The FAA Legal Interpretation (Gebhart) makes it clear that if:

  • Pilot A flies the whole XC flight (> 50 nm), including the enroute portion under the hood, and
  • Pilot B acts as safety pilot enroute


  • Pilot A can log PIC XC for the whole flight, and simulated instrument for the time spent under the hood, and
  • Pilot B can log PIC time when acting as safety pilot.

The reason Pilot B cannot log PIC XC time is given as follows:

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.

I'm wondering about a slightly different scenario:

  • Pilot A flies only the enroute portion of the XC flight under the hood, and
  • Pilot B acts as safety pilot enroute, and flies the takeoffs and landings.

In this scenario, Pilot B is "conducting the entire flight [...] as a required flight crewmember," as required by the legal interpretation. If Pilot B satisfies the other cross-country requirements specified in 61.1 (ex. navigates using navaids while giving simulated vectors to Pilot A under the hood), can Pilot B log PIC XC time while Pilot A logs simulated instrument for the enroute portion?

  • $\begingroup$ Welcome to A.S.E.! If understand your alternative scenario and question and it was considered legal, the end result would be that Pilot B would be able to log the entire time as cross-country PIC time. Pilot A would not be entitled to log any cross-country time, only simulated instrument time (under the hood) for the "enroute" time. Pilot A would also get the "enroute" time logged as PIC because he/she was sole manipulator of the controls. Am I understanding your question correctly? Thanks $\endgroup$
    – user22445
    Jul 10, 2023 at 22:49
  • $\begingroup$ Yes, that would be my conclusion! $\endgroup$
    – user69877
    Jul 11, 2023 at 0:39
  • $\begingroup$ There is a point of contention with a safety pilot logging PIC time. They are only allowed to log it per 61.51(e)(1)(iii) which states they are acting as the legal pilot in command of an aircraft requiring more than one pilot. If there is an accident or incident while the pilot under the hood is flying the safety pilot has told the FAA they were legally responsible for the flight and should be pilot who receives the consequences. All because, the safety pilot logged PIC time for the duration of the flight. I would rather log SIC time and show the FAA the pilot flying was responsible. FWIW $\endgroup$
    – wbeard52
    Jul 12, 2023 at 6:24

1 Answer 1


Yes, your interpretation is correct. Pilot B is a required flight member for the entire flight and can log PIC and cross-country time for the entire flight. Pilot A is only a required flight member while they are the sole manipulator under the hood, and can log PIC and simulated instrument time for that period, but cannot log cross-country time.

The Glenn interpretation touches on a similar question, where Pilot A and Pilot B trade controls during the flight. In that case, neither can log cross-country time. This sentence is relevant:

The rationale behind the cross-country requirement is to provide a pilot with aeronautical experience flying a significant distance and landing at an airport that is not the pilot's home airport.

By acting as a required crewmember for the entire flight, Pilot B satisfies this and Pilot A does not.


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