35Right

This does not hold water because as a safety pilot, you do not log PIC during the landing phase of flight, since the other person is not wearing the hood during landing.

Safety pilots cannot log landings, and do not log XC. You are only logging PIC during the time the other person is under the hood if you are ACTING as PIC for the flight. If the other person is acting as PIC and is wearing a hood, you log SIC (yes, even if it's a Warrior or Skyhawk) -- this is a serious issue because if there is an accident, the FAA will ask who the PIC is and you don't want to be pointing at each other. You can only have one designated ACTING pilot in command for a given flight. It's either the safety pilot or the pilot flying. If it's the pilot flying, what justification does the safety pilot have for logging PIC if they aren't touching the controls?

rickair7777

FloridaCFII was actually correct...he made the post in 2008, and everybody did log XC as SP back then. The FAA issued an interpretation in 2009 which indicated that you can't log XC if you didn't make the TO & LDG.

35Right

Yup...my bad, didn't look at the date of the post i quoted.

JohnBurke

That's not what the legal opinion states. It references a flight, a theoretical posited by the submitter, in which the safety pilot has acted as safety pilot for only a portion of the flight. A flight with multiple legs in which the safety pilot acts in that capacity for the duration of the legs, including approaches and landings (it's done; zero zero simulated takeoffs and landings with safety pilot or instructor), the legal interpretation does not prohibit logging of cross country for a safety pilot.

The rationale in the interpretation isn't about making a takeoff or landing, it's about acting as a required crew member for the duration of a flight. On a multiple-leg flight with each leg more than 50 nm from the point of origin, cross country time may be loggable for each segment. If the safety pilot is a required crew member for one or two segments, but not all, those segments for which the safety pilot remains a required crew member for the entire segment (not just a part) may be logged as cross country. Nothing in the legal interpretation prohibits this, but in fact, the interpretation supports it.

Note the relevant language: "However, Pilot B may not log any cross-country flight time because that pilot was a required flight crewmember for only a portion of the flight."

rickair7777

I know that, and that's a convoluted way of saying what I said in the first place. The net effect for most folks is that you cannot log XC on a flight where you served as SP pilot because you were not a required crewmember for the duration of the flight. Most of GA pilots can't do zero/zero LDGs and while zero/zero takeoffs may be technically legal in GA, it's not a very good idea at all.

JohnBurke

The point isn't whether it's a good idea or not, but that the legal interpretation needs to be referenced correctly. It does not state that a safety pilot must perform a takeoff or landing to qualify for cross country, but that the safety pilot must act as a required crew member for the duration of the flight.

It's easy to read into the opinion what isn't there, and to use that to cloud the meaning and language of the interpretation. It simply states that for the purposes of cross country, the safety pilot must be a required crew member for the duration of the flight, and not just part of it.

It's also well to remember that the scope of the petitioners question is limited in the application of cross country time; cross country is defined differently for various applications. At its most basic, a cross country must include a landing at a point other than the point of departure, with no specific distance. A cross country for ATP experience requirements need not having a landing at a point other than the point of departure; just reach a point more than 50 nm from departure. For private, commercial, and instrument, it's a landing 50 miles from the point of departure, and a student pilot requires authorization to go on a cross country of 25 miles.

The application of the interpretation to the logging of cross country and SIC time will vary with the application of the regulation to the specific use of the cross country experience; a SIC relevant to ATP-cross country will be different than an SIC for a private-pilot cross country for the purposes of meeting certification requirements.

The devil really is in the details.