Evans%TARTAN@CMU-CS-C.ARPA (07/20/83)
From: Art Evans <Evans%TARTAN@CMU-CS-C.ARPA>
FAR Part 91.21(b) states:
No person may operate a civil a civil aircraft in simulated instrument
flight unless--
(1) An appropriately rated pilot occupies the other control seat as a
safety pilot; ...
As others have pointed out, the question is what the phrase "appropriately
rated pilot" means.
In the Air Traffic Control section of Jeppesen's J-AIDs, which is almost
entirely copied from AIM Part 1, the following appears on page US-260 in a
section titled "Practice Instrument Approaches":
... pilots on VFR flight plans are required to comply with basic visual
flight rules (FAR 91.105). Application of ATC procedures ... does not
relieve IFR and VFR pilots of their responsibility to see and avoid other
traffic while operating in VFR conditions.
What this says is that someone in that aircraft is responsible for staying
clear of both clouds and other aircraft. Since the pilot under the hood
obviously can't do it, it's the task of the safety pilot. As far as I'm
concerned, while I'm under a hood, I want a safety pilot next to me who is
competent to perform these tasks, and the only way I can be sure is to have a
licensed pilot over there.
That's as much as I've been able to find from study of the regulations.
However, it's long been my understanding that "appropriately rated" means
"legally qualified to fly that aircraft at that time", and that's the
requirement I've always insisted on. That definition is surely consistent with
the wording of the FAR, though I suppose one could argue cogently for a more
lenient definition. The definition is certainly one that is safe.
For myself, that interpretation means that if I'm flying a high performance
airplane (as defined in FAR 61.31(e)), the safety pilot must also be so
qualified. If I were multi-rated (I'm not) and wanted to fly a twin under the
hood, I would insist on a multi-rated safety pilot. Also, of course, the
safety pilot has the same requirements as any other pilot with respect to
recent use of alcohol. Basically, the AIM quotation above makes it clear that
the safety pilot has legal responsibilities under the FARs, and I want (and I
believe the FARs require) somebody who has demonstrated the capability of
meeting those responsibilities.
Art Evans
Evans%Tartan@CMU-CS-C
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