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When one pilot is practicing instrument flying with a view limiting device (a "hood"), a licensed pilot needs to be along to watch for traffic (the safety pilot). There are several scenarios where none, either, or both are instrument rated, and the flight could be held in IMC or VMC. In this case neither pilot is instrument rated and are just following VORs in visual flight rules.

BasicMed applies to certain aircraft, so lets assume we are talking about your ordinary general aviation IFR capable aircraft with 4 seats and 150 knot cruise speed, while flying VFR.

The FAA states this in their FAQs:

Q25: Can I use BasicMed to act as a safety pilot, rather than holding a medical?
A: Only if you’re acting as PIC while performing the duties of safety pilot. The statutory language prescribing BasicMed said it only applies to people acting as PIC. BasicMed cannot be exercised by safety pilots who are not acting as PIC but are required crewmembers.

I find this confusing, aren't safety pilots acting as PIC because they are required crewmembers?

This question suggests that a BasicMed pilot can only be a safety pilot in VMC:Logging PIC time during IFR flight in VMC.

So my question is this (because it pertains to my present situation): Can I be a safety pilot for a non-instrument rated pilot when I have my BasicMed physical, as long as the flight is in VMC? Can I log PIC time while the pilot under the hood is flying? I should, because I am the PIC as safety pilot.

It would be nice if the FAA gave more clarification, and examples for all the practical scenarios pilots would experience. The safety pilot issue itself confuses a lot of people, now we have BasicMed regulations to add to the confusion.

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Short answer: the safety pilot with BasicMed must be acting as PIC, but all other regulations and considerations are the same (i.e. as if the safety pilot had a regular medical).


You have quite a lot of points in your question, but I'll try to break it down.

"[...] aren't safety pilots acting as PIC because they are required crewmembers?"

Not always. Being a required crewmember is not necessarily the same as being PIC, e.g. a typical airliner requires two pilots but only one of them is PIC. When you fly with a safety pilot there are two ways to do it:

  1. The safety pilot acts as PIC; the pilot under the hood is a required crewmember
  2. The pilot under the hood acts as PIC; the safety pilot is a required crewmember

As you (and the FAA FAQ) said, BasicMed only allows pilots to act as PIC, not as non-PIC required crewmembers. Therefore only scenario 1 is possible for a safety pilot with BasicMed.

Practically speaking, scenario 1 is what most people do anyway, because it allows both pilots to log PIC time; remember that acting as PIC and logging PIC time are two different things. (In scenario 2 the pilot under the hood would log PIC time but the safety pilot would log SIC time.)

"a BasicMed pilot can only be a safety pilot in VMC"

The concept of a safety pilot only applies to VMC; in IMC you're in real instrument conditions, not simulated ones. Perhaps you meant VFR, not VMC? This question (which you already found) is about acting as a safety pilot under IFR.

"Can I be a safety pilot for a non-instrument rated pilot when I have my BasicMed physical, as long as the flight is in VMC?"

Yes, if you act as PIC, as described above. And again, a safety pilot is only needed in VMC.

"Can I log PIC time while the pilot under the hood is flying?"

Yes, and this has nothing to do with BasicMed. Because simulated instrument flight requires a safety pilot (91.109), that means that if you're the safety pilot and acting as PIC, then you can log PIC time as described in 61.51(e)(iii) (emphasis mine):

When the pilot acts [...] as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted

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