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Aero-Tips 05.21.06

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 described:

• 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 time:

61.51(g), Logging instrument flight time.

1. 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.
2. 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 logbook—
3. • The location and type of each instrument approach accomplished; and
   • The name of the safety pilot, if required.

"Safety pilots", however, are addressed in FAR 91.109(b), which states:

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.
2. 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 CFII.  

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.

FMI: Aero-Tips