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For an IFR currency flight in a high-performance and/or complex airplane where the pilot flying has all the appropriate ratings and endorsements to be PIC, does another pilot with strictly a private ASEL certificate meet the legal requirements to be the safety pilot?

If so, I would assume the entire flight must be conducted in VMC. What other constraints or restrictions apply in such a scenario?

If permissible, how may the safety pilot log the flight so as to count toward future ratings and so on?

Greg Bacon
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  • Some good relevant reading: http://www.aopa.org/News-and-Video/All-News/2013/August/1/Pilot-Counsel-Safety-pilot – Fred Larson Apr 05 '16 at 19:07

2 Answers2

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First, can a pilot without an HP endorsement act as safety pilot in an HP aircraft? Since 14 CFR 91.109 only requires a safety pilot to have category and class ratings, there's no need to have any additional endorsements.

That's confirmed in this FAA legal interpretation:

there is no regulatory requirement that a safety pilot have a high performance endorsement to act as safety pilot

The same document says that safety pilots are "encouraged to be thoroughly familiar and current in the aircraft that is used" - which is great advice - but that's it.

As for the flight conditions (IMC/VMC) and rules (IFR/VFR), I'm not sure what you're asking. Is either pilot IFR current? If not, then the flight can only be VFR. This question might be relevant.

Ryan Mortensen
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Pondlife
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  • What about a complex endorsement for the safety pilot? I assume the PIC is current, instrument rated, endorsed out the wazoo. To simplify, the safety pilot has 42 hours total time and just passed a PVT-ASEL checkride yesterday. – Greg Bacon Apr 05 '16 at 20:31
  • just rated. and that includes a type rating if required – rbp Apr 05 '16 at 21:10
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61.31 requires these endorsements for the legal pilot in command only. If the safety pilot is not the legal pilot in command the endorsements are not required.

The only requirement is for the safety pilot to be appropriately rated and have a current medical. See 91.109

wbeard52
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    I understand the rule, but don't understand the intent. How can the safety pilot be "safe" if he/she is not IFR rated, doesn't know what to look for, and cannot take over if needed? – abelenky Apr 05 '16 at 19:39
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    @abelenky IF the actual PIC is the flying pilot (not the safety pilot), then the safety pilot's sole "job" is to be there to watch for conflicting traffic since the actual PIC is unable to do so when under the hood. He doesn't need to know the IFR rules, have an instrument rating, etc. because he isn't the PIC and isn't responsible for the safe outcome of the flight. The actual PIC is. – Lnafziger Apr 05 '16 at 20:01
  • Nowhere in 91.109 does it say the safety pilot needs a current medical. Please correct me if I am missing it. – Ryan Mortensen Jun 08 '19 at 05:44
  • @RyanMortison The safety pilot is a required crew member and as such needs a medical. The language in 91.109(c)(3)(ii) requires a pilot with at least a private pilot license. To exercise the privileges of such certificate a third class medical is required. See 61.23. – wbeard52 Jun 09 '19 at 00:53
  • @wbeard52 You can exercise private and PIC privileges with BasicMed, you don't need a third class medical. On the other hand, acting as a required crewmember (like a non-PIC safety pilot) does require a medical. See this question. – Pondlife Jun 09 '19 at 05:14
  • I agree. BasicMed is a medical certificate. – wbeard52 Jun 09 '19 at 21:25
  • Sure, but "See 91.109" does not explain that. I am simply point out that you've referenced 91.109 as your source for that statement, but 91.109 says no such thing. I am, however, not saying that isn't true in general (although I'm not 100% convinced it is) just that it is not in 91.109 as you're citing. – Ryan Mortensen Jun 12 '19 at 04:46
  • @Pondlife good link, does the FAA's answer, "BasicMed cannot be exercised by safety pilots who are not acting as PIC but are required crewmembers." not imply that A) a safety pilot could potentially NOT be acting as PIC, and B) that if they are a "required crewmember", then BasicMed IS NOT satisfactory? PIC or not, I would agree that the safety pilot is a required crewmember if the other pilot flies simulated IMC meaning a medical is required, and it can't be BasicMed. – Ryan Mortensen Jun 12 '19 at 04:53
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    @RyanMortensen I'm not sure what you're asking, which I'm sure is my fault :-) The FAA's FAQ seems to cover this? – Pondlife Jun 15 '19 at 04:39
  • @pondlife I think maybe I'm agreeing with you. – Ryan Mortensen Jun 15 '19 at 17:42
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    @RyanMortensen That's what I thought but I wasn't sure :-) – Pondlife Jun 15 '19 at 17:58