I am working on my instrument rating and I need to build up both my instrument time and Cross Country time to meet the requirements. I am planning on making most of that time by flying with a friend who I will switch off between hood time and safety pilot. We are planning on doing lots of cross country hood time to meet our hours. Also the safety pilot will be designated PIC so that we can claim PIC time as safety pilot.

We need to build 50 hours PIC cross country time so my question is can the safety pilot, if they are designated PIC for the flight, claim cross-country time even if they are not touching the controls for that flight?

  • $\begingroup$ "Also the safety pilot will be designated PIC so that we can claim PIC time as safety pilot." - You do realize that the legal pilot in command will be responsible for the other guys flying if there is a violation or accident. The logbooks will tell the story to the FAA on who was the legal pilot in command. $\endgroup$
    – wbeard52
    Commented Dec 10, 2019 at 18:30

3 Answers 3


The safety pilot cannot log cross-country time.

The FAA has issued a Legal Interpretation (Gebhart) that clarifies the FAR.

Section 61.65(d) contemplates that only the pilot conducting the entire flight, including takeoff, landing, and en route flight, as a required flight crewmember may log cross-country flight time. Because a safety pilot does not conduct the entire flight, a person acting as a safety pilot for a portion of the flight may not log any cross-country flight time for the flight.


According to FAR 61.1, one of the requirements of cross-country flight is that it is flight time that includes a landing at a point other than the point of departure. Presumably, no one is under the hood at that point, and so only the pilot who makes that landing is logging time at that moment, and so only they can log it as cross country time.

XC time also must include the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point. Which one of you is doing that?

  • $\begingroup$ I'd also add the aside that this is a really bad way to learn instruments. Presumably, you shouldn't have to "build your instrument time" by flying with a safety pilot before getting your rating. That's an excellent way to establish bad habits. $\endgroup$
    – Dave-CFII
    Commented Dec 10, 2019 at 18:20
  • $\begingroup$ I think that training with a safety pilot who is also working on the rating makes both better instrument pilots. After you learn the basics of instrument flying the rest of the hours are just learning to maintain focus and consistently fly the approaches. Unless you are really bad at instrument flying, the CFII is just acting as an expensive safety pilot for most of the 40 hours. $\endgroup$
    – JScarry
    Commented Dec 11, 2019 at 1:24

For Commercial and instrument ratings 61.1 (ii) you only have to navigate to a point of landing that is 50nm away. If you do a zero/zero takeoff and then perform a enroute procedures under the hood shoot the approach down to MDA. That in and of itself counts as a cross country for the pilot manipulating the controls, without landing. So if the safety pilot was the take over and conduct the landing, that would be technically and cross country for both pilots? Seeing as the safety pilot was required for the takeoff, enroute procedures and landing.

"Includes a landing" and "includes a point of landing" are two different things.

(ii) For the purpose of meeting the aeronautical experience requirements (except for a rotorcraft category rating), for a private pilot certificate (except for a powered parachute category rating), a commercial pilot certificate, or an instrument rating, or for the purpose of exercising recreational pilot privileges (except in a rotorcraft) under § 61.101 (c), time acquired during a flight -

(A) Conducted in an appropriate aircraft;

(B) That includes a point of landing that was at least a straight-line distance of more than 50 nautical miles from the original point of departure; and

(C) That involves the use of dead reckoning, pilotage, electronic navigation aids, radio aids, or other navigation systems to navigate to the landing point.

  • $\begingroup$ I think you would be hard pressed to find an FAA ASI or DPE who would agree with you on that interpretation about cross country time. $\endgroup$
    – wbeard52
    Commented Mar 5, 2023 at 0:08
  • $\begingroup$ It’s the same reason why when students conduct there 250 nm ifr cross country they don’t have to land anywhere other than where they took off from. It is all still considered a cross country. They shoot the approach don’t land and continue with there flight plan. $\endgroup$
    – James
    Commented Mar 5, 2023 at 14:32

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