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Let's say there is a private pilot ("primary pilot") practicing instrument training under the hood and a private pilot who is a Safety Pilot, and the flight involves a landing at an airport more than 50 nm away in VFR conditions. I want to see if I have this right:

  1. The primary pilot can log instrument time and cross country time, but not PIC time.
  2. The Safety Pilot can log PIC time, but not cross country time or instrument time.
  3. If flying a high-performance and complex airplane, both the primary pilot and Safety Pilot must have a complex and high-performance rating.
  4. The symbiotic benefit of this system is that the primary pilot gets instrument time and the Safety Pilot gets PIC time, both at half price if they split the cost of flying.

According to FAA regulations, do I have this right?

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2 Answers 2

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As background, see this question for a general explanation of how safety pilots can log time. Also have a look at the Gebhart (2009) interpretation for the cross-country part (and see this question too).

Note that the two key things to keep in mind in these logging scenarios are:

  1. Acting as PIC and logging PIC time are two different things
  2. You have to be very clear about who is the acting PIC for the flight

With all that in mind (and referring to 14 CFR 61.51):

The primary pilot can log instrument time and cross country time, but not PIC time

The primary pilot can log all three. Whether they're the acting PIC or not, they can still log PIC time as the sole manipulator of the controls (61.51(e)(i)). They can also log instrument time while they're under the hood (61.51(g)) and cross country time.

The Safety Pilot can log PIC time, but not cross country time or instrument time

If the safety pilot is acting as PIC then that's correct. They can log PIC time because they're acting as PIC "of an aircraft for which more than one pilot is required under [...] the regulations under which the flight is conducted" (61.51(e)(iii)). If the safety pilot is not acting as PIC then they can log SIC time.

But either way, the safety pilot may not log cross country time (Gebhart). They also can't log instrument time because they were never operating "the aircraft solely by reference to instruments under actual or simulated instrument flight conditions" (61.51(g)).

If flying a high-performance and complex airplane, both the primary pilot and Safety Pilot must have a complex and high-performance rating

Only the acting PIC requires those endorsements (not ratings), per 61.31(e) and (f). So if only one of the two pilots on board has them, that's the only pilot who can act as PIC.

If only the primary pilot has the endorsements the flight can still go ahead because a safety pilot isn't required to have them. However, the safety pilot couldn't act as PIC and could only log SIC time.

If only the safety pilot has the endorsements the primary pilot can still log PIC time because you don't need the endorsements to log PIC time. But the safety pilot must act as PIC.

The symbiotic benefit of this system is that the primary pilot gets instrument time and the Safety Pilot gets PIC time, both at half price if they split the cost of flying

Essentially, yes. Typical practice is for the pilots to agree that the safety pilot will act as PIC, and they split the costs 50/50 (61.113(c)). That way they can both log PIC time - which is valuable for further ratings - while only paying 50% of the costs. This question has more information on cost-sharing.

And thanks to JScarry for pointing out that if the safety pilot has BasicMed rather than a regular medical, they must act as PIC. See this question for more details.

Whatever you do please be sure that both pilots do know and understand who is acting PIC for the flight. That person has the final responsibility if something goes wrong. Knowing who's acting PIC is important to prevent things like a safety pilot without a complex endorsement agreeing to act as PIC in a complex aircraft, because "I'm just a safety pilot". You might also have insurance or flying club rules on who can act as PIC.

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  • $\begingroup$ This answer is the most thorough of those given. I would add though, if there is an incident or accident, the legal (acting) pilot in command will be the one in trouble... not necessarily the one who was flying. All the FAA has to do, is to look back on past flights to determine who the legal (acting) pilot in command was if there was a disagreement. Be careful what you log. I will only log SIC time for my safety pilot time in case there is an issue on the flight. $\endgroup$
    – wbeard52
    Commented Jun 28, 2020 at 1:12
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    $\begingroup$ One thing to note because of a quirk in the Basic Med rules. In the US, if the safety pilot is flying under Basic Med they must be acting as PIC and so would be required to have appropriate endoresments for the aircraft. $\endgroup$
    – JScarry
    Commented Jun 28, 2020 at 15:17
  • $\begingroup$ @JScarry Good point, thanks! I've added that to my answer. $\endgroup$
    – Pondlife
    Commented Jun 28, 2020 at 19:04
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In your scenario:

Let's say there is a private pilot ("primary pilot") practicing instrument training under the hood and a private pilot who is a Safety Pilot, and the flight involves a landing at an airport more than 50 nm away in VFR conditions. I want to see if I have this right:

  1. The primary pilot logs PIC time as long as they are the sole manipulator of the flight controls, instrument time as long as they are under the hood, and cross country time as long as he flight is made between airports more than 50 nautical miles away from each other.
  2. The safety pilot logs PIC time as long as the primary pilot is under the hood and cross country time as long as the primary pilot is under the during the flight between airports greater than 50 miles apart. No instrument time.
  3. Any pilot logging PIC must be properly certificated and rated. Although, a safety pilot with a private pilot certificate only can log SIC.
  4. The pilots can split the costs or not. It’s up to them at that point. But, if they split the costs, it must be evenly.
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  • $\begingroup$ #1 is correct. #2 is incorrect. Safety pilot cannot log cross-country time. #3 is partially incorrect. Piltots can agree that the safety pilot is PIC in which case they can log PIC time. If safety pilot is flying under Basic Med they must act as PIC. #4 is mostly correct. They safety pilot can pay no more than the pro rated cost. $\endgroup$
    – JScarry
    Commented Jun 29, 2020 at 0:39

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