Can a PPL exercise Sport Privs?
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Joined 03/13/2020 - 5 Posts
Answered By AOPA
As a licensed private pilot, am I automatically eligible to exercise sport pilot privileges, or would I need to explicitly apply for a separate sport pilot certificate?  Could you point me to the FAR that supports your answer, please?

Assuming the former, I can exercise those sport pilot privs with just my driver license, even with an expired medical, right?

Can I use sport pilot privs to "act as PIC" as a safety pilot for another pilot practicing under a hood in VFR?  Can I let a safety pilot "act as PIC" while I use sport pilot privs to practice in VFR under a hood?  Could you point me to the FAR that supports your answer as it specifically regards sport pilots, please?

Is the logging of PIC time in these scenarios the same as for two PPLs taking turns being safety pilots for each other?  Could you point me to the FAR that supports your answer as it specifically regards sport pilots, please?

If I can use sport pilot privs, both to be another pilot's safety pilot and to let another pilot be mine, this seems to be a workaround for BasicMed PPLs who can't let someone else be PIC while they exercise their privs.  Agree?
8 Replies
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Joined 01/30/2020 - 13 Posts
AOPA Staff Answer
Hi Brian,
Yes, as a licensed private pilot, you can operate under light sport privileges: see the matrix under FAR61.303(a)--- so long as per 61.303(b)- your most recent  medical certificate has not been denied, revoked, or suspended, -or: you do not have reason to know of any medical issues that would make you unsafe to operate a light-sport aircraft. 61.303(b)(4).

Simulated instrument flight requires two private pilots or higher (FAR 91.109(c)-- thus the term: "required crew member", and then, 61.23 shows us the requirements for medicals DOES include for 'required crew members'.

So no, sport-pilot-'privileges-only' pilots cannot act as safety pilots-- they don't have medicals. Again: FAR 61.23. Both pilots under simulated instruments are obviously required crew members and therefore both need medicals.

Your last statement then, no. No sport work-around.

Noting of course: A BasicMed pilot (FAR 68) CAN be a safety pilot (for a private pilot-or higher- with a medical) >> so long as the BM pilot is 'acting'  PIC while under simulated instrument conditions. FAR note (from official FAA BasicMed Q & A sheet , Q#25: https://www.faa.gov/licenses_certificates/airmen_certification/basic_med/media/basicmed_faq.pdf  .) Acting would be by verbal agreement between the pilots.

second note: both pilots immediately above can log PIC (FAR 61.51) because two pilots are required for simulated instruments FAR 91.109).

Hope this helps & simplifies.

 
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Joined 06/11/2017 - 697 Posts
 

A few clarifications...

First, simulated instrument flight does NOT require two pilots with Private or better.  A Sport or Recreational Pilot can log simulated instrument time in an aircraft in which s/he is rated as long as a Private or better is acting as safety pilot.  In addition, a Student Pilot can log simulated instrument time when a CFI is acting as safety pilot and PIC.

Second, the reason a Sport Pilot cannot act as safety pilot is not the lack of a medical (some Sport Pilots may be flying on a medical rather than a DL), but rather because 91.109(c) requires the safety pilot to hold Private or better.  Same for a Recreational Pilot (if you can find one) - less tha Private, can't be a safety pilot.

Third, the reason both pilots in the described scenario can log PIC time is different for the two pilots involved.  The pilot flying logs the time because s/he is the sole manipulator of the controls of an aircraft in which s/he is rated - 61.51(e)(1)(i).  The Basic Med safety pilot acting as PIC logs it as the PIC when two pilots are required - 61.51(e)(1)(iii).

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Joined 03/13/2020 - 5 Posts
Thank you both for your thoughtful, detailed, supported responses.  I agree that 91.109(c) requires a safety pilot to be at least a PPL.  However, I'm not sure I agree that 61.23(a)(3)(ii) requires all safety pilots to possess a medical or BasicMed.  That paragraph seems to apply the exercise of flight instructor privs while serving as a PIC or a safety pilot (e.g., a CFI giving dual instruction to a hooded student).

Given your responses, let me revise my initial question:

Two PPLs want to take turns practicing instrument approaches in simulated instrument conditions.  Both have expired medicals and both have satisfied the "BasicMed" conditions and limitations set forth in § 61.113(i).  As they take turns, they agree that the safety pilot will be the PIC.  A pilot operating under BasicMed must be PIC in order to exercise PPL privs, is allowed to serve as a required crew member, and per § 61.51(e)(1)(iii) can log the other pilot's hooded hours as PIC time since he was PIC of an aircraft for which more than one pilot is required under the regulations under which the flight is conducted.  Interestingly, per § 61.51(e)(1)(i), it would seem that the other (non-PIC) PPL can also log PIC hours "when the pilot is the sole manipulator of the controls of an aircraft for which the pilot is rated."  If I'm reading that correctly, the non-PIC pilot manipulating the controls gets to log PIC hours as long as he's rated in category and class -- even with an expired medical, suspended driver license, out of currency, and lacking tailwheel, HP, or complex endorsements.

Is my interpretation correct?
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Joined 06/11/2017 - 697 Posts
The paragraph that requires all safety pilots to have a medical or basic med is 61.23(a)(3)(i), not (a)(3)(ii), because by 91.109(c), safety pilots are exercising Private Pilot privileges. (a)(3)(ii) only applies to CFI's when they are giving training, and is irrelevant to this question.

As for your scenario, yes, that's legal as long as they transfer PIC duty to the pilot not flying under the hood each time they swap the hood.  As for logging the time, yes, that's all correct except that if Pilot A is "with an expired medical, suspended driver license, out of currency, and lacking tailwheel, HP, or complex endorsements (assuming one or more of those three endorsements applies)", Pilot A can't act as PIC/safety pilot when Pilot B flies under the hood since Pilot A isn't qualified to act as PIC and thus cannot act as legally safety pilot even if s/he has Basic Med -- and so can't log the time legally, either.
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Joined 03/13/2020 - 5 Posts
I completely agree with everything you just wrote except one little clarification: "that's legal as long as they transfer PIC duty to the pilot not flying under the hood each time they swap the hood."  This swap would have to take place on the ground, as a BasicMed pilot is required to act as PIC for the entire flight, so if pilot-A were to put on the hood midflight and make pilot-B his safety pilot, pilot-A would still have to be PIC, and pilot-B couldn't serve as merely a non-PIC required crew member.
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Joined 06/11/2017 - 697 Posts
Brian Blum:
...a BasicMed pilot is required to act as PIC for the entire flight,...

Can you point to the regulation which says that?  I'm not seeing it in 61.113(i) or any other regulation.

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Joined 03/13/2020 - 5 Posts
It's in this AC, paragraph 5.2.5:
https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_68-1.pdf
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Joined 06/11/2017 - 697 Posts
Advisory Circulars aren't regulatory.  In any event, no portion of the described flight goes beyond the limitations of 61.113(i), so there's no issue.  It's not like they're going over 250 knots or 18,000 feet during some portion of the flight.