Flight Training - September/October 2022 - 58

In a 2015 Information for Operators,
the FAA said that each segment of the
approach must be flown for an approach
to be logged, except for the missed
approach. Thankfully, there is a specified
exception for a pilot who receives vectors
to the final approach course, so you do
not need to start at the initial approach
fix in these cases.
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ument makes it clear that the approach
must continue to the decision height or
minimum descent altitude for it to be considered
valid for training or currency, so
no cheating and taking the hood off early.
For some reason the FAA also thought
it important to note in the document that
to log an approach, a pilot must also log
instrument time. I guess the thinking is
that you can't conduct a valid approach
without flying on instruments or under
the hood, which feels redundant.
This discussion brings up a whole slew
of additional questions concerning safety
pilots and their responsibilities. In short,
if you are flying in simulated instrument
conditions, a safety pilot is required. She
must be qualified for the category and
class of aircraft, but need not be current
or instrument rated. If the pilot flying
decides to act as pilot in command, the
safety pilot can log second in command
time as a required crewmember. When the
safety pilot acts as PIC, both can log PIC
time-the pilot as sole manipulator of the
controls and the safety pilot as acting PIC.
Much of the guidance of the Information
for Operators comes from previously
issued FAA letters of interpretation. The
scenarios and questions are virtually endless,
but two examples show how closely
the FAA parses these interpretations. In
one letter, a pilot asked whether acting
as second in command on an airline flight
BASICMED AND SAFETY PILOTS
Can a pilot on BasicMed be a safety pilot?
For a flight in which the pilot is in simulated
instrument conditions (wearing view-limiting
devices, for example) FAR 91.109(c) requires a
safety pilot with an unobstructed view.
While a BasicMed pilot cannot operate
as a safety pilot as a required crewmember,
he or she can operate as a safety pilot when
acting as the pilot in command. This works
58
FLIGHT TRAINING SEPTEMBER/OCTOBER 2022
in simulated instrument conditions because
PIC time can be logged by the person who is
the sole manipulator of the controls only for
that time that person is the sole manipulator
of the controls.
So, both pilots can log PIC time, although
it must be understood only one will be considered
the acting pilot in command-the pilot
who is on BasicMed.
THE RULES AROUND
LOGGING INSTRUMENT
FLIGHT TIME ARE
CONFUSING AND HAVE BEEN
THE SUBJECT OF VARIOUS
FAA GUIDANCE AND LEGAL
INTERPRETATIONS.
allowed him to log instrument time and
the approach when the captain was the
one flying the airplane. According to the
FAA's answer, the second in command
is a required crewmember, and may log
the instrument time as SIC, but didn't
perform the approach and therefore can't
log it for currency.
In a separate letter a CFI asks about
the same scenario, but between student
and instructor. Here the FAA considers
the CFI's supervision so important that
it said the CFI can log both instrument
time and the approach, even if she never
touches the controls.
Confused yet? Don't worry. Even the
FAA produces contradictory guidance
sometimes. Common sense goes a long
way toward answering some of these
questions, but if you're uncertain, seek
clarification before you make your logbook
entry. FT
ian.twombly@aopa.org
http://www.aopa.org/financemytraining
Flight Training - September/October 2022

Table of Contents for the Digital Edition of Flight Training - September/October 2022
