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I have a question regarding two pilots, Pilot A who flies under the hood, and Pilot B who is Safety Pilot. According to the FAA Hicks Letter, Pilot B can be made in charge of safety of flight to log the entire flight as PIC time; but my questions are:

  • if Pilot B is 'acting PIC' and Pilot A is the 'sole manipulator of the controls' then is the 0.2 of every flight able to be logged by Pilot A?
  • Once the hood is taken off but Pilot A is still the sole manipulator of the controls, does this count to log as PIC time?
  • Also if the Safety Pilot is acting PIC, who logs the X/C time? (0.2 being Takeoff and Landing out of a 1.0 total flight time).

Edit

I see what you all are saying, I just have one more follow up question regarding the FAA Hicks letter. It states:

Therefore, while it is not possible for two pilots to act as PIC simultaneously, it is possible for two pilots to log PIC flight time simultaneously. PIC flight time may be logged by both the PIC responsible for the operation and safety of the aircraft during flight time in accordance with FAR 1.1, and the by the pilot who acts as the sole manipulator of the controls of the aircraft for which the pilot is rated under FAR 61.51.

It then also states later that:

However, the two pilots may, prior to initiating the flight, agree that the safety pilot will be the PIC responsible for the operation and safety of the aircraft during the flight. If this is done, then the safety pilot may log all the flight time as PIC time in accordance with FAR 1.1 and the pilot under the hood may log, concurrently, all of the flight time during which he is the sole manipulator of the controls as PIC time in accordance with FAR 61.51(c)(2)(i).

So with the Hicks letter putting it this way, shouldn't Pilot B also be able to log the 0.2 of the flight as acting PIC as the Hicks letter states, while Pilot A is sole manipulator of the aircraft and logs it as well?

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  • $\begingroup$ I understand the question posed in your edit. I believe that the Hicks interpretation is misleading in indicating that simply because Pilot B is "acting" as PIC he/she can, on that basis alone, always "log" PIC time in spite of 61.51 (e), which states that there must be more than one "required" crewmember for both to "log" PIC (considering only the circumstances of your question). Read carefully the Speranza Interpretation and see if you agree. $\endgroup$
    – user22445
    Oct 16, 2023 at 17:41
  • $\begingroup$ Also, carefully read the Walker Interpretation. This interpretation affirms, based on the circumstances in your question, that when the regulations under which the flight is conducted do not require more than one pilot (61.51 (e)(iii)), the qualified sole manipulator of the controls can log PIC, but the actual PIC, who is not manipulating the controls, cannot log PIC flight time. $\endgroup$
    – user22445
    Oct 16, 2023 at 17:57

2 Answers 2

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You have 2 questions that can be answered by the Gebhart, 2009 FAA Interpretation: (my answers assume that both pilots A and B are rated in the aircraft)

General circumstances from the Gebhart Interpetation:

enter image description here

Your Questions:

1. "... if Pilot B is 'acting PIC' and Pilot A is the 'sole manipulator of the controls' then is the 0.2 of every flight able to be logged by Pilot A?"

According to the Gebhart Interpretation (pertinent portion below):

enter image description here

Answer: Therefore, as noted above, pilot A can log the entire flight time (sole manipulator of the controls) as PIC.


2. "Also if the Safety Pilot is acting PIC, who logs the X/C time?"

According to the Gebhart Interpretation (pertinent portion below):

enter image description here

Answer: As noted in the FAA Interpretation, pilot A may log the entire flight as cross-country flight time. "However, Pilot B may not log any cross-country flight time..."

(highlights and emphasis is mine)

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  • $\begingroup$ So in this case, Pilot B is the PIC but not a required crew member at certain times? $\endgroup$
    – Someone
    Oct 16, 2023 at 18:16
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    $\begingroup$ @Someone Pilot B would only be a required crewmember when Pilot A is under the hood and Pilot B is acting as Safety Pilot. During the 0.2 (takeoff/landing per the question), Pilot B is no longer a Safety Pilot because Pilot A is not under the hood and a Safety Pilot is not required. According to the Speranza and Walker interpretations (linked in comment to the OP), even though Pilot B is "acting" as PIC he/she cannot log PIC flight time because he is no longer "required". Pilot A can log PIC flight time under 61.51 because he/she is the sole manipulator of the controls. That's how I see it. $\endgroup$
    – user22445
    Oct 16, 2023 at 19:11
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The acting PIC can only log time while there are two required flight crewmembers. So, assuming the flight does not otherwise require two pilots, they can only log time while the sole manipulator is under the hood.

Only the sole manipulator can log cross country time. To log cross country time, the pilot in question must be a required crewmember for the entire flight. The acting PIC is not a required crewmember for the takeoff and landing and so cannot log cross country time.

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