I'd like to fly some hours towards an instrument rating by flying with a safety pilot. I have a safety pilot who is instrument-rated and current (he's working on building time towards a commercial rating). Since he's instrument-rated, can we fly in IMC on an instrument flight plan? If we do, can I be the manipulator of the controls, and can I log PIC time for the time that I'm the sole manipulator of the controls in IMC? And if we're in IMC on a instrument flight plan, do I need to be under the hood by using a view-limiting device, or is just being in IMC good enough to count as instrument time?


If you are the sole manipulator of the controls then yes you can log PIC time in this scenario, however you cannot act as PIC. The FAA discusses this in at least two letters of interpretation Speranza 2009 and Walker 2011. Both which lay out effectively the same situation (I would advise reading them) but in short they go into the fact that acting as PIC is not the same as being the sole manipulator of the controls and thus logging time as PIC.

Interestingly the IFR Rated pilot cannot log the PIC time while you are the sole manipulator of the controls as there is no prevision for that in the safety pilot regulations. The FAA words it as follows:

However, Pilot A may not log PIC time for the portion of the flight during which Pilot B is the sole manipulator of the controls, and is logging PIC time, because there is no provision for this logging in 61.51(e)


Although Pilot B [non IFR Rate Pilot] properly may log PIC time for a portion of the flight as discussed previously, Pilot B could not act as PIC and was not a required flight crew member for any portion of the flight under the aircraft's type certificate or the regulations under which the flight was conducted.

Speranza 2009

If you are in IMC then you do not need a hood as you would log that as actual IMC

The Herman Interpretation (2009) may also be relevant reading r.e. logging PIC vs Being PIC

  • $\begingroup$ That's not clear, I think you are saying no but it's hard to interpret. My understanding is that if it would be illegal to be PIC in actual IMC without an IR. $\endgroup$ – GdD Jan 18 at 12:31
  • $\begingroup$ @GdD the FAAs wording here is a bit vague but there is a difference between acting as PIC and logging PIC time. A non IR pilot could not accept a clearance but they could physically be in control of the airplane in IMC and log that time. The Herman interpretation 2009 explains this a bit more $\endgroup$ – Dave Jan 18 at 16:10
  • $\begingroup$ So what I hear you saying is that if I were to fly in IMC with an instrument-rated safety pilot, I could log the time as both instrument training and PIC time, but my safety pilot would not be able to log any PIC time. But this doesn't make sense to me because he must be PIC, as we're in IMC on an instrument flight plan and he's the only one with an instrument rating. So in this scenario, he would be PIC but he would not be able to log PIC time; I would not be PIC but I would be able to log PIC time. That doesn't seem right at all. $\endgroup$ – SurfandSky Jan 18 at 17:23
  • $\begingroup$ Update: so I read the Walker Letter and this pretty clearly answers the question. In my scenario, I can log PIC time but the instrument-rated safety pilot can't. That's good for me and bad for him, so that will probably be a no-go. This seems like a silly hair-splitting exercise in government bureaucratic rule-making, but I guess it is what it is. $\endgroup$ – SurfandSky Jan 18 at 23:14
  • $\begingroup$ @SurfandSky In the letters they even admit there is no prevision in the safety pilot regulation to allow the "acting PIC" to log the time in IMC. This is the classic "double dip" question that comes up often for safety pilot scenarios and maybe the regulation should be updates. Call your senator and ask! $\endgroup$ – Dave Jan 19 at 3:35

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