SAFE “CFI Pro” 2017

The Society of Aviation and Flight Educators (SAFE) works to create a safer aviation environment by “Promoting Excellence in Aviation Education”

The FAA Airman Certification Standard, envisioned at the SAFE Pilot Reform Symposium in 2011, is now FAA policy for pilot certification. New pilots now learn and demonstrate risk management in an integrated curriculum right from their first day of pilot training! Our Pilot Proficiency Program, started by Doug Stewart and others at SAFE in 2012, has become a national hit and the highlight of Oshkosh every year. SAFE is now focusing more intently on improving the level of professionalism of our aviation educators; this includes all CFIs and educators in all parts of aviation.

badcfisThere are far too many individuals in our industry who have acquired FAA teaching credentials and do not achieve (or maintain) the required professional standards to educate effectively and thoroughly. Every pilot and CFI reading this has experienced (and paid for) this depressing “educational experience.” Just focus on your memory of this for a moment and imagine if it was your first exposure to aviation. It is no wonder, new pilot candidates are dropping out at an 80% rate in our flight schools. Please refer to Rod Machado’s blog on this topic or see our recent post on professionalism here. Every one of these individuals potentially provides initial and remedial training to a large number of pilots every year. The required one hour of flight time for a flight review every two years is often a perfunctory “rubber stamp” with no true value. Imagine if each of these low functioning CFIs was teaching at a more professional level how much safer all our pilot population would become.

In the US, any commercial level pilot can acquire a CFI (plus CFII and MEI) certificate in a 10-14 day course and be teaching new pilots the very next day (potentially even in a twin)! Additionally, the CFI responsible for teaching these new CFI students is only required to have 200 hours of instructional time and no particular added pedagogical experience. The professionalism of our US aviation system runs entirely on personal integrity and this system is failing badly. If each of these new CFI graduates entered a mentored education environment, this system might work acceptably. Unfortunately many new CFIs are hired teach entirely on their own and have to figure it out as they go!

In Canada, flight instructors have four levels. A beginner Class 4 instructor can only teach under the supervision of a higher Class 2 or 1 instructor. Additionally, to instruct a potential CFI in Canada you must be a Class 1 instructor with years of proven experience. This insures that only experienced professionals are teaching the new instructors. In the US, our aviation “puppy mills” are churning out “hour builders” who use their new credentials to build required experience for their future careers in an unsupervised environment. The common joke “your first five students will teach you how to be a CFI” are unfortunately not far from true in the US.

On the other side of life, we have many retired professional 121/135 pilots returning to the education system after years of line flying. These individuals retain a CFI certificate with the minimal $99 online renewal every two years and “teach” at whatever level they maintain. Often these professionals crave a refresher but have no options to refresh their skills in our industry (we hope to change that at SAFE).  In our FAA marketplace, some CFIs are wonderful and some are terrible all depending on personal ability and integrity, there is  absolutely no verification of professionalism.

Largely for this reason, JoAnn and Sandy Hill created the Master Instructor Continuing Education Program in 1995. Master Instructors are highly vetted, peer reviewed professionals that are also active aviation citizens giving back to our industry. The rigorous requirements of this certification are well recognized in our industry and raise these individuals to a professional level of Master Instructor.

But not every aviation instructor (SAFE prefers the term “educator”) has the time or experience to become a Master Instructor, but all hopefully desire to become more professional in their teaching (again our FAA system runs primarily on integrity and compliance). This is where SAFE is stepping up our game. We provide the SAFE Toolkit with all the required FAA experience and endorsements (in addition to a wealth of other resources) free to everyone (Carry it all on your phone!) SAFE has an active CFI mentoring program for new or returning CFIs where you can be matched with an experienced CFI professional to provide necessary guidance for new CFIs. This year we are presenting “CFI Pro” branded seminars at Sun ‘N Fun and hope to also present a program bonding CFIs and DPEs soon (Join us and help!)

Look for our new initiatives to “raise the bar” on CFI professionalism rolling out this year. And please offer *your* suggestions to improve our efforts! CFIs are the secret sauce for safety in our industry that touch every pilot every day. They do this either by providing instruction or in the example the set in our community. Each aviation educator needs to teach with integrity and maintain the highest level of skill, knowledge and judgment. Step up to CFI professionalism with SAFE in 2017…and have a great year!

Please “follow” our SAFE blog to receive notification of new articles. Write us a comment if you see a problem or want to contribute an article. We are always seeking more input on aviation improvements and flight safety. There are many highly qualified aviation educators out there! If you are not yet a SAFE member, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment worthwhile and fun. Lastly, use our FREE SAFE Toolkit App to put pilot endorsements and experience requirements right on your smart phone and facilitate CFI+DPE teamwork. Working together we make safer pilots!

“CFI Pro!” The Critical Element in Pilot Training!

Our last blog post was a contribution from Rod Machado profiling “Bad Flight Instructors.” Though the majority of CFIs are hard-working, mostly underpaid, and diligent, there are some amazing abuses in our industry. The article before that examined our 80% drop out rate in aviation education. Both of these posts inspired a firestorm of comment and speculation. And all this comment and concern is wonderful news!  We obviously have many dedicated pilots and educators with a real passion to fix problems in aviation education. Some very successful aviation educators and schools are succeeding so well they reported “no completion problems” and are models for the rest of us to learn from. IN this post I hope to extract some of the goodness from all these posts and comments (especially the successful educators) and generalize some “best practices” that can help all of us be more successful in aviation education. Our next several posts will be on aviation educator professionalism.

From what I have seen and heard, what we need first in aviation is better honesty throughout the flight training industry. Flying is clearly expensive and it takes a commitment of time and effort to succeed. Accomplishment in aviation is not a sprint but requires sustained effort and a lifetime commitment to learning. This fact argues directly with our current social climate of immediate gratification. Industry improvement and each instructional session requires a serious initial discussion to both sell the value of safe flying practices and make clear the rewards of this total accomplishment. Honest aviation has little use for a fast superficial flight courses; selling “faster, cheaper” is just not part of the serious aviation formula for long-term success. An honest assessment of value will interest the proper people and cull out many “tire kickers” for whom flying is “cool” but too much work or expense. Offering discounted (or free) initial lessons without revealing the true cost and effort involved in learning to fly is not a sustainable solution.

One FaceBook posting advocated a new definition of STEM  for aviation education; Study-Time-Energy-Money. Indeed, aviation requires all these things and some personal grit and resilience. Additionally, the personality trait of PIC, being in charge, is difficult for many people raised in our modern culture, to develop and sustain. There is a lot of discipline and responsibility required to be successful in aviation. And the payback is not immediate gratification but hard won achievement. For those who persist (currently the 20%) it provides amazing rewards and satisfaction. We need to discuss these traits and the full process with potential students before we get fully involved.

screen-shot-2016-12-16-at-7-59-47-amIt was also clear from all the postings and comments (and again from the highly-valuable AOPA polling) that a caring compassionate CFI is an essential component for motivating and retaining flight students. Those students lucky enough to discover this knowledgeable and compassionate CFI will stick out the tough times and progress faster. If this lucky chemistry is not available, a caring aviation mentor or some club camaraderie is a wonderful buffer for getting through the difficult setbacks and plateaus we all know occur in aviation. Learning to fly is not always an easy journey. Greg Brown, who wrote the original (and newly updated) Savvy Flight Instructor, curates a very active FaceBook site assisting aviation students with their struggles and problems. From the amazing activity on this site I would guess Greg is donating his full time to assist aviation students. Compassionate people like this will surely go to aviation heaven.

Rod Machado has analyzed current IACRA data and revealed the average number of hours for completion of a private pilot certificate in the US is now at 105 hours (2.5 times the FAA minimum). But in one online forum an experienced (and busy) CFI is regularly educating fully competent, safe pilots that pass their flight tests in 40-45 hours. This veteran CFI had definitely “cracked the code” and I spent some time analyzing his success so we all could benefit.

This successful educator insisted on an honest, up front interview about the costs, effort and duration of the process of learning to fly. Again, this saves everyone time and disappointment. (If you do not have enough pilot candidates to be honest, I will reveal a way to double your intake in a future blog post!)  Another element of his method was including future assessments along the way and an honest, no guilt termination if the project looked like it was not going to work for either party. We all know some people just do not have the required skills, aptitude or judgment to become safe pilots. A serious professional must terminate training when it is obvious it is not going to work. Too many CFIs and schools avoid this discussion because of the emotional pain (or financial incentive to continue) and end up perpetuating a losing battle. This dishonest practice always ends up ugly and painful for everyone.

Another important element gleaned of this CFI’s amazing success was the benefit of years of experience so he could efficiently convey the important and necessary skills and knowledge elements. And though aviation education is not rocket science it does take time on task to become an efficient flight educator. (not *quite* the 10,ooo hour rule of Anders Ericcson but close) To speed up this process and become a pro CFI faster, a good relationship with your local DPE is highly recommended. Most DPEs are desperate to help eager, honest CFIs learn the necessary elements to successful flying and teaching. They will always share “what went right (or wrong)” with curious recommending CFIs. The key to receiving this valuable feedback is being emotionally mature enough to receive the good (and bad) news. As a CFI you will still be learning every day you teach. Some of this is technical knowledge but most is psychological techniques and pedagogical skills. I guarantee your passing percentages as a CFI will improve if you learn to listen and grow your basic teaching skills. I highly recommend this book (not in the FAA CFI list) for all serious educators.

A final element of CFI success is always using a shared flight syllabus so both student and CFI have a clear road map of skills and elements clearly laid out and leading to the final flight test. The famous question “Who are you and what are we doing today?” would be the ultimate sign of disaster for any flight student. (Review again the Ralph Hood video of the “evil flight instructor video”) Every instructional episode must have a clearly defined plan with the lesson and instructional elements clearly stated. Aviation is too expensive to squander useless hours in the air wandering around without a plan. If you are a student and your CFI is not using a syllabus RUN AWAY…you are wasting your money! If you are a CFI and do not have a syllabus, here are some resources for you.

Being a flight educator at any level is a huge responsibility. To just keep each flight operation safe is a large and time-consuming mandate. To additionally teach in this distracting environment and allow your student to make small self-correcting errors is challenging. This task requires experience and supreme organization. To this end, an efficient ground school and complete pre and post briefings are essential to reducing the total hours in training. It should be mandatory before going airborne, that every element is discussed and understood. The real goodness of a lesson comes after the flying with a thorough debrief. In this calm time after each lesson the student and educator can mutually determine the essence and meaning of each success and develop a plan for improvement and “next steps”. This review is essential so each student can personally code their experiences into meaningful insights for future success. A thorough debrief also keeps both student and instructor motivation charged up and moving toward improvement and future goals.

From what I hear/see online and in all the flight schools and CFIs I visit, some parts of this ideal process are usually violated when we witness unsuccessful pilot candidates or excessive hours to completion. Revisit the Rod Machado blog on the “bad CFI” soliciting reader input. Let’s fix all these unsuccessful practices and commit to keeping every honestly dedicated aviation student in the process and make sure they reach their goals in aviation. Your feedback and techniques are eagerly solicited here. We need every (safe) pilot!


amazonsmilesaferesultsAdd SAFE to your Amazon Smile account…this is easy and costs *you* nothing! The 0.5% sounds small be accrues us great benefits (could fund a scholarship!) Here are the simple instructions. Purchase your holiday gifts though Amazon Smile and SAFE gets $$ Members, please consider a step-up to increased support of your organization…Thanks!

 

Rod Machado on “Bad Instructors” :(

Thank-you to well known CFI and author/educator Rod Machado for allowing us to republish his blog on reports of “Bad CFIs” (And coming soon; how to be a NInja CFI!)

I’m curious about your experience with bad flight instructors and hope you’ll add to this blog with  your comments. Of course, most flight instructors do a fantastic job. I just can’t say that LOUD enough: Most flight instructors do a fantastic job! But unfortunately, not all do. And when they don’t, they cause a lot of damage to the flight training industry. So I’m curious if you’ve ever experienced a really bad flight instructor. Did this person scream a lot? Hit you with a sectional chart? Or a “whack” chart? Did he or she make calls and text friends while giving you dual? Call you a nasty name? Talk about you behind your back while standing in front of you? Overcharge you? Did this person drink or smoke while flying with you? Humiliate you? Berate you? Belittle you? Tell me about what he or she did or didn’t do. Spare no details.
The main reason I’m posting these initial responses to my query is to make sure that anyone interested in flight training recognize bad instructor behavior and then do something about it. Specifically, find another instructor. And, if at all possible, give the bad instructor some good feedback on how his or her behavior can rub an entire city the wrong way.
Then again, there’s an old Chinese saying that goes as follows: It’s better to spend three years looking for a good instructor than spend just three minutes with a bad one. This always sounds better when spoken by an old Chinese person, but you get the point, right?

Here are some responses to my query (unedited): 

Adam: First 5 or so flights he failed to notice I never touched the trim wheel once I set for take off for the entire flight. I had larger than normal control pressures because of never using trim. He also was so desperate for flight time he found any excuse to keep the Hobbs meter running like being overly courteous in letting other airplanes taxi, take off and land in front of us.

John: Okay, let’s start with going under the hood on my first lesson. I had no clue what vertigo was, and the CFI never told me. All he did was scream at me and tell my what a loser I was for not being able to hold my heading.

Chris:  I know a couple in Caldwell NJ that specialize in keeping as quiet as they can during dual training so you have to keep flying and flying in order to get the knowledge you need. They will only “release” you until they have milked you enough to be evident. Stuff like getting a BFR for them represent milking a sucker -like me apparently- for no less than 10 hrs until we are fed up and go to another place and get the damn BFR done in one day.

Jim: I had a younger CFI wen I was going through Multi Commercial. We were flying over congested area and that’s when he said, “My plane” and began doing barrel rolls in our Seminole. I took the aircraft back and told him I would throw his happy ass out of the airplane if he ever even attempted something so stupid. I was serious!

Jeffrey: I had one CFI try to teach me how to roll a Cessna 172 as a Primary Student. It was poorly executed and scared me into finding another instructor. The first instructor later had a gear-up landing in a twin and it freaked him out and he quit flying for many years until he recently reached out to me to see if I knew of any flying jobs. I couldn’t think of any I would recommend him for.

David: The only bad CFI I’ve had was the one who gave my first BFR back around 1978. He was a recent grad of an instructor mill. We got into the C-150 and I while running the checklist I noticed he had not put on his shoulder harness (this was before wearing them was mandatory). Thinking he was razzing me, I asked if he was going to put on the shoulder harness and he said “No”. Thinking he was still razzing me I asked him “Wait a minute, who’s the pilot in command here?” His response? “I am”. At this point I’d had enough and I told him “No you’re not. There’s nothing were going to do in this airplane that I am not qualified and current to do. Either you put on that shoulder harness, or I find myself a new instructor”. He put on the harness, we flew the review, he signed me off and I *never* flew with him again!

This is an open-ended blog that continues here!


4.1.1

Rod Machado is a professional aviation speaker who delights his listeners with upbeat and lively presentations. His unusual talent for simplifying the difficult and adding humor to make the lessons stick has made him a popular lecturer both in and out of aviation. Rod speaks on both aviation and non-aviation topics, including risk assessment, IFR charts, aviation weather, in-flight emergencies, and safety awareness. He has over 10,000 hours of flight experience earned the hard way—one CFI hour at a time.  He also holds degrees in aviation science and psychology. His blog has a special section with free tools created specifically for CFIs.


amazonsmilesaferesultsAdd SAFE to your Amazon Smile account…this is easy and costs *you* nothing! The 0.5% sounds small be accrues us great benefits (could fund a scholarship!) Here are the simple instructions. Purchase your holiday gifts though Amazon Smile and SAFE gets $$ (Thanks!)

How Can We Fix Our 80% Aviation Drop Out Rate?

It is amazing our aviation industry has survived this long while sustaining an amazing 80% drop out rate. Only one person in five actually makes it from first walking in the door of a flight school to becoming a certified pilot. The other four people end up discouraged and spread bad news about our process of learning to fly. And it gets even worse because we also know that after certification another 80% of new pilots fly very seldom or stop flying all together within two years. It seems as an industry we are failing as educators? I would be curious to see retention data for other challenging recreational activities.

screen-shot-2016-12-09-at-9-32-23-pm I know the common and easy explanation is blaming “the rising cost of modern aviation” but we also see many people spending scads of money on all kinds of expensive recreational toys. Quads, boats and RVs seem to be flying off the shelves (and admittedly require no training courses). Also, two other observations argue against the simple cost theory. First, in real dollars learning to fly is actually *cheaper* than when I learned in 1970 (though admittedly the cost of planes is *way* up). Second, AOPA’s extensive polling on this subject among students at all levels puts financial considerations something like 7th in picking a flight training operation. Cost is a dominant negative factor but only when people perceive they are not getting a good value for their money and there seems to be no real concern for their personal progress and success.

For more detail, read this reportscreen-shot-2016-12-09-at-8-57-35-pm  that AOPA generated from extensive data gathered from students at all levels. They discovered students highly value excellent instructors with a professional concern and involvement. An active social environment, camaraderie and a sense of caring are also very important positive factors to students. And notice, these are the “soft skills”, not the expensive hardware and gizmos that drive up a flight school’s expenses. With minimal investment we should be able to provide a better learning environment, more fun and keep people engaged. Sit back and think for a moment about *your* flying experience and your pilot group. Are they welcoming and professional? Does your tribe actively seek out and gather interested new people? Can we grow aviation?

screen-shot-2016-12-10-at-6-34-25-pm

This (admittedly ancient) Ralph Hood tape is an obvious exaggeration, but as people in the industry we also have to confess, it contains a lot of truth. We do not do “customer service” well in aviation. Take a look at this video and I bet you will recognize some characters from your local airport.

screen-shot-2016-12-09-at-9-21-33-pmThe 2016 AOPA Excellence Poll was published recently and we are very proud that our SAFE member Brenda Tibbs is the National #1 CFI based the AOPA criteria and the enormous feedback they gather. You will notice she is not a multi-hour veteran but instead a fairly new CFI, starting a new flight school business. The ratings from AOPA, based on extensive research, highly value customer feedback in many areas. Technical subject matter mastery is surely important, but it also investigates the value of “soft skills’ like communication and motivation…again the glue that binds students to aviation when the learning can be a struggle.

So moving forward, how can we build a better flight training environment and reduce our aviation attrition rate? Lots of things have not changed since this video was made in the 90s. I personally think it would help to train compassion and caring into our ardent “hour builder” CFIs. Flight academies do pretty well teaching academic and technical skills but fall short imparting the soft skills of customer service and  concern. A personal bond between CFI and student goes a long way toward motivating and inspiring a student. We are very clearly at the cusp of a huge pilot shortage and unless we successfully rebuild and regenerate the pilot training infrastructure, our GA world will continue to diminish and large academies will do all future flight training. Expect to see more articles here focusing on flight educator professionalism; your ideas, comments and suggestions are eagerly solicited.

Please “follow” our SAFE blog to receive notification of new articles. Write us a comment if you see a problem or want to contribute an article. We are always seeking more input on aviation improvements and flight safety. There are many highly qualified aviation educators out there! If you are not yet a SAFE member, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment worthwhile and fun. Lastly, use our FREE SAFE Toolkit App to put pilot endorsements and experience requirements right on your smart phone and facilitate CFI+DPE teamwork. Working together we make safer pilots!

Who’s In Charge? Logging/Acting PIC

Republished from FAA Safety Briefing; author James Williams is FAA Safety Briefing’s associate editor and photo editor. He is also a pilot and ground instructor.

Once you get a new pilot certificate, the next step is to spread your wings and explore the grand new world you’re now a part of. While being out of the initial training environment allows you to have some great new freedoms, it also means some new responsibilities. One of those new responsibilities is managing your logbook. In this article, we will focus on answering common questions about logging Pilot in Command (PIC) time, an area that can be confusing for some new pilots to master. Let’s start by defining PIC.

The FAA defines PIC in Title 14 of the Code of Federal Regulations (14 CFR) section (§) 1.1 as the person who:
(1) Has final authority and responsibility for the operation and safety of the flight,
(2) Has been designated as pilot in command before or during the flight, and
(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

Acting as PIC vs. Logging as PIC

In both a practical and legal sense, only one pilot may act as PIC for any given flight. However, there are situations where a pilot can log PIC time while not acting as pilot in command. “One of the biggest issues when considering PIC time is that in order to understand it, you have to look across multiple regulations in 14 CFR parts 1, 61, and 91,” explains Allan Kash, an Aviation Safety Inspector (ASI) with the Flight Standards General Aviation and Commercial Division. To understand when you can log PIC time, you also need to understand how and why the FAA requires pilots to log flight time. For FAA purposes, a pilot is required to log certain flight time primarily to qualify for or maintain an airman certificate or rating.

Inspector Kash elaborated, “The next big issue is that the requirements to act as PIC and to log PIC time are different. There is a legal distinction. You could very well have a situation where you have both pilots legally logging PIC time, even though the regulations only allow for one pilot to act as PIC. ”

The FAA lists the requirements to serve as a required pilot flight crewmember in 14 CFR § 61.3(a) and (c). These requirements include holding a pilot certificate, photo ID, and a medical certificate (or the ability to meet sport pilot medical requirements). Additionally, § 61.3(e) requires a person acting as PIC under IFR or in IMC conditions to hold an instrument rating. Furthermore, § 61.31 requires a person acting as PIC to hold the appropriate ratings and endorsements for the aircraft type to be flown and § 61.56 requires a pilot to have a current flight review to act as PIC. So far it seems pretty straightforward, right? Here’s where the questions arise. The FAA’s standards for logging PIC time are found in § 61.51(e):

(e) Logging pilot-in-command flight time. (1) A sport, recreational, private, commercial, or airline transport pilot may log pilot in command flight time for flights November/December 2016 FAA Safety Briefing 15 Your friend asks if you want to fly one of the legs. Are you legally allowed to fly? Are you able to act as PIC? Are you able to log as PIC? (i) When the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated, or has sport pilot privileges for that category and class of aircraft, if the aircraft class rating is appropriate, (ii) When the pilot is the sole occupant in the aircraft, (iii) When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted. …

Note: There are other conditions under which a pilot can log PIC in §61.51 (e)(1)(iv). These regulations don’t quite appear to match up: the rule for logging PIC time has fewer restrictions than the rule to act as PIC. So there are circumstances where you can log PIC while not acting as PIC, but you can also be acting as PIC and not be able to log PIC. Stay with me — the details and examples below will help.

screen-shot-2016-11-02-at-10-15-59-am

Solo vs. Sole Manipulator

Let’s look at § 61.51(e)(1)(ii) first, since that’s probably the simplest to define and contains what you may be most familiar with from your initial training as a solo student pilot. Under § 61.51(e) (1)(ii), you may log PIC flight time when you’re the only person on board the aircraft. In the most basic sense, all solo time is PIC, but not all PIC time is solo. For such a flight, you would also have to meet the requirements of § 61.3 (including holding a medical certificate), § 61.56 (flight review requirements), and § 61.31 (appropriate ratings and any endorsements required by the aircraft, such as high performance or complex).

Once you’ve been certificated as a pilot, if you take a non-pilot friend along on your solo cross country trip, you’re no longer the sole occupant. Accordingly, you may not log PIC under § 61.51(e) (1)(ii), but you may log PIC under § 61.51(e)(1)(i) as the sole manipulator of the controls of an aircraft for which you are rated. You would still have to meet the requirements in § 61.3, 61.31, and 61.56 just as you did for a solo flight. To further complicate matters, if you take a fellow pilot along on your cross-country trip, so long as you are the sole manipulator of the controls, you may log PIC under § 61.51(e) 1)(i) regardless of who is acting as PIC. However, the fellow pilot may not simultaneously log PIC time for the portion of the flight that you are logging PIC time as the sole manipulator of the controls, even if the fellow pilot is acting as PIC, unless the requirements of § 61.51(e)(1)(iii) are met, namely more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted.

PF vs. PIC

The next quirk is that the Pilot Flying (PF) may not always be the PIC. The PF and PIC are definitely not synonymous. The clearest example is in an airline cockpit where crews will generally swap legs. The captain and first officer will switch between the PF and Pilot Monitoring (PM) roles. Regardless of who is actually flying the airplane, the captain is always the PIC. This situation could also occur in GA. Therefore, the question here is: When may a GA pilot log PIC under § 61.51(e), when not acting as PIC? One example is when a certificated flight instructor (CFI) is providing flight instruction to a student who holds at least a private pilot certificate and who is qualified to act as PIC. A CFI providing instruction to a person who is qualified to act as PIC need not be the acting PIC, yet still may legally log PIC under § 61.51(e)(3), regardless of who is manipulating the controls.

Let’s examine another common example in the GA world. Let’s say and a pilot friend are going for a $100 hamburger. Your friend suggests taking her Piper Saratoga (a complex high performance airplane). You both have private pilot certificates with an airplane single engine land (ASEL) rating. Your friend has both high performance and complex endorsements, but you do not. You do, however, have a lot of experience with similar airplanes and even some time in a Saratoga. For the purposes of this example, you both have current medicals and flight reviews. Your friend asks if you want to fly one of the legs. Are you legally allowed to fly? Are you able to act as PIC? Are you able to log as PIC?

The answers are yes, no, and yes. You may be the PF, but you may not act as PIC because you do not hold the complex and high performance endorsements required by § 61.31(e) and (f ). In this circumstance, your friend is acting as PIC while you fly. You may, however, log PIC time under § 61.51(e) (1)(i) as the sole manipulator of the controls because § 61.51(e)(1)(i) requires only that you are rated for the aircraft. In this situation, you would be flying and logging as PIC while your friend is acting as PIC but not able to log PIC per § 61.51(e)(1)(iii). This is 16 FAA Safety Briefing November/December 2016 further explained by a legal interpretation in 2009 (Speranza) http://go.usa.gov/xk4TM.

PIC vs. Safety Pilot

As we discussed earlier, the devil really is in the details when it comes to logging of PIC time. Nowhere is this truer than in § 61.51(e)(1)(iii). “The most common mistake I see with logging PIC is with safety pilots when required by § 91.109(c),” Kash said. He explained, “people don’t really understand the implications in § 61.51(e)(1)(iii).” Section 61.51(e)(1)(iii) reads:

“When the pilot, except for a holder of a sport or recreational pilot certificate, acts as pilot in command of an aircraft for which more than one pilot is required under the type certification of the aircraft or the regulations under which the flight is conducted”.

GA pilots often overlook this point because for the most part, our aircraft don’t require more than one pilot. However, in the case of simulated instrument flight, the regulations do require more than one pilot. Per 14 CFR § 91.109(c)(1), a safety pilot is required to operate in simulated conditions. This makes the safety pilot a required pilot flight crewmember under the regulations for the simulated instrument portion of the flight. The safety pilot is required to hold at least a private pilot certificate, be rated for the category and class of airplane to be flown, and hold a current medical as required by § 61.3(c). If the safety pilot is acting as PIC for the simulated instrument portion of the flight, the safety pilot may log that time as PIC time under § 61.51(e)(1)(iii) because he is acting as PIC of an aircraft for which more than one pilot is required under the regulations. The PF may also log the time as PIC time under § 61.51(e)(1)(i) as the sole manipulator of the controls of an aircraft for which the pilot is rated. Additionally, the pilot flying under simulated instruments log simulated instrument time.

However, if the PF is acting as PIC and is the sole manipulator of the controls during the simulated instrument portion of the flight, then the safety pilot may log that time as second in command (SIC) time because he or she holds the appropriate category and class ratings for the aircraft being flown and more than one pilot is required under the regulations under which the flight is being conducted in accordance with § 61.51(f)(2). This is further explained by a legal interpretation in 2012 (Trussell) http://go.usa.gov/xk4bB.

Let’s look at an example. You want to do some practice approaches to get ready for a big trip coming up next month, but your medical has lapsed and your appointment at the aviation medical examiner (AME) isn’t until next week. Your friend volunteers to be your safety pilot. Both of you are instrument-rated private pilots with all appropriate endorsements for the airplane. Your friend has a current medical. Can you fly? Can you act as PIC? Can you log PIC? Can you log simulated instrument time?

The answers are: Yes, no, yes, and yes. For the purposes of this flight, your friend meets the requirements for a safety pilot and the operation requires more than one pilot by regulation. You may not act as PIC because you do not have a current medical. Therefore, your friend would be acting as PIC and may log PIC under § 61.51(e)(1)(iii), but you could also log PIC time as sole manipulator of the controls when operating by sole reference to instruments and using a view-limiting device under § 61.51(e)(1)(i).

Now let’s say you have a medical and your friend does not. Does this change the answers? It does, because your friend no longer meets the requirements for a safety pilot as a required pilot flight crewmember directed by § 61.3(c). In that case, you couldn’t fly simulated instruments
per § 91.109(c).

Let’s look at another example. You own a Cessna 182RG and need to do some practice approaches. Your friend volunteers to be your safety pilot. You both have private pilot certificates with ASEL ratings, with current medicals and flight reviews. You have a complex endorsement, but your friend does not. Can you fly under simulated instruments? Can you log PIC? What does your friend log?

The answers are: Yes, yes, and your friend may log SIC. You may operate the aircraft in simulated instrument flight because your friend meets the requirements to serve as a safety pilot. Your friend has a current medical, which is required by § 61.3(c), and § 91.109(c) requires only category and class ratings appropriate to the aircraft being flown. In this case, you would be the only one eligible to act as PIC since your friend doesn’t hold a complex endorsement, which is required by § 61.31(e) to act as PIC. You may therefore log PIC under § 61.51(e)(1) (i) as the sole manipulator of the controls or under § 61.51(e)(1)(iii) because you are acting as PIC of an aircraft for which more than one pilot is required under the regulations under which the flight is conducted. Your friend may log SIC under § 61.51(f)(2) because he or she holds the appropriate category and class ratings for the aircraft being flown and more than one pilot is required under the regulations under which the flight is being conducted.

PIC vs. Dual Received

As we hinted at earlier, another common question is whether it is acceptable to log PIC and dual received at the same time. The answer is, under the right circumstances, yes. You may simultaneously log PIC and dual received if you are rated in the aircraft (category and class), are the sole manipulator of the controls, and are receiving flight instruction.
That means that once you earn your private pilot certificate (ASEL), you can log PIC during training in a single-engine land aircraft. You can log any commercial or instrument training, even in a complex airplane, as PIC for that time that you are the sole manipulator of the controls under § 61.51(e)(1)(i). This would also apply to training toward an endorsement like tailwheel, complex, or high performance. However, it would not apply to training toward a rotorcraft, glider, balloon, or airship since those are different categories. It would also not apply toward any training in a multiengine or seaplane, because those are different classes.

“I’ve seen lots of really smart people miss the mark when it comes to PIC,” Kash explained. “The bottom line is the need to look at § 61.51(e) in light of multiple pertinent regulations and use that as the guide to whether you can still log PIC.” He continued, “But just meeting the requirements to act as PIC might not mean you can log PIC because only one pilot can log PIC when the operation doesn’t require, or the aircraft type certification does not require, two pilots.”

Have a question about a specific circumstance? Let us know.


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