presence in the regulations I had overlooked.

Do you think I'm breaking any rule when my non-pilot father-in-law looks out for traffic while I practice holds under the hood? In the US that would not be permitted, but I think it's fine in Canada.

[Foregone]

Not sure if this helps with clearing ambiguity, but according to US regulations, the “safety pilot” must just be certified to fly the category & type of aircraft being flown, not necessarily Instrument rated, as the purpose of a safety pilot is for “simulated” instrument flight in VFR conditions.
CFR 61 91.109
(c)(1) requires that the Safety Pilot must hold at least a private pilot certificate. The pilot certificate must have category and class ratings that are appropriate to the aircraft being flown.

However, the US regs go on to say that a “safety pilot” can log PIC time, as long as the pilot at the controls is under “simulated instrument conditions”, ie. “under the hood”.
Flight schools in the US advertise this fact to prospective students and/or timebuilders to indicate that they can save a lot of money on airplane costs since they can share the time.
The sticky thing that people run into down there, is that the “safety pilot” better not log the whole flight, as obviously the person under the hood will not be in simulated instrument conditions the entire flight.
From my research and from what I’ve heard, there is no specific reference under the CARs that indicate that the safety pilot can log any of that time, unfortunately.

[photofly]

There's no ambiguity